{"operation":"document","citation":"CPF 320105002W","title":"ENBRIDGE ENERGY, LIMITED PARTNERSHIP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-01-21","effective_on":null,"summary":"CLOSED warning letter citing 195.579(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320105002w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320105002w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320105002w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320105002W","body":"Warning Letter involving ENBRIDGE ENERGY, LIMITED PARTNERSHIP. PHMSA's enforcement data identifies the cited regulation as 195.579(b). The case was opened on 2010-01-21 and is reported as closed as of 2010-01-21. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320105002W_Warning Letter_01212010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320105002W/320105002W_Warning%20Letter_01212010.pdf\n\n320105002W_Warning Letter_01212010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320105002W/320105002W_Warning%20Letter_01212010_text.pdf\n\n320105002W_Warning Letter_01212010_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 21, 2010\nMr. Terry McGill, President\nEnbridge Energy Partners, L.P.\n1100 Louisiana, Suite 3300\nHouston, Texas 77002\nCPF 3-2010-5002W\nDear Mr. McGill:\nOn October 6-8, 2008, October 28, 2008, and January 21-22, 2009, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of\n49 United States Code inspected your facilities associated with the Griffith Unit in Griffith,\nIndiana, and surrounding locations.\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 and\nthe probable violation(s) are:\n1. 195.579 What must I do to mitigate internal corrosion?\n(b) Inhibitors. If you use corrosion inhibitors to mitigate internal corrosion, you\nmust--\n\n\n\n(1) Use inhibitors in sufficient quantity to protect the entire part of the pipeline\nsystem that the inhibitors are designed to protect;\n(2) Use coupons or other monitoring equipment to determine the effectiveness of\nthe inhibitors in mitigating internal corrosion; and\n(3) Examine the coupons or other monitoring equipment at least twice each\ncalendar year, but with intervals not exceeding 7 1/2 months.\nInternal corrosion monitoring was discontinued on the five hydrogen permeation monitors\n(Beta Foils) installed on Line 6B. Two manually-interrogated monitors were discontinued in\nMay 2006. One remotely-interrogated monitor was discontinued in January 2006, and the\nother two remotely-interrogated monitors were discontinued in October 2007. Enbridge\nrepresentatives stated the monitoring was discontinued due to\n“communication/instrumentation problems.\n”\nEnbridge is in the process of implementing an alternative method of internal corrosion\nmonitoring on Line 6B utilizing a technology referred to as Electrical Resistance Tomography\n(FSM-IT), however, it is not expected to be implemented on Line 6B until sometime during\nthe first half of 2010. In the interim, Enbridge provided the following information as\ndemonstration that the internal corrosion threat is being properly managed:\n• a comprehensive report related to the internal corrosion mitigation and\nmonitoring program for their heavy oil pipeline system\n• repair sleeve installations (which require circumferential non-destructive\ntesting)\n• inspection of the Line 6B Pig Sending Trap at Griffith Station (which included\nultrasonic inspection of the trap floor between the 5:00 and 7:00 positions)\n• detailed pipe examinations at in-line inspection indications\n• records for a weight loss coupon at the Stockbridge Pumping Station (Line 17),\nwhich sees only fluid flow from Line 6B\nThe information provided does not demonstrate compliance with the above regulation. Line\n6B has been subject to a batch chemical treatment program to inhibit internal corrosion for\nseveral years. As required by 195.579(b), Line 6B must have coupons or other monitoring\nequipment to determine the effectiveness of the inhibitor program, and the coupons or other\nmonitoring equipment must be examined at least twice each calendar year, at intervals not to\nexceed 7-1/2 months. PHMSA acknowledges the positive steps being taken to improve\nEnbridge’s internal corrosion mitigation and monitoring program. However, the transition\nfrom one technology to another must be implemented in a manner that ensures continued\ncompliance with the regulations.\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 $1,000,000\nfor any related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement\n2\n\n\n\naction or penalty assessment proceedings at this time. We advise you to correct the item\nidentified in this letter. Failure to do so will result in Enbridge being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 3-2010-5002W. 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 portion\nof your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along\nwith the complete original document you must provide a second copy of the document with\nthe portions you believe qualify for confidential treatment redacted and an explanation of why\nyou believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nIvan A. Huntoon\nDirector, Central Region\nPipeline and Hazardous Materials Safety Administration\n3","truncated":false,"body_characters":5479}