VECTOR PIPELINE, L.P. — Warning Letter

320091015W_Warning Letter_07282009_text.pdf, page 1Official PDFWARNING LETTER CERTIFIED MAIL - RETURN RECEIPT REQUESTED July 28, 2009 Mr. Steve Letwin Executive Vice President, Gas Enbridge Employee Services Inc. 1100 Louisiana Houston, Texas 77002 CPF 3-2009-1015W Dear Mr. Letwin: On July 23-27, 2007 and July 30-31, 2007, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code inspected the Vector Pipeline L.P. (Vector) integrity management plan and procedures in Superior, Wisconsin. As a result of the inspection, it appears that you have committed a probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable violation(s) are: §192.911 What are the elements of an integrity management program? An operator's initial integrity management program begins with a framework (see §192.907) and evolves into a more detailed and comprehensive integrity management program, as information is gained and incorporated into the program. An operator must make continual improvements to its program. The initial program framework and subsequent program must, at minimum, contain the following elements. (When indicated, refer to ASME/ANSI B31.8S (ibr, see §192.7) for more detailed information on the listed element.)#

320091015W_Warning Letter_07282009_text.pdf, page 21. §192.911(k) A management of change process as outlined in ASME/ANSI B31.8S, section 11. Item 1A: ASME/ANSI B31.8S Section 11(b) The operator shall recognize that system changes can require changes in the integrity management program and, conversely, results from the program can cause system changes. Significant equipment and system changes (addition of compressor stations and the relocation of the control center from Edmonton to Houston) have been initiated on the Vector pipeline without documenting the changes consistent with the requirements of ASME B31.8S. Vector now has a procedure in place that addresses this concern for future projects and activities. Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000 for each violation for each day the violation persists up to a maximum of $1,000,000 for any related series of violations. We have reviewed the circumstances and supporting documents involved in this case, and have decided not to conduct additional enforcement action or penalty assessment proceedings at this time. We advise you to correct the item(s) identified in this letter. Failure to do so will result in Enbridge Energy Partners, L.P. being subject to additional enforcement action. No reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 3-2009-1015W. Be advised that all material you submit in response to this enforcement action is subject to being made publicly available. If you believe that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original document you must provide a second copy of the document with the portions you believe qualify for confidential treatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b). Sincerely, Ivan A. Huntoon Director, Central Region Pipeline and Hazardous Materials Safety Administration 2#