ENTERPRISE PRODUCTS OPERATING LLC — Notice of Probable Violation

party submissionOfficial PDF420175035_Operator Request for Hearing_02282018.pdf#

party submissionOfficial PDF420175035_Operator Response to Notice_02282018.pdf#

420175035_NOPV PCP PCO_11022017_text.pdf, page 1Official PDFNOTICE OF PROBABLE VIOLATION PROPOSED CIVIL PENALTY and PROPOSED COMPLIANCE ORDER CERTIFIED MAIL - RETURN RECEIPT REQUESTED November 2, 2017 Bacon Graham Executive Vice President Enterprise Products Operating 1100 Louisiana Street Houston Texas 77002 CPF 4-2017-5035 Dear Mr. Graham: On January 9 2017 through May 24 2017, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected Enterprise Products Operating LLC (Enterprise) procedures for Operations and maintenance were inspected in Houston, Texas. As a result of the inspection, it is alleged that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected and the probable violations are:#

420175035_NOPV PCP PCO_11022017_text.pdf, page 21. §195.507– Record Keeping Each operator shall maintain records that demonstrate compliance with this subpart. (a) Qualification records shall include: (3) Dates of current qualification; (b) Records supporting an individual’s current qualification shall be maintained while The individual is performing the covered task. Records of prior qualification and records of individuals no longer performing covered tasks shall be retained for a period of five years. A review of Appendix H of Enterprise’s Operator Qualification plan(OQ) revealed that three of the OQ reports listed there do show that current qualification records for individuals performing those covered tasks under the mutual assistance requirements of the plan were not on record. The affected OQ records are for Koch Pipeline (last reviewed on 06/27/2011), Conoco Phillips (last reviewed on 05/10/2011) and Energy Transfer (Lone Star NGL last reviewed on 7/28/2011). Section 4 of the OQ plan under the subtitle of “Covered Tasks” states that at a minimum the established reevaluation frequency will not exceed 5 years. Hence the listed OQ records above all expired in 2016 (Koch- 06/27/2016, Conoco Phillips- 05/10/2016, Energy Transfer – 07/28/2016) and no requalification 69,records had been obtained at the time of this inspection. 2. §195.575-Which facilities must I electrically isolate and what inspection tests, and Safeguards are required? (e) If a pipeline is in close proximity to electrical transmission power footings, ground cables, or counterpoise or in other areas where it is reasonable to foresee fault currents or an unusual risk of lightning, you must protect the pipeline against damage from fault currents or lightning and take protective measures at insulating devices. Enterprise’s Chaparral Line is in close proximity to electrical transmission power lines for a considerable length of miles between Mont Belvieu and Bryan TX, but is not protected from the risk of damage from the effects of fault currents or lightning even when Enterprise’s Standard 7006 in section 1.2 references NACE SP0177 (Mitigation of Alternating Current and Lightning Effects on Metallic Structures and Corrosion Control Systems) as the primary reference to be utilized in determining the protective measure to be taken and implemented. Enterprise did not provide any record that showed the line was protected from the effects of the usual risk of fault currents or lightning. 2#

420175035_NOPV PCP PCO_11022017_text.pdf, page 33. Enterprise representatives stated during a meeting with PHMSA on August 16, 2017 that there was no protection for this line from lightning or fault currents and as such did not have any records to provide. They also stated that no engineering analysis had been carried out to determine the effects of the fault currents or lightning on the pipeline at the location. §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. Enterprise Products Operating, LLC failed to update its procedure for “close interval potential survey specification” – CP 05 to ensure it was effective for all close interval potential surveys even after realizing from survey records in 2015 that the procedure was the source of errors in measurements taken while carrying out a close interval survey on the Chaparral pipeline system. Enterprise representatives stated during a meeting on August 16, 2017 with PHMSA that results from a close interval survey on the portion of the Chaparral pipeline between Mont Belvieu and Bryan Texas carried out in February through march of 2015 included errors and resulted in elevated AC measurements which could be attributed to the #32-gauge wire which was run underneath high voltage power lines. A follow up survey conducted on July 30, 2015 showed some of the readings being much lower than initially taken at those locations. Enterprise’s personnel stated that this error could be directly attributed to the procedure and proffered to make the required changes to the procedure to avoid any such errors to the survey readings in the future. A copy of the corrected procedure was submitted to PHMSA on September 12, 2017 and reflected the changes made on August 24, 2017. Enterprise products operating, LLC failed to make the required update to its procedure for over 2 years even when they were aware of needed update and carried out other surveys using the same procedure. 3#

420175035_NOPV PCP PCO_11022017_text.pdf, page 44. §195.452 – Pipeline Integrity Management in high consequence areas (b) Each operator of a pipeline covered by this section must: (1) Develop a written integrity management program that addresses the risks on each segment of pipeline in the first column of the following table not later than the date in the second column: (4) Include in the program a framework that- (ii) Initially indicates how decisions will be made to implement each element. (5) Implement and follow the program Enterprise Products Operating LLC failed to follow its Line Pipe Risk Analysis procedure (IM Procedure 2-01L) developed as part of its Integrity Management Program to address risks on its Pipeline systems and in this particular case the Maljamar to Maljamar Launcher segment. Records for the Information Analysis carried out on December 4,2014 includes information from the risk assessment completed for this line segment and incorporated as part of the information analyzed in the report which shows a high probability risk score of 10 out of a total score of 10 for the threat of Stress Corrosion Cracking(SCC). The report attributed the excessively high score to the lack of available information on the coating type on the line segment thereby allowing for a misguided review from the reviewing personnel. However, a review of records for Coating and CP source provided by Enterprise during the screening exercise showed that the information on the coating type for this Line segment was available and showed it to be Coal Tar Enamel which if properly entered in the risk assessment would have allowed for the analyst to consider the score and be properly guided in evaluating the condition of the line at the time. The IM procedure 2-01L in section 2-01.2.2 requires the Pipeline Integrity Engineer to be responsible for the collection of this data from about 12 sources and provides for the validation of the Risk analysis results and data inputted to ensure that the process works well. Information Analysis carried out on December 4,2014 for the Maljamar to Maljamar Launcher segment includes the record of the risk assessment for the threat of Stress Corrosion Cracking with a probability score of 10 out of a total of 10 and the note stating the coating type was unknown allowing for a misguided review from the analyst reviewing the information 5. §195.589 – What corrosion control information do I have to maintain (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. 4#

420175035_NOPV PCP PCO_11022017_text.pdf, page 5Enterprise Products Operating LLC’s corrosion control records for the section of the Chaparral line between Conroe and Mont Belvieu in Texas lacks sufficient details to demonstrate the adequacy of the corrosion control measures in place. A comparison of the close interval survey records conducted on March 12, 2015,with records of AC readings on the remedial action form from July 23, 2015 and the survey report from May 26, 2017(specifically intended to capture readings from locations with high readings on the CIS survey but still no readings were taken at the required locations) in addition to previous annual survey records from 2015 through 2017(scarcely has any AC readings even at the locations with the high readings from the 2015 CIS survey) does present a number of questions concerning the adequacy of the corrosion control measures in place. During a meeting with Enterprise personnel on August 16, 2017 representatives from Enterprise tried to clarify some of questions posed in these records. Sufficient detail in the records would explain how high AC readings (attributed to errors from the #32-gauge wire and the procedure utilized for the survey) dropped so low without any remediation to the readings recorded on July 23, 201. Also there were no other readings from 3 years of survey at same locations to compare and make a determination of adequacy of the corrosion control measures in place for the protection of the pipeline and safety of personnel carrying out the surveys / testing’s. Without the meeting with Enterprise’s personnel for clarification, the records independently raise questions on the adequacy of the corrosion control measures in place. Proposed Civil Penalty As of April 27, 2017, under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $209,002 per violation per day the violation persists up to a maximum of $2,090,022 for a related series of violations. The Compliance Officer has reviewed the circumstances and supporting documentation involved in the above probable violations and has recommended that you be preliminarily assessed a civil penalty of $69,700 as follows: Item number PENALTY 1 $33,500 2 $36,200 Warning Items With respect to items 3,4 and 5, 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. Failure to do so may result in additional enforcement action. 5#

420175035_NOPV PCP PCO_11022017_text.pdf, page 6Proposed Compliance Order With respect to item 1 pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration proposes to issue a Compliance Order to Enterprise Products Operating, 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. All material submit in response to this enforcement action may be 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). Following the receipt of this Notice, you have 30 days to submit written comments, or request a hearing under 49 CFR § 190.211. 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 you are responding to this Notice, we propose that you submit your correspondence to my office within 30 days from the receipt of this Notice. This period may be extended by written request for good cause. In your correspondence on this matter, please refer to CPF 4-2017-5035 and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Frank Causey Acting Director, Southwest Region Pipeline and Hazardous Materials Safety Administration Enclosure: Proposed Compliance Order Response Options for Pipeline Operators in Compliance Proceedings 6#

420175035_NOPV PCP PCO_11022017_text.pdf, page 7PROPOSED COMPLIANCE ORDER Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposes to issue to Enterprise Products Operating, LLC a Compliance Order incorporating the following remedial requirements to ensure the compliance of Enterprise Products Operating, LLC with the pipeline safety regulations: 1. 2. 3. In regard to Item Number 1 of the Notice pertaining to the mutual assistance program and the requirements for reviewing and maintaining qualification records and program reviews contained within, Enterprise Products Operating, LLC shall revise the process to ensure that all personnel carrying out covered tasks under the mutual assistance program are qualified and records showing current qualifications are maintained. Item 1 shall be submitted to PHMSA no later than 30 days from the issuance of the Final Order in this case. It is requested (not mandated) that Enterprise Products Operating, LLC maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to Terri Binns, Acting Director, Southwest Region, Pipeline and Hazardous Materials Safety Administration. It is requested that these costs 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 changes to pipeline infrastructure. 7#

420175035_Final Order_12202018_text.pdf, page 1Official PDFDecember 20, 2018 Mr. A. J. Teague Director and Chief Executive Officer Enterprise Products Partners, LP 1100 Louisiana Street, 10th Floor Houston, TX 77002 Re: CPF No. 4-2017-5035 Dear Mr. Teague: Enclosed please find the Final Order issued in the above-referenced case to your subsidiary, Enterprise Products Operating LLC. It withdraws one alleged violation and associated civil penalty, makes a finding of violation for another, assesses a civil penalty of $33,500, and specifies actions that need to be taken by Enterprise 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 and the terms of the compliance order completed, as determined by the Director, Southwest Region, this enforcement action will be closed. Service of the Final Order by certified mail is effective upon the date of mailing 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: Director, Southwest Region, Office of Pipeline Safety, PHMSA Mr. James B. Curry, Esq., and Brianne K. Kurdock, Esq., Babst, Calland, Clements and Zomnir, PC, 505 9th Street, N.W., Suite 700, Washington, D.C. 20004, Counsel for Enterprise Products Operating, LLC Mr. Graham W. Bacon, Executive Vice President, Operations and Engineering, Enterprise Products Partners, LP CERTIFIED MAIL - RETURN RECEIPT REQUESTED#

420175035_Final Order_12202018_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 ) Enterprise Products Operating, LLC, ) CPF No. 4-2017-5035 a subsidiary of Enterprise Products Partners, LP, ) ) ) ) Respondent. ) ________________________________________________) FINAL ORDER From January 9 through May 24, 2017, 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 facilities and records of Enterprise Products Operating, LLC (EPO or Respondent), in Houston, Texas. EPO is a wholly-owned subsidiary of Enterprise Partners, LP (Enterprise).1 Enterprise conducts substantially all of its operations through EPO, including more than 50,000 miles of pipeline and approximately 260 million barrels of hazardous-liquid storage capacity.2 As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to Respondent, by letter dated November 2, 2017, a Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order (Notice), which also included warnings pursuant to 49 C.F.R. § 190.205. In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Enterprise had violated 49 C.F.R. §§ 195.507 and 195.575(e) and proposed assessing a civil penalty of $69,700 for the alleged violations.3 The Notice also proposed ordering Respondent to take certain measures to correct one of the alleged violations. The warning items required no further action but warned the operator to correct the probable violations or face possible future enforcement action. 1 Enterprise Products Partners, LP, Form 10-Q submitted to U.S. Securities and Exchange Commission, available at http://services.corporate- ir.net/SEC/Document.Service?id=P3VybD1hSFIwY0RvdkwyRndhUzUwWlc1cmQybDZZWEprTG1OdmJTOWti M2R1Ykc5aFpDNXdhSEEvWVdOMGFXOXVQVkJFUmlacGNHRm5aVDB4TWpNNU5UYzJOaVp6ZFdKemF XUTlOVGM9JnR5cGU9MiZmbj1FbnRlcnByaXNlUHJvZHVjdHNQYXJ0bmVyc0wucGRm (last accessed November 8, 2018). 2 Enterprise Products Partners, LP, website, available at https://www.enterpriseproducts.com/about-us/business- profile (last accessed November 8, 2018). 3 The Notice was issued in conjunction with a separate Notice of Amendment (CPF No. 4-2017-5036M). An Order Directing Amendment in that case will be issued separately.#

420175035_Final Order_12202018_text.pdf, page 3CPF No. 4-2017-5035 Page 2 After requesting and receiving an extension of time to respond, Enterprise responded to the Notice by letter dated February 28, 2018 (Response). Respondent contested one of the allegations and requested a hearing on that item. By email dated May 4, 2018, Respondent withdrew its request for a hearing and thereby authorized the entry of this Final Order without further notice. FINDING OF VIOLATION The Notice alleged that Respondent violated 49 C.F.R. Part 195, as follows: Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.507, which states, in relevant part: § 195.507 Recordkeeping. Each operator shall maintain records that demonstrate compliance with this subpart. (a) Qualification records shall include: (1) . . . (3) Date(s) of current qualification; and . . . . (b) Records supporting an individual's current qualification shall be maintained while the individual is performing the covered task. Records of prior qualification and records of individuals no longer performing covered tasks shall be retained for a period of five years. The Notice alleged that Respondent violated 49 C.F.R. § 195.507 by failing to maintain operator qualification (OQ) records for individuals performing covered tasks on three pipelines. Specifically, the Notice alleged that Enterprise did not maintain current qualification records for individuals performing covered tasks under the mutual-assistance requirements of Enterprise’s OQ plan. The three pipelines at issue were the Koch Pipeline, Conoco Phillips, and Energy Transfer (Lone Star NGL) pipelines. Section 4 of Enterprise’s OQ plan required Enterprise to maintain records for each individual’s current qualification by reevaluating such individuals at least once every five years. The OQ records for all three of the pipelines at issue were last evaluated in 2011; accordingly, the OQ records should have been reevaluated in 2016. In its Response, Enterprise did not contest the allegations of Item 1 and provided information about updates it had made to its OQ plan. Accordingly, after considering all of the evidence, I find that Respondent violated 49 C.F.R. § 195.507 by failing to maintain OQ records for individuals performing covered tasks on three pipelines. This finding of violation will be considered a prior offense in any subsequent enforcement action taken against Respondent. Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.575(e), which states: § 195.575 Which facilities must I electrically isolate and what inspections, tests, and safeguards are required?#

420175035_Final Order_12202018_text.pdf, page 4CPF No. 4-2017-5035 Page 3 (a) . . . . (e) If a pipeline is in close proximity to electrical transmission tower footings, ground cables, or counterpoise, or in other areas where it is reasonable to foresee fault currents or an unusual risk of lightning, you must protect the pipeline against damage from fault currents or lightning and take protective measures at insulating devices. The Notice alleged that Respondent violated 49 C.F.R. § 195.575(e) by failing to protect a pipeline against damage from fault currents or lightning and take protective measures at insulating devices. Specifically, the Notice alleged that Enterprise failed to protect the company’s Chaparral Line, which runs in close proximity to electrical transmission power lines between Mont Belvieu and Bryan, Texas. In its Response, Enterprise contested this allegation of violation. Following Enterprise’s response, pursuant to § 190.209(b)(7), the Director has recommended withdrawal of this item, and simultaneously, on May 3, 2018, the Director issued a separate Notice of Probable Violation and Proposed Compliance Order addressing this alleged violation. 4 Accordingly, Item 2 and its associated proposed penalty are withdrawn without prejudice. ASSESSMENT OF PENALTY Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed $200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any related series of violations.5 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; 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. The Notice proposed a total civil penalty of $69,700 for the violations cited above. Item 1: The Notice proposed a civil penalty of $33,500 for Respondent’s violation of 49 C.F.R. § 195.507, for failing to maintain OQ records for individuals performing covered tasks on three pipelines. Respondent did not contest this violation or the proposed civil penalty. Accordingly, having reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of $33,500 for violation of 49 C.F.R. § 195.507. Item 2: The Notice proposed a civil penalty of $36,200 for Respondent’s violation of 49 C.F.R. § 195.575(e), for failing to protect a pipeline against damage from fault currents or lightning and 4 The May 3, 2018 Notice was issued under case number CPF No. 4-2018-5009. Enterprise responded to that case by letter dated June 7, 2018. That case is being adjudicated separately under 49 C.F.R. § 190.213. 5 These amounts are adjusted annually for inflation. See, e.g., Pipeline Safety: Inflation Adjustment of Maximum Civil Penalties, 82 Fed. Reg. 19325 (April 27, 2017).#

420175035_Final Order_12202018_text.pdf, page 5CPF No. 4-2017-5035 Page 4 take protective measures at insulating devices. For the reasons stated above, Item 2 is withdrawn and, therefore, the proposed penalty for the alleged violation of 49 C.F.R. § 195.575(e) is not assessed. 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 (AMK-325), Federal Aviation Administration, Mike Monroney Aeronautical Center, 6500 S MacArthur Blvd, Oklahoma City, Oklahoma 79169. The Financial Operations Division telephone number is (405) 954-8845. Failure to pay the $33,500 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 Item 1 in the Notice for a violation of 49 C.F.R. § 195.507. 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. Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following actions to ensure compliance with the pipeline safety regulations applicable to its operations: 1. With respect to the violation of § 195.507 (Item 1), Respondent must revise its procedures to ensure that all persons carrying out qualified tasks under its mutual assistance program are qualified, and must maintain records showing current qualifications. Respondent must submit the revised procedures and other records necessary for compliance with this item within 30 days after receipt of this Order. 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. It is requested that Respondent maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to the Director. It is requested that these costs 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 changes to pipeline infrastructure. Failure to comply with this Order may result in the administrative assessment of civil penalties not to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), for each violation for#

420175035_Final Order_12202018_text.pdf, page 6CPF No. 4-2017-5035 Page 5 each day the violation continues or in referral to the Attorney General for appropriate relief in a district court of the United States. WARNING ITEMS With respect to Items 3, 4, and 5, 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: 49 C.F.R. § 195.402(a) (Item 3) ─ Respondent’s alleged failure to update its procedures for conducting close interval surveys; 49 C.F.R. § 195.452(b) (Item 4) ─ Respondent’s alleged failure to follow its Integrity Management Program by not incorporating all available information into the risk analysis; and 49 C.F.R. § 195.589(c) (Item 5) ─ Respondent’s alleged failure to maintain records containing sufficient detail about corrosion-control measures in place on a segment of pipe. Enterprise requested withdrawal of Items 3, 4, and 5, alleging that the facts did not support findings of probable violation. Under § 190.205, PHMSA does not adjudicate warning items to determine whether a probable violation occurred or not. If OPS finds a violation of any of these items in a subsequent inspection, Respondent may be subject to future enforcement action. Under 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this Final Order 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 service of this Final Order 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 filing of a petition automatically stays the payment of any civil penalty assessed. The other 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 Final Order are effective upon service in accordance with 49 C.F.R. § 190.5. December 20, 2018 ___________________________________ _________________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety#

420175035_Closure Letter_04022019_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED April 2, 2019 A.J. Teague Director and Chief Executive Officer Enterprise Products Partners 1100 Louisiana Street, 10th Floor Houston, Texas 77002 CPF 4-2017-5035 Dear Mr. Teague: On December 20, 2018, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to Enterprise Products Operating LLC a Final Order in the above-referenced case. This Order included a Compliance Order and Civil Penalty assessment. Based on our review of the documentation you provided and confirmation of payment of the civil penalty, it has been determined that you have complied with the terms of this Order. Accordingly, this case is now closed and no further action is contemplated with respect to the matters involved in this case. Thank you for your cooperation in this matter. Sincerely, Mary. L. McDaniel, P.E Director, Southwest Region Pipeline and Hazardous Materials Safety Administration#