{"operation":"document","citation":"CPF 220191002H","title":"TEXAS EASTERN TRANSMISSION, LP (SPECTRA ENERGY PARTNERS, LP) — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-08-08","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220191002h.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220191002h.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220191002h","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220191002H","body":"Corrective Action Order involving TEXAS EASTERN TRANSMISSION, LP (SPECTRA ENERGY PARTNERS, LP). The dataset does not identify a cited regulation for this case. The case was opened on 2019-08-08 and is reported as closed as of 2023-09-06. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220191002H_Amended Corrective Action Order_04282020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191002H/220191002H_Amended%20Corrective%20Action%20Order_04282020.pdf\n\n220191002H_Amended Corrective Action Order_04282020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191002H/220191002H_Amended%20Corrective%20Action%20Order_04282020_text.pdf\n\n220191002H_Closure Letter_09062023_(19-166438S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191002H/220191002H_Closure%20Letter_09062023_(19-166438S).pdf\n\n220191002H_Closure Letter_09062023_(19-166438S)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191002H/220191002H_Closure%20Letter_09062023_(19-166438S)_text.pdf\n\n220191002H_Corrective Action Order_08082019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191002H/220191002H_Corrective%20Action%20Order_08082019.pdf\n\n220191002H_Corrective Action Order_08082019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191002H/220191002H_Corrective%20Action%20Order_08082019_text.pdf\n\n220191002H_Second Amended Corrective Action Order_06012020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191002H/220191002H_Second%20Amended%20Corrective%20Action%20Order_06012020.pdf\n\n220191002H_Second Amended Corrective Action Order_06012020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191002H/220191002H_Second%20Amended%20Corrective%20Action%20Order_06012020_text.pdf\n\n220191002H_Corrective Action Order_08082019_text.pdf\n\nAugust 8, 2019\nCORRECTIVE ACTION ORDER\nISSUED WITHOUT PRIOR NOTICE\nVIA CERTIFIED MAIL AND FAX TO: 403-231-3920\nMr. William T. Yardley\nExecutive VP and President\nGas Transmission and Midstream\nEnbridge Inc.\n1100 Louisiana Street, Suite 300\nHouston, Texas 77002\nRe: CPF No. 2-2019-1002H\nDear Mr. Yardley:\nEnclosed is a Corrective Action Order issued in the above-referenced case to your subsidiary,\nTexas Eastern Transmission, LP, to take certain corrective actions with respect to Line 15, which\nfailed on August 1, 2019, near Danville Kentucky, and the adjacent Lines 10 and 25. Service is\nbeing made by certified mail and facsimile. Service of the Corrective Action Order by electronic\ntransmission is deemed complete upon transmission and acknowledgement of receipt, or as\notherwise provided under 49 C.F.R. § 190.5. The terms and conditions of this Order are\neffective upon completion of service.\nThank you for your cooperation in this matter.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nor Pipeline Safety\nEnclosure\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, Office of\nPipeline Safety, PHMSA\nMr. James Urisko, Director, Southern Region, Office of Pipeline Safety, PHMSA\nMr. Rick Kivela, Manager, Operational Compliance, Enbridge Inc.\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nTexas Eastern Transmission, LP, ) CPF No. 2-2019-1002H\na subsidiary of Enbridge Inc., )\n)\n)\n)\nRespondent. )\n____________________________________)\nCORRECTIVE ACTION ORDER\nPurpose and Background:\nThis Corrective Action Order (Order) is being issued under the authority of 49 U.S.C. § 60112,\nto require Texas Eastern Transmission, LP (TETLP or Respondent), to take the necessary\ncorrective action to protect the public, property, and the environment from potential hazards\nassociated with the recent gas transmission pipeline failure on TETLP’s 30-inch Line 15 near\nDanville, Kentucky (Failure).\nOn August 1, 2019, an incident occurred on Line 15, resulting in the release of approximately 66\nmillion cubic feet of natural gas, which ignited and resulted in the death of one person and the\nhospitalization of six others. The resulting fire also destroyed multiple structures and burned\nvegetation over approximately 30 acres of land. Pursuant to 49 U.S.C. § 60117, the Pipeline and\nHazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), initiated\nan investigation of the accident. The National Transportation Safety Board (NTSB) is now\nleading the investigation. The preliminary findings of PHMSA’s ongoing investigation are as\nfollows.\nPreliminary Findings:\n TETLP is a wholly-owned subsidiary of Spectra Energy Partners, LP, which is in turn a\nwholly-owned subsidiary of Enbridge Inc. (Enbridge), which is based in Calgary,\nAlberta, Canada.1 TETLP operates an approximately 9,100-mile pipeline system,\ntransporting natural gas from the northeastern United States to the Gulf Coast Region.\n1 Enbridge Inc. website, available at\nhttps://www.enbridge.com/~/media/Enb/Documents/Investor%20Relations/Texas%20Eastern%20Transmission/TE\nTLP%20Q1%202019%20Financial%20Statements%20-%20Final.pdf?la=en (last accessed August 6, 2019).\n\n\n\nCPF No. 2-2019-1002H\nPage 2\n TETLP’s system transports natural gas to and through Texas, Louisiana, the Gulf of\nMexico, Mississippi, Arkansas, Missouri, Tennessee, Illinois, Indiana, Kentucky, Ohio,\nPennsylvania, New Jersey, and New York.\n The failed pipeline (Line 15 or Affected Segment) is a component of the above-reference\nTETLP system. It is a 775-mile long, 30-inch diameter, bi-directional pipeline that\ntransports natural gas between Kosciusko, Mississippi and Uniontown, Pennsylvania.\nLine 15 is one of three parallel TETLP pipelines running in a common corridor near the\nsite of the Failure. The other two TETLP pipelines are the 30-inch Line 10 and the\n30/36-inch Line 25. At the Failure Site, Line 15 is the middle of the three pipelines. The\nFailure occurred near MP 423.4, approximately 6 miles south of Danville, Kentucky\n(Failure Site), on the Danville to Tompkinsville portion of the Affected Segment.\n Line 15 was constructed beginning in 1942. The portion of Line 15 at the Failure Site\nconsists of 0.375-inch wall thickness, American Petroleum Institute X-52 grade pipe,\nmanufactured by A.O. Smith using flash welding, and is coated with coal tar enamel.\nThe line is cathodically protected with impressed current.\n Line 15 is a bi-directional pipeline. The maximum allowable operating pressure (MAOP)\nof Line 15 is dependent on flow direction. When flowing south-to-north, the MAOP is\n1000 psig, established as 76.92 percent of the specified minimum yield strength (SMYS)\nof Line 15. When flowing north-to-south, the MAOP is 936 psig, established as 72\npercent of the SMYS. When first constructed, Line 15 flowed south-to-north. In 2014,\nTETLP reversed the flow to north-to-south. At the time of the Failure, Line 15 was\nflowing north-to-south and was operating at 925 psig.\n It is estimated that approximately 66 million cubic feet of natural gas was released by the\nFailure.\n The Failure occurred at approximately 1:24 a.m. EDT. At approximately 1:25 am,\nEnbridge’s Gas Control in Houston, Texas, received a rate of change alarm on Line 15 on\nthe south side of Danville Compressor Station and during the ensuing minutes, received\nreports from the public of a fire in the area south of Danville Compressor Station. A\nDanville Compressor Station operator also received a rate of change alarm and observed\nthe rupture fire from the window of the compressor station control room. During the\nensuing minutes, other Enbridge employees confirmed the reported fire, indicating the\nfailure of Line 15.\n TETLP’s Danville Compressor Station personnel closed the Line 15 discharge valve\nlocated north of the Failure Site. TETLP field personnel responded by closing the Line\n15 Main Line Block Valve located at Valve Site #4 (MP 408.48), located south of the\nFailure Site. Following confirmation of the Failure, Enbridge further isolated a portion\n(Isolated Segment) of the Affected Segment by closing Valve 15-382 at MP 408.48 and\nValve 15-393 at the Danville Compressor Station near MP 427.5. Enbridge also shut\ndown and shut in Lines 10 and 25, which are blocked in between the Danville\nCompressor Station and the Tompkinsville Compressor Station.\n\n\n\nCPF No. 2-2019-1002H\nPage 3\n The Failure resulted in the ejection of an approximately 30-foot long section of Line 15,\nwhich landed approximately 460 feet from the Failure Site. Additionally, the Failure\nresulted in a 50-foot long, 35-foot wide, 13-foot deep crater at the Failure Site. Gas\nreleased from the Failure ignited, causing a fire that resulted in the death of one person,\nthe hospitalization of six people, and the destruction of several nearby homes and other\nstructures. Railroad tracks operated by Norfolk Southern Corporation (NSC) were also\ndamaged by the fire. NSC temporarily suspended rail service through the area. The fire\nalso scorched or burned approximately 30 acres of land, resulting in numerous burned\ntrees and grass.\n Fire fighters from the Lincoln County were the first responders to arrive at the Failure\nSite. Other local fire departments responded to this event and evacuated approximately\n75 people from the nearby Indian Camp subdivision. Casey County emergency medical\nservices transported one injured person to Ephraim McDowell emergency medical center\nand Boyle County emergency medical services transported 2 injured persons to the same\nemergency medical center. Other injured persons were self-transported to medical\ncenters.\n The Affected Segment contains an as-yet-to-be-determined amount of A.O. Smith-\nmanufactured pipe of similar vintage and type to the pipe involved in the Failure. At this\ntime, the actual cause of the Failure has not been determined. The origin of the Failure\nhas been identified and the specimen pipe is under control of the NTSB. NTSB and\nPHMSA investigators are collecting information related to potential causal factors and\ncircumstances that may have led to the Failure. The NTSB will conduct a metallurgical\ninvestigation to determine the exact cause.\n Lines 10 and 25 run on either side of Line 15 in the immediate vicinity of the Failure\nSite. At this time, the possibility of damage to Lines 10 and 25 from the concussive force\nof the Failure or of thermal damage from the resulting fire cannot be ruled out.\n On November 2, 2003, Line 15 failed at MP 501.72 near Morehead, Kentucky, between\nthe Danville Compressor Station and the Owingsville Compressor Station to the north of\nthe Danville Compressor Station. The 2003 failure also occurred on A.O. Smith-\nmanufactured pipe, and resulted from interactions between hard spots and mid-wall\nlamination, and in PHMSA’s predecessor agency issuing a Corrective Action Order to\nTETLP’s predecessor entity on November 6, 2003, in CPF 2-2003-1018H.\n TETLP reported that it performed an in-line inspection (ILI) to detect hard spots on Line\n15 in 2011. The company also reported that it ran an ILI with a magnetic flux leakage\ntool in 2018 and an ILI with a dent and inertial measurement unit tool in 2019. The 2018\ntool data indicated a small dent with metal loss that did not require action under federal\npipeline safety regulations or TETLP’s procedures. The results of the 2019 ILIs have not\nyet been provided to PHMSA.\n\n\n\nCPF No. 2-2019-1002H\nPage 4\nDetermination of Necessity for Corrective Action Order and Right to Hearing:\nSection 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action\nOrder, after reasonable notice and the opportunity for a hearing, requiring corrective action,\nwhich may include the suspended or restricted use of a pipeline facility, physical inspection,\ntesting, repair, replacement, or other action, as appropriate. The basis for making the\ndetermination that a pipeline facility is or would be hazardous and requiring corrective action, is\nset forth both in the above-referenced statute and 49 C.F.R. § 190.233.\nSection 60112 and the regulations promulgated thereunder provide for the issuance of a\nCorrective Action Order, without prior notice and opportunity for hearing, upon a finding that\nfailure to issue the Order expeditiously would result in the likelihood of serious harm to life,\nproperty, or the environment. In such cases, an opportunity for a hearing and expedited review\nwill be provided as soon as practicable after the issuance of the Order.\nAfter evaluating the foregoing preliminary findings of fact, I find that continued operation of the\nAffected Segment and the two other adjacent TETLP pipelines, Line 10 and Line 25, without\ncorrective measures is or would be hazardous to life, property, or the environment. The adjacent\nlines could potentially have been affected by the Failure and that, accordingly, should not be\nrestarted without further investigation. At this time, the risk of concussive force or thermal\ndamage to the adjacent lines cannot be ruled out. In addition, having considered the\nuncertainties of the cause of the Failure, the pressure at which gas is transported, the vintage and\ntype of pipe, the risk of fire to the environment and populated areas in the vicinity of the\nAffected Segment, and the potential damage to the two adjacent TETLP pipelines, I find that a\nfailure to issue this Order expeditiously to require immediate corrective action would result in\nthe likelihood of serious harm to life, property, or the environment.\nAccordingly, this Order mandating immediate corrective action is issued without prior notice and\nopportunity for a hearing. The terms and conditions of this Order are effective upon receipt.\nWithin 10 days of receipt of this Order, Respondent may contest its issuance and obtain\nexpedited review either by answering in writing or requesting a hearing under 49 C.F.R.\n§ 190.211, to be held as soon as practicable under the terms of such regulation, by notifying the\nAssociate Administrator for Pipeline Safety in writing, with a copy to the Director, Eastern\nRegion, PHMSA (Region Director). If Respondent requests a hearing, it will be held\ntelephonically or in-person in Atlanta, Georgia, or Washington, D.C, unless a different location\nis expressly agreed-to in writing by the Director.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA\nmay identify other corrective measures that need to be taken on the Affected Segment or\nother pipelines in the TETLP system. In that event, PHMSA will notify Respondent of any\nadditional measures that are required and an amended Order will be issued, if necessary. To the\nextent consistent with safety, Respondent will be afforded notice and an opportunity for a\nhearing prior to the imposition of any additional corrective measures.\n\n\n\nCPF No. 2-2019-1002H\nPage 5\nRequired Corrective Actions:\nDefinitions:\nAffected Segment means the approximately 775-mile long, 30-inch diameter Line\n15 that transports natural gas between Kosciusko, Mississippi and Uniontown,\nPennsylvania.\nIsolated Segment means the approximately 19 miles of the Affected Segment\nbetween the Danville Compressor Station at MP 427.5 and Valve 15-382 at MP\n408.48. It is the portion of the Affected Segment that was shut-in after the Failure\non August 1, 2019, by closing main-line valves upstream and downstream of the\nFailure Site and that remains shut-in as of the date of this Order.\nDirector means the Director, Southern Region, Office of Pipeline Safety,\nPHMSA.\nPursuant to 49 U.S.C. § 60112, I hereby order Texas Eastern Transmission, LP to immediately\ntake the following corrective actions for the Affected Segment, Line 10, and Line 25:\n1. Shutdown of Isolated Section. Texas Eastern Transmission, LP (TETLP) must not\noperate the Isolated Segment or Lines 10 and 25 until authorized to do so by the Director\n2. Operating Pressure Restriction. With respect to the remainder of the Affected Segment\nnot shut down under Item 1, above, TETLP must reduce and maintain a twenty percent\n(20%) pressure reduction in the actual operating pressure along the entire length of the\nAffected Segment such that the operating pressure along the Affected Segment will not\nexceed eighty percent (80%) of the actual operating pressure in effect immediately prior\nto the Failure.\n(A)This pressure restriction is to remain in effect until the Director provides written\napproval for TETLP to either increase the pressure or return the pipeline to its\npre-Failure operating pressure.\n(B) By August 21, 2019, TETLP must provide the Director the actual operating\npressures of each compressor station and each main line pressure regulating\nstation on the Affected Segment at the time of Failure and the reduced pressure\nrestriction set-points at these same locations.\n(C) This pressure restriction requires any relevant remote or local alarm limits,\nsoftware programming set-points or control points, and mechanical over-pressure\ndevices to be adjusted accordingly.\n(D)When determining the pressure restriction set-points, TETLP must take into\naccount any ILI features or anomalies present in the Affected Segment to provide\nfor continued safe operation while further corrective actions are completed.\n\n\n\n3. CPF No. 2-2019-1002H\nPage 6\n(E) TETLP must review the pressure restriction monthly by analyzing the operating\npressure data. TETLP must take into account any ILI features or anomalies\npresent in the Affected Segment and immediately reduce the operating pressure to\nmaintain the safe operations of the Affected Segment, if warranted by the monthly\nreview. TETLP must submit the results of the monthly review to the Director.\nThe results must include, at a minimum, the current discharge set-points\n(including any additional pressure reductions), and any pressure exceedance at\ndischarge set-points.\nRestart Plan. Prior to resuming operation of the Isolated Segment, TETLP must develop\nand submit a written Restart Plan to the Director for prior approval.\n(A)The Director may approve the Restart Plan incrementally without approving the\nentire plan but the Isolated Segment cannot resume operation until the Restart\nPlan has been approved in its entirety.\n(B) Once approved by the Director, the Restart Plan will be incorporated by reference\ninto this Order.\n(C) The Restart Plan must provide for adequate patrolling of the Isolated Segment\nduring the restart process and must include incremental pressure increases during\nstart up, with each increment to be held for at least two hours.\n(D)The Restart Plan must include sufficient surveillance of the pipeline during each\npressure-increase increment to ensure that no leaks are present when operation of\nthe line resumes.\n(E) The Restart Plan must specify a day-light restart and include advance\ncommunications with local emergency response officials.\n(F) The Restart Plan must provide for a review of the Isolated Segment for conditions\nsimilar to those surrounding the Failure including a review of construction,\noperating and maintenance (O&M) and integrity management records such as ILI\nresults, hydrostatic tests, root cause failure analysis of prior failures, aerial and\nground patrols, corrosion, cathodic protection, excavations and pipe replacements.\nTETLP must address any findings that require remedial measures to be\nimplemented prior to restart.\n(G)The Restart Plan must also include documentation of the completion of all\nmandated actions, and a management of change plan to ensure that all procedural\nmodifications are incorporated into TETLP’s operations and maintenance\nprocedures manual.\n(H)Procedures for the exposure, testing, and repair of Line 15 must include:\ni. Exposure of Line 15 extending for at least two girth welds on either side\nof the Failure Site to examine for corrosion, coating condition, concussive\ndamage, and thermally-impacted areas. If damage to the exposed pipe is\ndiscovered, TETLP must expose additional pipe until at least 10 feet of\n\n\n\nCPF No. 2-2019-1002H\nPage 7\nundamaged pipe is exposed and examined. TETLP must perform safe\noperating-pressure calculations and remediation for any anomalies or\nthreat found, using permanent repair methods and design factors based\nupon 49 C.F.R. §§ 192.713 and 192.111 and using ASME/ANSI B31G or\nR STRENG methods. TETLP must repair or replace pipe or coating, as\nnecessary. Upon completion of pipe replacement and repairs, TETLP\nmust provide proper backfill and protection from stones and rocks,\npursuant to procedures developed under this Order;\nii. Establishment of adequate cathodic protection for the area where the\nFailure occurred. TETLP must replace any damaged rectifier(s) and must\nre-establish the electrical test station at the railroad crossing. Once\nbackfill and land settling have occurred, TETLP must ensure pipe-to-soil\nreadings are within applicable criteria; and\niii. Development of additional requirements for remediation and the eventual\nrestart for Line 15 as the investigation yields more information about the\ncause of the Failure and the condition of the Affected Segment.\n(I) Procedures for the exposure, examination, remediation, and restart of Lines 10\nand 25 must include:\ni. Development of assessment, remediation, and restart plans that are aligned\nwith the criteria show immediately below;\nii. Exposure of Lines 10 and 25, extending for at least two girth welds in both\ndirections from the Failure location. TETLP must examine the girth welds\nand pipeline coating materials for damage caused by thermal and\nconcussive forces. TETLP must continue a broader exposure of each line\nif associated damage is discovered, until 10 feet of undamaged pipe is\nreached and verified. Any needed repairs are to be guided by established\nEnbridge procedures and safe operating-pressure calculations and the\nremediation for any pits or other forms of anomalies found, using\nengineering permanent repair methods and design factors based upon 49\nC.F.R. §§ 192.713 and 192.111 and using ASME/ANSI B31O or R-\nSTRENG methods. TETLP must repair or replace pipe or coating, as\nnecessary. Upon completion of pipe replacement and repairs, and provide\nproper backfill and protection from stones and rocks, all pursuant to\nEnbridge's established procedures;\niii. Restarts for each individual line in pressure-increase increments, at 25%,\n50%, and 80%, with each increment held for at least one hour after\npressure stabilization. After reaching 80% pressure, Respondent must\nobtain specific individual written approval from the Director to increase\npressure to pre-Failure normal pressure. Respondent must obtain separate\napproval for each pipe (Lines 10 and 25) before increasing pressure to the\nfinal normal operating pressure; and\n\n\n\n4. 5. 6. 7. 8. CPF No. 2-2019-1002H\nPage 8\niv. A ground-level, instrumented leak survey on Lines 10 and 25, for a\ndistance of two miles in both directions from the Failure Site. TETLP\nmust investigate any elevated readings and make all appropriate repairs.\nReturn to Service. After the Director approves the Restart Plan, TETLP may return the\nIsolated Segment to service but the operating pressure must not exceed 80% of the actual\noperating pressure in effect immediately prior to the Failure, in accordance with Item 2\nabove.\nRemoval or Modification of Pressure Restriction. The pressure restriction required by\nthe above Items may be removed or modified, as follows:\n(A)The Director may allow the removal or modification of the pressure restriction\nupon a written request from TETLP demonstrating that restoring the pipeline to\nits pre-Failure operating pressure is justified based on a reliable engineering\nanalysis showing that the pressure increase is safe considering all known defects,\nanomalies, and operating parameters of the pipeline.\n(B) The Director may allow the temporary removal or modification of the pressure\nrestrictions upon a written request from TETLP demonstrating that temporary\nmitigative and preventive measures are being implemented prior to and during the\ntemporary removal or modification of the pressure restriction. The Director's\ndetermination will be based on the Failure cause and provision of evidence that\npreventive and mitigative actions taken by TETLP provide for the safe operation\nof the Affected Segment during the temporary removal or modification of the\npressure restriction. Appeals to determinations of the Director in this regard will\nbe decided by the Associate Administrator for Pipeline Safety.\nInstrumented Leakage Survey. Within 180 days of receipt of this Order, TETLP must\nperform an aerial or ground instrumented leakage survey of the Affected Segment.\nTETLP must investigate all leak indications and remedy all leaks discovered. TETLP\nmust submit documentation of this survey to the Director within 45 days of the\ncompletion of the leak survey.\nRecords Verification. As recommended in PHMSA Advisory Bulletin 2012-06, verify\nthe records for the Affected Segment to confirm the maximum allowable operating\npressure (MAOP). The Affected Segment is bi-directional with two different MAOPs.\nTETLP must confirm the MAOPs for both flow directions. TETLP must submit\ndocumentation of this records verification to the Director within 45 days of receipt of this\nOrder.\nReview of Prior ILI Results. Within 30 days of receipt of this Order, conduct a review\nof the previous ILI results of the Affected Segment. TETLP must re-evaluate all ILI\nresults from the past 20 calendar years, include a review of the ILI vendors' raw data and\nanalysis. TETLP must determine whether any features were present in the failed pipe\njoint and/or any other pipe removed. Also, TETLP must determine if any features are\npresent elsewhere on the Affected Segment. TETLP must submit documentation of this\nILI review to the Director within 45 days of receipt of this Order as follows:\n\n\n\nCPF No. 2-2019-1002H\nPage 9\n(A)List all ILI tool runs, tool types, and the calendar years of the tool runs.\n(B) List, describe (type, size, wall loss, etc.), and identify the specific location of all\nILI features present in the failed joint and/or other pipe removed.\n(C) Explain the process used to review the ILI results and the results of the\nreevaluation.\n9. Mechanical and Metallurgical Testing. Mechanical and metallurgical testing, including\nfailure analysis will be performed by the NTSB in accordance with NTSB procedures and\nprotocols. In the event the NTSB does not perform these functions, TETLP will be\nresponsible for completing all testing and analysis. If the NTSB does not perform the\nanalysis, TETLP must submit to the Director for prior approval a plan to complete the\ntesting and analysis.\n10. Root Cause Failure Analysis. The NTSB will perform a root cause failure analysis\n(RCFA) to determine the cause of the Failure. TETLP must incorporate the findings the\nNTSB RCFA into its integrity management plan and operations and maintenance manual.\nIf the NTSB does not perform these tasks, TETLP must submit to the Director for prior\napproval a plan to complete an RCFA.\n11. Emergency Response Plan and Training Review. TETLP must review and assess the\neffectiveness of its emergency response plan and operational actions with regards to the\nFailure. TETLP must include in the review and assessment the on-scene response and\nsupport, coordination, and communication with emergency responders and public\nofficials. Also, TETLP must include a review and assessment of the effectiveness of its\nemergency training program. TETLP must amend its emergency response plan and\nemergency training, if necessary, to reflect the results of this review. The documentation\nof this Emergency Response Plan and Training Review must be included in the CAO\nDocumentation Report (see Item 14 for description of the CAO Documentation Report).\n12. Public Awareness Program Review. TETLP must review and assess the effectiveness of\nits Public Awareness Program with regards to the Failure. TETLP must amend its Public\nAwareness Program, if necessary, to reflect the results of this review. The documentation\nof this Public Awareness Program Review must be provided to the Director.\n13. Remedial Work Plan (RWP).\n(A)Within 90 days following receipt of this Order, TETLP must submit a Remedial\nWork Plan (RWP) to the Director for approval.\n(B) The Director may approve the RWP incrementally without approving the entire\nRWP.\n(C) Once approved by the Director, the RWP will be incorporated by reference into\nthis Order.\n(D)The RWP must specify the tests, inspections, assessments, evaluations, and\nremedial measures TETLP will use to verify the integrity of the Affected\n\n\n\nCPF No. 2-2019-1002H\nPage 10\nSegment. The RWP must address all known or suspected factors and causes of\nthe Failure. TETLP should consider both the risks and consequences of another\nfailure arising from the same root cause as the August 1, 2019 Failure to develop\na prioritized schedule for RWP related work along the Affected Segment.\n(E) The RWP must include a procedure or process to:\ni. Identify pipe in the Affected Segment with characteristics similar to the\ncontributing factors identified for the Failure.\nii. Gather all data necessary to review the failure history (in service and\npressure test failures) of the Affected Segment and to prepare a written\nreport containing all the available information such as the locations, dates,\nand causes of leaks and failures.\niii. Integrate the results and conclusions of the NTSB’s metallurgical testing\nand RCFA, and other corrective actions required by this Order with all\nrelevant pre-existing operational and assessment data for the Affected\nSegment. Pre-existing operational data includes, but is not limited to,\nconstruction, operations, maintenance, testing, repairs, prior metallurgical\nanalyses, and any third-party consultation information. Pre-existing\nassessment data includes, but is not limited to, ILI tool runs, hydrostatic\npressure testing, direct assessments, close interval surveys, and\nDCVG/ACVG surveys.\niv. Determine if conditions similar to those contributing to the Failure are\nlikely to exist elsewhere on the Affected Segment.\nv. Conduct additional field tests, inspections, assessments, and/or evaluations\nto determine whether, and to what extent, the conditions associated with\nthe Failure, and other failures from the failure history (see Item 13(E)(ii),\nabove) or any other integrity threats are present elsewhere on the Affected\nSegment. At a minimum, this process must consider all failure causes and\nspecify the use of one or more of the following:\na. Inline inspection (ILI) tools that are technically appropriate for\nassessing the pipeline system based on the cause of Failure, and\nthat can reliably detect and identify anomalies,\nb. Hydrostatic pressure testing,\nc. Close-interval surveys,\nd. Cathodic protection surveys, to include interference surveys in\ncoordination with other utilities (e.g. underground utilities,\noverhead power lines, etc.) in the area,\ne. Coating surveys,\n\n\n\nCPF No. 2-2019-1002H\nPage 11\nf. Stress corrosion cracking surveys,\ng. Selective seam corrosion surveys; and,\nh. Other tests, inspections, assessments, and evaluations appropriate\nfor the failure causes.\nNote: TETLP may use the results of previous tests, inspections,\nassessments, and evaluations if approved by the Director, provided\nthe results of the tests, inspections, assessments, and evaluations\nare analyzed with regard to the factors known or suspected to have\ncaused the Failure.\nvi. Describe the inspection and repair criteria TETLP will use to prioritize,\nexcavate, evaluate, and repair anomalies, imperfections, and other\nidentified integrity threats. Include a description of how any defects will\nbe graded and a schedule for repairs or replacement.\nvii. Based on the known history and condition of the Affected Segment,\ndescribe the methods TETLP will use to repair, replace, or take other\ncorrective measures to remediate the conditions associated with the\npipeline Failure, and to address other known integrity threats along the\nAffected Segment. The repair, replacement, or other corrective measures\nmust meet the criteria specified in Item 13(E)(iv), above.\nviii. Implement continuing long-term periodic testing and integrity verification\nmeasures to ensure the ongoing safe operation of the Affected Segment\nconsidering the results of the analyses, inspections, evaluations, and\ncorrective measures undertaken pursuant to the Order.\nix. Implement specific actions TETLP will take on its entire pipeline system\nas a result of the lessons learned from work on this Order. Incorporate\nlessons learned on TETLP’s entire pipeline system. TETLP will report\nlessons learned in the CAO Documentation Report (see Item 14 for\ndescription of the CAO Documentation Report).\n(F) TETLP must include a proposed schedule for completion of the RWP.\n(G)TETLP must revise the RWP as necessary to incorporate new information\nobtained during the NTSB and PHMSA’s failure investigation and remedial\nactivities taken under this Order, to incorporate the results of actions undertaken\npursuant to this Order, and/or to incorporate modifications required by the\nDirector.\ni. TETLP must submit any plan revisions to the Director for prior approval.\nii. The Director may approve plan revisions incrementally.\n\n\n\nCPF No. 2-2019-1002H\nPage 12\niii. Any and all revisions to the RWP after it has been approved and\nincorporated by reference into this Order will be fully described and\ndocumented in the CAO Documentation Report (CDR).\n(H)Implement the RWP as it is approved by the Director, including any revisions to\nthe plan.\n14. CAO Documentation Report (CDR). TETLP must create and revise, as necessary, a\nCAO Documentation Report (CDR). When TETLP has concluded all the items in this\nOrder it will submit the final CDR in its entirety to the Director. This will allow the\nDirector to complete a thorough review of all actions taken by TETLP with regards to\nthis Order prior to approving the closure of this Order. The intent is for the CDR to\nsummarize all activities and documentation associated with this Order in one document.\n(A)The Director may approve the CDR incrementally without approving the entire\nCDR.\n(B) Once approved by the Director, the CDR will be incorporated by reference into\nthis Order.\n(C) The CDR must include but not be limited to:\ni. Table of Contents;\nii. Summary of the pipeline Failure, and the response activities;\niii. Summary of pipe data/properties and all prior assessments of the Affected\nSegment;\niv. Summary of all tests, inspections, assessments, evaluations, and analysis\nrequired by the Order;\nv. Summary of the Mechanical and Metallurgical Testing as required by the\nOrder;\nvi. Documentation of all actions taken by TETLP to implement the RWP, the\nresults of those actions, and the inspection and repair criteria used;\nvii. Documentation of any revisions to the RWP including those necessary to\nincorporate the results of actions undertaken pursuant to this Order and\nwhenever necessary to incorporate new information obtained during the\nfailure investigation and remedial activities;\nviii. Lessons learned while completing this Order;\nix. A description of specific actions TETLP will take on its entire pipeline\nsystem as a result of the lessons learned from work on this Order; and\nx. Appendices (if required).\n\n\n\nCPF No. 2-2019-1002H\nPage 13\nOther Requirements:\n1. Reporting. Submit monthly reports to the Region Director that: (1) include all available\ndata and results of the testing and evaluations required by this Order; and (2) describe the\nprogress of the repairs or other remedial actions being undertaken. The first monthly\nreport for the period August 1 through August 31 is due on September 15, 2019. The\nRegion Director may change the interval for the submission of these reports.\n2. Documentation of Costs. It is requested but not required that Respondent maintain\ndocumentation of the costs associated with implementation of this Order. Include in each\nmonthly report the to-date total costs associated with: (1) preparation and revision of\nprocedures, studies and analyses; (2) physical changes to pipeline infrastructure,\nincluding repairs, replacements and other modifications; and (3) environmental\nremediation, if applicable.\n3. Approvals. With respect to each submission requiring the approval of the Region\nDirector, the Region Director may: (a) approve the submission in whole or in part; (b)\napprove the submission on specified conditions; (c) modify the submission to cure any\ndeficiencies; (d) disapprove the submission in whole or in part and direct Respondent to\nmodify the submission; or (e) any combination of the above. In the event of approval,\napproval upon conditions, or modification by the Region Director, Respondent shall\nproceed to take all action required by the submission, as approved or modified by the\nRegion Director. If the Region Director disapproves all or any portion of a submission,\nRespondent must correct all deficiencies within the time specified by the Region Director\nand resubmit it for approval.\n4. Extensions of Time. The Region Director may grant an extension of time for compliance\nwith any of the terms of this Order upon a written request timely submitted and\ndemonstrating good cause for an extension.\n5. Be advised that all material you submit in response to this enforcement action is subject\nto being made publicly available. If you believe that any portion of your responsive\nmaterial qualifies for confidential treatment under 5 U.S.C. § 552(b), along with the\ncomplete original document you must provide a second copy of the document with the\nportions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under\n5 U.S.C. § 552(b).\nIn your correspondence on this matter, please refer to “CPF No.2-2019-1002H” and for each\ndocument you submit, please provide a copy in electronic format whenever possible. The\nactions required by this Order are in addition to and do not waive any requirements that apply to\nRespondent's pipeline system under 49 C.F.R. Parts 190 through 199, under any other order\nissued to Respondent under authority of 49 U.S.C. Chapter 601, or under any other provision of\nFederal or State law.\nRespondent may appeal any decision of the Region Director to the Associate Administrator for\nPipeline Safety. Decisions of the Associate Administrator shall be final.\n\n\n\nCPF No. 2-2019-1002H\nPage 14\nFailure to comply with this Order may result in the assessment of civil penalties and in referral to\nthe Attorney General for appropriate relief in United States District Court pursuant to 49 U.S.C.\n§ 60120.\nThe terms and conditions of this Corrective Action Order are effective upon service in\naccordance with 49 C.F.R. § 190.5.\nAugust 8, 2019\n__________________________________ __________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n220191002H_Closure Letter_09062023_(19-166438S)_text.pdf\n\nVIA ELECTRONIC MAIL TO: cynthia.hansen@enbridge.com;\nNathan.Atanu@enbridge.com; Thomas.Wooden@enbridge.com;\nandy.drake@enbridge.com; Sherif.Hassanien@enbridge.com\nSeptember 6, 2023\nTexas Eastern Transmission, LP\nCynthia Hansen, President\n915 North Eldridge Parkway\nHouston, Texas 77079\nRE: CPF 2-2019-1002H\nDear Ms. Hansen:\nOn August 8, 2019, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued\nto Texas Eastern Transmission, LP a Corrective Action Order in the above-referenced case. This\nOrder included a requirement to take corrective actions on your pipeline. Based on our review of\nthe documentation you provided, it has been determined that you have complied with the terms of\nthis Order.\nAccordingly, this case is now closed, and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nJames A. Urisko\nDirector, Office of Pipeline Safet","truncated":true,"body_characters":132670}