{"operation":"document","citation":"CPF 42022010NOPV","title":"ENERGY TRANSFER COMPANY — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-02-09","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.262(d), 195.403(a)(2), 195.412(a), 195.452(f)(1), 195.452(f)(6), 195.452(h)(4)(i)(A), 195.452(i)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42022010nopv.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42022010nopv.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42022010nopv","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42022010NOPV","body":"Notice of Probable Violation involving ENERGY TRANSFER COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.262(d),  195.403(a)(2),  195.412(a),  195.452(f)(1),  195.452(f)(6),  195.452(h)(4)(i)(A),  195.452(i)(1). The case was opened on 2022-02-09 and is reported as closed as of 2023-02-08. Proposed civil penalty: $57,700. Assessed civil penalty: $57,700. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42022010NOPV_Closure Letter_02082023_(21-199751).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022010NOPV/42022010NOPV_Closure%20Letter_02082023_(21-199751).pdf\n\n42022010NOPV_Closure Letter_02082023_(21-199751)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022010NOPV/42022010NOPV_Closure%20Letter_02082023_(21-199751)_text.pdf\n\n42022010NOPV_Final Order_09192022_(21-199751).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022010NOPV/42022010NOPV_Final%20Order_09192022_(21-199751).pdf\n\n42022010NOPV_Final Order_09192022_(21-199751)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022010NOPV/42022010NOPV_Final%20Order_09192022_(21-199751)_text.pdf\n\n42022010NOPV_Operator Response to Notice_03112022_(21-199751).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022010NOPV/42022010NOPV_Operator%20Response%20to%20Notice_03112022_(21-199751).pdf\n\n42022010NOPV_PCO PCP_02092022_(21-199751).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022010NOPV/42022010NOPV_PCO%20PCP_02092022_(21-199751).pdf\n\n42022010NOPV_PCO PCP_02092022_(21-199751)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022010NOPV/42022010NOPV_PCO%20PCP_02092022_(21-199751)_text.pdf\n\n42022010NOPV_Final Order_09192022_(21-199751)_text.pdf\n\nSeptember 19, 2022\nVIA ELECTRONIC MAIL TO: gregory.mcilwain@energytransfer.com\nMr. Greg McIlwain\nExecutive Vice President, Operations\nEnergy Transfer Company\n1300 Main Street\nHouston, Texas 77002\nRe: CPF No. 4-2022-010-NOPV\nDear Mr. McIlwain:\nEnclosed please find the Final Order issued in the above-referenced case. It withdraws two of\nthe allegations of violation, makes other findings of violation, and assesses a civil penalty of\n$57,700. The penalty payment terms are set forth in the Final Order. It further finds that Energy\nTransfer Company has completed some of the actions specified in the Notice of Probable\nViolation to comply with the pipeline safety regulations. When the civil penalty has been paid\nand the remaining terms of the compliance order have been completed, as determined by the\nDirector, Southwest Region, this enforcement action will be closed. Service of the Final Order\nby e-mail is effective upon the date of transmission and acknowledgement of receipt as provided\nunder 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. Bryan Lethcoe, Director, Southwest Region, Office of Pipeline Safety\nMr. Todd Nardozzi, Director, Regulatory Compliance, Energy Transfer Company,\n\n\n\ntodd.nardozzi@energytransfer.com\nMr. Eric Amundsen, Senior Vice President, Operations, Energy Transfer Company,\neric.amundsen@energytransfer.com\nMr. Chris Lason, Vice President – Asset Integrity, Energy Transfer Company,\nchris.lason@energytransfer.com\nMr. Mark Milliken, Vice President, Technical Services, Energy Transfer Company,\nmark.milliken@energytransfer.com\nMs. Heidi Slinkard, Chief Counsel, Energy Transfer Company,\nheidi.slinkard@energytransfer.com\nCONFIRMATION OF RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nEnergy Transfer Company, ) CPF No. 4-2022-010-NOPV\n)\n)\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nFrom March 1, 2021, through October 20, 2021, pursuant to 49 U.S.C. § 60117, a representative\nof the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline\nSafety (OPS), inspected Energy Transfer Company’s (ETC or Respondent) Lone Star NGL\nNorth Pipeline System located in New Mexico and Texas. ETC operates approximately 5,500\nmiles of NGL pipelines with an aggregate transportation capacity of approximately 3 million\nbarrels per day.\n1\nAs a result of the inspection, the Director, Southwest Region, OPS (Director), issued to\nRespondent, by letter dated February 9, 2022, a Notice of Probable Violation, Proposed Civil\nPenalty, and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the\nNotice proposed finding that ETC had committed four violations of 49 C.F.R. part 195, proposed\nassessing a civil penalty of $57,700 for the alleged violations, and proposed ordering Respondent\nto take certain measures to correct the alleged violations. The Notice also included an additional\ntwo warning items pursuant to 49 C.F.R. § 190.205, which warned the operator to correct the\nprobable violations or face possible future enforcement action.\nETC responded to the Notice by letter dated March 11, 2022 (Response). Respondent contested\nseveral of the allegations, offered additional information in response to the Notice, and requested\nthat the proposed civil penalty be reduced. Respondent did not request a hearing and therefore\nhas waived its right to one.\n1 Business Overviews, ENERGY TRANSFER, available at https://energytransfer.com/natural-gas-liquids/ (last visited\nAugust 25, 2022).\n\n\n\nFINDINGS OF VIOLATION\nThe Notice alleged that Respondent violated 49 C.F.R. part 195, as follows:\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.262(d), which states:\n§ 195.262 Pumping equipment.\n(a) . . . .\n(d) Except for offshore pipelines, pumping equipment must be installed\non property that is under the control of the operator and at least 15.2 m (50\nft) from the boundary of the pump station.\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.262(d) by failing to install pumping\nequipment at least 15.2 meters (50 feet) from the boundary of the pump station. Specifically, the\nNotice alleged that ETC’s pumping equipment for the Lone Star NGL North Pipeline System at\nPump Station 4 (LSX4), located approximately four miles northeast of Morgan, Texas, was not\ninstalled 50 feet from the boundary of the pump station, but rather 38 feet.\nIn its Response, ETC disagreed with PHMSA’s allegation, and argued that the pumping\nequipment is installed 57 feet from the boundary of ETC controlled property. Respondent noted\nthat during the inspection the PHMSA inspector measured the distance from the base of the\npumping equipment to the closest chain-link fence surrounding the pumping equipment.\nHowever, Respondent provided documentation with its Response showing that ETC controlled\nproperty extending beyond the chain-link fence, including up to a second barbed wire fence, for\na total distance of 57 feet from the pumping equipment to ETC’s property boundary.\nIn a recommendation for final action submitted pursuant to § 190.209(b)(7), the Director\nrecommended withdrawing the alleged violation of § 195.262(d). Accordingly, after considering\nall of the evidence, I hereby order that Item 1 of the Notice be withdrawn.\nItem 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.403(a)(2), which states:\n§ 195.403 Emergency response training.\n(a) Each operator shall establish and conduct a continuing training\nprogram to instruct emergency response personnel to:\n(1) . . . .\n(2) Know the characteristics and hazards of the hazardous liquids or\ncarbon dioxide transported, including, in case of flammable HVL,\nflammability of mixtures with air, odorless vapors, and water reactions;\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.403(a)(2) by failing to conduct a\ntraining program to instruct emergency response personnel to know the characteristics and\nhazards of the hazardous liquids transported. Specifically, the Notice alleged that the drills\nconducted by ETC for the Northeast Texas Team of the Lone Star NGL North Pipeline System,\nwhich transports highly-volatile liquid (HVL), did not simulate emergency situations and\nspecific company response activities required for HVL. It further alleged that Respondent was\n\n\n\nunable to provide records of emergency response personnel training for the Northeast Texas\nTeam of the Lone Star NGL North Pipeline System.\nIn its Response, ETC neither admitted nor denied the allegations described in the Notice. Nor\ndid it contest the factual allegations underlying the alleged violation. Rather, ETC asked for a\nreduction of the proposed civil penalty. Respondent also provided additional information as to\nthe measures it undertook in response to the proposed compliance order (PCO) and asked that it\nbe considered satisfied.\nAccordingly, after considering all of the evidence, I find that Respondent violated 49 C.F.R.\n§ 195.403(a)(2) by failing to conduct a training program to instruct emergency response\npersonnel to know the characteristics and hazards of the hazardous liquids transported.\nETC’s request for a reduction of the civil penalty and its request that the PCO be considered\nsatisfied are discussed in the sections below.\nItem 4: The Notice alleged that Respondent violated 49 C.F.R. § 195.452(f)(1), which states:\n§ 195.452 Pipeline integrity management in high consequence areas.\n(a) . . . .\n(f) What are the elements of an integrity management program? An\nintegrity management program begins with the initial framework. An\noperator must continually change the program to reflect operating\nexperience, conclusions drawn from results of the integrity assessments,\nand other maintenance and surveillance data, and evaluation of\nconsequences of a failure on the high consequence area. An operator must\ninclude, at minimum, each of the following elements in its written integrity\nmanagement program:\n(1) A process for identifying which pipeline segments could affect a\nhigh consequence area;\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.452(f)(1) by failing to have and\nfollow a process for identifying which pipeline segments could affect a high consequence area\n(HCA). Specifically, the Notice alleged that Respondent failed to correctly identify and verify\nlocations and boundaries of pipe segments that could affect HCAs. The Notice further alleged\nthat during inspection of the Lone Star NGL North Pipeline System, PHMSA requested ETC\nField Operations personnel identify HCAs in their area of responsibility. Of the five teams of\npersonnel, only one team identified two segments that could affect HCAs in their areas. There\nwere five other segments that could affect HCAs for that team that it did not identify.\nFurthermore, HCA milage and location records provided by ETC showed a total of 40 segments\nthat could affect HCAs, of which only two were correctly identified by Field Operations\npersonnel.\nIn its Response, ETC argued that during the inspection it provided PHMSA with a listing of all\nHCA segments of the Lone Star NGL North Pipeline System. Respondent further stated that, per\ntheir integrity management program, it conducts site-specific identification and verification of\n\n\n\nthe pipeline segments that could affect HCAs. ETC asserted that the inability of Field Operation\npersonnel to identify which pipeline segments could affect HCAs in the field without reference\nto maps or web-based mapping programs does not demonstrate a lack of a process for identifying\nwhich pipeline segments could affect an HCA.\nIn a recommendation for final action submitted pursuant to § 190.209(b)(7), the Director\nrecommended withdrawing the alleged violation of § 195.452(f)(1). Accordingly, after\nconsidering all of the evidence, I hereby order that Item 4 of the Notice be withdrawn.\nItem 5: The Notice alleged that Respondent violated 49 C.F.R. § 195.452(f)(6) and\n195.452(i)(1), which states:\n§ 195.452 Pipeline integrity management in high consequence areas.\n(a) . . . .\n(f) What are the elements of an integrity management program?....An\noperator must include, at minimum, each of the following elements in its\nwritten integrity management program:\n(1) . . . .\n(6) Identification of preventative and mitigative measures to protect the\nhigh consequence area (see paragraph (i) of this section); . . .\n(i) What preventative and mitigative measures must an operator take to\nprotect the high consequence area?\n(1) General requirements. An operator must take measures to prevent\nand mitigate the consequences of a pipeline failure that could affect a high\nconsequence area. These measures include conducting a risk analysis of the\npipeline segment to identify additional actions to enhance public safety or\nenvironmental protection. Such actions may include, but are not limited to,\nimplementing damage prevention best practices, better monitoring of\ncathodic protection where corrosion is a concern, establishing shorter\ninspection intervals, installing EFRDs on the pipeline segment, modifying\nthe systems that monitor pressure and detect leaks, providing additional\ntraining to personnel on response procedures, conducting drills with local\nemergency responders and adopting other management controls.\nThe Notice alleged that Respondent violated 49 C.F.R. §§ 195.452(f)(6) and 195.452(i)(1) by\nfailing to demonstrate its process for identifying threats by conducting segment risk analysis, and\nby failing to demonstrate the identification, evaluation, and implementation for preventive and\nmitigative measures (P&MMs) in accordance with the regulations and its Pipeline Integrity\nManagement Plan. Specifically, the Notice alleged that for the 2021 risk analysis and the three\nIntegrity Segment Summaries for the Baden North to LSX2, LSX2 to LSX3, and LSX3 to LSX4\nsegments of the Lone Star NGL North Pipeline System, ETC failed to list all threat concerns\nprioritized by risk and failed to develop proposed P&MMs and time frames to address each\nthreat.\nIn its Response, ETC neither admitted nor denied the allegations described in the Notice. Nor\ndid it contest the factual allegations underlying the alleged violation. Accordingly, after\n\n\n\nconsidering all of the evidence, I find that Respondent violated 49 C.F.R. §§ 195.452(f)(6) and\n195.452(i)(1) by failing to demonstrate its process for identifying threats by conducting segment\nrisk analysis, and by failing to demonstrate the identification, evaluation, and implementation for\nP&MMs in accordance with the regulations and its Pipeline Integrity Management Plan.\nThese findings of violation will be considered prior offenses in any subsequent enforcement\naction taken against Respondent.\nASSESSMENT OF PENALTY\nUnder 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed\n$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any\nrelated series of violations.2\nIn determining the amount of a civil penalty under 49 U.S.C. § 60122 and 49 C.F.R. § 190.225, I\nmust consider the following criteria: the nature, circumstances, and gravity of the violation,\nincluding adverse impact on the environment; the degree of Respondent’s culpability; the history\nof Respondent’s prior offenses; any effect that the penalty may have on its ability to continue\ndoing business; the good faith of Respondent in attempting to comply with the pipeline safety\nregulations; and self-disclosure or actions to correct a violation prior to discovery by PHMSA.\nIn addition, I may consider the economic benefit gained from the violation without any reduction\nbecause of subsequent damages, and such other matters as justice may require. The Notice\nproposed a total civil penalty of $57,700 for the violation cited above.\nItem 2: The Notice proposed a civil penalty of $57,700 for Respondent’s violation of 49 C.F.R.\n§ 195.403(a)(2), for failing to conduct a training program to instruct emergency response\npersonnel to know the characteristics and hazards of the hazardous liquids transported.\n3 ETC\nrequested that PHMSA reconsider the civil penalty calculation, specifically the factors of\n“history of prior offenses” and “good faith.”\nRegarding the history of prior offenses factor, Respondent argued that PHMSA assigned a point\nvalue of five to this factor in the civil penalty worksheet, commensurate to a history of two to\nthree prior violations, despite ETC not having a prior violation of § 195.403. I find this\nargument unpersuasive. History of prior offenses is not the same as repeat offenses. An alleged\nviolation is a repeat violation if, during the five years prior to the issuance of this case’s notice\nletter, the allegation cites the same basic conduct that was cited (even if, in rare circumstances, a\ndifferent code section was used) as a finding of violation in PHMSA’s final action in a previous\ncase (Final Order, Consent Order, or Decision on Petition for Reconsideration) and it occurred\nafter PHMSA’s final decision was issued. In this case, repeat offense was calculated as zero in\nthe civil penalty worksheet. History of prior offenses includes all prior violations, not limited to\n2 These amounts are adjusted annually for inflation. See 49 C.F.R. § 190.223.\n3 The Notice listed the amount of the proposed civil penalty twice. In the first instance, the Notice listed it as\n$57,700. In the second instance, the Notice listed it as $57,000. On February 23, 2022, the Director provided to\nRespondent the civil penalty worksheet in this matter. The worksheet confirms the correct value is $57,700.\n\n\n\nviolations of § 195.403. Since ETC has had three findings of violation in the past five years (see\nCPF 4-2019-5016), the appropriate point value is five.\nRegarding the “good faith” factor, ETC requested a point reduction of up to -10 (negative 10) “in\nacknowledgement of the comprehensive drills and actual events that required the activation of\nthe emergency response plan for the Northeast Texas Team of the Long Star NGL North Pipeline\nSystem.” I find this argument unpersuasive. As Respondent acknowledges, these drills and\nevents did not involve HVL products. Per the violation report, good faith is not a gauge of an\noperator’s system-wide approach to regulatory compliance generally, but it instead focuses\nsolely on efforts taken to comply with the requirement that was violated, and considers whether\nthe operator had a reasonable justification for its non-compliance. Respondent did not have, and\ndid not provide, a reasonable justification for non-compliance. Accordingly, having reviewed\nthe record and considered the assessment criteria, I assess Respondent a civil penalty of $57,700\nfor violation of 49 C.F.R. § 195.403(a)(2).\nPayment of the civil penalty must be made within 20 days after receipt of this Final Order.\nFederal regulations (49 C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer\nthrough the Federal Reserve Communications System (Fedwire), to the account of the U.S.\nTreasury. Detailed instructions are contained in the enclosure. Questions concerning wire\ntransfers should be directed to: Financial Operations Division (AMK-325), Federal Aviation\nAdministration, Mike Monroney Aeronautical Center, 6500 S MacArthur Blvd, Oklahoma City,\nOklahoma 79169. The Financial Operations Division telephone number is (405) 954-8845.\nFailure to pay the $57,700 civil penalty will result in accrual of interest at the current annual rate\nin accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to\nthose same authorities, a late penalty charge of six percent (6%) per annum will be charged if\npayment is not made within 110 days of service. Furthermore, failure to pay the civil penalty\nmay result in referral of the matter to the Attorney General for appropriate action in a district\ncourt of the United States.\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Items 1, 2, 4, and 5 in the Notice for\nviolations of 49 C.F.R. §§ 195.262(d), 195.403(a)(2), 195.452(f)(1), and 195.452(f)(6) and\n195.452(i)(1), respectively. Under 49 U.S.C. § 60118(a), each person who engages in the\ntransportation of hazardous liquids or who owns or operates a pipeline facility is required to\ncomply with the applicable safety standards established under chapter 601. The Director has\nindicated that Respondent has taken the following actions to address the cited violation for\nItem 2:\nRespondent, in September and October 2021, conducted HVL-specific training and\nexercises for the Northwest and Northeast areas of the Lone Star Express pipeline\nsystem, and provided documentation of both training sessions and exercises to\nPHMSA.\n\n\n\nAccordingly, I find that compliance has been achieved with respect to Item 2. Therefore, the\ncompliance terms proposed in the Notice for Item 2 is not included in this Order.\nFor the reasons set forth in the Findings of Violation section above, I have withdrawn Items 1\nand 4 of the Notice. Accordingly, I hereby withdraw the compliance terms proposed in the\nNotice for these Items.\nAs for the remaining compliance terms, pursuant to the authority of 49 U.S.C. § 60118(b) and 49\nC.F.R. § 190.217, Respondent is ordered to take the following actions to ensure compliance with\nthe pipeline safety regulations applicable to its operations:\nWith respect to the violation of §§ 195.452(f)(6) and 195.452(i)(1) (Item 5),\nRespondent must amend its procedure to identify when an identified threat is\nsignificant enough to warrant implementation. ETC must also review the most recent\nrisk analysis for the Lone Star NGL North Pipeline System, prioritize threats\nidentified, and determine appropriate P&MMs to address those threats. The amended\nprocedure and the P&MM analysis must be provided to PHMSA within 60 days of\nreceipt of the Final Order.\nThe Director may grant an extension of time to comply with any of the required items upon a\nwritten request timely submitted by the Respondent and demonstrating good cause for an\nextension.\nPHMSA requests that Respondent maintain documentation of the safety improvement costs\nassociated with fulfilling this Compliance Order and submit the total to the Director. It is\nrequested that these costs be reported in two categories: (1) total cost associated with\npreparation/revision of plans, procedures, studies and analyses; and (2) total cost associated with\nreplacements, additions and other changes to pipeline infrastructure.\nFailure to comply with this Order may result in administrative assessment of civil penalties not\nto exceed $200,000, as adjusted for inflation (see 49 C.F.R. § 190.223), for each violation for\neach day the violation continues or in referral to the Attorney General for appropriate relief in a\ndistrict court of the United States.\nWARNING ITEMS\nWith respect to Items 3 and 6, the Notice alleged probable violations of Part 195, but identified\nthem as warning items pursuant to § 190.205. The warnings were for:\n49 C.F.R. § 195.412(a) (Item 3) ─ Respondent’s alleged failure to inspect the\nsurface conditions on or adjacent to each pipeline right-of-way at intervals not\nexceeding three weeks, but at least 26 times each calendar year; and\n\n\n\n49 C.F.R. § 195.452(h)(4)(i)(A) (Item 6) ─ Respondent’s alleged failure to\ntemporarily reduce operating pressure until repairs could be made to an\nimmediate repair condition.\nETC presented information in its Response showing that it had taken certain actions to address\nthe cited items. If OPS finds a violation of these provisions in a subsequent inspection,\nRespondent may be subject to future enforcement action.\nUnder 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this Final\nOrder to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey\nAvenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of\nChief Counsel, PHMSA, at the same address. The written petition must be received no later than\n20 days after receipt of the Final Order by Respondent. Any petition submitted must contain a\nstatement of the issue(s) and meet all other requirements of 49 C.F.R. § 190.243. The filing of a\npetition automatically stays the payment of any civil penalty assessed. The other terms of the\norder, including corrective action, remain in effect unless the Associate Administrator, upon\nrequest, grants a stay.\nThe terms and conditions of this Final Order are effective upon service in accordance with 49\nC.F.R. § 190.5.\nSeptember 19, 2022\n___________________________________ __________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n42022010NOPV_Closure Letter_02082023_(21-199751)_text.pdf\n\nVIA ELECTRONIC MAIL\nFebruary 8, 2023\nGreg McIlwain\nExecutive Vice President Operations\nEnergy Transfer Company\n1300 Main Street\nHouston, Texas 77002\nCPF 4-2022-010-NOPV\nDear Mr. McIlwain:\nOn September 19, 2022, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued to Energy Transfer Company’s Lone Star NGL North Pipeline System a Final Order in the\nabove-referenced case. This Order included a Compliance Order and Civil Penalty assessment.\nBased on our review of the documentation you provided and confirmation of payment of the civil\npenalty, it has been determined that you have successfully complied with the terms of this Order.\nAccordingly, this case is now closed, and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\ncc: Todd Nardozzi, Director, Regulatory Compliance, Energy Transfer,\ntodd.nardozzi@energytransfer.com","truncated":false,"body_characters":25777}