EAGLE US 2 LLC — Notice of Amendment

party submissionOfficial PDF420181011M_Operator Response to Notice_11092018.pdf#

420181011M_Closure Letter_02272019_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED February 27, 2019 Andrew Kenner Vice President of Manufacturing Eagle US 2 LLC 2801 Post Oak Blvd. Houston, Texas 77056 CPF 4-2018-1011M Dear Mr. Kenner: On October 10, 2018, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to Eagle US 2 LLC (Eagle) a Notice of Amendment in the above referenced case. Based on our review of the documentation you provided, it has been determined that you have complied with the terms of this Notice. Accordingly, this case is now closed and no further action is contemplated with respect to the matters involved with this case. Thank you for your cooperation. Sincerely, Mary L. McDaniel, P.E. Director, Southwest Region Pipeline and Hazardous Materials Safety Administration#

420181011M_Notice of Amendment_10102018_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED October 10, 2018 Andrew Kenner Vice President of Manufacturing Eagle US 2 LLC 2801 Post Oak Blvd. Houston, Texas 77056 CPF 4-2018-1011M Dear Mr. Kenner: On August 14 – 18, 2017; December 4 – 8, 2017; and January 30 – February 2, 2018, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Eagle US 2 LLC (Eagle) procedures for your Eagle US 2 LLC (Eagle), LA-TX Ethylene pipeline in Lake Charles, Louisiana and Orange, Texas. On the basis of the inspection, PHMSA has identified the apparent inadequacies found within Eagle’s plans or procedures, as described below: 1. §192.935 What additional preventive and mitigative measures must an operator take? (a) General requirements. An operator must take additional measures beyond those already required by Part 192 to prevent a pipeline failure and to mitigate the consequences of a pipeline failure in a high consequence area. An operator must base the additional measures on the threats the operator has identified to each pipeline segment. (See § 192.917) An operator must conduct, in accordance with one of the risk assessment approaches in ASME/ANSI B31.8S (incorporated by reference, see § 192.7), section 5, a risk analysis of its pipeline to identify additional measures to protect the high consequence area and enhance public safety. Such additional measures include, but are not limited to, installing Automatic Shut-off Valves or#

420181011M_Notice of Amendment_10102018_text.pdf, page 2Remote Control Valves, installing computerized monitoring and leak detection systems, replacing pipe segments with pipe of heavier wall thickness, providing additional training to personnel on response procedures, conducting drills with local emergency responders and implementing additional inspection and maintenance programs. Eagle must amend its IMP manual, document #2305-IM-1000, revision date 1/15/18, Section 32.0 – 35.0 Preventive and Mitigative Measures – Regulatory Compliance Positions to ensure it considers all threats associated with their pipeline. Additionally, Eagle must provide procedures for the justification, as necessary, for the elimination of any specific threat from their risk assessment. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §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 an Order Directing Amendment. If 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. § 190.206). 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. 2#

420181011M_Notice of Amendment_10102018_text.pdf, page 3It is requested (not mandated) that Eagle US 2 LLC maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Mary L. McDaniel, Director, Southwest Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 4-2018-1011M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Mary L. McDaniel, P.E. Director, Southwest Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings 3#