{"operation":"document","citation":"CPF 32025027NOPV","title":"TEXAS EASTERN TRANSMISSION, LP — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-07-01","effective_on":null,"summary":"CLOSED notice of probable violation citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025027nopv.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025027nopv.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025027nopv","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32025027NOPV","body":"Notice of Probable Violation involving TEXAS EASTERN TRANSMISSION, LP. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2025-07-01 and is reported as closed as of 2026-01-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32025027NOPV_Closure Letter_01262026_(24-299195).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025027NOPV/32025027NOPV_Closure%20Letter_01262026_(24-299195).pdf\n\n32025027NOPV_Closure Letter_01262026_(24-299195)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025027NOPV/32025027NOPV_Closure%20Letter_01262026_(24-299195)_text.pdf\n\n32025027NOPV_Final Order_10202025_(24-299195).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025027NOPV/32025027NOPV_Final%20Order_10202025_(24-299195).pdf\n\n32025027NOPV_Final Order_10202025_(24-299195)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025027NOPV/32025027NOPV_Final%20Order_10202025_(24-299195)_text.pdf\n\n32025027NOPV_Operator Response to Notice_07312025_(24-299195).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025027NOPV/32025027NOPV_Operator%20Response%20to%20Notice_07312025_(24-299195).pdf\n\n32025027NOPV_PCO_07012025_(24-299195).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025027NOPV/32025027NOPV_PCO_07012025_(24-299195).pdf\n\n32025027NOPV_PCO_07012025_(24-299195)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025027NOPV/32025027NOPV_PCO_07012025_(24-299195)_text.pdf\n\n32025027NOPV_Final Order_10202025_(24-299195)_text.pdf\n\nOctober 20, 2025\nVIA ELECTRONIC MAIL TO: cynthia.hansen@enbridge.com\nMs. Cynthia Hansen\nPresident & Chief Operating Officer\nTexas Eastern Transmission, LP\n915 North Eldridge Parkway\nHouston, Texas 77079\nRe: CPF No. 3-2025-027-NOPV\nDear Ms. Hansen:\nEnclosed please find the Final Order issued in the above-referenced case. It makes a finding of\nviolation and specifies actions that need to be taken to comply with the pipeline safety\nregulations. When the terms of the compliance order are completed, as determined by the\nDirector, Central Region, this enforcement action will be closed. Service of the Final Order by e-\nmail is effective upon the date of transmission and acknowledgement of receipt as provided\nunder 49 CFR § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nLinda Daugherty\nActing Associate Administrator\nfor Pipeline Safety\nEnclosures (Final Order and NOPV)\ncc: David Barrett, Acting Director, Central Region, Office of Pipeline Safety, PHMSA\nMr. Peter Seydewitz, Director, Operational Excellence, Peter.Seydewitz@enbridge.com\nMs. Salima Abdulla, Manager, Operational Compliance, Salima.Abdulla@enbridge.com\nMr. Michael McGrath, Strategic Advisor, Operational Compliance,\nMichael.McGrath@enbridge.com\n\n\n\nCONFIRMATION OF RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\n)\nIn the Matter of )\n)\nTexas Eastern Transmission, LP, )\na subsidiary of Enbridge Inc., ) CPF No. 3-2025-027-NOPV\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nOn July 1, 2025, pursuant to 49 CFR § 190.207, the Acting Director, Central Region, Office of\nPipeline Safety (OPS), issued a Notice of Probable Violation (Notice) to Texas Eastern\nTransmission, LP (Respondent). The Notice proposed finding that Respondent had violated the\npipeline safety regulations in 49 CFR Part 192. The Notice also proposed certain measures to\ncorrect the violation. Respondent did not contest the allegation of violation or corrective\nmeasures.\nPursuant to 49 CFR § 190.213, I find Respondent violated the pipeline safety regulation listed\nbelow, as more fully described in the enclosed Notice, which is incorporated by reference:\n49 CFR § 192.605(a) (Item 1) ─ Respondent failed to follow its manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response.\nThis finding of violation will be considered a prior offense in any subsequent enforcement action\ntaken against Respondent.\nCompliance Actions\nPursuant to 49 U.S.C. § 60118(b) and 49 CFR § 190.217, Respondent is ordered to take the\nactions proposed in the enclosed Notice to correct the violation. The Director may grant an\nextension of time to comply with any of the required items upon a written request timely\nsubmitted by the Respondent and demonstrating good cause for an extension. Upon completion\nof the ordered actions, Respondent may request that the Director close the case. Respondent\npreviously submitted evidence to show appropriate actions have been started to correct the\nviolations. This evidence is currently under review by the Director. Failure to comply with this\nOrder may result in the assessment of civil penalties under 49 CFR § 190.223 or in referral to the\n\n\n\nAttorney General for appropriate relief in a district court of the United States.\nThe terms and conditions of this order are effective upon service in accordance with 49 CFR\n§ 190.5.\n___________________________________ __________________________\nLinda Daugherty Date Issued\nActing Associate Administrator\nfor Pipeline Safety\n\n\n\nNOTICE OF PROBABLE VIOLATION\nand\nPROPOSED COMPLIANCE ORDER\nVIA ELECTRONIC MAIL TO: cynthia.hansen@enbridge.com;\npeter.seydewitz@enbridge.com; salima.abdulla@enbridge.com; michael.mcgrath@enbridge.com\nJuly 1, 2025\nMs. Cynthia Hansen\nPresident / Chief Operating Officer\nTexas Eastern Transmission, LP\n915 North Eldridge Parkway\nHouston, TX 77079\nCPF 3-2025-027-NOPV\nDear Ms. Hansen:\nFor the weeks of May 13, June 3, and June 24, 2024, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code\n(U.S.C.), inspected Texas Eastern Transmission, LP’s procedures and records for the new gas\nintegrity rule1 in Houston, Texas.\nAs a result of the inspection, it is alleged that Texas Eastern Transmission, LP’s (TET) has\ncommitted a probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal\nRegulations (CFR). The item inspected and the probable violation is:\n1. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include procedures\nfor handling abnormal operations. This manual must be reviewed and updated by the\noperator at intervals not exceeding 15 months, but at least once each calendar year.\nThis manual must be prepared before operations of a pipeline system commence.\n1 Pipeline Safety: Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment\nRequirements, and Other Related Amendments, 84 Fed. Reg. 52,180 (October 1, 2019).\n\n\n\nAppropriate parts of the manual must be kept at locations where operations and\nmaintenance activities are conducted.\nTET did not follow its manual of written procedures in accordance with § 192.605(a). Specifically,\nTET did not follow its “Pipeline Integrity – Integrity Management Plan” (IMP), section 7.3.1\nwhich required the identification of Moderate Consequence Areas (MCA) for the purpose of\nconducting baseline assessments in accordance with § 192.710(b). Section 7.3.1 referenced\nprocedure OC-52.201 – “HCA/MCA Identification Process” which states in section 3 that “HCAs\nand MCAs shall be identified, evaluated, and published once per calendar year, not to exceed a\nperiod of 15 months for all US Enbridge (as built/in service) gas transmission pipelines.”\nDuring PHMSA’s inspection, PHMSA inspectors reviewed TET’s pipeline system for MCAs and\ndetermined that six MCAs were missed at the time of the inspection. A historical review of\npublicly available satellite imagery found that these locations existed prior to the effective date of\nthe regulation, which was July 1, 2020. The missed MCAs discovered during PHMSA’s\ninspection were as follows:\nLocation\n• 40.439063°, -78.978202° - ARMA-LILL/12 was not designated as an MCA even though it\nmet the 5 buildings intended for human occupancy density count within a potential impact\nradius. The adjacent lines ARMA-LILL/19 and ARMA-LILL/27 were designated as MCAs\nwithin this area.\n• 40.338835°, -75.078314° - EAGL-LAMT/1 line segment had an MCA identified in this area\ndue to the house density. However, the MCA should have been longer than what was\ndesignated in the map. This MCA was right next to a designated high consequence area\n(HCA) for this line. The adjacent line EAGL-LAMT/2 was designated an HCA throughout\nthis entire area.\n• 40.116594°, -75.272552° - EAGL-LAMT/1-B-2 had an MCA established for the PA\nTurnpike (Hwy 276). However, the MCA stopped short of a location where the pipe\nsegments met the house density count requirement. Therefore, the MCA should have been\nexpanded to include this area.\n• 40.134355°, -75.248624° - EAGL-LAMT/1-B-1 did not have an MCA designated at this\nlocation, despite it meeting the criteria due to the housing density.\n• 40.111930°, -75.270010° - EAGL-LAMT/1-B-1 and EAGL-LAMT/1-B-2 were not\nidentified MCAs at this location, despite meeting the criteria due to housing density. This\narea was adjacent to existing MCAs on both lines.\n• 40.081469°, -75.134934° - EAGL-LAMT/1-F did not have an MCA designated in this area,\ndespite meeting the criteria due to housing density.\nThus, TET did not follow its IMP, Section 7.3.1, for the identification of MCAs in six locations,\nin violation of § 192.605(a).\n\n\n\nProposed Civil Penalty\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 related\nseries of violations. For violation occurring on or after December 28, 2023 and before December\n30, 2024 the maximum penalty may not exceed $266,015 per violation per day the violation\npersists, up to a maximum of $2,660,135 for a related series of violations. For violation occurring\non or after January 6, 2023 and before December 28, 2023 the maximum penalty may not exceed\n$257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related\nseries of violations. For violation occurring on or after March 21, 2022 and before January 6, 2023\nthe maximum penalty may not exceed $239,142 per violation per day the violation persists, up to\na maximum of $2,391,412 for a related series of violations. For violation occurring on or after\nMay 3, 2021 and before March 21, 2022 the maximum penalty may not exceed $225,134 per\nviolation per day the violation persists, up to a maximum of $2,251,334 for a related series of\nviolations. For violation occurring on or after January 11, 2021 and before May 3, 2021 the\nmaximum penalty may not exceed $222,504 per violation per day the violation persists, up to a\nmaximum of $2,225,034 for a related series of violations. For violation occurring on or after July\n31, 2019, and before January 11, 2021 the maximum penalty may not exceed $218,647 per\nviolation per day the violation persists, up to a maximum of $2,186,465 for a related series of\nviolations.\nWe have reviewed the circumstances and supporting documents involved in this case and have\ndecided not to propose a civil penalty assessment at this time.\nProposed Compliance Order\nWith respect to Item 1 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials Safety\nAdministration proposes to issue a Compliance Order to Texas Eastern Transmission, LP. Please\nrefer to the Proposed Compliance Order, which is enclosed and made a part of this Notice.\nResponse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in\nEnforcement Proceedings. Please refer to this document and note the response options. All\nmaterial you submit in response to this enforcement action may be made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. §552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 U.S.C. § 552(b).\n\n\n\nFollowing your receipt of this Notice, you have 30 days to respond as described in the enclosed\nResponse Options. If you do not respond within 30 days of receipt of this Notice, this constitutes\na waiver of your right to contest the allegations in this Notice and authorizes the Associate\nAdministrator for Pipeline Safety to find facts as alleged in this Notice without further notice to\nyou and to issue a Final Order. If you are responding to this Notice, we propose that you submit\nyour correspondence to my office within 30 days from receipt of this Notice. The Region Director\nmay extend the period for responding upon a written request timely submitted demonstrating good\ncause for an extension.\nIn your correspondence on this matter, please refer to CPF 3-2025-027-NOPV and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nDavid Barrett\nActing Director, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Mr. Peter Seydewitz, Director - Operational Excellence\nMs. Salima Abdulla, Manager – Operational Compliance\nMr. Michael McGrath, Strategic Advisor, Operational Compliance\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Enforcement Proceedings\n\n\n\nPROPOSED COMPLIANCE ORDER\nPursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) proposes to issue to Texas Eastern Transmission, LP a Compliance\nOrder incorporating the following remedial requirements to ensure the compliance of Texas\nEastern Transmission, LP, with the pipeline safety regulations:\nA. In regard to Item 1 of the Notice pertaining to missed Moderate Consequence Areas\n(MCAs), Texas Eastern Transmission, LP, must review all processes that are\nassociated with the identification of MCAs to determine how existing structure MCAs\nwere not previously identified and provide documentation of the review and approval\nto the Director, Central Region within 90 days of issuance of the Final Order. Once\nthis review is complete, Texas Eastern Transmission, LP, must ensure all MCAs and\nother pipe segments subject to § 192.710 are identified and submit the final results to\nthe Director, Central Region for review and approval within 180 days of issuance of\nthe Final Order.\nB. It is requested (not mandated) that Texas Eastern Transmission maintain\ndocumentation of the safety improvement costs associated with fulfilling this\nCompliance Order and submit the total to Director, Central Region, Pipeline and\nHazardous Materials Safety Administration. It is requested that these costs be reported\nin two categories: 1) total cost associated with preparation/revision of plans,\nprocedures, studies and analyses, and 2) total cost associated with replacements,\nadditions and other changes to pipeline infrastructure.\n\n32025027NOPV_Closure Letter_01262026_(24-299195)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\n901 Locust Street, Suite 480\nKansas City, MO 64106\nVIA ELECTRONIC MAIL TO: cynthia.hansen@enbridge.com\nJanuary 26, 2026\nMs. Cynthia Hansen\nPresident / Chief Operating Officer\nTexas Eastern Transmission, LP\n915 North Eldridge Parkway\nHouston, TX 77079\nRE: CPF 3-2025-027-NOPV\nDear Ms. Hansen:\nOn October 20, 2025, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued to Texas Eastern Transmission, LP (“TET”) a Final Order, pursuant to 49 CFR § 190.213.\nThis Order included a Compliance Order. Based on our review of the documentation provided, it\nhas been determined that TET has complied with the terms of the Order.\nAccordingly, this case is now closed, and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nDavid Barrett\nActing Director, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Mr. Peter Seydewitz, Director - Operational Excellence, peter.seydewitz@enbridge.com;\nMs. Salima Abdulla, Manager – Operational Compliance, salima.abdulla@enbridge.com\nMr. Michael McGrath, Strategic Advisor, Compliance, michael.mcgrath@enbridge.com","truncated":false,"body_characters":16732}