# ENTERPRISE CRUDE PIPELINE LLC — Notice of Amendment

- **operation:** document
- **citation:** CPF 420175008M
- **title:** ENTERPRISE CRUDE PIPELINE LLC — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2017-03-30
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 195.202.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-420175008m.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-420175008m.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-420175008m
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420175008M
**body:**

Notice of Amendment involving ENTERPRISE CRUDE PIPELINE LLC. PHMSA's enforcement data identifies the cited regulation as 195.202. The case was opened on 2017-03-30 and is reported as closed as of 2021-04-02. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420175008M_Closure Letter_04022021_(15-149775S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175008M/420175008M_Closure%20Letter_04022021_(15-149775S).pdf

420175008M_Closure Letter_04022021_(15-149775S)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175008M/420175008M_Closure%20Letter_04022021_(15-149775S)_text.pdf

420175008M_Notice of Amendment_03302017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175008M/420175008M_Notice%20of%20Amendment_03302017.pdf

420175008M_Notice of Amendment_03302017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175008M/420175008M_Notice%20of%20Amendment_03302017_text.pdf

420175008M_Operator Response to Notice_06152017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175008M/420175008M_Operator%20Response%20to%20Notice_06152017.pdf

420175008M_Order Directing Amendment_08112020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175008M/420175008M_Order%20Directing%20Amendment_08112020.pdf

420175008M_Order Directing Amendment_08112020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175008M/420175008M_Order%20Directing%20Amendment_08112020_text.pdf

420175008M_Closure Letter_04022021_(15-149775S)_text.pdf

ELECTRONIC MAIL - RETURN RECEIPT REQUESTED
April 2, 2021
Graham Bacon
Executive Vice President, Operations & Engineering
Enterprise Products Operating, LLC
P. 0. Box 4735
Houston, Texas 77210-47352
CPF 4-2017-5008M
Dear Mr. Bacon:
From March 4, 2015 through October 9, 2015, representatives from the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,
conducted an on-site pipeline safety inspection of Enterprise Products Operating, LLC’s
(Enterprise) construction procedures for its Rancho Pipeline system between Sealy and Houston,
Texas. On March 30, 2017, PHMSA issued to Enterprise a Notice of Amendment (NOA), and
subsequently issued an Order Directing Amendment (ODA) on August 11, 2020 to address
outstanding concerns.
Enterprise submitted its last series of revisions on November 6, 2020. A review of these revisions
found that they adequately address the requirements in the ODA.
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely,
Mary L. McDaniel, P.E.
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
cc: Nhan Truong, Engineer, Pipeline Compliance, Western Region
Enterprise Products Operating, LLC, NVTRUONG@eprod.com

420175008M_Notice of Amendment_03302017_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
March 30, 2017
Mr. Graham Bacon
Group Senior Vice President, Operations & EHS&T
Enterprise Crude Pipeline, LLC
1100 Louisiana Street
Houston, TX 77002
4-2017-5008M
Dear Mr. Bacon:
Between March 4 and October 9, 2015, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected
Enterprise Crude Pipeline, LLC (Enterprise) procedures for constructing the Rancho Pipeline
between Sealy, TX to Houston, TX.
On the basis of the inspection, PHMSA has identified the apparent inadequacy found within
Enterprise’s procedures, as described below:
1. §195.202 Compliance with specifications or standards.
Each pipeline system must be constructed in accordance with comprehensive written
specifications or standards that are consistent with the requirements of this part.
The Enterprise Engineering and Specifications STD .8706 Bending and Alignment (Rev
No. 0.1, June 2012), does not provide adequate requirements for performing field bends of
spiral-weld seam pipe. Enterprise was found to be constructing the Rancho Pipeline using
spiral seam pipe but the specifications for bending did not address this type of pipe.
Enterprise’s procedure provides detailed specifications for bending longitudinal-weld seam
pipe but is silent on requirements for spiral-weld pipe actually being used to construct the
Rancho pipeline.



Some of the specifications that must be addressed in the Enterprise’s procedure include:
position of bending shoes, whether the shoes can press on the spiral-weld seam, test bends,
etc.… Enterprise must amend its procedure to meet the requirements in §195.202 with
relation to its use of spiral-weld seam pipe.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. 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.
If, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in this
Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49
C.F.R. § 190.237). If you are not contesting this Notice, we propose that you submit your amended
procedures to my office within 60 days of receipt of this Notice. This period may be extended by
written request for good cause. Once the inadequacies identified herein have been addressed in
your amended procedures, this enforcement action will be closed.
It is requested (not mandated) that Enterprise maintain documentation of the safety improvement
costs associated with fulfilling this Notice of Amendment (preparation/revision of plans,
procedures) and submit the total to R. M. Seeley, Director, Southwest, Pipeline and Hazardous
Materials Safety Administration. In correspondence concerning this matter, please refer to 4-2017-
5008M and, for each document you submit, please provide a copy in electronic format whenever
possible.
Sincerely,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
2

420175008M_Order Directing Amendment_08112020_text.pdf

August 11, 2020
VIA ELECTRONIC MAIL TO: rfowler@eprod.com
Mr. W. Randall Fowler
Director, Co-Chief Executive Officer, and Chief Financial Officer
Enterprise Products Partners, LP
1100 Louisiana Street
Houston, Texas 77002-5227
Re: CPF No. 4-2017-5008M
Dear Mr. Fowler:
Enclosed please find the Order Directing Amendment issued in the above-referenced case. It
makes findings of inadequate procedures and requires that Enterprise Crude Pipeline, LLC, a
subsidiary of Enterprise Products Partners, LP, amend certain written procedures. When the
amendment of procedures is completed, as determined by the Director, Southwest Region, this
enforcement action will be closed. Service of the Order Directing Amendment by electronic
mail is effective upon the date of transmission as provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure
cc: Ms. Mary McDaniel, Director, Southwest Region, Office of Pipeline Safety, PHMSA
Mr. Graham W. Bacon, Executive Vice President, Operations & Engineering, Enterprise
Products Partners, LP, gbacon@eprod.com
CONFIRMATION OF RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
_____________________________________________
)
In the Matter of )
)
Enterprise Crude Pipeline, LLC, ) CPF No. 4-2017-5008M
a subsidiary of Enterprise Products Partners, LP, )
)
Respondent. )
_____________________________________________)
ORDER DIRECTING AMENDMENT
From March 4 through October 9, 2015, pursuant to 49 U.S.C. § 60117, a representative of the
Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
(OPS), conducted an on-site pipeline safety inspection of the construction procedures for the
Rancho Pipeline of Enterprise Crude Pipeline, LLC (Enterprise or Respondent), in Texas.
Enterprise, a subsidiary of Enterprise Products Partners, LP, operates the Rancho Pipeline, a 36-
inch diameter crude oil line stretching from Jones Creek, Texas to Echo Park Terminal outside of
Galena Park, Texas.1
As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to
Respondent, by letter dated March 30, 2017, a Notice of Amendment (Notice). In accordance
with 49 C.F.R. § 190.206, the Notice alleged certain inadequacies in Respondent’s written
procedures and proposed requiring Enterprise to amend its procedures to ensure safe operation of
its pipeline facilities.
After requesting and receiving an extension of time, Enterprise Products Partners, LP, on behalf
of Enterprise, responded to the Notice by letter dated June 15, 2017 (Response). In its Response,
Enterprise did not contest the allegation that its procedures were inadequate and submitted copies
of its amended procedures. After reviewing the amended procedures and engaging in additional
discussions with PHMSA to clarify certain aspects of the amended procedures, Enterprise
submitted an additional set of revised procedures in April 2019.2 After reviewing these
procedures, on September 26, 2019, the Director determined that the revised procedures were
inadequate to ensure safe operation of Enterprise’s pipeline facilities. Enterprise contested the
allegation that its revised procedures were inadequate and provided additional information by
electronic mail dated October 18, 2019 (Supplemental Response). Respondent did not request a
hearing and therefore has waived its right to one.
1 Pipeline Safety Violation Report (Report), at 1 (Mar. 30, 2017) (on file with PHMSA).
2 Enterprise Engineering and Specifications STD.8706 Bending and Alignment (STD.8706) REV.2.2 (Apr. 2019)
(on file with PHMSA).



CPF No. 4-2017-5008M
Page 2
FINDING OF INADEQUATE PROCEDURES
Item 1: The Notice alleged that Respondent’s procedures were inadequate with regard to
49 C.F.R. §195.202, which states:
§195.202 Compliance with specifications or standards.
Each pipeline system must be constructed in accordance with
comprehensive written specifications or standards that are consistent with
the requirements of this part.
The Notice alleged that Respondent’s written construction procedures were inadequate to assure
safe operation of the pipeline facility because they failed to confirm construction in accordance
with comprehensive written specifications or standards consistent with Part 195 requirements.
Specifically, the Notice alleged that the Enterprise Engineering and Specifications STD.8706
Bending and Alignment (STD.8706) procedure did not provide adequate requirements for
performing field bends of spiral-weld seam pipe. Although Enterprise was constructing the
Rancho Pipeline using spiral seam pipe, the Notice alleged that its written specifications for
bending did not specifically address bending this type of pipe. Instead, Enterprise’s procedures
applied to all types of pipe generally and only specifically mentioned specifications for bending
longitudinal-weld seam pipe. The Notice proposed that Enterprise revise its procedures with
regard to bending spiral-weld pipe to include, at a minimum, position of bending shoes, whether
the shoes can press on the spiral-weld seam, and test bends.
In its Response, Enterprise amended Sections 2.2 and 2.3 of STD.8706 to exclude spiral-weld
(also referred to as helically-weld) pipe from the generally-applicable weld seam and bending
shoe positioning requirements.3 Enterprise also amended Section 2.4 to include a table limiting
the allowable minimum bend radii and applicable tolerances when using spiral-weld source
pipe.4 Finally, Enterprise added Section 2.6 to address material properties and the potential need
for producing and testing prototype bends.5 During follow-up discussions, the Region informed
Enterprise that it believed its amended procedures still did not adequately address spiral seam
3 Response, at 2. Revised Section 2.2. states: “All overbends, sags and sidebends shall be made to provide an
adequate amount of slack or flexibility in the pipeline and shall conform to engineering design tolerances. Where no
such tolerances were provided, the Contractor shall consult with Company to seek guidance prior to proceeding. Weld
seams shall be positioned as near as practicable to the neutral axis of the bend. Helically-welded pipe is an exception
to this weld seam position requirement.” Revised Section 2.3 states: “Each bend shall be made using Company
approved bending machines having full encirclement bending shoes with a neoprene or urethane lining to produce a
smooth, symmetrical bend, unless specified otherwise by Company. If the pipe is internally coated, the bearing
surfaces of the mandrel shall be constructed to avoid permanently marking or damaging the internal coating. Position
bending shoes and mandrels so as not to apply a point load to the seam weld and minimize stresses in the seam weld.
Helically-welded pipe is an exception to this bending shoe positioning requirement. No appreciable stretching or
thinning of the pipe wall thickness shall be permitted.”
4 Id., at 2-3.
5 Id., at 3. Section 2.6 states: “(1) Bends used in sour gas pipelines should meet the hardness requirements of NACE
MR0175 in the as-bent condition. Bends exposed to or used in low temperature service should meet toughness and
tensile requirements in the as-bent condition. (2) The Company may request that prototype bends are made and tested
to ensure that a particular field bending procedure produces bends meeting the material property requirements.”



CPF No. 4-2017-5008M
Page 3
pipe. In response, Enterprise submitted a new set of revised procedures (STD.8706 REV2.2).
Enterprise contended that STD.8706 REV2.2 adequately covered position of bending shoes,
whether shoes can press on the spiral-weld seams, and test bends.6
After additional discussions with the operator, the Region found Enterprise’s written procedures,
as amended, were still inadequate to ensure safe operation of the pipeline system. Specifically,
the Region noted that the revised procedures did not adequately address spiral seam pipe since
Sections 3.2 and 3.3 excepted helically-welded pipe.7
In its Supplemental Response, Enterprise stated that STD.8706 REV2.2 “did not take exception
to” helically-welded pipe.8 Rather, “in order to prevent confusion, it provides exemptions from
applying the unavoidable weld seam and bending shoe positioning requirements to helically-
welded pipe when those requirements are specifically applicable to longitudinally welded pipe.”9
Enterprise contended that these amended procedures were consistent with industry standards in
ASME B31.4 and ASME B31.8, and therefore comply with § 195.202.
49 C.F.R. §195.202 requires that each pipeline system be constructed in accordance with
comprehensive written specifications or standards that are consistent with the requirements of
Part 195. The construction of the Rancho Pipeline involved spiral seam pipe that required
bending; therefore, Enterprise was required to construct the line in accordance with written
specifications and standards for bending spiral seam pipe consistent with Part 195. There are
several specifications and standards governing bending of pipe, including: (1) ASME
International (ASME) B31.4 Pipeline Transportation Systems for Liquid Hydrocarbons and
Other Liquids (2006); and (2) ASME B31.8 Gas Transmission and Distribution Piping Systems
(2007).10 While these standards are not incorporated by reference into Part 195, Respondent
cited to them as evidence that its procedures are consistent with such standards. Further, Part
195 includes regulations for bending pipe in §195.212. I will address each one separately below.
6 Enterprise explained that STD.8706 REV2.2, Section 3.3(4) addressed position of bending shoes, stating that “[t]he
contractor shall use a consistent method of measurement when both marking the pipe in preparation for bending and
in subsequent post-bending inspections” and Section 3.4(4) addressed whether shoes can press on the spiral-weld
seam, noting that “[t]he bending operations shall be inspected to verify that the minimum allowable radius of the bend
is not exceeded and that there is no wrinkling or excessive flattening of the pipe.” Finally, Section 3.6(2) discusses
test bends, stating that “[t]he Company Project Manager may request that prototype bends are made and tested to
ensure that a particular field bending procedure produces bends meeting the material property requirements.” Id.
7 See Email from Region to Operator (Sept. 26, 2019) (on file with PHMSA) (noting that STD.8706 REV2.2, Section
3.2(3) states that “[h]elically welded pipe is an exception to this weld seam position requirement,” and Section 3.3(4)
states that “[h]elically welded pipe is an exception to this bending shoe positioning requirement”).
8 Supplemental Response, at 1.
9 Id.
10 Other standards, including NACE International (NACE) MR0175 Standard Material Requirements- Sulfide Stress
Cracking Resistant Metallic Materials for Oilfield Equipment (2009), also discuss bending of pipe. However, for
purposes of brevity, additional standards are not discussed here.



CPF No. 4-2017-5008M
Page 4
First, Respondent cited to the specifications for bending pipe in ASME B31.4, which are set
forth in Section 434.7.1 Bends Made From Pipe. That section includes five subparts, only one of
which specifically addresses longitudinal seams.11 The remaining four subparts do not specify
seam type and instead provide general requirements. Second, the specifications for bending pipe
in ASME B31.8 are set forth in Section 841.231. That section discusses maximum degrees of
bending, appropriate wall thickness after bending, and other restrictions on bending of pipe, but
does not specify seam type.
Finally, the regulations governing bending pipe in Part 195 are set forth in §195.212. Except for
§195.212(b)(3) which is specific to longitudinal weld pipe,12 §195.212 is silent on seam type.
Therefore, because industry standards and regulations on bending pipe do not specify seam type
for each bending requirement, and instead only call out those specific to longitudinal seams, I do
not find it to be inconsistent that STD.8706 REV2.2 similarly does not specify seam types,
unless specifically noted. Enterprise’s written specifications are not excluding helically-welded
pipe; instead, they simply have certain requirements for longitudinal-seam pipe that do not apply
to helical-seam pipe. Despite this, given the unique safety concerns involving bending spiral-
seam pipe,13 Enterprise must amend its procedures to include a section clarifying the
applicability and scope of its field bending and alignment procedures with regard to seam type at
the beginning of STD.8706 REV2.2, Section 3.14
In her Region Recommendation, the Director also noted that several of Enterprise’s procedures
on bending pipe provide the Company Project Manager broad discretion in determining
applicability of the procedures.15 For example, Section 3.3(5) states that “[a]n internal bending
mandrel will be used when bending welded pipe unless approved by the Company Project
Manager” (emphasis added). Although providing flexibility to address unique circumstances is
important, written procedures should specify, to the extent practicable, the conditions under
which deviation is allowable. Therefore, Enterprise must further amend its procedures to explain
when deviation is permissible by the Company Project Manager or other personnel. Further,
Enterprise should document the reasons why the Company Project Manager chose to deviate
from the written procedures, and should consider having this decision reviewable by his/her
supervisor prior to implementation.
11 Section 434.7.1(e) states that “[w]hen bends are made in longitudinally welded pipe, the longitudinal weld should
be located on or near the neutral axis of the bend.”
12 Specifically, §195.212(b)(3) requires that pipe containing a longitudinal weld, the longitudinal weld must be as
near as practicable to the neutral axis of the bend unless - (i) The bend is made with an internal bending mandrel; or
(ii) The pipe is 12 3/4 in (324 mm) or less nominal outside diameter or has a diameter to wall thickness ratio less than
70.
13 Spiral-weld pipe presents unique issues because the configuration of the weld does not allow for the seam to be in
a purely neutral position in the bending machine, making it important for the operator to use specifications designed
to ensure safe bending.
14 Enterprise may wish to consider adding a new section to STD.8706 REV2.2 that specifically addresses helically-
welded pipe.
15 Region Recommendation, at 2-3.



CPF No. 4-2017-5008M
Page 5
Accordingly, I find that Enterprise’s procedures are inadequate to ensure safe operation of its
pipeline system. Pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206, Enterprise is
ordered to make revisions to its procedures to address the adequacies noted above within 60 days
of the issuance of the Order Directing Amendment.
The Director may grant an extension of time to comply with any of the required items upon a
written request timely submitted by the Respondent and demonstrating good cause for an
extension.
Failure to comply with this Order may result in administrative assessment of civil penalties not
to exceed $213,268, as adjusted for inflation (49 C.F.R. § 190.223), for each violation for each
day the violation continues or in referral to the Attorney General for appropriate relief in a
district court of the United States.
Under 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this
Amended Order Directing Amendment to the 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, no later than 20 days
after receipt of this Order Directing Amendment by Respondent. Any petition submitted must
contain a statement of the issue(s) and meet all other requirements of 49 C.F.R. § 190.243. The
terms of the order, including corrective action, remain in effect unless the Associate
Administrator, upon request, grants a stay.
The terms and conditions of this Order Directing Amendment are effective upon service in
accordance with 49 C.F.R. § 190.5.
August 11, 2020
___________________________________ ______________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety
- **truncated:** false
- **body characters:** 23680