ENBRIDGE PIPELINES (TOLEDO) INC — Notice of Probable Violation

party submissionOfficial PDF320125020_Operator Response to Notice_10122012.pdf#

320125020_NOPV PCP PCO_09132012_text.pdf, page 1Official PDFNOTICE OF PROBABLE VIOLATION PROPOSED CIVIL PENALTY and PROPOSED COMPLIANCE ORDER UPS NEXT DAY AIR and FACSIMILE September 13, 2012 Mr. Richard Adams Vice President U.S. Operations Enbridge Pipelines (Toledo) Inc. City Center Office 1409 Hammond Avenue Superior, WI 54880-5247 CPF 3-2012-5020 Dear Mr. Adams: On July 12-15, 2010, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your 16- inch crude oil pipeline from Stockbridge, Michigan to Oregon, Ohio. As a result of the inspection, it appears that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable violation(s) are: 1. §195.412 Inspection of rights-of-way and crossings under navigable waters. (a) Each operator shall, at intervals not exceeding 3 weeks, but at least 26 times each calendar year, inspect the surface conditions on or adjacent to each pipeline right-of-way. Methods of inspection include walking, driving, flying or other appropriate means of traversing the right-of-way.#

320125020_NOPV PCP PCO_09132012_text.pdf, page 2Enbridge Pipelines (Toledo) Inc. {Enbridge} failed to adequately inspect the surface conditions at the main line valve located at Hoffman Road (Toledo) at an interval not exceeding 3 weeks, but at least 26 times each calendar year. The valve location was overgrown with brush. Records indicate the pipeline was inspected by aerial patrol. During PHMSA’s field inspection, the main line valve located at Hoffman Road was observed to be overgrown with small trees and brush; therefore, the surface conditions of this section of pipeline was not adequately inspected during the aerial patrols. 2. §195.428 Overpressure safety devices and overfill protection system (a) Except as provided in paragraph (b) of this section, each operator shall, at intervals not exceeding 15 months, but at least once each calendar year, or in the case of pipelines used to carry highly volatile liquids, at intervals not to exceed 7½ months, but at least twice each calendar year, inspect and test each pressure limiting device, relief valve, pressure regulator, or other item of pressure control equipment to determine that it is functioning properly, is in good mechanical condition, and is adequate from the standpoint of capacity and reliability of operation for the service in which it is used. Enbridge failed to inspect the overpressure safety devices at intervals not exceeding 15 months, but at least once each calendar year. The inspection intervals exceeded the maximum 15 month interval by 14-24 days for each of the following overpressure safety devices: 1. VA170197-08 – 24 days 2. VA170197-02 – 24 days 3. VA170197-07 – 24 days 4. VA197173 -9 – 24 days 5. VA0168708-49 – 24 days 6. VA0168708-39 – 24 days 7. VA0168708-18 – 24 days 8. VA0168718-21 – 24 days 9. Britton 30304-1 – 24 days 10. Danflo 800-PSE-1 – 17 days 11. FB#1 4684-1 – 14 days 12. FB#2 4684-2 – 14 days 2#

320125020_NOPV PCP PCO_09132012_text.pdf, page 33. §195.432 (d) Inspection of in-service breakout tanks (d) The intervals of inspection specified by documents referenced in paragraphs (b) and (c) of this section begin on May 3, 1999, or on the operator's last recorded date of the inspection, whichever is earlier. Enbridge failed to perform internal inspections or establish a corrosion rate for the bottom plates of the following tanks within the 10 year period prescribed by API Standard 653, and exceeded the maximum internal inspection interval for tanks 300-TK- 80 and 300-TK-81. API 653 Section 6.4.2 describes the method for establishing the inspection intervals for internal inspections. Section 6.4.2 requires the calculation of the internal inspection intervals in accordance with Section 4.4.7 of the standard, with a maximum internal inspection interval of 20 years. If, however, the corrosion rates are unknown, the maximum inspection interval is not to exceed 10 years, unless similar service experience is available to estimate the bottom plate thickness at the next inspection. Enbridge failed to demonstrate that they had established a basis for the corrosion rate for the tank bottoms listed above; and exceeded the 10 year maximum internal inspection interval for unknown corrosion rates. Additionally, Enbridge did not have similar service experience, or procedures to apply similar service experience available to make this inspection interval determination. The records reviewed demonstrate the last internal inspection performed for Tank #300- TK-80 was performed on June 25, 1998. Tank#300-TK-81 was put into service in 1999 and an internal inspection was not performed until 2011. No calculations were provided that establishes a corrosion rate for the bottom plate. Inspection dates for future internal and external inspections on these tanks have been provided to PHMSA. Proposed Civil Penalty Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 for each violation for each day the violation persists up to a maximum of $2,000,000 for any related series of violations. For violations occurring prior to January 3, 2012, the maximum penalty may not exceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a related series of violations. The Compliance Officer has reviewed the circumstances and supporting documentation involved in the above probable violation(s) and has recommended that you be preliminarily assessed a civil penalty of $68,600 as follows: Item number PENALTY 2 $39,000 3 $29,600 3#

320125020_NOPV PCP PCO_09132012_text.pdf, page 4Warning Items With respect to item 1, 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 promptly correct this item. Failure to do so may result in additional enforcement action. Proposed Compliance Order With respect to items 2 and 3 pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration proposes to issue a Compliance Order to Enbridge. Please refer to the Proposed Compliance Order, which is enclosed and made a part of this Notice. Response to this Notice Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings. Please refer to this document and note the response options. 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). If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue a Final Order. In your correspondence on this matter, please refer to CPF 3-2012-5020 and for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, David Barrett Director, Central Region Pipeline and Hazardous Materials Safety Administration Enclosures: Proposed Compliance Order Response Options for Pipeline Operators in Compliance Proceedings 4#

320125020_NOPV PCP PCO_09132012_text.pdf, page 5PROPOSED COMPLIANCE ORDER Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposes to issue to Enbridge Pipelines (Toledo) Inc. {Enbridge} a Compliance Order incorporating the following remedial requirements to ensure the compliance of Enbridge with the pipeline safety regulations: 1. 2. 3. 4. 5. In regard to Item Number 2 of the Notice pertaining to the inspection of overpressure safety devices, Enbridge shall submit documentation of all inspections performed on each of the devices listed in Item Number 2 from 2010 to present. In regard to Item Number 2 of the Notice pertaining to the inspection of overpressure safety devices, Enbridge shall submit the required documentation within 30 days after receipt of the Final Order. In regard to Item Number 3 of the Notice pertaining to the inspection of in-service breakout tanks, Enbridge shall internally inspect each of the tanks in accordance with the inspection dates proposed by Enbridge and submit copies of the API 653 inspection reports for Tanks 80 and 81. In regard to Item Number 3 of the Notice pertaining to the internal inspection of in- service breakout tanks, Enbridge shall submit the required documentation within 30 days after receipt of the Final Order. If the 2012 inspection for Tank 80 has not been completed, the inspection record shall be submitted within 30 days after completion of the internal inspection. It is requested that Enbridge maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to David Barrett, Director, Central Region, Pipeline and Hazardous Materials Safety Administration. It is requested that these costs be reported in two categories: 1) total cost associated with preparation/revision of plans, procedures, studies and analyses, and 2) total cost associated with replacements, additions and other changes to pipeline infrastructure. 5#

320125020_Final Order_08222013_text.pdf, page 1Official PDFAUGUST 22, 2013 Mr. Terrance L. McGill President Enbridge Pipelines (Toledo) Inc. 1100 Louisiana St., Ste. 3300 Houston, TX 77002-5217 Re: CPF No. 3-2012-5020 Dear Mr. McGill: Enclosed please find the Final Order issued in the above-referenced case. It makes findings of violation, assesses a civil penalty of $68,600, and specifies actions that need to be taken by Enbridge Pipelines (Toledo) Inc., to comply with the pipeline safety regulations. The penalty payment terms are set forth in the Final Order. When the civil penalty has been paid and the terms of the compliance order completed, as determined by the Director, Central Region, this enforcement action will be closed. Service of the Final Order by certified mail is deemed effective upon the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5. Thank you for your cooperation in this matter. Sincerely, Jeffrey D. Wiese Associate Administrator for Pipeline Safety Enclosure cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS CERTIFIED MAIL - RETURN RECEIPT REQUESTED#

320125020_Final Order_08222013_text.pdf, page 2U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 ____________________________________ ) In the Matter of ) ) Enbridge Pipelines (Toledo) Inc., ) CPF No. 3-2012-5020 a subsidiary of Enbridge, Inc., ) ) Respondent. ) ____________________________________) FINAL ORDER On July 12-15, 2010, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), conducted an on-site pipeline safety inspection of certain facilities and records of Enbridge Pipelines (Toledo) Inc. (Enbridge or Respondent). The inspection included physical inspection of a 16-inch diameter pipeline running approximately 88 miles from Stockbridge, Michigan to Oregon, Ohio, and records inspection at Respondent’s offices in Griffith, Indiana. 1 Respondent, a Canadian company incorporated in Delaware, is a wholly-owned subsidiary of Enbridge, Inc.,2 a transporter of crude oil with approximately 15,294 miles of pipelines delivering on average more than 2.2 million barrels per day of crude oil and other products.3 As a result of the inspection, the Director, Central Region, OPS (Director), issued to Respondent, by letter dated September 13, 2012, a Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order (Notice), which also included a warning pursuant to 49 C.F.R. § 190.205. In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Enbridge had violated 49 C.F.R. §§ 195.412(a), 195.428 and 195.432(d), and proposed assessing a civil penalty of $68,600 for the alleged violations. The Notice also proposed ordering Respondent to take certain measures to correct the alleged violations. The warning item required no further action, but warned the operator to correct the probable violation or face possible enforcement action. 1 Pipeline Safety Violation Report (Violation Report), (September 12, 2012) (on file with PHMSA), at 1. 2 Enbridge Pipelines (Toledo) Inc., Annual Report , 12 (FERC Form No. 6), FERC Accession No. 20130419-8087 (Apr. 18, 2013) available at http://elibrary ferc.gov/. 3 Enbridge, Liquid Pipelines, available at http://www.enbridge.com/DeliveringEnergy/OurPipelines/LiquidsPipelines.aspx (last accessed July 23, 2013).#

320125020_Final Order_08222013_text.pdf, page 32 Enbridge Energy Company, Inc.,4 responded to the Notice on behalf of Enbridge by letter dated October, 12, 2012 (Response). The company provided an explanation of its actions and information concerning the corrective actions it had taken, and requested reconsideration of the alleged violations, proposed civil penalties and proposed compliance order. Respondent did not request a hearing and therefore has waived its right to one. FINDINGS OF VIOLATION The Notice alleged that Respondent violated 49 C.F.R. Part 195, as follows: Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.428(a), which states: § 195.428 Overpressure safety devices and overfill protection system (a) Except as provided in paragraph (b) of this section, each operator shall, at intervals not exceeding 15 months, but at least once each calendar year, or in the case of pipelines used to carry highly volatile liquids, at intervals not to exceed 7½ months, but at least twice each calendar year, inspect and test each pressure limiting device, relief valve, pressure regulator, or other item of pressure control equipment to determine that it is functioning properly, is in good mechanical condition, and is adequate from the standpoint of capacity and reliability of operation for the service in which it is used. The Notice alleged that Respondent violated 49 C.F.R. § 195.428 by failing to inspect each pressure limiting device, relief valve, pressure regulator, and other item of pressure control equipment at intervals not exceeding 15 months, but at least once each calendar year. Specifically, the Notice alleged that Enbridge’s inspection intervals exceeded the maximum 15- month interval by 14 days on two overpressure safety devices, by 17 days on one overpressure safety device, and by 24 days on nine overpressure safety devices. In its Response, Enbridge acknowledged that the maximum inspection interval had been exceeded by 14-24 days and did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.428 by failing to inspect each pressure limiting device, relief valve, pressure regulator, and other item of pressure control equipment at intervals not exceeding 15 months, but at least once each calendar year. 4 Enbridge Energy Company, Inc., is an indirect wholly owned subsidiary of Enbridge Inc. Enbridge Energy Partners, L.P., Amendment No. 2 to Schedule 13D (May 8, 2013) available at http://www.sec.gov/Archives/edgar/data/880285/000119312513224471/d542746dsc13da htm.#

320125020_Final Order_08222013_text.pdf, page 43 Item 3: The Notice alleged that Respondent violated 49 C.F.R. § 195.432(d), which states: § 195.432 Inspection of in-service breakout tanks (a) . . . . (b) Each operator must inspect the physical integrity of in-service atmospheric and low-pressure steel aboveground breakout tanks according to API Standard 653 (incorporated by reference, see § 195.3). However, if structural conditions prevent access to the tank bottom, the bottom integrity may be assessed according to a plan included in the operations and maintenance manual under § 195.402(c)(3). (c) Each operator shall inspect the physical integrity of in-service steel aboveground breakout tanks built to API Standard 2510 according to section 6 of API 510. (d) The intervals of inspection by documents referenced in paragraphs (b) and (c) of this section begin on May 3, 1999, or on the operator’s last recorded date of the inspection, whichever is earlier. The Notice alleged that Respondent violated 49 C.F.R. § 195.432(d) by failing to inspect two in- service atmospheric and low-pressure steel aboveground breakout tanks according to the intervals of inspection in API Standard 653. Specifically, the Notice alleged that Enbridge exceeded the maximum internal inspection interval for tanks 300-TK-80 and 300-TK-81. For those tanks, Enbridge lacked records indicating that it had estimated the corrosion rates for the tank bottoms or the bottom plate thickness. In that circumstance, API 653 limits the maximum inspection interval to 10 years. Enbridge’s records showed that the last internal inspection for tank 300-TK-80 was performed on June 25, 1998 and that tank 300-TK-81, which entered service in 1999, did not have an internal inspection until 2011. In its response, Enbridge explained that it had made internal procedural changes to correct the historical timing issues related to the tank re-inspection intervals, but did not refute the allegation that the applicable intervals were exceeded for the specified tanks. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.432(d) by failing to perform internal inspections of in-service breakout tanks according to the intervals of inspection in API Standard 653. To the extent Respondent’s explanations may be relevant to the proposed civil penalty amount for this item, they will be addressed in the Assessment of Penalty section below. These findings of violation will be considered prior offenses in any subsequent enforcement action taken against Respondent. ASSESSMENT OF PENALTY Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed $100,000 per violation for each day of the violation, up to a maximum of $1,000,000 for any related series of violations. In determining the amount of a civil penalty under 49 U.S.C. § 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature,#

320125020_Final Order_08222013_text.pdf, page 54 circumstances, and gravity of the violation, including adverse impact on the environment; the degree of Respondent’s culpability; the history of Respondent’s prior offenses; the Respondent’s ability to pay the penalty and any effect that the penalty may have on its ability to continue doing business; and the good faith of Respondent in attempting to comply with the pipeline safety regulations. In addition, I may consider the economic benefit gained from the violation without any reduction because of subsequent damages, and such other matters as justice may require. The Notice proposed a total civil penalty of $68,600 for the violations cited above. Item 2: The Notice proposed a civil penalty of $39,000 for Respondent’s violation of 49 C.F.R. § 195.428(a), for failing to inspect each pressure limiting device, relief valve, pressure regulator, and other item of pressure control equipment at intervals not exceeding 15 months, but at least once each calendar year. With respect to the nature, circumstances, and gravity of this violation, timely inspection of these devices is a key part of pipeline safety because their malfunction can cause or contribute to a release incident. Respondent is culpable for this violation in light of the fact that there were 12 different instances each exceeding the maximum 15-month interval by 14-24 days and the pipeline’s safe operation could have been compromised in a populated area. I recognize that Enbridge now uses the Maximo work management system to schedule compliance-related tasks and that, since the inspection, employees have undergone additional training in using the system to appropriately assign and complete maintenance tasks. However, this does not diminish Respondent’s culpability at the time of the violation or constitute a good faith effort to comply prior to the violation. Enbridge did not present any evidence or argument justifying a reduction in the proposed penalty. Accordingly, having reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of $39,000 for violation of 49 C.F.R. § 195.428(a). Item 3: The Notice proposed a civil penalty of $29,600 for Respondent’s violation of 49 C.F.R. § 195.432(d), for failing to inspect two in-service atmospheric and low-pressure steel aboveground breakout tanks according to API Standard 653. With respect to the nature, circumstances, and gravity of this violation, timely tank inspections are essential to ensuring that tank failures do not occur because tank failures can have serious consequences. I recognize that Enbridge has communicated with OPS in the past and began taking steps under a Corrective Action Order to evaluate the corrosion rate and revise the inspection intervals for Tanks 80 and 81 to meet the requirements of API 653. Nevertheless, for the relevant period reviewed during the OPS inspection, the tanks were still out of compliance with the applicable inspection interval. Enbridge has not presented any evidence or argument justifying a reduction in the proposed penalty. Accordingly, having reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of $29,600 for violation of 49 C.F.R. § 195.432(d). In summary, having reviewed the record and considered the assessment criteria for each of the Items cited above, I assess Respondent a total civil penalty of $68,600. Payment of the civil penalty must be made within 20 days of service. Federal regulations (49 C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer through the Federal Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed instructions are contained in the enclosure. Questions concerning wire transfers should be directed to: Financial Operations Division (AMZ-341), Federal Aviation Administration, Mike#

320125020_Final Order_08222013_text.pdf, page 65 Monroney Aeronautical Center, P.O. Box 269039, Oklahoma City, Oklahoma 73125. The Financial Operations Division telephone number is (405) 954-8893. Failure to pay the $68,600 civil penalty will result in accrual of interest at the current annual rate in accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to those same authorities, a late penalty charge of six percent (6%) per annum will be charged if payment is not made within 110 days of service. Furthermore, failure to pay the civil penalty may result in referral of the matter to the Attorney General for appropriate action in a district court of the United States. WARNING ITEM With respect to Item 1, the Notice alleged probable violations of Part 195 but did not propose a civil penalty or compliance order for this item. Therefore, this is considered to be a warning item. The warning was for: 49 C.F.R. § 195.412 (Item 1) ─ Respondent’s alleged failure to adequately inspect the surface conditions at the main line valve at Hoffman Road (Toledo) at an interval not exceeding 3 weeks, but at least 26 times each calendar year. Enbridge presented information in its Response showing that it had taken certain actions to address the cited items. If OPS finds a violation of this provision in a subsequent inspection, Respondent may be subject to future enforcement action. COMPLIANCE ORDER The Notice proposed a compliance order with respect to Items 2 and 3 in the Notice for violations of 49 C.F.R. §§ 195.428 and 195.432(d), respectively. Under 49 U.S.C. § 60118(a), each person who engages in the transportation of hazardous liquids or who owns or operates a pipeline facility is required to comply with the applicable safety standards established under chapter 601. Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following actions to ensure compliance with the pipeline safety regulations applicable to its operations: 1. With respect to the violation of § 195.428(a) (Item 2), pertaining to the inspection of safety devices, Respondent must submit documentation of all inspections performed on each of the devices listed in Item 2 of the Notice from 2010 to present. Respondent must submit the required documentation within 30 days after receipt of this Order. 2. With respect to the violation of § 195.432(d)(Item 3), pertaining to the inspection of in-service breakout tanks, Respondent must internally inspect each of the tanks in accordance with the inspection dates proposed by Enbridge and submit copies of the API 653 inspection reports for Tanks 80 and 81. Respondent must submit the required documentation within 30 days after the receipt of this Order. If the 2012#

320125020_Final Order_08222013_text.pdf, page 76 inspection for Tank 80 has not been completed, the inspection record must be submitted within 30 days after completion of the internal inspection. 3. PHMSA requests that Respondent maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to the Director. PHMSA requests that Respondent report these costs in two categories: (1) total cost associated with preparation/revision of plans, procedures, studies, and analyses; and (2) total cost associated with personnel training or any physical changes to pipeline facilities and infrastructure. The Director may grant an extension of time to comply with any of the required items upon a written request timely submitted by the Respondent and demonstrating good cause for an extension. Failure to comply with this Order may result in administrative assessment of civil penalties not to exceed $200,000 for each violation for each day the violation continues or in referral to the Attorney General for appropriate relief in a district court of the United States. Under 49 C.F.R. § 190.215, Respondent has a right to submit a petition for reconsideration of this Final Order. Should Respondent elect to do so, the petition must be sent to: Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address. PHMSA will accept petitions received no later than 20 days after receipt of service of this Final Order by Respondent, provided they contain a brief statement of the issue(s) and meet all other requirements of 49 C.F.R. § 190.215. The filing of the petition automatically stays the payment of any civil penalty assessed. Unless the Associate Administrator, upon request, grants a stay, all other terms and conditions of this Final Order are effective upon service in accordance with 49 C.F.R. § 190.5. ___________________________________ __________________________ Jeffrey D. Wiese Date Issued Associate Administrator for Pipeline Safety#

320125020_Closure Letter_06032016_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED June 3, 2016 Mr. Terrance L. McGill President Enbridge Pipelines (Toledo), Inc. 1100 Louisiana St., Ste. 3300 Houston, TX 77002-5217 CPF 3-2012-5020 Dear Mr. McGill: On August 22, 2013, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to Enbridge Pipelines (Toledo), Inc., a Final Order in the above-referenced case. This Order included a Compliance Order and Civil Penalty assessment. Based on our review of the documentation you provided and confirmation of payment of the civil penalty, 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, Allan C. Beshore Director, Central Region, OPS Pipeline and Hazardous Materials Safety Administration#