# ENTERPRISE PRODUCTS OPERATING LLC — Warning Letter

- **operation:** document
- **citation:** CPF 42021007WL
- **title:** ENTERPRISE PRODUCTS OPERATING LLC — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2021-01-22
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.54(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-42021007wl.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-42021007wl.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-42021007wl
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/42021007WL
**body:**

Warning Letter involving ENTERPRISE PRODUCTS OPERATING LLC. PHMSA's enforcement data identifies the cited regulation as 195.54(a). The case was opened on 2021-01-22 and is reported as closed as of 2021-01-22. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

42021007WL_Warning Letter_01222021_(20-172502).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021007WL/42021007WL_Warning%20Letter_01222021_(20-172502).pdf

42021007WL_Warning Letter_01222021_(20-172502)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021007WL/42021007WL_Warning%20Letter_01222021_(20-172502)_text.pdf

42021007WL_Warning Letter_01222021_(20-172502)_text.pdf

WARNING LETTER
ELECTRONIC MAIL - RETURN RECEIPT REQUESTED
January 22, 2021
Graham Bacon
Executive Vice President, Chief Operating Officer
Enterprise Products Operating, LLC
1100 Louisiana Street
Houston, Texas 77002
CPF 4-2021-007-WL
Dear Mr. Bacon:
From February 24, 2020 through October 30, 2020, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code
(U.S.C.) inspected Enterprise Products Operating, LLC’s (Enterprise) operations, maintenance,
and integrity management records for Enterprise MAPCO system in Kansas, Nebraska, Iowa,
Minnesota, Missouri, Illinois, and Wisconsin.
As a result of the inspection, it is alleged that Enterprise has committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and
probable violation is:
1. § 195.54 Accident reports.
(a) Each operator that experiences an accident that is required to be reported under
§ 195.50 must, as soon as practicable, but not later than 30 days after discovery of the
accident, file an accident report on DOT Form 7000-1.
Enterprise failed to file an accident report on DOT Form 7000-1 within 30 days of
discovering a reportable release at its Mankato Station in Minnesota. Enterprise
experienced a release of HVL on May 21, 2018, but did not file the DOT Form 7000-1
until August 19, 2018, which was 90 days after the day of the release.



2
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related
series of violations. For violation occurring on or after November 27, 2018 and before July 31,
2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum
penalty not to exceed $2,132,679. For violation occurring on or after November 2, 2015 and before
November 27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a
maximum penalty not to exceed $2,090,022. For violations occurring prior to November 2, 2015,
the maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty
not to exceed $2,000,000 for a related series of violations. 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 correct the
item(s) identified in this letter. Failure to do so will result in Enterprise Products Operating, LLC
being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 4-2021-007-WL. 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).
Sincerely,
Mary L. McDaniel, P.E.
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
cc: Jeff Morton, Sr. Director, Transportation Compliance, Enterprise Products,
jcmorton@eprod.com
Hans Deeb, Sr. Pipeline Compliance Engineer, Enterprise Products, hdeeb@eprod.com
Suzie Davis, Manager, Compliance, Enterprise Products, smdavid@eprod.com
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