TE PRODUCTS PIPELINE COMPANY, LLC — Notice of Probable Violation

party submissionOfficial PDF420095010_Operator_Response_10082009.pdf#

420095010_FinalOrder_12302010_text.pdf, page 1Official PDFDEC 30 2010 Mr. Terry L. Hurlburt Senior Vice President, Operations Enterprise Products Operating, LLC P. O. Box 4324 Houston, TX 77210-4324 Re: CPF No. 4-2009-5010 Dear Mr. Hurlburt: Enclosed please find the Final Order issued in the above-referenced case. It withdraws one allegation of violation, makes two findings of violation, assesses a civil penalty of $53,400, and finds that Texas Eastern Products Pipeline Company, LLC, has completed the actions specified in the Notice 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, 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: Mr. R. M. Seeley, Director, Southwest Region, PHMSA Mr. Josh E. Kohler Manager, Pipeline Compliance Texas Eastern Products Pipeline Company, LLC 1100 Louisiana Street, Suite 1600 Houston, TX 77002-5227 CERTIFIED MAIL - RETURN RECEIPT REQUESTED [7005 1160 0001 0040 0030]#

420095010_FinalOrder_12302010_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 ) ) Texas Eastern Products ) Pipeline Company, LLC, ) CPF No. 4-2009-5010 ) a subsidiary of ) Enterprise Products Operating, LLC, ) ) Respondent. ) ____________________________________) FINAL ORDER On October 21-24 and 27-31, 2008, and January 15, 2009, pursuant to 49 U.S.C. § 60117, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), conducted an on-site pipeline safety inspection of the facilities and records of Texas Eastern Products Pipeline Company, LLC (TEPPCO or Respondent), in Louisiana and Texas. Following a merger with subsidiaries of Enterprise Products Partners, L.P., on October 26, 2009, TEPPCO is now a wholly-owned subsidiary of Enterprise Products miles of pipelines carrying refined petroleum products and highly volatile liquids. Operating, LLC (Enterprise).1 At the time of the inspection, TEPPCO’s system included 4,500 As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to Respondent, by letter dated August 31, 2009, a Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that TEPPCO had committed various violations of 49 C.F.R. Part 195, assessing a civil penalty of $72,400 for the alleged violations, and ordering Respondent to take certain measures to correct the alleged violations. The Notice also proposed finding that Respondent had committed certain other probable violations of 49 C.F.R. Part 195 and warning Respondent to take appropriate corrective action or be subject to future enforcement action. TEPPCO responded to the Notice by letter dated October 8, 2009 (Response). The company contested one of the allegations and described the steps it had taken to complete the terms of the proposed compliance order. Respondent did not request a hearing and therefore has waived its right to one. 1 SEC Form 10-K, Enterprise Products Partners, L.P., March 1, 2010.#

420095010_FinalOrder_12302010_text.pdf, page 32 FINDINGS OF VIOLATION The Notice alleged that Respondent violated 49 C.F.R. Part 195, as follows: Item 3: The Notice alleged that Respondent violated 49 C.F.R. § 195.428(a), which states: § 195.428 – Overpressure safety devices and overfill protection systems. (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 7 ½ 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(a) by failing to conduct required inspections of two pressure control valves at intervals not exceeding 7½ months, but at least twice each calendar year. Specifically, the Notice alleged that Respondent could not provide documentation to indicate that the Hankamer Station valves, which are part of a pipeline used to carry highly volatile liquids, were inspected twice in 2007 and 2008. In its Response, the company provided copies of records indicating that the valves at issue were actually inspected twice in 2007 and 2008, as required. Accordingly, after considering all of the evidence, I find that Respondent did not violate § 195.428(a). Based upon the foregoing, I hereby order that Item 3 be withdrawn. Item 4: The Notice alleged that Respondent violated 49 C.F.R. § 195.428(d), which states: § 195.428 – Overpressure safety devices and overfill protection systems. (a) . . . . (d) After October 2, 2000, the requirements of paragraphs (a) and (b) of this section for inspection and testing of pressure control equipment apply to the inspection and testing of overfill protection systems. The Notice alleged that Respondent violated 49 C.F.R. § 195.428(d) by failing to conduct required inspections and tests of the overfill protection systems of three breakout tanks at Beaumont Terminal at intervals not exceeding 15 months, but at least once each calendar year. Respondent 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(d) by failing to inspect and test the overfill protection systems of three breakout tanks with the required frequency. Item 5: The Notice alleged that Respondent violated 49 C.F.R. §§ 195.589(c) and 195.573(a)(1), which state:#

420095010_FinalOrder_12302010_text.pdf, page 43 § 195.589 – What corrosion control information do I have to maintain? (a) . . . . (c) You must maintain a record of each analysis, check, demonstration, examination, inspection, investigation, review, survey, and test required by this subpart in sufficient detail to demonstrate the adequacy of corrosion control measures or that corrosion requiring control measures does not exist. You must retain these records for at least 5 years, except that records related to §§ 195.569, 195.573(a) and (b), and 195.579(b)(3) and (c) must be retained for as long as the pipeline remains in service. § 195.573 – What must I do to monitor external corrosion control? (a) Protected pipelines. You must do the following to determine whether cathodic protection required by this subpart complies with §195.571: (1) Conduct tests on the protected pipeline at least once each calendar year, but with intervals not exceeding 15 months. However, if tests at those intervals are impractical for separately protected short sections of bare or ineffectively coated pipelines, testing may be done at least once every 3 calendar years, but with intervals not exceeding 39 months The Notice alleged that Respondent violated 49 C.F.R. §§ 195.589(c) and 195.573(a)(1) by failing to conduct and maintain records of required corrosion control tests at certain pipeline locations. Specifically, the Notice alleged that at the time of the inspection, TEPPCO’s records indicated that pipe-to-soil surveys were not conducted at 19 locations in 2007. Respondent 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. §§ 195.589(c) and 195.573(a)(1) by failing to conduct and maintain records of required corrosion control tests at certain pipeline locations. 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, 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; 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.#

420095010_FinalOrder_12302010_text.pdf, page 54 The Notice proposed a total civil penalty of $72,400 for the violations cited above.2 Item 3: The Notice proposed a civil penalty of $19,000 for Respondent’s violation of 49 C.F.R. § 195.428(a), for failing to carry out required inspections of overpressure valves. As discussed above, I ordered that the allegations in Item 3 be withdrawn. Accordingly, I also withdraw the proposed penalty for this Item. Item 4: The Notice proposed a civil penalty of $32,900 for Respondent’s violation of 49 C.F.R. § 195.428(d), for failing to conduct required inspections and tests of the overfill protection systems of three breakout tanks. Respondent did not object to the proposed civil penalty. Overfill protection systems provide crucial protection against spills. Regular inspections and tests of such systems are key to ensuring that these systems operate properly. In this case, Respondent failed to inspect and test three breakout tanks. Respondent has provided no information that would justify a reduction in the proposed civil penalty. Accordingly, having reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of $32,900 for violation of 49 C.F.R. § 195.428(d). Item 5: The Notice proposed a civil penalty of $20,500 for Respondent’s violation of 49 C.F.R. §§ 195.589(c) and 195.573(a)(1), for failing to conduct and maintain records of required corrosion control tests at certain pipeline locations. Respondent did not object to the proposed civil penalty. Regular pipe-to-soil surveys are crucial to measuring the effectiveness of corrosion control measures and indentifying areas at risk of corrosion. Maintaining adequate protection against corrosion, in turn, protects against potentially dangerous pipeline leaks and releases. In this case, Respondent failed to conduct annual tests at nineteen locations. Respondent has provided no information that would justify a reduction in the proposed civil penalty. Accordingly, having reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of $20,500 for violation of 49 C.F.R. §§ 195.589(c) and 195.573(a)(1). 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 $53,400. 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 Monroney Aeronautical Center, P.O. Box 269039, Oklahoma City, Oklahoma 73125. The Financial Operations Division telephone number is (405) 954-8893. 2 The Notice incorrectly stated that the total proposed civil penalty was $72,500.#

420095010_FinalOrder_12302010_text.pdf, page 65 Failure to pay the $53,400 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. COMPLIANCE ORDER The Notice proposed a compliance order with respect to Items 3, 4, and 5 in the Notice for violations of 49 C.F.R. §§ 195.428(a), 195.428(d), 195.589(c), and 195.573(a)(1). 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. Because I ordered that the allegations in Item 3 be withdrawn, the compliance terms proposed for that Item are not included in this order. The Director has indicated that Respondent has taken the following actions to address the cited violations: 1. With respect to Item 4, Respondent has: a. reviewed its procedures for the inspection of overfill protection systems, b. inspected the overfill protection for the breakout tanks referenced in Item 4, and c. provided documentation indicating that these inspections have been performed. 2. With respect to Item 5, Respondent has: a. reviewed its procedures on performing cathodic protection testing, b. performed pipe-to-soil surveys of the P-2 and P-62 pipelines, including the areas that were not tested in 2006 and 2007, and c. provided documentation indicating that these surveys have been performed. Accordingly, I find that compliance has been achieved with respect to these violations. Therefore, the compliance terms proposed in the Notice for Items 4 and 5 are not included in this Order. WARNING ITEMS With respect to Items 1 and 2, the Notice alleged probable violations of Part 195 but did not propose a civil penalty or compliance order for these items. Therefore, these are considered to be warning items. The warnings were for:#

420095010_FinalOrder_12302010_text.pdf, page 76 49 C.F.R. § 195.402(a) (Item 1) ─ Respondent’s alleged failure to follow its written procedures relating to inspections of firefighting equipment; and 49 C.F.R. § 195.402(a) (Item 2) ─ Respondent’s alleged failure to inspect shorted casing vents every six months, as required by the company’s written procedures. Respondent presented information in its Response showing that it had taken certain actions to address the cited items. Accordingly, having considered such information, I find, pursuant to 49 C.F.R. § 190.205, that probable violations of 49 C.F.R. § 195.402(a) (Notice Items 1 and 2) have occurred and Respondent is hereby advised to correct such conditions. In the event that OPS finds a violation of this provision in a subsequent inspection, Respondent may be subject to future enforcement action. Under 49 C.F.R. § 190.215, Respondent has a right to submit a Petition for Reconsideration of this Final Order. 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 this Final Order by the 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 a 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#

420095010_NOPV PCP PCO_08312009_text.pdf, page 1Official PDFNOTICE OF PROBABLE VIOLATION PROPOSED CIVIL PENALTY and PROPOSED COMPLIANCE ORDER CERTIFIED MAIL - RETURN RECEIPT REQUESTED August 31, 2009 Mr. Terry Hulbert Senior Vice President – Operations TE Products Pipeline Company, LLC 1100 Louisiana Street Houston, Texas 77002-5227 CPF 4-2009-5010 Dear Mr. Hulbert: From October 21 – 24, October 27 – 31, 2008, and January 15, 2009, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your records and pipeline facilities in the Louisiana and Texas. 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 violations are: 1. §195.402 Procedural manual for operations, maintenance, and emergencies (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. This manual shall be reviewed at intervals not exceeding 15 months, but at least once each calendar year, and appropriate changes made as necessary to insure that the manual is effective. This manual shall be prepared before initial operations of a pipeline system commence, and appropriate parts shall be kept at locations where operations and maintenance activities are conducted. TE Products procedures for fire fighting equipment states that fire fighting equipment will be located at each pump station and breakout tank area. It also states that the fire fighting equipment must be in proper operating condition at all times and that local personnel or contract services shall inspect all fire fighting equipment monthly. TE#

420095010_NOPV PCP PCO_08312009_text.pdf, page 2personnel are not following their written procedures for fire fighting equipment. During the records inspection, it was understood that Baytown is where official records reside. During the records evaluation of TE Products, personnel had difficulty in locating records to indicate that items were inspected according to your written procedures. Personnel were unable to locate records to indicate that the fire fighting equipment was inspected for Many pump station for the months of June 2007 and August 2007. Also, personnel were unable to provide inspection records for August 2008 for the Tyler Station to indicate that fire fighting equipment was inspected. Also, at the Beaumont Terminal, records did not indicate that paperwork was filled out according to your procedures. Records were incomplete, dates of the next hydro test date, any comments or the Supervisor’s signature was not on monthly inspection report. 2. §195.402 Procedural manual for operations, maintenance, and emergencies (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. This manual shall be reviewed at intervals not exceeding 15 months, but at least once each calendar year, and appropriate changes made as necessary to insure that the manual is effective. This manual shall be prepared before initial operations of a pipeline system commence, and appropriate parts shall be kept at locations where operations and maintenance activities are conducted. TE Products procedures (Cathodic Protection Annual Survey) states that shorted casing vents shall be checked with a gas detector for signs of leakage every six months until the short is cleared or the casing is filled with corrosion inhibitor. At the time of the inspection, inspectors were provided records that would indicate that shorted casings were not checked every six months. According to these records, they were only checked once each calendar year. This office understands that TE has a new technician that has identified this as a high priority and has taken steps to assure that this does not happen again. 3. §195.428 Overpressure safety devices and overfill protection systems (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 7 ½ months, but at least twice each calendar ear, 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. At the time of the inspection, TE Products could not provide documentation to indicate that at the Hankamer Pressure Control Valves were inspected twice each calendar year for 2007 and 2008. Records were provided for the June 2007 inspection, but there were#

420095010_NOPV PCP PCO_08312009_text.pdf, page 3no other records available during the inspection to indicate that the control valves were inspected twice each calendar year for 2007 or 2008. 4. §195.428 Overpressure safety devices and overfill protection systems. §195.428(d) After October 2, 2000, the requirements of paragraphs (a) and (b) of this section for inspection and testing of pressure control equipment apply to the inspection and testing of overfill protection systems. At the Beaumont Terminal, there are three tanks (Breakout tank # 734, 735, and 771) that the overfill protection has not been tested. According to TE Product records, inspectors performing the inspections on these tanks have noted time and time again that they were unable to test. This indicates that when personnel perform their duties in inspecting breakout tanks and note deficiencies that these deficiencies are not being acted upon. 5. §195.589 What corrosion control information do I have to maintain? §195. 589( c) You must maintain a record of each analysis, check, demonstration, examination, inspection, investigation, review, survey, and test required by this subpart in sufficient detail to demonstrate the adequacy of corrosion control measures or that corrosion requiring control measures does not exist. You must retain these records for at least 5 years, except that records related to §§195.569, 195.573(a) and (b), and 195.579(b)(3) and ( c) must be retained for as long as the pipeline remains in service. §195.573 (a)(1) Protected pipeline. You must do the following to determine whether cathodic protection required by this subpart complies with §195.571: (1) Conduct tests on the protected pipeline at least once each calendar year, but with intervals not exceeding 15 months. However, it test at those intervals are impractical for separately protected short sections of bare or ineffectively coated pipelines, testing may be done at least once every 3 calendar years, but with intervals not exceeding 39 months. TE Products conducted their pipe-to-soil surveys in November of 2006 and again in November of 2007. During the inspection, the inspectors reviewed your ‘TEPPCO Products P/S Survey’ records and there are 19 locations that were not tested in 2007 for the P-2 and P-62 pipelines. The records indicate that the ‘Water too high to access’, ‘No test lead’, ‘Hunters in ROW’, or ‘Not allowed access by landowner’. At the time of the inspection these locations still had not been surveyed, exceeding once each calendar year, not to exceed 15 months. TE Products had not conducted the 2008 survey at the time of the inspection.#

420095010_NOPV PCP PCO_08312009_text.pdf, page 4Proposed Civil Penalty Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000 for each violation for each day the violation persists up to a maximum of $1,000,000 for any 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 $72,500.00 as follows: Item number PENALTY 3 $19,000 4 $32,900 5 $20,500 Warning Items With respect to items 1 and 2 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 these items. Be advised that failure to do so may result in TE Products Pipeline Company, LLC being subject to additional enforcement action. Proposed Compliance Order With respect to items 3, 4, and 5, pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration proposes to issue a Compliance Order to TE Products Pipeline Company, LLC. 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 4-2009-5010 and for each document you submit, please provide a copy in electronic format whenever possible.#

420095010_NOPV PCP PCO_08312009_text.pdf, page 5Sincerely, R. M. Seeley Director, Southwest Region Pipeline and Hazardous Materials Safety Administration Enclosures: Proposed Compliance Order Response Options for Pipeline Operators in Compliance Proceedings#

420095010_NOPV PCP PCO_08312009_text.pdf, page 6PROPOSED COMPLIANCE ORDER Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposes to issue to TE Products Pipeline Company, LLC, a Compliance Order incorporating the following remedial requirements to ensure the compliance of TE Products Pipeline Company, LLC with the pipeline safety regulations: 1. In regard to Item Number 3 of the Notice pertaining to the pressure control valves at Hankamer: a. Review procedures for the inspection of pressure control valves, and modify the procedures to assure that employees understand what is required during the inspection of pressure control valves and how to fill out the appropriate inspection reports. b. Perform the inspection of the pressure control valves at Hankamer. c. Submit completed procedures and the records to indicate that the inspection has been completed. 2. In regard to Item Number 4 of the Notice pertaining to the overfill protection at the Beaumont Terminal, TE Products will: a. Review procedures for the inspection of overfill protection, and modify the procedures. Review the modified procedures with employees to assure that they understand their responsibilities. Also, assure that management understands that when deficiencies are found, they know their responsibilities in correcting the deficiency. b. Perform the inspection of the overfill protection for Breakout tanks #734, 735, and 771. c. Provide documentation to indicate that the inspections have been performed. 3. In regard to Item Number 5 of the Notice pertaining to the pipe-to-soil surveys for the P-2 and P-62: a. Review procedures for performing cathodic protection testing, and modify the procedures if necessary. Review the procedures with employees to assure that they understand their roles and responsibilities. b. Perform the pipe-to soil surveys of the P-2 and P-62, including those areas that were not accessible during the 2006 and 2007 surveys. c. Provide documentation to indicate that the inspections have been performed, including the locations that were not tested in 2006 and 2007. 5. TE Products Pipeline Company, LLC shall complete the items above within 60 days after receipt of the Final Order. 6. TE Products Pipeline Company, LLC shall maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to R.M. Seeley, Director, Southwest Region, Pipeline and Hazardous Materials Safety Administration. Costs shall 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#

420095010_NOPV PCP PCO_08312009_text.pdf, page 7changes to pipeline infrastructure.#