{"operation":"document","citation":"CPF 420145018W","title":"ENTERPRISE CRUDE PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-08-12","effective_on":null,"summary":"CLOSED warning letter citing 195.202.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420145018w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420145018w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420145018w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420145018W","body":"Warning Letter involving ENTERPRISE CRUDE PIPELINE LLC. PHMSA's enforcement data identifies the cited regulation as 195.202. The case was opened on 2014-08-12 and is reported as closed as of 2014-08-12. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420145018W_Operator Response to Notice_10032014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420145018W/420145018W_Operator%20Response%20to%20Notice_10032014.pdf\n\n420145018W_Warning_08122014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420145018W/420145018W_Warning_08122014.pdf\n\n420145018W_Warning_08122014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420145018W/420145018W_Warning_08122014_text.pdf\n\n420145018W_Warning_08122014_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 12, 2014\nMr. Kevin Bodenhamer\nSenior Vice President, Liquid Pipeline Operations\nEnterprise Crude Pipeline LLC\n1100 Louisiana Street\nHouston, TX 770022\nCPF 4-2014-5018W\nDear Mr. Bodenhamer:\nBetween July 2013 and May 2014, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) inspected several Enterprise Crude Pipeline, LLC\n(“Enterprise”) construction projects including: ATEX (spread 6 in TX), Seaway Loop (spread 1\nin OK, spreads 2, 4, 5, 6, and 7 in TX), and Western Expansion (WEP) III in the Texas and New\nMexico area pursuant to Chapter 601 of 49 United States Code. The inspections included a\nreview of construction records, procedures, and field site visits.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n1. §195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive\nwritten specifications or standards that are consistent with the requirements of this\npart.\n\n\n\nEnterprise failed to construct the Seaway Loop Project in accordance with comprehensive\nwritten specifications or standards by failing to inspect all external pipe coating just prior to\nlowering the pipe into the ditch or submerging the pipe as required by §195.561(a).\nPHMSA reviewed Enterprise Engineering Standards & Specifications, STD.7002, Protective\nCoatings - Below Ground Steel Surfaces-Field Applied, Sec. 4.7 Recoat - Holiday Detection,\nRev. 2, dated May 2013, which states in paragraph (2):\n“… Holiday inspection shall be conducted just prior to lowering the pipe into the\nditch… Any coating damage discovered must be repaired. All inspection and\nrepair results must be documented on the Company Coating Inspection form.”\nOn Seaway Loop Segment 5, PHMSA observed that the pipe section at Station 515+00 (the “515\npipe section”) was laid into the ditch without being inspected for holidays. The utility inspector\nstated that the decision to “pre-jeep” the pipe was made and it was inspected for holidays\n“yesterday.”\nThe Chief Inspector was advised of the incident where the pipe was not tested for holidays just\nprior to being placed in the ditch. The Chief Inspector stated that he would look into the\nsituation, and assured that all pipe will be tested for holidays “just prior” to being laid-in the\nditch.\n2. §195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive\nwritten specifications or standards that are consistent with the requirements of this\npart.\nEnterprise failed to construct the Seaway Loop Project in accordance with comprehensive\nwritten specifications or standards by failing to follow its STD.7002, Section 4.7 and use the\nprescribed voltage settings for the Holiday Detector when jeeping the pipeline.\nPHMSA reviewed Enterprise Engineering Standards & Specifications, STD.7002, Protective\nCoatings - Below Ground Steel Surfaces-Field Applied, Sec. 4.7 Recoat - Holiday Detection,\nRev. 2, dated May 2013, which states in paragraph (1) and (3):\n“(1) Holiday inspection shall be in accordance with NACE SP0188, SP0274, or\nSP0490, as appropriate. … (3) … The minimum voltage output for coating\nthickness shall be determined according to the following calculation or by\nconsulting the manufacture's product data sheet. As a general minimum rule, at\nleast 100 volts per mil of coating will be required (EXAMPLE: 20 mils DFT x\n100 volts/mil = 2,000 volts).”\n2\n\n\n\nThe actual voltage set point of the Holiday detectors as applied to the ATEX, Seaway Loop, and\nWEP III Projects does not conform to STD.7002, Protective Coatings - Below Ground Steel\nSurfaces - Field Applied.\nWestern Expansion (WEP) III Project: New Mexico area: During a field inspection, PHMSA\ndiscovered that Enterprise has been setting the Holiday detector at 1,900 volts for both pipe\ncoated with 14-16 mils of FBE and for field joints coated with 39 mils. The setting of the\nHoliday detector to 1,900 volts was confirmed with a field utility Inspector at station 659+ 79.\nAgain, the Enterprise construction standard, STD.7002, Section 4.7, is not followed by\nEnterprise contract personnel.\nSeaway Loop and ATEX Projects: Texas and Oklahoma areas: During the field inspection,\nPHMSA observed Enterprise using a setting of 4,000 volts for Holiday detection (“jeeping”) for\npipe coating thicknesses in the range of 25 mils to 80 mils. Also, PHMSA observed Enterprise\nusing a setting of 2,500 volts for pipe coating thicknesses in the range of 15 mils to 70 mils.\nThus, the Enterprise construction standard, STD.7002, Section 4.7, is not followed by Enterprise\nor its contract personnel.\nOn October 21, 2013, a conference call was held with a PHMSA representative, several\nEnterprise field personnel, and the Enterprise Corrosion Group (HQ office) to discuss the\nrelationship between the voltage setting of the Holiday detector and the thickness of the coating\non the pipe. Also discussed was amending the Enterprise construction specification, STD.7002,\nSection 4.7.\nDuring the conference call, Enterprise revealed that it was using a June 4, 2013 email as its\nstandard. Further, Enterprise revealed that the email was sent to its field personnel prior to the\nbeginning of construction. The email provided for using 4,000 volts for “40 to 70 mil Abrasion\nResistant standard,” and 2,500 volts for “20 to 50 mil corrosion protection standard.” PHMSA\nrequested that STD.7002, Protective Coatings - Below Ground Steel Surfaces - Field Applied, be\namended to conform to the requirements provided in the June 4, 2013 email that was represented\nto have been used in the field.\nOn the Seaway Loop project, Segment 6, on March 11, 2014, a test of sensitivity was conducted\nat Sta. 682+39, adjacent to weld number 6MLB0045 by the coating crew. During the normal\ncourse of detecting holidays, a holiday was visually located. A SPY 785 Holiday Detector, which\nhad been previously calibrated, was used. The holiday was a large gouge on the line pipe with\nthe pipe having 15 mils of FBE coating. Measurements were taken with the Holiday Detector set\nat varying voltages, and the results were recorded. The test established that any measurement\nmade at a voltage below 2,000 volts is unreliable when using a SPY 785 Holiday Detector\ncalibrated pursuant to the Enterprise calibration methodology.\nThe sensitivity test was confirmed the next day using an Enterprise calibration method. The\nEnterprise calibration method provided for the detection of the bare metal circumference at the\nend of a joint of pipe as a holiday. The inspector set the holiday detector at 1,800 volts, as\n3\n\n\n\nrepresented to be normally done. The test was conducted near Sta. 370+36 on Segment 6 of the\nSeaway Loop Project. The Holiday Detector was tested on the bare, uncoated end of a pipe\nusing 1,800 volts, and the unit detected the presence of a holiday. The inspector confirmed that\nthe holiday detector was considered to be functioning properly based upon the detection of the\nuncoated end of pipe using 1,800 volts. When asked to prove the calibration was accurate, a\nholiday was fabricated several feet from the uncoated end by the inspector, i.e., a hole was made\nin the coating. The Holiday Detector was run down the coated pipe with the voltage unchanged\nat 1,800 volts to the fabricated holiday. The holiday was not detected. The Enterprise calibration\nmethod corroborated the sensitivity test that was run the previous day, i.e., any measurement\nmade at a voltage below 2,000 volts is unreliable.\n3. §195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive\nwritten specifications or standards that are consistent with the requirements of this\npart.\nEnterprise failed to construct the Seaway Loop Project in accordance with comprehensive\nwritten specifications or standards by failing to follow the Enterprise Engineering Standards &\nSpecifications, STD.7002, Protective Coatings - Below Ground Steel Surfaces-Field Applied,\nSec. 3.4.2(f) Liquid Coatings and check the film hardness in accordance with manufacturer’s\nrecommendations.\nPHMSA reviewed Enterprise Engineering Standards & Specifications, STD.7002, Protective\nCoatings - Below Ground Steel Surfaces-Field Applied, Sec. 3.4.2(f) Liquid Coatings, Rev. 2,\ndated May 2013, which states:\n“Coating shall be allowed to cure adequately before the structure is handled or\nbackfilled. Wet and dry film thickness and hardness shall be in accordance with\nmanufacturer's recommendations.”\nDuring the records review, PHMSA identified that Enterprise is not documenting and/or\nmeasuring the hardness of the field applied coating.\n4. §195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive\nwritten specifications or standards that are consistent with the requirements of this\npart.\nEnterprise failed to construct the Seaway Loop Project in accordance with comprehensive\nwritten specifications or standards by failing to apply field coating at joints to a maximum of 50\nmils DFT (Dry Film Thickness) or more appropriately, match the total mill-applied coating\nthickness as required by Enterprise Engineering Standards & Specifications, STD.7002,\n4\n\n\n\nProtective Coatings - Below Ground Steel Surfaces-Field Applied, Sec. 3.3.3(6) Liquids over\nmill applied ARO liquids.\nPHMSA reviewed Enterprise Engineering Standards & Specifications, STD.7002, Protective\nCoatings - Below Ground Steel Surfaces-Field Applied, Sec. 3.3.3(6) Liquids over mill applied\nARO liquids, Rev. 2, dated May 2013, which states:\n“Contractor shall apply liquid coatings by brushing, rolling, or spray application\nin accordance with manufacturer's recommendation to achieve the same coating\nthickness as the original pipe coating thickness. The ARO should achieve a\nminimum of 20 mils and a maximum of 50 mils dry-film thickness, or more\nappropriately, match the total mill-applied coating thickness.”\nDuring the field inspections, it was observed on numerous occasions that the field applied\ncoating of joints had areas where the DFT was greater than 50 mils.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this letter.\nFailure to do so will result in Enterprise Crude Pipeline, LLC being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2014-5018W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n5","truncated":false,"body_characters":12682}