EXPRESS HOLDINGS (USA), LLC — Notice of Amendment

party submissionOfficial PDF320205017M_Operator Response to Notice_11062020.pdf#

320205017M_Notice of Amendment_10072020_text.pdf, page 1Official PDFNOTICE OF AMENDMENT VIA ELECTRONIC MAIL TO: Michael.Koby@enbridge.com and David.Stafford@enbridge.com October 7, 2020 Mr. Michael Koby Vice President, US Operations Enbridge Inc. Express Holdings (USA), LLC 7701 France Ave. S. Suite 600 Edina, MN 55435 CPF 3-2020-5017M Dear Mr. Koby: From June 10, 2019 to September 13, 2019, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code, inspected your Express Holdings (USA), LLC (Express Holdings) procedures for Integrity Management in Casper, Wyoming. On the basis of the inspection, PHMSA has identified the apparent inadequacy found within Express Holdings plans or procedures, as described below: 1. §195.452 Pipeline integrity management in high consequence areas. (a) . . . (j) What is a continual process of evaluation and assessment to maintain a pipeline's integrity? – (5) Assessment methods. An operator must assess the integrity of the line pipe by any of the following methods. The methods an operator selects to assess low frequency#

320205017M_Notice of Amendment_10072020_text.pdf, page 2electric resistance welded pipe or lap welded pipe susceptible to longitudinal seam failure must be capable of assessing seam integrity and of detecting corrosion and deformation anomalies. (i) . . . (iv) Other technology that the operator demonstrates can provide an equivalent understanding of the condition of the line pipe. An operator choosing this option must notify OPS 90 days before conducting the assessment, by sending a notice to the address or facsimile number specified in paragraph (m) of this section. Express Holdings’ procedure PI-141, dated 3/20/2018, is inadequate because it does not include the notification to OPS requirement of §195.452(j)(5)(iv) when “other technology” is selected as the assessment tool as part of an integrity assessment. Express Holdings must amend their procedures to include this requirement. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. 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 an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that Express Holdings maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Allan Beshore, Director, Central Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 3-2020-5017M and, for each document you submit, please provide a copy in electronic format whenever possible. 2#

320205017M_Notice of Amendment_10072020_text.pdf, page 3Sincerely, Gregory A. Ochs Director, Central Region, OPS Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings cc: David Stafford, Manager, US Pipeline Compliance, David.Stafford@enbridge.com 3#

320205017M_Closure Letter_11102020_text.pdf, page 1Official PDFVIA ELECTRONIC MAIL TO: Michael.Koby@enbridge.com and David.Stafford@enbridge.com November 10, 2020 Mr. Micheal Koby VP, US Operations Express Holdings (USA), LLC 5400 Westheimer Court Houston, TX 77056 Re: CPF 3-2020-5017M Dear Mr. Koby: On June 10-September 13, 2019, representatives from the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site pipeline safety inspection of Expess Holdings(USA), LLC (Express Holdings) procedures in Casper, WY. As a result of the inspection, Express Holdings was issued a Notice of Amendment on October 7, 2020, which proposed amendment of your procedures. Express Holdings submitted its amended procedures on November 6, 2020. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Gregory A. Ochs Director, Central Region, OPS Pipeline and Hazardous Materials Safety Administration cc: David Stafford, Manager, US Pipeline Compliance, David.Stafford@enbridge.com#