{"operation":"document","citation":"CPF 42023056NOPSO","title":"ENERGY TRANSFER COMPANY — Safety Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2023-10-13","effective_on":null,"summary":"OPEN safety order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42023056nopso.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42023056nopso.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42023056nopso","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42023056NOPSO","body":"Safety Order involving ENERGY TRANSFER COMPANY. The dataset does not identify a cited regulation for this case. The case was opened on 2023-10-13 and is reported as open. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42023056NOPSO_Consent Agreement and Order_04242025_(23-281044).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023056NOPSO/42023056NOPSO_Consent%20Agreement%20and%20Order_04242025_(23-281044).pdf\n\n42023056NOPSO_Consent Agreement and Order_04242025_(23-281044)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023056NOPSO/42023056NOPSO_Consent%20Agreement%20and%20Order_04242025_(23-281044)_text.pdf\n\n42023056NOPSO_Notice of Proposed Safety Order_10132023_(23-281044).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023056NOPSO/42023056NOPSO_Notice%20of%20Proposed%20Safety%20Order_10132023_(23-281044).pdf\n\n42023056NOPSO_Notice of Proposed Safety Order_10132023_(23-281044)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023056NOPSO/42023056NOPSO_Notice%20of%20Proposed%20Safety%20Order_10132023_(23-281044)_text.pdf\n\n42023056NOPSO_Operator RfH Req Inf Consultation Mtg_11102023_(23-281044).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023056NOPSO/42023056NOPSO_Operator%20RfH%20Req%20Inf%20Consultation%20Mtg_11102023_(23-281044).pdf\n\n42023056NOPSO_Notice of Proposed Safety Order_10132023_(23-281044)_text.pdf\n\nVIA ELECTRONIC MAIL TO: tom.long@energytransfer.com\nOctober 13, 2023\nMr. Thomas E. Long\nChief Executive Officer\nEnergy Transfer, LP\n8111 Westchester Drive\nDallas, Texas 75225\nCPF 4-2023-056-NOPSO\nDear Mr. Long:\nEnclosed is a Notice of Proposed Safety Order (Notice) issued by the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) in the above-referenced case. The Notice proposes\nthat Energy Transfer, LP, take certain measures to ensure facility safety with respect to the Mid-\nValley Pipeline system that includes over 1,000 miles of crude oil pipeline originating in\nLongview, Texas, and terminating in Samaria, Michigan. Your options for responding are set forth\nin the Notice. Service of this Notice by electronic mail is deemed effective upon the date of\ntransmission, or as otherwise provided under 49 C.F.R. § 190.5.\nWe look forward to a successful resolution to improve the safety and integrity of the Mid-Valley\nPipeline system. Please direct any questions on this matter to me at (713) 773-7215.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosures: Notice of Proposed Safety Order\ncc: Mr. Alan K. Mayberry, Associate Administrator for Pipeline Safety, OPS, PHMSA\nMs. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS,\nPHMSA\nMr. Greg McIlwain, Executive Vice President of Operations, Energy Transfer, LP,\ngregory.mcilwain@energytransfer.com\n\n\n\nMr. Eric Amundsen, Senior Vice President of Operations, Energy Transfer, LP,\neric.amundsen@energytransfer.com\nMr. Todd Stamm, Senior Vice President of Operations, Energy Transfer, LP,\ntodd.stamm@energytransfer.com\nMs. Jennifer Street, Senior Vice President of Operations Services, Energy Transfer, LP,\njennifer.street@energytransfer.com\nMs. Heidi Murchison, Chief Counsel, Energy Transfer, LP,\nheidi.murchison@energytransfer.com\nMr. Leif Jensen, Vice President of Tech Services, Energy Transfer, LP,\nleif.jensen@energytransfer.com\nMr. Todd Nardozzi, Director, Regulatory Compliance, Energy Transfer, LP,\ntodd.nardozzi@energytransfer.com\nMs. Susie Sjulin, Director, Regulatory Compliance, Energy Transfer, LP,\nsusie.sjulin@energytransfer.com\n\n\n\nDEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nSOUTHWEST REGION\nHOUSTON, TX 77074\n____________________________________\n)\nIn the Matter of )\n)\nMid-Valley Pipeline Company, LLC, ) CPF No. 4-2023-056-NOPSO\na subsidiary of Energy Transfer, LP, )\n)\nRespondent. )\n____________________________________)\nNOTICE OF PROPOSED SAFETY ORDER\nBackground and Purpose:\nThis Notice of Proposed Safety Order (NOPSO or Notice) is being issued by the Pipeline and\nHazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), under the\nauthority of 49 U.S.C. § 60117. Pursuant to § 60117, PHMSA initiated an investigation of the\nsafety of Energy Transfer’s Mid-Valley Pipeline following a series of recent failures, including\nthe following:\n• On July 14, 2023, Energy Transfer experienced a pipeline failure at its terminal facility\nnear Oregon, Ohio, resulting in the initial reported release of approximately 6 barrels of\ncrude oil. This was later updated to 28 barrels of crude oil and 42 barrels of an oil/water\nmixture. The release was spotted on the ground by facility personnel during a routine walk-\naround during the day. PHMSA requested additional information related to the cause of\nthe failure, the repair plans prior to placing the facility back in service, and the inspections\nperformed at the facility to ensure that similar conditions that could lead to a failure did\nnot exist elsewhere in the facility. On July 16, 2023, Energy Transfer indicated the\napparent cause was internal corrosion, identified other at-risk locations within the facility\nbut did not provide any inspection results prior to placing the facility back in service.\nEnergy Transfer indicated that the failed segment would be cut out and replaced but did\nnot specify if the pipe would be sent for metallurgical evaluation to confirm the cause of\nfailure. Energy Transfer did not indicate it made any improvements to its internal corrosion\nprogram or altered its periodic inspections of terminal piping.\n• On July 11, 2023, Energy Transfer experienced a failure at its terminal facility near\nLongview, Texas, which resulted in the release of crude oil and a fire. Energy Transfer\nreported the release to be 2 gallons of crude oil into the secondary containment, which\n\n\n\nsubsequently caught fire and was extinguished by the fire suppression system in the\nfacility. The apparent cause was determined by Energy Transfer to be misalignment\nbetween the pump unit and motor which resulted in excessive vibration and failure of the\npump seals. The pump unit failed to shut down due to the high vibration condition as it\nwas intended.\n• On July 5, 2023, Energy Transfer experienced a failure near Cygnet, Ohio, resulting in the\ninitial reported release of approximately 1,000 barrels of crude oil. The release quantity\nwas later revised by the Energy Transfer to less than 5 barrels. Energy Transfer stated the\ninitial reported release amount was incorrect due to a miscommunication between the\ncontrol center and a regulatory compliance representative. Energy Transfer initially\ndetermined the original imbalance alarm, set at 200 barrels, was caused by a measurement\nerror, and restarted the pipeline. Subsequently, their aerial patrol reported evidence of a\nrelease on the Mid-Valley right-of-way before the pipeline was shut down and the oil spill\ncontractor dispatched to the site. The release was initially reported to have been caused by\na “linear” defect. Energy Transfer did not perform a cutout of the failed pipe segment so\nthat it could be sent for metallurgical evaluation. Energy Transfer stated in a meeting on\nJuly 6, 2023, that performing a cutout would disrupt deliveries to a refinery in the upper\nMidwest and likely result in shortages of gasoline. Energy Transfer installed a bolt-on\nsleeve and returned the pipeline to service and stated the cutout would be performed at a\nlater, unspecified date. The property damage was approximately $411,205.\n• On March 3, 2023, Energy Transfer experienced a failure at the Karnak Pump Station on\nthe Longview to Mayersville 20-inch pipeline segment, which resulted in the release of\napproximately 0.3 barrels (12 gallons) of crude oil. The release was contained on property\ncontrolled by Energy Transfer. The apparent cause was determined by Energy Transfer to\nbe failure of the pump seals. However, the automation detected the loss of pressure and\nclosed the suction and discharge valves on the pump station. The pump unit continued to\nrun causing an overpressure condition and had to be shut down manually by a technician\nthat tripped the station breaker. The property damage was approximately $12,530.\n• On January 25, 2023, Energy Transfer experienced a failure at the Mayersville Pump\nStation that resulted in the release of approximately 3 barrels of crude oil, which was\ncontained on the property controlled by Energy Transfer. The apparent cause of the failure\nwas determined by Energy Transfer to be internal corrosion. The property damage was\napproximately $43,726.\n• On December 23, 2022, Energy Transfer experienced a failure at the Cygnet Pump Station\nthat resulted in the release of approximately 1,974 barrels of crude oil, a portion which\nmigrated off property controlled by Energy Transfer. A highway adjacent to the pump\nstation was closed by local law enforcement due to the threat to public safety. The cause\nof the failure was determined by metallurgical evaluation to be a hydrogen crack in a\nbranch weld that increased to a critical size so that it could no longer contain the pipeline\npressure. Energy Transfer stated that it performed visual inspections of other branch welds\nat the Cygnet Pump Station. Energy Transfer did not conduct any non-destructive\n\n\n\nexaminations to determine if defects existed on similar welds. The property damage was\napproximately $2,306,948.\nIn addition to the above, the following failures have occurred on the Mid-Valley Pipeline system\nsince 2014:\n• On June 29, 2022, Energy Transfer experienced a failure on the Abbeville to Denver 22-\ninch segment near Henderson, TN, which resulted in the release of approximately 4,345\nbarrels of crude oil. The release occurred when a mowing contractor struck an exposed\nsegment of pipeline resulting in a gouge and release of crude oil. Energy Transfer\nindicated that the segment had 42-inches of cover; however, the same report stated that\nthe pipeline was exposed due to loss of cover. The release affected soil, vegetation,\nwildlife, and water. Energy Transfer estimated that approximately 3,300 barrels of the\n4,345 barrels of crude oil released affected Horse Creek. Energy Transfer applied a bolt-\non clamp and restarted the pipeline. Energy Transfer did not mention taking any additional\npreventative and mitigation measures. The property damage was approximately\n$4,651,397.\n• On June 1, 2022, Energy Transfer experienced a failure on the Haynesville to Magnolia\n8-inch pipeline segment that resulted in the release of approximately 8 barrels of crude oil.\nThe release occurred at a road crossing and was reported by a member of the public. The\napparent cause of the failure was determined by Energy Transfer to be third-party damage\nfrom excavation work that occurred while a third party was performing maintenance work\non a ditch adjacent to the pipeline. The pipe damage included an inward dent\napproximately 6-inches in length and 4-inches wide with a 1-inch puncture through the\npipeline wall. The property damage was approximately $42,565.\n• On December 28, 2021, Energy Transfer experienced a failure at Lima Station (located in\na High Consequence Area) that resulted in the release of approximately 5 barrels of crude\noil. The apparent cause of the failure was determined by Energy Transfer to be internal\ncorrosion. A bolt-on sleeve was installed, and the pipeline was placed back in service.\nThe property damage was approximately $40,860.\n• On November 19, 2021, Energy Transfer experienced a failure at Lima Station (located in\na High Consequence Area) that resulted in the release of approximately 1 barrel of crude\noil from a 30-inch breakout tank pipeline. The release was discovered on the ground by\noperator personnel during a routine check of the station and was contained on property\ncontrolled by Energy Transfer. The apparent cause of the failure was determined by\nEnergy Transfer to be failure of a bolt-on sleeve that had been installed as a previous repair\nfor an internal corrosion release. The property damage was approximately $23,380.\n\n\n\n• On September 20, 2021, Energy Transfer experienced a failure at Lima Station (located in\na High Consequence Area) that resulted in the release of approximately 0.3 barrels of\ncrude oil. The release was discovered by local personnel during a routine check of the\nstation. The apparent cause was determined by Energy Transfer to be the release of crude\noil from a previously abandoned pipeline that had not been purged. The property damage\nwas approximately $47,050.\n• On June 10, 2021, Energy Transfer experienced a failure at Lima Station (located in a\nHigh Consequence Area) that resulted in the release of approximately 17 barrels of crude\noil. The release was discovered by a contractor while mowing at the station. The apparent\ncause of the failure was determined by Energy Transfer to be internal corrosion of a\nbreakout tank pipeline. The property damage was approximately $79,229.\n• On March 16, 2021, Energy Transfer experienced a failure at the Longview Station that\nresulted in the release of approximately 0.8 barrels of crude oil from a breakout tank. The\napparent cause of the failure was determined by Energy Transfer to be operator error due\nto overfilling the tank, resulting in a release of crude oil from the top of the tank after\nexceeding the maximum liquid level height. The property damage was approximately\n$5,376.\n• On February 22, 2021, Energy Transfer experienced a failure at the Abbeville Pump\nStation that resulted in the release of approximately 15 barrels of crude oil. The release\nwas discovered on the ground near a 12-inch relief pipeline by operator personnel. The\napparent cause of the failure was determined by Energy Transfer to be internal corrosion.\nEnergy Transfer bypassed the station and continued operation of the pipeline. The failed\npipe segment at the station was cut out and replaced. The property damage was\napproximately $81,512.\n• On December 28, 2020, Energy Transfer experienced a failure at the Samaria Station that\nresulted in the release of approximately 3 barrels of crude oil. The release was discovered\non the ground by operator personnel performing a routine station check. The apparent\ncause of the failure was determined by Energy Transfer to be internal corrosion of a 12-\ninch pipeline flange weld. The weld was cut out and replaced. The property damage was\napproximately $48,782.\n• On May 29, 2019, Energy Transfer experienced a failure at Lima Station (located in a\nHigh Consequence Area) that resulted in the release of approximately 0.2 barrels of crude\noil. Energy Transfer stated the apparent cause of the release was residual product on the\ninside of the tank shell mixed with water on the floating roof that was released when the\nexternal floating roof drains were opened. The property damage was approximately\n$7,052.\n\n\n\n• On March 22, 2019, Energy Transfer experienced a failure at Hebron Station, KY, (located\nin a High Consequence Area) which resulted in the release of 0.24 barrels of crude oil.\nThe apparent cause of the failure was determined by Energy Transfer to be operator error\nwhen a valve was left partially open during a pigging operation. The property damage\nwas approximately $1,030.\n• On March 18, 2019, Energy Transfer experienced a failure at Longview Station (located\nin a High Consequence Area) that resulted in the release of approximately 10 barrels of\ncrude oil. The apparent cause of the failure was determined by Energy Transfer to be a\npinhole leak in a breakout tank pipeline cause by internal corrosion. The failed pipe\nsegment at the station was cut out and replaced. The property damage was approximately\n$15,719.\n• On February 1, 2017, Energy Transfer experienced a failure at Mayersville Pump Station\nthat resulted in the release of approximately 0.24 barrels of crude oil. The apparent cause\nof the failure was determined by Energy Transfer to be a faulty liquid level switch that led\nto crude oil backing up into the scraper trap containment basin. The property damage was\napproximately $1,000.\n• On January 11, 2017, Energy Transfer experienced a failure at Lima Pump Station (located\nin a High Consequence Area) that resulted in the release of approximately 2 barrels of\ncrude oil. The release was discovered on the ground near a pump unit by operator\npersonnel. The apparent cause of the failure was determined by Energy Transfer to be\nfailure of a bolt on the pump shaft. The bolt had been replaced during previous\nmaintenance with one that did not meet the manufacturer’s specifications. The property\ndamage was approximately $45,000.\n• On December 19, 2016, Energy Transfer experienced a failure at Spearsville Pump Station\nthat resulted in the release of approximately 0.12 barrels of crude oil. The apparent cause\nof the failure was determined by Energy Transfer to be the unexpected start of a pump unit\nwith the intake and discharge valves closed. The pump unit overheated the seals leading\nto a release of commodity. Energy Transfer noted that the fire suppression system\nactivated, meaning the released commodity had ignited. The property damage was\napproximately $328,857.\n• On August 9, 2016, Energy Transfer experienced a failure at Lima Pump Station (located\nin a High Consequence Area) that resulted in the release of approximately 2 barrels of\ncrude oil. The apparent cause of the failure was determined by Energy Transfer to be\ninternal corrosion on a 16-inch breakout tank pipeline. Energy Transfer installed a bolt-\non sleeve and returned the pipeline to service. The property damage was approximately\n$29,040.\n\n\n\n• On June 1, 2016, Energy Transfer experienced a failure at Cygnet Pump Station (located\nin a High Consequence Area) that resulted in the release of approximately 2 barrels of\ncrude oil. The apparent cause of the failure was determined by Energy Transfer to be\noperator error. The liquid level in Tank 83 was lowered so that the floating roof contacted\nthe tank mixer impeller and caused the mixer seal to fail resulting in the release. The tank\nmixer was removed, and a blind manway cover installed. The property damage was\napproximately $4,200.\n• On February 3, 2016, Energy Transfer experienced a failure at Lima Station (located in a\nHigh Consequence Area) that resulted in the release of approximately 1.2 barrels (50\ngallons) of crude oil. The apparent cause of the failure was determined by Energy Transfer\nto be a leak in the valve stem packing on a partially buried 16-inch valve that isolated\ndead-leg piping. The property damage was approximately $15,000.\n• On January 8, 2016, Energy Transfer experienced a failure at Hebron Station (located in a\nHigh Consequence Area) that resulted in the release of approximately 10 barrels of crude\noil. The apparent cause of the failure was determined by Energy Transfer to be internal\ncorrosion in the sump pump piping. The property damage was approximately $43,800.\n• On January 9, 2015, Energy Transfer experienced a failure at Lima Station (located in a\nHigh Consequence Area) that resulted in the release of approximately 100 barrels of crude\noil. The apparent cause of the failure was determined by Energy Transfer to be a cracked\nfitting on the pump discharge valve. The property damage was approximately $45,946.\n• On October 13, 2014, Energy Transfer experienced a pipeline failure near Mooringsport,\nLA, which resulted in the release of approximately 4,509 barrels of crude oil in a High\nConsequence Area that affected soil, vegetation, and surface water. The apparent cause\nof the failure was determined by Energy Transfer to be stress corrosion cracking. The\nproperty damage was approximately $11,702,787.\n• On April 18, 2014, Energy Transfer experienced a failure at Longview Station (located in\na High Consequence Area) that resulted in the release of approximately 3 barrels of crude\noil. The apparent cause of the failure was determined by Energy Transfer to be a failed\npump seal. The property damage was approximately $4,501.\n• On April 4, 2014, Energy Transfer experienced a failure at Longview Station (located in\na High Consequence Area) that resulted in the release of approximately 1 barrel of crude\noil. The apparent cause of the failure was determined by Energy Transfer to be a failed\ntank mixer seal. The property damage was approximately $20,798.\n• On March 22, 2014, Energy Transfer experienced a failure of the Mid-Valley Pipeline at\nDenver Station (located in a High Consequence Area) that resulted in the release of\napproximately 2 barrels of crude oil. The release was reported by the local fire department.\nThe apparent cause was not identified by Energy Transfer, but the release was from a\nbreakout tank pipeline. Energy Transfer drained the pipeline and installed a bolt-on clamp.\nThe property damage was approximately $25,000. An NRC report was filed.\n\n\n\n• On March 17, 2014, Energy Transfer experienced a failure of the Mid-Valley Pipeline\nHebron to Lima 20-inch segment near Colerain Township that resulted in the release of\napproximately 450 barrels of crude oil. The release was reported by local emergency\nresponders. Metallurgical evaluation determined the cause to be near neutral stress\ncorrosion cracking on the body of the pipe. The release was in a High Consequence Area\nand affected soil, vegetation, wildlife, and water. The property damage was estimated to\nbe approximately $7,174,939.\n• On February 24, 2014, Energy Transfer experienced a failure of the Mid-Valley Pipeline\nat Clarksville Station that resulted in the release of approximately 1 barrel of crude oil. The\nrelease was discovered by local operating personnel. The apparent cause was not identified\nby Energy Transfer, but the release was from a breakout tank pipeline. Energy Transfer\ninstalled a bolt-on clamp and returned the pipeline to service. The property damage was\napproximately $48,200.\n• On February 20, 2014, Energy Transfer experienced a failure of the Mid-Valley Pipeline\nat Samaria Station that resulted in the release of approximately 1 barrel of crude oil. Energy\nTransfer reported that ice in the pig trap drain line prevented commodity from draining into\nthe sump and subsequent heavy rain caused crude oil to float out of the containment basin.\nThe property damage was approximately $1,720.\n• On February 17, 2014, Energy Transfer experienced a failure of the Mid-Valley Pipeline\nat Lima Station (located in a High Consequence Area) that resulted in the release of less\nthan 1 barrel of crude oil. The release was discovered by local operating personnel. The\napparent cause of the failure was determined to Energy Transfer to be a crack in a fitting\non the small diameter piping around the pump discharge valve. Energy Transfer replaced\nthe cracked fitting but provided no additional information as to the cause. The property\ndamage was approximately $5,136.\nAdditionally, there have been recent public complaints expressing concerns about the safety\nof the Mid-Valley Pipeline. PHMSA’s investigation of these complaints have determined the\nfollowing:\n• An encroachment involving a temporary building was found on the Mid-Valley Pipeline\nright-of-way in Cecelia, KY. Energy Transfer stated that an agreement had been made\nwith the landowner to allow the building to remain on the pipeline right-of-way. PHMSA\nasked to review this agreement to verify that there were restrictions on what could be stored\nin the building and that Energy Transfer could move or demolish the building should it be\nrequired for maintenance or emergency response. Energy Transfer declined to provide the\nagreement.\n\n\n\n• An exposed pipe in a stream crossing was found near Collinsville, OH, with large stumps\nand tree limbs present in the channel. PHMSA issued an Advisory Bulletin on April 9,\n2015, (ADB-2015-01, 80 Fed. Reg. 19114), which provided notification to pipeline\noperators about the need for operators to take actions to ensure the integrity of pipelines in\nthe event of flooding, river scour, and river channel migration that may result in additional\nstresses imposed on the pipe by undermining the underlying support soils, exposing the\npipeline to lateral water forces, and impact from waterborne debris. This pipeline appears\nto be at risk for these threats. The pipeline coating also appears to be in poor condition\nresulting in diminished protection from atmospheric corrosion. No apparent actions have\nbeen taken by Energy Transfer to mitigate the threats presented by the exposed pipe.\n• The condition of the right-of-way (ROW) near the Collinsville, OH, stream crossing\nexposure obscured the ROW in a manner that would limit the effectiveness of patrolling\nand potentially obscure a release. There was a notable absence of pipeline markers to\nidentify the location of the pipeline. The pipeline also crosses under railroad tracks in the\nsame area with no casing vents present that could be used to detect leaks in the carrier pipe.\nIn response to PHMSA questions about this crossing, Energy Transfer confirmed that the\ncasing is shorted which does not meet the requirements of 49 C.F.R. § 195.575 for electrical\nisolation.\nAs a result of numerous failures, existing integrity concerns, and PHMSA’s preliminary\ninvestigation, it appears that conditions exist on the Mid-Valley Pipeline that pose a pipeline\nintegrity risk to public safety, property, or the environment. Pursuant to 49 U.S.C. § 60117(m),\nPHMSA issues this Notice of Proposed Safety Order, notifying you of the preliminary findings of\nthe investigation, and proposing that you take measures to ensure that the public, property, and the\nenvironment are protected from the potential risks.\nPreliminary Findings:\nThe preliminary findings of PHMSA’s ongoing investigation are as follows:\n• The Mid-Valley Pipeline consists of approximately 1,048 miles of primarily 20- and 22-\ninch mainline pipeline that originates near Longview, TX, and terminates near Samaria,\nMI. The pipeline system includes 14 pump stations and 41 breakout tanks. It was\nconstructed in the 1950s and is designed to deliver approximately 240,000 barrels of crude\noil per day to refineries in the upper Midwest.\n• The pipeline traverses near or through several high population areas, other populated\nareas, unusually sensitive areas, lakes, and crosses several rivers and streams, highways,\nroads, and railroads. Many of the pump stations and terminals are located in High\nConsequence Areas.\n• The Mid-Valley Pipeline has experienced at least 34 failures since 2014 from various\ncauses, including internal corrosion, pump failures, third-party damage, faulty equipment,\nhydrogen cracking, stress corrosion cracking, pipeline exposures, failed repairs, operator\nerrors, and unidentified causes. Some of these failures do not appear to have had a\n\n\n\ncomplete investigation as to the causes and contributing factors and it is unclear to\nPHMSA the actions taken by the Energy Transfer to determine if similar integrity threats\nmay exist elsewhere on the Mid-Valley Pipeline system.\n• After the July 5, 2023, failure, PHMSA requested Energy Transfer remove the failed\nsection of pipe and send it to a metallurgical laboratory for evaluation and determination\nof the cause of the failure. Instead, Energy Transfer installed a temporary bolt-on sleeve\nand stated that the cutout and permanent repair would be scheduled at a later date.\nConsequently, there was no investigation of the cause of the failure and no determination\nby Energy Transfer of the causes and contributing factors.\n• The apparent cause of several failures was determined by Energy Transfer to be internal\ncorrosion. Energy Transfer stated it has an internal corrosion monitoring program and, in\nsome cases, injects chemicals to inhibit internal corrosion. However, multiple failures\nrelated to internal corrosion have sometimes occurred at the same locations. PHMSA was\nunable to determine if the failures were thoroughly investigated, the specific causes\ndetermined, and preventative and mitigative measures implemented.\n• For several failures (August 9, 2016; December 28, 2021; June 29, 2022; July 5, 2023),\nEnergy Transfer installed temporary bolt-on sleeves. Energy Transfer did not immediately\ncut out the failed sections and conduct metallurgical analyses on each of the failures to\ndetermine or confirm the cause of the failure.\n• After the July 14, 2023, failure at the Mid-Valley terminal near Oregon, OH, PHMSA\nrequested that Energy Transfer perform additional inspections to determine if similar\nintegrity threats existed elsewhere in the terminal. Based on the Energy Transfer’s\nresponse, PHMSA was unable to determine if Energy Transfer conducted inspections to\ndetermine if additional similar integrity threats existed at the terminal or took measures to\nprevent additional failures.\n• Lima Station, a pump station located in a High Consequence Area, experienced at least\neight (8) failures since 2014. Three of the failures were apparently caused by internal\ncorrosion, while other failures were caused by equipment failure, failure to purge an\nabandoned pipeline, and a failed temporary repair.\n• Energy Transfer has an exposed pipe in a stream crossing near Collinsville, OH, with large\nstumps and tree limbs present in the channel. There appears to be a threat to the exposed\npipeline segment due to debris carried by the stream, particularly during high water. The\nneed to evaluate these types of threats was the subject of a PHMSA Advisory Bulletin\n(ADB-2015-01, 80 Fed. Reg. 19114) reminding pipeline operators about the need to\nevaluate these threats and take the appropriate preventative and mitigative measures as\nrequired by the underlying regulations. PHMSA also observed damage to the coating on\nthe exposed pipeline segment that could result in additional issues related to atmospheric\ncorrosion.\n\n\n\n• There were multiple instances of malfunction of control equipment such as an un-\ncommanded pump station start, a pump starts with the suction and discharge valves closed,\nand a pump that would not shut down on command. In one instance, it was necessary for\nthe technician to use the main station breaker to finally shut the pump unit down. These\nissues led to releases due to secondary effects such as pump seal failure. On at least one\noccasion, the released commodity ignited and activated the pump station fire suppression\nsystem. There were apparent flaws in the control equipment that were not fully\ninvestigated and corrected.\n• There were instances of equipment failure that resulted in releases, such as a faulty liquid\nlevel switch that resulted in a sump overflow, an incorrect bolt being used on a pump shaft\nrepair which subsequently failed, a valve packing leak, a cracked fitting, misalignment of\na pump unit that resulted in vibration and failure of the seals, and a failed pump mixer seal.\n• There have been releases caused by operator error such as overfilling a breakout tank,\nallowing water to accumulate on the roof of a breakout tank allowing commodity to mix\nwith the water which was released when the roof drains were opened, and lowering the\nliquid level in a tank to the point where the roof contacted the tank mixer and caused the\nseals to fail.\n• There have been releases due to time dependent threats such as external corrosion, internal\ncorrosion, stress corrosion cracking, and hydrogen cracking. It is unclear what preventative\nand mitigative measures the Energy Transfer has taken to prevent additional similar\nfailures.\n• Numerous failures have been discovered by members of the public and or contractors.\nOther failures were discovered by Energy Transfer personnel during routine movements\naround its facilities, and not through Energy Transfer’s instrumentation and control system.\nThese trends indicate Energy Transfer’s inability to self-monitor and detect failures.\n• The Mid-Valley Pipeline accident history indicates there are unmitigated threats associated\nwith internal corrosion, time dependent threats, third party damage, equipment failure, and\noperator error.\n• During the investigation of the July 5, 2023, failure near Cygnet, OH, PHMSA noted an\ninterrupted cathodic protection pipe-to-soil measurement that was higher than the\nenergized measurement. This may be an indication of cathodic protection interference.\nEnergy Transfer shares the right-of-way with Buckeye Pipeline but stated no CIS or\ninterference studies had been performed on this pipeline segment to determine if the\nrequirement of electrical isolation required by § 195.575 has been met. In addition, Energy\nTransfer has stated that the cased crossing under the railroad tracks near the Collinsville,\nOH stream crossing was shorted, another instance where the requirements for electrical\nisolation have not been met.\n\n\n\nProposed Issuance of Safety Order:\nSection 60117(m) of Title 49, United States Code, provides for the issuance of a Safety Order,\nafter reasonable notice and the opportunity for a hearing, requiring corrective measures, which\nmay include physical inspection, testing, repair, or other actions, as appropriate. The basis for\nmaking the determination that a pipeline facility has a condition or conditions that pose a pipeline\nintegrity risk to public safety, property, or the environment is set forth both in the above-referenced\nstatute and 49 C.F.R. § 190.239, a copy of which is enclosed.\nAfter evaluating the foregoing preliminary findings of fact and considering the hazardous nature\nof the product, the proximity of the area in which the hazardous liquid pipeline facility is located\nto environmentally sensitive areas, the population density and population and growth patterns of\nthe area in which the pipeline facility is located (HCAs), the number of failures that have occurred\n(many with similar and/or related causes) within the past decade, the inadequate or limited failure\ninvestigations, the absence of preventative and mitigative measures or corrective actions taken to\nmitigate underlying issues and improve the failure trend, the temporary repairs (bolt-on sleeves)\nmade with no apparent investigations, the likelihood that these conditions are present or may\ndevelop in other segments of the pipeline, multiple equipment and material failures, multiple\nreleases caused by operator error, and identified integrity issues, the continued operation of the\nMid-Valley Pipeline without corrective measures poses a threat to public safety, property, and the\nenvironment.\nAccordingly, PHMSA issues this Notice to notify Energy Transfer of the proposed issuance of a\nsafety order and to propose that Energy Transfer take measures specified herein to address the\npotential risks identified in the Preliminary Findings and other risks that may be determined as a\nresult of the proposed corrective measures.\nProposed Corrective Measures:\nPursuant to 49 U.S.C. § 60117(m) and 49 C.F.R. § 190.239, PHMSA proposes to issue to Energy\nTransfer, LP, a safety order incorporating the following remedial requirements with respect to the\nMid-Valley Pipeline:\n1. Within 60 days of issuance of the Order, the Energy Transfer must complete a review\nof all accidents, unintentional releases, and other reportable failures on the Mid-\nValley Pipeline since 2014, determine root causes of each event, and make\nassessments about program deficiencies that cause or contribute to integrity risks. At\na minimum, the review must include all the accidents and other integrity issues\nidentified by this Order. A detailed written report of the program deficiencies that\nresulted in the releases and other integrity threatening conditions must be submitted to\nthe Director, Southwest Region (Director) within 60 days of issuance of the Order.\nEnergy Transfer must complete a full review of its written Mid-Valley Pipeline\nOperating and Maintenance Procedures, Integrity Management Program, and\nOperator Qualification Program to identify deficiencies or inadequacies that cause or\ncontribute to integrity risks and corresponding programmatic changes or actions to\n2.\n\n\n\naimed at eliminating integrity risks. Within 120 days of issuance of the Order,\nEnergy Transfer must submit a written report detailing the review and findings. This\nreview must include, but is not limited to, the following:\na. A review of all Operating and Maintenance Procedures and associated training\nrequirements to reduce accidents resulting from maintenance issues and\noperator errors. In addition, Energy Transfer must perform a complete review\nof Energy Transfer Qualification Program including procedures, covered\ntasks, training requirements, qualification and re-qualification requirements,\nspan of control, and Abnormal Operating Conditions. Energy Transfer must\ncomplete modifications to the Mid-Valley Operating and Maintenance\nProcedures and Operator Qualification Program and submit a redlined version\nof the revised procedures showing the changes to the Director for review and\napproval within 120 days of issuance of the Order.\nb. A review of the Integrity Management plan, threat identification, risk\ndetermination, and preventative and mitigative measures needed to reduce the\nfailures on the Mid-Valley Pipeline system. This review must include all\naccidents, specifically including but not limited to those related to depth of\ncover and pipeline exposures, third party damage, and corrosion. A redlined\nversion of the revised Integrity Management Plan must be submitted to the\nDirector for review and approval within 120 days of issuance of the Order.\nc. Inspection of all branch welds at pump stations and terminals using a\ncombination of visual examination and at least one other form of Non-\ndestructive Examination to determine if there are additional cracks that may\nresult in failures similar to the Cygnet Station failure that occurred on December\n23, 2022. The Inspection Plan must be submitted to the Director for review and\napproval within 90 days of issuance of the Order and prior to commencing the\ninspections. The results of the inspections including the specific locations\nwithin each pump station and terminal where the inspections were conducted\nmust be submitted to the Director within 180 days of approval of the Inspection\nPlan.\nd. Visual inspection of all above ground piping and fittings to identify defects such\nas cracks, corrosion, and mechanical damage that require repair or replacement.\nA written report detailing the specific locations of the inspections and\ninspection results must be submitted to the Director within 120 days of issuance\nof the Order.\ne. A review of the pump station control logic at each pump station to determine\nthat no unordered startups will occur, the valves are in the proper positions for\nthe stations to start, and station shutdowns will occur properly based on certain\nalarm conditions. The failures at Longview, Karnak, and Spears Stations must\nbe fully investigated to ensure that the units will properly shut down or not start\nwithout the valves in correct positions. The control logic at all stations must be\n\n\n\nf. reviewed and corrected, if necessary. A detailed written report on this review,\nthe findings, and the revisions to the control logic or circuits must be submitted\nto the Director within 120 days of issuance of the Order.\nA review of the internal corrosion program must be conducted. This includes\nbut is not limited to the following:\ni. Investigate and determine the specific causes of the internal corrosion\nfailures listed above.\nii. Revise the internal corrosion program to include appropriate periodic\ninspections of piping and facilities for internal corrosion.\niii. Define and implement preventative measures to detect corrosion and\ntake corresponding action.\niv. Implement a comprehensive monitoring program using coupons and\ntesting of the commodity for residuals of injected chemicals to ensure\n","truncated":true,"body_characters":88677}