# TEXAS EASTERN TRANSMISSION, LP — Warning Letter

- **operation:** document
- **citation:** CPF 32023012WL
- **title:** TEXAS EASTERN TRANSMISSION, LP — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2023-11-21
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.603(b).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-32023012wl.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-32023012wl.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-32023012wl
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/32023012WL
**body:**

Warning Letter involving TEXAS EASTERN TRANSMISSION, LP. PHMSA's enforcement data identifies the cited regulation as 192.603(b). The case was opened on 2023-11-21 and is reported as closed as of 2023-11-21. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

32023012WL_Warning Letter_11212023_(22-234926).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023012WL/32023012WL_Warning%20Letter_11212023_(22-234926).pdf

32023012WL_Warning Letter_11212023_(22-234926)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023012WL/32023012WL_Warning%20Letter_11212023_(22-234926)_text.pdf

32023012WL_Warning Letter_11212023_(22-234926)_text.pdf

WARNING LETTER
VIA ELECTRONIC MAIL TO: cynthia.hansen@enbridge.com;
michael.koby@enbridge.com
November 21, 2023
Cynthia Hansen
EVP & President Gas Transmission and Midstream - Enbridge Inc.
TEXAS EASTERN TRANSMISSION, LP
915 N Eldridge Parkway, Suite 1100
Houston, TX 77079
CPF 3-2023-012-WL
Dear Ms. Hansen:
From March 28 through September 23, 2022, representatives of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter
601 of 49 United States Code (U.S.C.), inspected the Enbridge_Gas_Spectra_TX_Eastern_East
inspection system, which consists of two of your subsidiaries, namely, Texas Eastern
Transmission, LP (TET East) and Egan Hub Storage, LLC, across Alabama, Kentucky,
Louisiana, Mississippi, Tennessee, and Texas.
As a result of the inspection, it is alleged that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected
and the probable violations are:
1. § 192.603 General provisions.
(a) . . . .
(b) Each operator shall keep records necessary to administer the procedures
established under § 192.605.
TET East’s records to administer the procedures required by § 192.605(b)(8) were
incomplete. PHMSA’s review of Form 7T-298 records showed a single method was used
to review the work done by operator personnel to determine the effectiveness and
adequacy of the procedures used in normal operations and maintenance. TET East’s
“Effectiveness Review Procedure” included multiple methods such as, observation of
work as it is performed and post-assessment with operating personnel after work



completion. On the 7T-298 forms reviewed during PHMSA’s inspection these methods were not
documented as being utilized; therefore, the records did not demonstrate that the
“Effectiveness Review Procedure” was administered in its entirety.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a
related series of violations. For violation occurring on or after March 21, 2022 and before
January 6, 2023, the maximum penalty may not exceed $239,142 per violation per day the
violation persists, up to a maximum of $2,391,142 for a related series of violations. For violation
occurring on or after May 3, 2021 and before March 21, 2022, the maximum penalty may not
exceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for
a related series of violations. For violation occurring on or after January 11, 2021 and before
May 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation
persists, up to a maximum of $2,225,034 for a related series of violations. For violation
occurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not
exceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for
a related series of violations. For violation occurring on or after November 27, 2018 and before
July 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a
maximum penalty not to exceed $2,132,679. For violation occurring on or after November 2,
2015 and before November 27, 2018, the maximum penalty may not exceed $209,002 per
violation per day, with a maximum penalty not to exceed $2,090,022.
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
Texas Eastern Transmission 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 3-2023-012-WL. 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,
Gregory A. Ochs
Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Michael Koby, SVP & Chief Operations Officer (michael.koby@enbridge.com)
- **truncated:** false
- **body characters:** 5390