TRUNKLINE GAS CO — Notice of Amendment

party submissionOfficial PDF42023028NOA_Operator Response to Notice_03202023_(22-239724).pdf#

42023028NOA_Notice of Amendment_03032023_(22-239724)_text.pdf, page 1Official PDFNOTICE OF AMENDMENT VIA ELECTRONIC MAIL March 3, 2023 Eric Amundsen Senior Vice President, Operations Trunkline Gas Company 1300 Main Street Houston, TX 77002 CPF 4-2023-028-NOA Dear Mr. Amundsen: From February 28 to August 25, 2022, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Trunkline Gas Company’s (Trunkline) written procedures for controlling corrosion in Shaw, MS. Based on the inspection, PHMSA has identified the apparent inadequacies found within Trunkline’s procedures, as described below: 1. § 192.605 Procedural manual for operations, maintenance, and emergencies. (a) . . . . (b) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following, if applicable, to provide safety during maintenance and operations. (1) . . . . (2) Controlling corrosion in accordance with the operations and maintenance requirements of subpart I of this part. § 192.481 Atmospheric corrosion control: Monitoring. (a) . . . . (b) During inspections the operator must give particular attention to pipe at soil-to-air interfaces, under thermal insulation, under disbonded coatings, at pipe supports, in splash zones, at deck penetrations, and in spans over water.#

42023028NOA_Notice of Amendment_03032023_(22-239724)_text.pdf, page 2Trunkline’s written procedures for controlling corrosion were inadequate to assure safe operation of a pipeline facility in accordance with § 192.605(b)(2). Specifically, Trunkline’s atmospheric corrosion inspection procedure, D.44 Atmospheric Corrosion Inspection, fails to require inspectors to give particular attention to pipe under disbonded coatings, as required by § 192.481(b). Section 7.1 of this procedure instructs inspectors to inspect and give special attention “where damaged coating is visible” but does not require inspectors to inspect underneath the damaged or disbonded coating. Therefore, Trunkline’s written procedures for controlling corrosion were inadequate to assure safe operation of a pipeline facility in accordance with § 192.605(b)(2). Trunkline must revise its procedures to specify that inspectors must inspect under disbonded coatings in accordance with § 192.481(b). 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. It is requested (not mandated) that Trunkline Gas Company maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Bryan Lethcoe, Director, Southwest Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 4-2023-028-NOA, and for each document you submit, please provide a copy in electronic format whenever possible.#

42023028NOA_Notice of Amendment_03032023_(22-239724)_text.pdf, page 3Sincerely, Bryan Lethcoe Director, Southwest Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings cc: Todd Nardozzi, Director Regulatory Compliance, todd.nardozzi@energytransfer.com#

42023028NOA_Closure Letter_05302024_(22-239724)_text.pdf, page 1Official PDFVIA ELECTRONIC MAIL TO: tom.long@energytransfer.com May 30, 2024 Thomas Long Chief Executive Officer Energy Transfer, LP 8111 Westchester Dallas, Texas 75225 CPF 4-2023-028-NOA Dear Mr. Long: From February 28, through August 25, 2022, a representative from 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.), conducted an on-site pipeline safety inspection of Trunkline Gas Company, LLC’s (Trunkline) written procedures for controlling corrosion in Shaw, Mississippi. As a result of the inspection, Trunkline was issued a Notice of Amendment (Notice) on March 3, 2023, requiring amendment to its corrosion control procedure. Trunkline submitted its amended procedure on March 20, 2023, and its final amended procedure implemented for company use on May 3, 2023. My staff reviewed the amended procedure, and it appears that the inadequacy outlined in this Notice has been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Bryan Lethcoe Director, Southwest Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration cc: Greg McIlwain, Executive Vice President, Operations, Energy Transfer LP, greg.mcilwain@energytransfer.com Eric Amundsen, Senior Vice President, Operations, Energy Transfer LP, eric.Amundsen@energytransfer.com Todd Stamm, Senior Vice President, Operations, Energy Transfer LP, todd.stamm@energytransfer.com#

42023028NOA_Closure Letter_05302024_(22-239724)_text.pdf, page 2Jennifer Street, Senior Vice President, Operations Services, Energy Transfer LP, jennifer.street@energytransfer.com Keegan Pieper, Assistant General Counsel, Energy Transfer LP, keegan.pieper@energytransfer.com Matthew Stork, Vice President, Technical Services, Energy Transfer LP, matthew.stork@energytransfer.com Todd Nardozzi, Director – DOT Compliance, Energy Transfer LP, todd.nardozzi@energytransfer.com Susie Sjulin, Director – DOT Compliance, Energy Transfer LP, susie.sjulin@energytransfer.com#