{"operation":"document","citation":"CPF 32025025WL","title":"TEXAS EASTERN TRANSMISSION, LP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-06-06","effective_on":null,"summary":"CLOSED warning letter citing 192.603(b), 192.709(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025025wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025025wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025025wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32025025WL","body":"Warning Letter involving TEXAS EASTERN TRANSMISSION, LP. PHMSA's enforcement data identifies the cited regulations as 192.603(b),  192.709(c). The case was opened on 2025-06-06 and is reported as closed as of 2025-06-06. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32025025WL_Warning Letter_06062025_(24-297371).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025025WL/32025025WL_Warning%20Letter_06062025_(24-297371).pdf\n\n32025025WL_Warning Letter_06062025_(24-297371)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025025WL/32025025WL_Warning%20Letter_06062025_(24-297371)_text.pdf\n\n32025025WL_Warning Letter_06062025_(24-297371)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: cynthia.hansen@enbridge.com;\nmichael.koby@enbridge.com; peter.seydewitz@enbridge.com\nJune 6, 2025\nCynthia Hansen\nEVP & President Texas Eastern Transmissions, LP\n915 North Eldridge Parkway, Suite 1100,\nHouston, TX 77079\nCPF 3-2025-025-WL\nDear Ms. Hansen:\nFrom March 26 to October 25, 2024, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49\nUnited States Code (U.S.C.), conducted an inspection of the Texas Eastern North Gas\nTransmission system of Enbridge, Inc. (“Enbridge”) in Ohio, Pennsylvania, New Jersey, West\nVirginia, and New York.\nAs a result of the inspection, it is alleged that Enbridge committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. § 192.603 General provisions.\n(a) . . . .\n(b) Each operator shall keep records necessary to administer the procedures\nestablished under § 192.605.\nEnbridge failed to properly manage its computerized records necessary to administer the\nprocedures required by § 192.605 when it transitioned to a new work management system\n(WMS).\nStarting in calendar year 2021, Enbridge began the process of transitioning from its existing\nSystems, Applications, and Products (SAP) to its new asset management and work management\n\n\n\nsystem, Maximo. As part of the process, Enbridge migrated electronic records from SAP to\nMaximo. The data transfer included records from annual and bi-annual valve inspections,\nremote control valve inspections, over-pressure protection switch devices, pressure relief valves,\nand pressure limiting regulators. During the inspection PHMSA requested follow-ups for several\nmissing or incomplete records, and records with inspection dates that exceeded maximum re-\ninspection intervals for inspection years 2021-2023. Enbridge provided additional information\nfor several of the identified missing records and provided updated inspection dates. However,\nEnbridge was unable to locate or provide missing information for approximately 74 inspection\nrecords. Enbridge confirmed that an error resulted in Work Order specifications not populating,\ncausing the data to be missing from certain inspection records. Enbridge’s inability to locate\ncertain inspection records or provide specific inspection record data resulted in a failure to\nproperly manage its electronic records in accordance with Part § 192.603(b).\n2. § 192.709 Transmission lines: Record keeping.\nEach operator shall maintain the following records for transmission lines for the\nperiods specified:\n(a) . . . .\n(c) A record of each patrol, survey, inspection, and test required by subparts L and\nM of this part must be retained for at least 5 years or until the next patrol,\nsurvey, inspection, or test is completed, whichever is longer.\nEnbridge failed to properly maintain “as found” and “as left” settings records from inspections\nand tests of overpressure safety devices to ensure they are functioning properly and are in good\nmechanical condition and adequate. Enbridge’s recent migration from SAP to a Maximo work\nmanagement database system included the transfer of inspection records for over-pressure\nprotection switch devices, pressure relief valves, and pressure limiting regulators. A review of\nthe post-migration records revealed that several of those records were lacking “as found” and “as\nleft” information presumably due to an error resulting in the Work Order specifications not\npopulating. Recording and periodically reviewing “as found” and “as left” settings demonstrate\nif a set point for an overpressure safety device is drifting and not functioning properly.\nEnbridge’s failure to maintain a record of each inspection and test of overpressure safety devices\nconducted pursuant to § 192.739, including “as found” and “as left” settings, was not in\naccordance with § 192.739, and their retention is required by § 192.709(c).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a\nrelated series of violations. For violation occurring on or after December 28, 2023 and before\nDecember 30, 2024 the maximum penalty may not exceed $266,015 per violation per day the\nviolation persists, up to a maximum of $2,660,135 for a related series of violations. For violation\noccurring on or after January 6, 2023 and before December 28, 2023 the maximum penalty may\nnot exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627\nfor a related series of violations. For violation occurring on or after March 21, 2022 and before\nJanuary 6, 2023 the maximum penalty may not exceed $239,142 per violation per day the\nviolation persists, up to a maximum of $2,391,142 for a related series of violations. For violation\n\n\n\noccurring on or after May 3, 2021 and before March 21, 2022 the maximum penalty may not\nexceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for\na related series of violations. For violation occurring on or after January 11, 2021 and before\nMay 3, 2021 the maximum penalty may not exceed $222,504 per violation per day the violation\npersists, up to a maximum of $2,225,034 for a related series of violations. For violation\noccurring on or after July 31, 2019 and before January 11, 2021 the maximum penalty may not\nexceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for\na related series of violations.\nWe have reviewed the circumstances and supporting documents involved in this case and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the items identified in this letter. Failure to do so will result in\nEnbridge being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 3-2025-025. Be advised that all material you submit in response to this enforcement action\nis subject to being made publicly available. If you believe that any portion of your responsive\nmaterial qualifies for confidential treatment under 5 U.S.C. § 552(b), along with the complete\noriginal document you must provide a second copy of the document with the portions you\nbelieve qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. § 552(b).\nSincerely,\nDave Barrett\nActing Director, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Michael Koby, Sr. VP & Chief Operations Officer, GTM, Texas Eastern Transmissions, LP\nmichael.koby@enbridge.com\nPeter Seydewitz, Director, Operational Excellence, Texas Eastern Transmissions, LP\npeter.seydewitz@enbridge.com","truncated":false,"body_characters":7741}