# ENTERPRISE PRODUCTS OPERATING LLC — Corrective Action Order

- **operation:** document
- **citation:** CPF 320045032H
- **title:** ENTERPRISE PRODUCTS OPERATING LLC — Corrective Action Order
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2004-10-29
- **effective on:** Not available
- **summary:** CLOSED corrective action order.
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-320045032h.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-320045032h
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/320045032H
**body:**

Corrective Action Order involving ENTERPRISE PRODUCTS OPERATING LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2004-10-29 and is reported as closed as of 2012-03-30. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320045032H_Closure_03302012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320045032H/320045032H_Closure_03302012.pdf

320045032H_Closure_03302012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320045032H/320045032H_Closure_03302012_text.pdf

320045032H_Corrective Action Order_10292004.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320045032H/320045032H_Corrective%20Action%20Order_10292004.pdf

320045032H_Corrective Action Order_10292004.pdf

o
U.S.Deportment
of Tronsportotron
Reseorch ond
Speciol Progroms Administrqtion 400 Seventh Sl S W
Washrnglon. D.C 20590
OCT 2 g ?,:ff.
Mr. Terry L. Hurlburt
Vice President/General Manager Operations
Enterprise Products Operating L.P.
2727 Northloop West
Houston, TX 77008-1044
Re: CPF No. 3-2004-5032H
Dear Mr. Hurlburt:
Enclosed is a Corrective Action Order issued by the Associate Administrator for Pipeline
Safety in the above-referenced case. It requires you to take certain corrective actions, including a
pressure reduction, with respect to the Enid lateral on your anhydrous ammonia system. Service is
being made by certified mail and facsimile. Your receipt of this Corrective Action Order constitutes
service of that document under 49 C.F.R. $ 190.5. The terms and conditions of this Corrective
Action Order are effective upon receipt.
Sincerely,
$*" w
James Reynolds
Pipeline Compliance RegistrY
Office of Pipeline SafetY
Enclosure



DEPARTMENT OF TRANSPORTATION
RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON. DC 20590
In the Matter of
Enterprise Products Operating L.P,
Respondent.
CPF No. 3-2004-5032H
CORRECTIVE ACTION ORDER
Purpose and Background
This Corrective Action Order is being issued, under authority of 49 U.S.C. $ 60112, to require
Enterprise Products Operating L.P. (Respondent) to take the necessary corrective action to protect
the public, property, and the environment from potential hazards associated with the October 27,
2004 fallure of Respondent's anhydrous ammonia pipeline near Kingman, Kansas.
The October 27,2004, failure resulted in the release ofmore than 3000 bbls of anhydrous ammonia
from the 8-inch diameter Enid lateral. The cause of the failure has not yet been determined.
Pursuant to 49 U.S.C. $ 601 17, the Central Region, Office of Pipeline Safety (OPS) initiated an
investigation of the accident.
Preliminary Findings
1. On October 27,2004, at2:08.p.m. Eastern time, Respondent reported to the National
Response Center (t{RC) that a rupture had occurred on its 8-inch anhydrous ammonia
pipeline near Kingman, Kansas. The NRC report stated that the failure had occurred at
approximately 11 :52 a.m., Central time, on that day.
2. A vapor cloud approximately %-mile wide that resulted from the failure delayed access to
the failure site. Once the vapor cloud dissipated, Respondent was able to uncover the pipe
at the failure site for an initial visual inspection. Both Respondent's personnel and OPS
personnel made the visual inspection. The initial visual inspection found al2-14-inch split
that runs longitudinally on the pipe at about the one o'clock position. At the midpoint of the
split, the pipe opened about | lz-inches. The visual inspection reported marks on the pipe
similar to those associated with backhoe teeth marks. There appeared to be a dent at one end
ofthese marks. The split in the pipe was within one of these marks. Visual observation also
found parallel marks running along the pipe at about the ten o'clock position. The cause of
failure has not yet been determined, but third party damage is suspected



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3. 4. 5. 6. 7. 8. 9. Respondent's anhydrous ammonia system includes the Enid lateral that runs from Enid,
Oklahoma to Partridge, Kansas and the Verdigris lateralthat runs from Verdigris, Oklahoma
to Enid, Oklahoma. The October 27 failure occured in the Enid lateral. (This section of
the line will be referred to as the affected segment.) The Enid lateral runs through Grant
County in Oklahoma and the Kansas counties of Harper, Kingman and Reno.
The release occurred in a rural area. The town of Kingman, Kansas is approximately six
miles from the failure site. The failure site is approximately one mile north ofHighway 54.
At least 3000 bbls of anhydrous ammonia were released from the rupture. Some of the
discharge spilled into a drainage ditch approximately 30 feet from the failure site. The ditch
flowed into a small pond on Smoots Creek. High pH readings were found on Smoots Creek,
about 2.2m1les downstream from the pond. Smoots Creek is a tributary of the South Fork
Ninnescah River. The pH readings taken at the river did not indicate that the anhydrous
ammonia had migrated to the river. The area in which the spill occurred is classified as a
drinkingwaterunusuallysensitiveenvironmentalareaperthedefinitionin4gC.F.R. $195.6.
Emergencyresponse officials evacuated 30 homes in a four-square mile area ofthe leak site.
Anhydrous ammonia is ahazardous substance that is used in the manufacture of fertilizer,
pesticides and plastics. According to its Material Safety Data Sheet, anhydrous ammonia is
an irritant and corrosive to skin, eye, respiratory tract and mucous membranes.
The Enid lateral was constructed in 1973 and hydrostatically tested in Decemb er 1973 and
early 1974. The pipeline consists of 8-inch, X-46pipe with 0.156-inch wall thickness. The
pipe was manufactured by Lone Star with ERW longitudinal weld seams.
The maximum operating pressure for the line segment at the failure site was established by
the pressure test to be 1185 psig. At the time of the failure, the operating pressure at the
Enid, Oklahoma station was 1329 psig, 1063 psig at the Harper, Kansas station, and 897 psig
at the Partridge Station. The calculated pressure at the leak site (MP 26) was 981 psig . The
maximum operating pressure from the Enid station (MP 118) to MP 87.2 is 1395 psig, from
MP 87.2 to the Harpet Kansas station (MP 51) 1200 psig, and from the Harper station (MP
51) to Partridge Station (MP 0 )1185 psig.
Respondent has scheduled internal inspection of the affected segment of line for 2006; the
segment has not been previously inspected using internal inspection tools.
10. Respondent operates the pipeline. Magellan Midstream Partners, L.P. owns the pipeline.
Determination of Necessiff for Corrective Aetion Order and Right to Hearing
Section 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action
Order, after reasonable notice and the opportunity for a hearing, requiring corrective action, which



3
mayinclude the suspended orrestricted use of apipeline facility, physical inspection, testing, repair,
replacement, or other action as appropriate. The basis for making the determination that apipeline
facility is hazardous, requiring corrective action, is set forth both in the above referenced statute and
49 C.F.R. 5 190.233, a copy of which is enclosed
Section 60112, and the regulations promulgated thereunder, provide for the issuance of a Corrective
Action Order without prior opportunity for notice and hearing upon a finding that failure to issue the
Order expeditiously will likely result in serious harm to life, property or the environment. In such
cases, an opportunity for a hearing will be provided as soon as practicable after the issuance of the
Order.
After evaluating the foregoing prcliminary ftndings of fact,I findtbatthe continued operation of the
affected segment without correetive measures would be hazardous to life, property and the
environment. Additionally, after considering the age of the pipe, the proximity of the pipeline to
populated areas, highways and waterways, including a drinking water unusually sensitive
environmental area, the lack of information concerning the reason for the failure, and the hazardous
nature of the product being transported, I find that a failure to expeditiously issue this Order
requiring immediate corrective action would likely result in serious harm to life, property, or the
environment.
Accordingly, this Corrective Action Order mandating immediate corrective action is issued without
prior notice and opportunity for a hearing. The terms and conditions of this Order are effective upon
receipt.
Within 10 days of receipt of this Order, Respondent may request a hearing, to be held as soon as
practicable, by notifying the Associate Administrator for Pipeline Safety in writing, delivered
personally, by mail or by telecopy at (202) 366-4566. The hearing will be held in Kansas City, MO
or Washington, DC on a date that is mutually convenient to OPS and Respondent.
After receiving and analyzingadditional data in the course of this investigation, OPS may identify
other corrective measures that need to be taken. In that event, Respondent will be notified of any
additional measures required and amendment of this Order will be considered. To the extent
consistent with safety, Respondent will be afforded notice and an opportunity for a hearing prior to
the imposition of any additional corrective measures.
Required Corrective Action
Pursuant to 49 U.S.C. $ 60l l2,Ihereby order Enterprise Products Operating L.P. to immediately
take the following corrective actions with respect to the Enid lateral that runs from Enid Station,
Oklahoma (MP 118) to Partridge Station, Kansas (MP 0) :
1. Maintain the operating pressure on the affected segment not to exceed 80 percent (80%) of
the actual operating pressure in effect just prior to the October 27 ,2004 failure. Specifically,



2.
a
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the pressure is not to exceed 785 psig at the failure site. This pressure restriction will remain
in effect until the Director, Central Region, OPS gives written approval to increase the
pressure or return the pipeline to its pre-failure operating pressure.
Within 30 days ofreceipt ofthis Order, develop and submit to the Central Regional Director
aplan for the mechanical and metallurgical testing ofthe failed pipe section. The plan must
include:
(A) A protocol for the testing of the failed pipe section. The protocol must provide for
collecting, cataloging, and sealing the pipe and all other evidence in the presence of
OPS or an OPS representative and documenting the chain-of-custody. Respondent
must obtain prior approval of the testing protocol, from the Director, Central Region,
OPS;
(B) Prior to commencing the metallurgical testing, providing the Director, Central
Region, OPS with the scheduled date, time, and location of the testing to allow an
OPS representative to witness the testing; and
(C) Provision for ensuring that the laboratory distributes all resulting metallurgical
reports, whether draft or final, to the Central Regional Director at the same time as
they are made available to Respondent.
Within 60 days of receipt of this Order, develop and submit a written plan to verify the
integrity of the affected segment to the Director, Central Region, OPS. The Director must
approve the plan before it is implemented.
(A) The plan must include a detailed description of the integrity verification measures
proposed.
(B) The plan must fully address all known or suspected factors that caused or contributed
to the October 27,2004 failure.
(B) The plan must include a detailed description of the inspection and repair criteria that
will be used in the field evaluation of the anomalies that are excavated..
(c)
The plan must provide for prior notification to the Director, Central Region, OPS of
the scheduled date, time, and location of any testing or other integrity verification
measure the plan calls for to allow an OPS representative to witness the test.
(D)
The plan must provide for submitting to the Central Regional Director the records of
any testing conducted under the integrity verification plan within 30 days after
completing the test.



5
4. Submittherequiredplansto: Director,CentralRegion,OfficeofPipelinesafety,g0lLocust
Street, Suite 462, Kansas City, MO 64106-2641. The Director may approve plan elements
incrementally. Implement the plan as it is approved.
5. The Director, Central Region, OPS may allow the removal or modification of the pressure
restriction set forth in Item 1 upon a written request from Respondent demonstra tingthat the
hazardhas been abated and that restoring the pipeline to its pre-failure operating pressure is
justified based on a reliable engineering analysis showing that the pressure increase is safe
considering all known defects, anomalies and operating parameters of the pipeline.
6. The Director, Central Region, OPS maygrantanextension of time for compliance with any
of the terms of this Order for good cause. A request for an extension must be in writing.
The corrective actions required by this Corrective Action Order are in addition to and do not waive
any requirements that apply to the pipeline under 49 C.F.R. Part 195, including the integrity
management pr o gr am regul ati ons.
Respondent may appeal any decision of the Director to the Associate Administrator for Pipeline
Safety. Decisions of the Associate Administrator are final.
Failure to comply with this Order may result in the assessment of civil penalties of not more than
$100,000 per day and in referral to the Attorney General for appropriate relief in United States
District Court.
Wut&*- *(W Q g ^ "
Stacey Gerard
Associate Administrator
for Pipeline Safety
OCI 2 g ,:j*ir.4
Date Issued

320045032H_Closure_03302012_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
TRANSMITTED ELECTRONICALLY [Mr. Michael Pearson]
March 30, 2012
Mr. Michael Pearson
Vice President
Magellan Ammonia Pipeline, L.P.
One Williams Center
P.O. Box 22186
MD 27
Tulsa, Oklahoma 74121-2186
CPF 3-2004-5032H
Dear Mr. Pearson:
On October 29, 2004, the Pipeline and Hazardous Materials Safety Administration
(PHMSA) issued to Enterprise Products Operating LLC a Corrective Action Order (Order)
in the above-referenced case. This Order included a requirement to take corrective actions
on their pipeline that Magellan Ammonia Pipeline assumed responsibility for on July 1,
2008, with the acquisition of the system. Based on our review of the documentation you
provided, it has been determined that you have complied with the terms of this Order.
Accordingly, this case is now closed and no further action is contemplated with respect to
the matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
David Barrett
Director, Central Region
Pipeline and Hazardous Materials Safety Administration
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