{"operation":"document","citation":"CPF 320091015W","title":"VECTOR PIPELINE, L.P. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2009-07-28","effective_on":null,"summary":"CLOSED warning letter citing 192.911(k).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320091015w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320091015w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320091015w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320091015W","body":"Warning Letter involving VECTOR PIPELINE, L.P.. PHMSA's enforcement data identifies the cited regulation as 192.911(k). The case was opened on 2009-07-28 and is reported as closed as of 2009-07-28. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320091015W_Warning Letter_07282009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320091015W/320091015W_Warning%20Letter_07282009.pdf\n\n320091015W_Warning Letter_07282009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320091015W/320091015W_Warning%20Letter_07282009_text.pdf\n\n320091015W_Warning Letter_07282009_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 28, 2009\nMr. Steve Letwin\nExecutive Vice President, Gas\nEnbridge Employee Services Inc.\n1100 Louisiana\nHouston, Texas 77002\nCPF 3-2009-1015W\nDear Mr. Letwin:\nOn July 23-27, 2007 and July 30-31, 2007, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States\nCode inspected the Vector Pipeline L.P. (Vector) integrity management plan and\nprocedures in Superior, Wisconsin.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected\nand the probable violation(s) are:\n§192.911 What are the elements of an integrity management program?\nAn operator's initial integrity management program begins with a framework (see\n§192.907) and evolves into a more detailed and comprehensive integrity management\nprogram, as information is gained and incorporated into the program. An operator\nmust make continual improvements to its program. The initial program framework\nand subsequent program must, at minimum, contain the following elements. (When\nindicated, refer to ASME/ANSI B31.8S (ibr, see §192.7) for more detailed\ninformation on the listed element.)\n\n\n\n1. §192.911(k) A management of change process as outlined in ASME/ANSI\nB31.8S, section 11.\nItem 1A: ASME/ANSI B31.8S Section 11(b) The operator shall recognize that\nsystem changes can require changes in the integrity management program\nand, conversely, results from the program can cause system changes.\nSignificant equipment and system changes (addition of compressor stations and the\nrelocation of the control center from Edmonton to Houston) have been initiated on\nthe Vector pipeline without documenting the changes consistent with the\nrequirements of ASME B31.8S. Vector now has a procedure in place that addresses\nthis concern for future projects and activities.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of\n$1,000,000 for any related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to\ncorrect the item(s) identified in this letter. Failure to do so will result in Enbridge Energy\nPartners, L.P. being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please\nrefer to CPF 3-2009-1015W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C.\n552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nSincerely,\nIvan A. Huntoon\nDirector, Central Region\nPipeline and Hazardous Materials Safety Administration\n2","truncated":false,"body_characters":3969}