# VECTOR PIPELINE, L.P. — Warning Letter

- **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:** Not available
- **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.

Official case documents:

320091015W_Warning Letter_07282009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320091015W/320091015W_Warning%20Letter_07282009.pdf

320091015W_Warning Letter_07282009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320091015W/320091015W_Warning%20Letter_07282009_text.pdf

320091015W_Warning Letter_07282009_text.pdf

WARNING 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.)



1. §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
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