# ENERGY TRANSFER COMPANY — Safety Order

- **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:** Not available
- **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.

Official case documents:

42023056NOPSO_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

42023056NOPSO_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

42023056NOPSO_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

42023056NOPSO_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

42023056NOPSO_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

42023056NOPSO_Notice of Proposed Safety Order_10132023_(23-281044)_text.pdf

VIA ELECTRONIC MAIL TO: tom.long@energytransfer.com
October 13, 2023
Mr. Thomas E. Long
Chief Executive Officer
Energy Transfer, LP
8111 Westchester Drive
Dallas, Texas 75225
CPF 4-2023-056-NOPSO
Dear Mr. Long:
Enclosed is a Notice of Proposed Safety Order (Notice) issued by the Pipeline and Hazardous
Materials Safety Administration (PHMSA) in the above-referenced case. The Notice proposes
that Energy Transfer, LP, take certain measures to ensure facility safety with respect to the Mid-
Valley Pipeline system that includes over 1,000 miles of crude oil pipeline originating in
Longview, Texas, and terminating in Samaria, Michigan. Your options for responding are set forth
in the Notice. Service of this Notice by electronic mail is deemed effective upon the date of
transmission, or as otherwise provided under 49 C.F.R. § 190.5.
We look forward to a successful resolution to improve the safety and integrity of the Mid-Valley
Pipeline system. Please direct any questions on this matter to me at (713) 773-7215.
Sincerely,
Bryan Lethcoe
Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Enclosures: Notice of Proposed Safety Order
cc: Mr. Alan K. Mayberry, Associate Administrator for Pipeline Safety, OPS, PHMSA
Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS,
PHMSA
Mr. Greg McIlwain, Executive Vice President of Operations, Energy Transfer, LP,
gregory.mcilwain@energytransfer.com



Mr. Eric Amundsen, Senior Vice President of Operations, Energy Transfer, LP,
eric.amundsen@energytransfer.com
Mr. Todd Stamm, Senior Vice President of Operations, Energy Transfer, LP,
todd.stamm@energytransfer.com
Ms. Jennifer Street, Senior Vice President of Operations Services, Energy Transfer, LP,
jennifer.street@energytransfer.com
Ms. Heidi Murchison, Chief Counsel, Energy Transfer, LP,
heidi.murchison@energytransfer.com
Mr. Leif Jensen, Vice President of Tech Services, Energy Transfer, LP,
leif.jensen@energytransfer.com
Mr. Todd Nardozzi, Director, Regulatory Compliance, Energy Transfer, LP,
todd.nardozzi@energytransfer.com
Ms. Susie Sjulin, Director, Regulatory Compliance, Energy Transfer, LP,
susie.sjulin@energytransfer.com



DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
SOUTHWEST REGION
HOUSTON, TX 77074
____________________________________
)
In the Matter of )
)
Mid-Valley Pipeline Company, LLC, ) CPF No. 4-2023-056-NOPSO
a subsidiary of Energy Transfer, LP, )
)
Respondent. )
____________________________________)
NOTICE OF PROPOSED SAFETY ORDER
Background and Purpose:
This Notice of Proposed Safety Order (NOPSO or Notice) is being issued by the Pipeline and
Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), under the
authority of 49 U.S.C. § 60117. Pursuant to § 60117, PHMSA initiated an investigation of the
safety of Energy Transfer’s Mid-Valley Pipeline following a series of recent failures, including
the following:
• On July 14, 2023, Energy Transfer experienced a pipeline failure at its terminal facility
near Oregon, Ohio, resulting in the initial reported release of approximately 6 barrels of
crude oil. This was later updated to 28 barrels of crude oil and 42 barrels of an oil/water
mixture. The release was spotted on the ground by facility personnel during a routine walk-
around during the day. PHMSA requested additional information related to the cause of
the failure, the repair plans prior to placing the facility back in service, and the inspections
performed at the facility to ensure that similar conditions that could lead to a failure did
not exist elsewhere in the facility. On July 16, 2023, Energy Transfer indicated the
apparent cause was internal corrosion, identified other at-risk locations within the facility
but did not provide any inspection results prior to placing the facility back in service.
Energy Transfer indicated that the failed segment would be cut out and replaced but did
not specify if the pipe would be sent for metallurgical evaluation to confirm the cause of
failure. Energy Transfer did not indicate it made any improvements to its internal corrosion
program or altered its periodic inspections of terminal piping.
• On July 11, 2023, Energy Transfer experienced a failure at its terminal facility near
Longview, Texas, which resulted in the release of crude oil and a fire. Energy Transfer
reported the release to be 2 gallons of crude oil into the secondary containment, which



subsequently caught fire and was extinguished by the fire suppression system in the
facility. The apparent cause was determined by Energy Transfer to be misalignment
between the pump unit and motor which resulted in excessive vibration and failure of the
pump seals. The pump unit failed to shut down due to the high vibration condition as it
was intended.
• On July 5, 2023, Energy Transfer experienced a failure near Cygnet, Ohio, resulting in the
initial reported release of approximately 1,000 barrels of crude oil. The release quantity
was later revised by the Energy Transfer to less than 5 barrels. Energy Transfer stated the
initial reported release amount was incorrect due to a miscommunication between the
control center and a regulatory compliance representative. Energy Transfer initially
determined the original imbalance alarm, set at 200 barrels, was caused by a measurement
error, and restarted the pipeline. Subsequently, their aerial patrol reported evidence of a
release on the Mid-Valley right-of-way before the pipeline was shut down and the oil spill
contractor dispatched to the site. The release was initially reported to have been caused by
a “linear” defect. Energy Transfer did not perform a cutout of the failed pipe segment so
that it could be sent for metallurgical evaluation. Energy Transfer stated in a meeting on
July 6, 2023, that performing a cutout would disrupt deliveries to a refinery in the upper
Midwest and likely result in shortages of gasoline. Energy Transfer installed a bolt-on
sleeve and returned the pipeline to service and stated the cutout would be performed at a
later, unspecified date. The property damage was approximately $411,205.
• On March 3, 2023, Energy Transfer experienced a failure at the Karnak Pump Station on
the Longview to Mayersville 20-inch pipeline segment, which resulted in the release of
approximately 0.3 barrels (12 gallons) of crude oil. The release was contained on property
controlled by Energy Transfer. The apparent cause was determined by Energy Transfer to
be failure of the pump seals. However, the automation detected the loss of pressure and
closed the suction and discharge valves on the pump station. The pump unit continued to
run causing an overpressure condition and had to be shut down manually by a technician
that tripped the station breaker. The property damage was approximately $12,530.
• On January 25, 2023, Energy Transfer experienced a failure at the Mayersville Pump
Station that resulted in the release of approximately 3 barrels of crude oil, which was
contained on the property controlled by Energy Transfer. The apparent cause of the failure
was determined by Energy Transfer to be internal corrosion. The property damage was
approximately $43,726.
• On December 23, 2022, Energy Transfer experienced a failure at the Cygnet Pump Station
that resulted in the release of approximately 1,974 barrels of crude oil, a portion which
migrated off property controlled by Energy Transfer. A highway adjacent to the pump
station was closed by local law enforcement due to the threat to public safety. The cause
of the failure was determined by metallurgical evaluation to be a hydrogen crack in a
branch weld that increased to a critical size so that it could no longer contain the pipeline
pressure. Energy Transfer stated that it performed visual inspections of other branch welds
at the Cygnet Pump Station. Energy Transfer did not conduct any non-destructive



examinations to determine if defects existed on similar welds. The property damage was
approximately $2,306,948.
In addition to the above, the following failures have occurred on the Mid-Valley Pipeline system
since 2014:
• On June 29, 2022, Energy Transfer experienced a failure on the Abbeville to Denver 22-
inch segment near Henderson, TN, which resulted in the release of approximately 4,345
barrels of crude oil. The release occurred when a mowing contractor struck an exposed
segment of pipeline resulting in a gouge and release of crude oil. Energy Transfer
indicated that the segment had 42-inches of cover; however, the same report stated that
the pipeline was exposed due to loss of cover. The release affected soil, vegetation,
wildlife, and water. Energy Transfer estimated that approximately 3,300 barrels of the
4,345 barrels of crude oil released affected Horse Creek. Energy Transfer applied a bolt-
on clamp and restarted the pipeline. Energy Transfer did not mention taking any additional
preventative and mitigation measures. The property damage was approximately
$4,651,397.
• On June 1, 2022, Energy Transfer experienced a failure on the Haynesville to Magnolia
8-inch pipeline segment that resulted in the release of approximately 8 barrels of crude oil.
The release occurred at a road crossing and was reported by a member of the public. The
apparent cause of the failure was determined by Energy Transfer to be third-party damage
from excavation work that occurred while a third party was performing maintenance work
on a ditch adjacent to the pipeline. The pipe damage included an inward dent
approximately 6-inches in length and 4-inches wide with a 1-inch puncture through the
pipeline wall. The property damage was approximately $42,565.
• On December 28, 2021, Energy Transfer experienced a failure at Lima Station (located in
a High Consequence Area) that resulted in the release of approximately 5 barrels of crude
oil. The apparent cause of the failure was determined by Energy Transfer to be internal
corrosion. A bolt-on sleeve was installed, and the pipeline was placed back in service.
The property damage was approximately $40,860.
• On November 19, 2021, Energy Transfer experienced a failure at Lima Station (located in
a High Consequence Area) that resulted in the release of approximately 1 barrel of crude
oil from a 30-inch breakout tank pipeline. The release was discovered on the ground by
operator personnel during a routine check of the station and was contained on property
controlled by Energy Transfer. The apparent cause of the failure was determined by
Energy Transfer to be failure of a bolt-on sleeve that had been installed as a previous repair
for an internal corrosion release. The property damage was approximately $23,380.



• On September 20, 2021, Energy Transfer experienced a failure at Lima Station (located in
a High Consequence Area) that resulted in the release of approximately 0.3 barrels of
crude oil. The release was discovered by local personnel during a routine check of the
station. The apparent cause was determined by Energy Transfer to be the release of crude
oil from a previously abandoned pipeline that had not been purged. The property damage
was approximately $47,050.
• On June 10, 2021, Energy Transfer experienced a failure at Lima Station (located in a
High Consequence Area) that resulted in the release of approximately 17 barrels of crude
oil. The release was discovered by a contractor while mowing at the station. The apparent
cause of the failure was determined by Energy Transfer to be internal corrosion of a
breakout tank pipeline. The property damage was approximately $79,229.
• On March 16, 2021, Energy Transfer experienced a failure at the Longview Station that
resulted in the release of approximately 0.8 barrels of crude oil from a breakout tank. The
apparent cause of the failure was determined by Energy Transfer to be operator error due
to overfilling the tank, resulting in a release of crude oil from the top of the tank after
exceeding the maximum liquid level height. The property damage was approximately
$5,376.
• On February 22, 2021, Energy Transfer experienced a failure at the Abbeville Pump
Station that resulted in the release of approximately 15 barrels of crude oil. The release
was discovered on the ground near a 12-inch relief pipeline by operator personnel. The
apparent cause of the failure was determined by Energy Transfer to be internal corrosion.
Energy Transfer bypassed the station and continued operation of the pipeline. The failed
pipe segment at the station was cut out and replaced. The property damage was
approximately $81,512.
• On December 28, 2020, Energy Transfer experienced a failure at the Samaria Station that
resulted in the release of approximately 3 barrels of crude oil. The release was discovered
on the ground by operator personnel performing a routine station check. The apparent
cause of the failure was determined by Energy Transfer to be internal corrosion of a 12-
inch pipeline flange weld. The weld was cut out and replaced. The property damage was
approximately $48,782.
• On May 29, 2019, Energy Transfer experienced a failure at Lima Station (located in a
High Consequence Area) that resulted in the release of approximately 0.2 barrels of crude
oil. Energy Transfer stated the apparent cause of the release was residual product on the
inside of the tank shell mixed with water on the floating roof that was released when the
external floating roof drains were opened. The property damage was approximately
$7,052.



• On March 22, 2019, Energy Transfer experienced a failure at Hebron Station, KY, (located
in a High Consequence Area) which resulted in the release of 0.24 barrels of crude oil.
The apparent cause of the failure was determined by Energy Transfer to be operator error
when a valve was left partially open during a pigging operation. The property damage
was approximately $1,030.
• On March 18, 2019, Energy Transfer experienced a failure at Longview Station (located
in a High Consequence Area) that resulted in the release of approximately 10 barrels of
crude oil. The apparent cause of the failure was determined by Energy Transfer to be a
pinhole leak in a breakout tank pipeline cause by internal corrosion. The failed pipe
segment at the station was cut out and replaced. The property damage was approximately
$15,719.
• On February 1, 2017, Energy Transfer experienced a failure at Mayersville Pump Station
that resulted in the release of approximately 0.24 barrels of crude oil. The apparent cause
of the failure was determined by Energy Transfer to be a faulty liquid level switch that led
to crude oil backing up into the scraper trap containment basin. The property damage was
approximately $1,000.
• On January 11, 2017, Energy Transfer experienced a failure at Lima Pump Station (located
in a High Consequence Area) that resulted in the release of approximately 2 barrels of
crude oil. The release was discovered on the ground near a pump unit by operator
personnel. The apparent cause of the failure was determined by Energy Transfer to be
failure of a bolt on the pump shaft. The bolt had been replaced during previous
maintenance with one that did not meet the manufacturer’s specifications. The property
damage was approximately $45,000.
• On December 19, 2016, Energy Transfer experienced a failure at Spearsville Pump Station
that resulted in the release of approximately 0.12 barrels of crude oil. The apparent cause
of the failure was determined by Energy Transfer to be the unexpected start of a pump unit
with the intake and discharge valves closed. The pump unit overheated the seals leading
to a release of commodity. Energy Transfer noted that the fire suppression system
activated, meaning the released commodity had ignited. The property damage was
approximately $328,857.
• On August 9, 2016, Energy Transfer experienced a failure at Lima Pump Station (located
in a High Consequence Area) that resulted in the release of approximately 2 barrels of
crude oil. The apparent cause of the failure was determined by Energy Transfer to be
internal corrosion on a 16-inch breakout tank pipeline. Energy Transfer installed a bolt-
on sleeve and returned the pipeline to service. The property damage was approximately
$29,040.



• On June 1, 2016, Energy Transfer experienced a failure at Cygnet Pump Station (located
in a High Consequence Area) that resulted in the release of approximately 2 barrels of
crude oil. The apparent cause of the failure was determined by Energy Transfer to be
operator error. The liquid level in Tank 83 was lowered so that the floating roof contacted
the tank mixer impeller and caused the mixer seal to fail resulting in the release. The tank
mixer was removed, and a blind manway cover installed. The property damage was
approximately $4,200.
• On February 3, 2016, Energy Transfer experienced a failure at Lima Station (located in a
High Consequence Area) that resulted in the release of approximately 1.2 barrels (50
gallons) of crude oil. The apparent cause of the failure was determined by Energy Transfer
to be a leak in the valve stem packing on a partially buried 16-inch valve that isolated
dead-leg piping. The property damage was approximately $15,000.
• On January 8, 2016, Energy Transfer experienced a failure at Hebron Station (located in a
High Consequence Area) that resulted in the release of approximately 10 barrels of crude
oil. The apparent cause of the failure was determined by Energy Transfer to be internal
corrosion in the sump pump piping. The property damage was approximately $43,800.
• On January 9, 2015, Energy Transfer experienced a failure at Lima Station (located in a
High Consequence Area) that resulted in the release of approximately 100 barrels of crude
oil. The apparent cause of the failure was determined by Energy Transfer to be a cracked
fitting on the pump discharge valve. The property damage was approximately $45,946.
• On October 13, 2014, Energy Transfer experienced a pipeline failure near Mooringsport,
LA, which resulted in the release of approximately 4,509 barrels of crude oil in a High
Consequence Area that affected soil, vegetation, and surface water. The apparent cause
of the failure was determined by Energy Transfer to be stress corrosion cracking. The
property damage was approximately $11,702,787.
• On April 18, 2014, Energy Transfer experienced a failure at Longview Station (located in
a High Consequence Area) that resulted in the release of approximately 3 barrels of crude
oil. The apparent cause of the failure was determined by Energy Transfer to be a failed
pump seal. The property damage was approximately $4,501.
• On April 4, 2014, Energy Transfer experienced a failure at Longview Station (located in
a High Consequence Area) that resulted in the release of approximately 1 barrel of crude
oil. The apparent cause of the failure was determined by Energy Transfer to be a failed
tank mixer seal. The property damage was approximately $20,798.
• On March 22, 2014, Energy Transfer experienced a failure of the Mid-Valley Pipeline at
Denver Station (located in a High Consequence Area) that resulted in the release of
approximately 2 barrels of crude oil. The release was reported by the local fire department.
The apparent cause was not identified by Energy Transfer, but the release was from a
breakout tank pipeline. Energy Transfer drained the pipeline and installed a bolt-on clamp.
The property damage was approximately $25,000. An NRC report was filed.



• On March 17, 2014, Energy Transfer experienced a failure of the Mid-Valley Pipeline
Hebron to Lima 20-inch segment near Colerain Township that resulted in the release of
approximately 450 barrels of crude oil. The release was reported by local emergency
responders. Metallurgical evaluation determined the cause to be near neutral stress
corrosion cracking on the body of the pipe. The release was in a High Consequence Area
and affected soil, vegetation, wildlife, and water. The property damage was estimated to
be approximately $7,174,939.
• On February 24, 2014, Energy Transfer experienced a failure of the Mid-Valley Pipeline
at Clarksville Station that resulted in the release of approximately 1 barrel of crude oil. The
release was discovered by local operating personnel. The apparent cause was not identified
by Energy Transfer, but the release was from a breakout tank pipeline. Energy Transfer
installed a bolt-on clamp and returned the pipeline to service. The property damage was
approximately $48,200.
• On February 20, 2014, Energy Transfer experienced a failure of the Mid-Valley Pipeline
at Samaria Station that resulted in the release of approximately 1 barrel of crude oil. Energy
Transfer reported that ice in the pig trap drain line prevented commodity from draining into
the sump and subsequent heavy rain caused crude oil to float out of the containment basin.
The property damage was approximately $1,720.
• On February 17, 2014, Energy Transfer experienced a failure of the Mid-Valley Pipeline
at Lima Station (located in a High Consequence Area) that resulted in the release of less
than 1 barrel of crude oil. The release was discovered by local operating personnel. The
apparent cause of the failure was determined to Energy Transfer to be a crack in a fitting
on the small diameter piping around the pump discharge valve. Energy Transfer replaced
the cracked fitting but provided no additional information as to the cause. The property
damage was approximately $5,136.
Additionally, there have been recent public complaints expressing concerns about the safety
of the Mid-Valley Pipeline. PHMSA’s investigation of these complaints have determined the
following:
• An encroachment involving a temporary building was found on the Mid-Valley Pipeline
right-of-way in Cecelia, KY. Energy Transfer stated that an agreement had been made
with the landowner to allow the building to remain on the pipeline right-of-way. PHMSA
asked to review this agreement to verify that there were restrictions on what could be stored
in the building and that Energy Transfer could move or demolish the building should it be
required for maintenance or emergency response. Energy Transfer declined to provide the
agreement.



• An exposed pipe in a stream crossing was found near Collinsville, OH, with large stumps
and tree limbs present in the channel. PHMSA issued an Advisory Bulletin on April 9,
2015, (ADB-2015-01, 80 Fed. Reg. 19114), which provided notification to pipeline
operators about the need for operators to take actions to ensure the integrity of pipelines in
the event of flooding, river scour, and river channel migration that may result in additional
stresses imposed on the pipe by undermining the underlying support soils, exposing the
pipeline to lateral water forces, and impact from waterborne debris. This pipeline appears
to be at risk for these threats. The pipeline coating also appears to be in poor condition
resulting in diminished protection from atmospheric corrosion. No apparent actions have
been taken by Energy Transfer to mitigate the threats presented by the exposed pipe.
• The condition of the right-of-way (ROW) near the Collinsville, OH, stream crossing
exposure obscured the ROW in a manner that would limit the effectiveness of patrolling
and potentially obscure a release. There was a notable absence of pipeline markers to
identify the location of the pipeline. The pipeline also crosses under railroad tracks in the
same area with no casing vents present that could be used to detect leaks in the carrier pipe.
In response to PHMSA questions about this crossing, Energy Transfer confirmed that the
casing is shorted which does not meet the requirements of 49 C.F.R. § 195.575 for electrical
isolation.
As a result of numerous failures, existing integrity concerns, and PHMSA’s preliminary
investigation, it appears that conditions exist on the Mid-Valley Pipeline that pose a pipeline
integrity risk to public safety, property, or the environment. Pursuant to 49 U.S.C. § 60117(m),
PHMSA issues this Notice of Proposed Safety Order, notifying you of the preliminary findings of
the investigation, and proposing that you take measures to ensure that the public, property, and the
environment are protected from the potential risks.
Preliminary Findings:
The preliminary findings of PHMSA’s ongoing investigation are as follows:
• The Mid-Valley Pipeline consists of approximately 1,048 miles of primarily 20- and 22-
inch mainline pipeline that originates near Longview, TX, and terminates near Samaria,
MI. The pipeline system includes 14 pump stations and 41 breakout tanks. It was
constructed in the 1950s and is designed to deliver approximately 240,000 barrels of crude
oil per day to refineries in the upper Midwest.
• The pipeline traverses near or through several high population areas, other populated
areas, unusually sensitive areas, lakes, and crosses several rivers and streams, highways,
roads, and railroads. Many of the pump stations and terminals are located in High
Consequence Areas.
• The Mid-Valley Pipeline has experienced at least 34 failures since 2014 from various
causes, including internal corrosion, pump failures, third-party damage, faulty equipment,
hydrogen cracking, stress corrosion cracking, pipeline exposures, failed repairs, operator
errors, and unidentified causes. Some of these failures do not appear to have had a



complete investigation as to the causes and contributing factors and it is unclear to
PHMSA the actions taken by the Energy Transfer to determine if similar integrity threats
may exist elsewhere on the Mid-Valley Pipeline system.
• After the July 5, 2023, failure, PHMSA requested Energy Transfer remove the failed
section of pipe and send it to a metallurgical laboratory for evaluation and determination
of the cause of the failure. Instead, Energy Transfer installed a temporary bolt-on sleeve
and stated that the cutout and permanent repair would be scheduled at a later date.
Consequently, there was no investigation of the cause of the failure and no determination
by Energy Transfer of the causes and contributing factors.
• The apparent cause of several failures was determined by Energy Transfer to be internal
corrosion. Energy Transfer stated it has an internal corrosion monitoring program and, in
some cases, injects chemicals to inhibit internal corrosion. However, multiple failures
related to internal corrosion have sometimes occurred at the same locations. PHMSA was
unable to determine if the failures were thoroughly investigated, the specific causes
determined, and preventative and mitigative measures implemented.
• For several failures (August 9, 2016; December 28, 2021; June 29, 2022; July 5, 2023),
Energy Transfer installed temporary bolt-on sleeves. Energy Transfer did not immediately
cut out the failed sections and conduct metallurgical analyses on each of the failures to
determine or confirm the cause of the failure.
• After the July 14, 2023, failure at the Mid-Valley terminal near Oregon, OH, PHMSA
requested that Energy Transfer perform additional inspections to determine if similar
integrity threats existed elsewhere in the terminal. Based on the Energy Transfer’s
response, PHMSA was unable to determine if Energy Transfer conducted inspections to
determine if additional similar integrity threats existed at the terminal or took measures to
prevent additional failures.
• Lima Station, a pump station located in a High Consequence Area, experienced at least
eight (8) failures since 2014. Three of the failures were apparently caused by internal
corrosion, while other failures were caused by equipment failure, failure to purge an
abandoned pipeline, and a failed temporary repair.
• Energy Transfer has an exposed pipe in a stream crossing near Collinsville, OH, with large
stumps and tree limbs present in the channel. There appears to be a threat to the exposed
pipeline segment due to debris carried by the stream, particularly during high water. The
need to evaluate these types of threats was the subject of a PHMSA Advisory Bulletin
(ADB-2015-01, 80 Fed. Reg. 19114) reminding pipeline operators about the need to
evaluate these threats and take the appropriate preventative and mitigative measures as
required by the underlying regulations. PHMSA also observed damage to the coating on
the exposed pipeline segment that could result in additional issues related to atmospheric
corrosion.



• There were multiple instances of malfunction of control equipment such as an un-
commanded pump station start, a pump starts with the suction and discharge valves closed,
and a pump that would not shut down on command. In one instance, it was necessary for
the technician to use the main station breaker to finally shut the pump unit down. These
issues led to releases due to secondary effects such as pump seal failure. On at least one
occasion, the released commodity ignited and activated the pump station fire suppression
system. There were apparent flaws in the control equipment that were not fully
investigated and corrected.
• There were instances of equipment failure that resulted in releases, such as a faulty liquid
level switch that resulted in a sump overflow, an incorrect bolt being used on a pump shaft
repair which subsequently failed, a valve packing leak, a cracked fitting, misalignment of
a pump unit that resulted in vibration and failure of the seals, and a failed pump mixer seal.
• There have been releases caused by operator error such as overfilling a breakout tank,
allowing water to accumulate on the roof of a breakout tank allowing commodity to mix
with the water which was released when the roof drains were opened, and lowering the
liquid level in a tank to the point where the roof contacted the tank mixer and caused the
seals to fail.
• There have been releases due to time dependent threats such as external corrosion, internal
corrosion, stress corrosion cracking, and hydrogen cracking. It is unclear what preventative
and mitigative measures the Energy Transfer has taken to prevent additional similar
failures.
• Numerous failures have been discovered by members of the public and or contractors.
Other failures were discovered by Energy Transfer personnel during routine movements
around its facilities, and not through Energy Transfer’s instrumentation and control system.
These trends indicate Energy Transfer’s inability to self-monitor and detect failures.
• The Mid-Valley Pipeline accident history indicates there are unmitigated threats associated
with internal corrosion, time dependent threats, third party damage, equipment failure, and
operator error.
• During the investigation of the July 5, 2023, failure near Cygnet, OH, PHMSA noted an
interrupted cathodic protection pipe-to-soil measurement that was higher than the
energized measurement. This may be an indication of cathodic protection interference.
Energy Transfer shares the right-of-way with Buckeye Pipeline but stated no CIS or
interference studies had been performed on this pipeline segment to determine if the
requirement of electrical isolation required by § 195.575 has been met. In addition, Energy
Transfer has stated that the cased crossing under the railroad tracks near the Collinsville,
OH stream crossing was shorted, another instance where the requirements for electrical
isolation have not been met.



Proposed Issuance of Safety Order:
Section 60117(m) of Title 49, United States Code, provides for the issuance of a Safety Order,
after reasonable notice and the opportunity for a hearing, requiring corrective measures, which
may include physical inspection, testing, repair, or other actions, as appropriate. The basis for
making the determination that a pipeline facility has a condition or conditions that pose a pipeline
integrity risk to public safety, property, or the environment is set forth both in the above-referenced
statute and 49 C.F.R. § 190.239, a copy of which is enclosed.
After evaluating the foregoing preliminary findings of fact and considering the hazardous nature
of the product, the proximity of the area in which the hazardous liquid pipeline facility is located
to environmentally sensitive areas, the population density and population and growth patterns of
the area in which the pipeline facility is located (HCAs), the number of failures that have occurred
(many with similar and/or related causes) within the past decade, the inadequate or limited failure
investigations, the absence of preventative and mitigative measures or corrective actions taken to
mitigate underlying issues and improve the failure trend, the temporary repairs (bolt-on sleeves)
made with no apparent investigations, the likelihood that these conditions are present or may
develop in other segments of the pipeline, multiple equipment and material failures, multiple
releases caused by operator error, and identified integrity issues, the continued operation of the
Mid-Valley Pipeline without corrective measures poses a threat to public safety, property, and the
environment.
Accordingly, PHMSA issues this Notice to notify Energy Transfer of the proposed issuance of a
safety order and to propose that Energy Transfer take measures specified herein to address the
potential risks identified in the Preliminary Findings and other risks that may be determined as a
result of the proposed corrective measures.
Proposed Corrective Measures:
Pursuant to 49 U.S.C. § 60117(m) and 49 C.F.R. § 190.239, PHMSA proposes to issue to Energy
Transfer, LP, a safety order incorporating the following remedial requirements with respect to the
Mid-Valley Pipeline:
1. Within 60 days of issuance of the Order, the Energy Transfer must complete a review
of all accidents, unintentional releases, and other reportable failures on the Mid-
Valley Pipeline since 2014, determine root causes of each event, and make
assessments about program deficiencies that cause or contribute to integrity risks. At
a minimum, the review must include all the accidents and other integrity issues
identified by this Order. A detailed written report of the program deficiencies that
resulted in the releases and other integrity threatening conditions must be submitted to
the Director, Southwest Region (Director) within 60 days of issuance of the Order.
Energy Transfer must complete a full review of its written Mid-Valley Pipeline
Operating and Maintenance Procedures, Integrity Management Program, and
Operator Qualification Program to identify deficiencies or inadequacies that cause or
contribute to integrity risks and corresponding programmatic changes or actions to
2.



aimed at eliminating integrity risks. Within 120 days of issuance of the Order,
Energy Transfer must submit a written report detailing the review and findings. This
review must include, but is not limited to, the following:
a. A review of all Operating and Maintenance Procedures and associated training
requirements to reduce accidents resulting from maintenance issues and
operator errors. In addition, Energy Transfer must perform a complete review
of Energy Transfer Qualification Program including procedures, covered
tasks, training requirements, qualification and re-qualification requirements,
span of control, and Abnormal Operating Conditions. Energy Transfer must
complete modifications to the Mid-Valley Operating and Maintenance
Procedures and Operator Qualification Program and submit a redlined version
of the revised procedures showing the changes to the Director for review and
approval within 120 days of issuance of the Order.
b. A review of the Integrity Management plan, threat identification, risk
determination, and preventative and mitigative measures needed to reduce the
failures on the Mid-Valley Pipeline system. This review must include all
accidents, specifically including but not limited to those related to depth of
cover and pipeline exposures, third party damage, and corrosion. A redlined
version of the revised Integrity Management Plan must be submitted to the
Director for review and approval within 120 days of issuance of the Order.
c. Inspection of all branch welds at pump stations and terminals using a
combination of visual examination and at least one other form of Non-
destructive Examination to determine if there are additional cracks that may
result in failures similar to the Cygnet Station failure that occurred on December
23, 2022. The Inspection Plan must be submitted to the Director for review and
approval within 90 days of issuance of the Order and prior to commencing the
inspections. The results of the inspections including the specific locations
within each pump station and terminal where the inspections were conducted
must be submitted to the Director within 180 days of approval of the Inspection
Plan.
d. Visual inspection of all above ground piping and fittings to identify defects such
as cracks, corrosion, and mechanical damage that require repair or replacement.
A written report detailing the specific locations of the inspections and
inspection results must be submitted to the Director within 120 days of issuance
of the Order.
e. A review of the pump station control logic at each pump station to determine
that no unordered startups will occur, the valves are in the proper positions for
the stations to start, and station shutdowns will occur properly based on certain
alarm conditions. The failures at Longview, Karnak, and Spears Stations must
be fully investigated to ensure that the units will properly shut down or not start
without the valves in correct positions. The control logic at all stations must be



f. reviewed and corrected, if necessary. A detailed written report on this review,
the findings, and the revisions to the control logic or circuits must be submitted
to the Director within 120 days of issuance of the Order.
A review of the internal corrosion program must be conducted. This includes
but is not limited to the following:
i. Investigate and determine the specific causes of the internal corrosion
failures listed above.
ii. Revise the internal corrosion program to include appropriate periodic
inspections of piping and facilities for internal corrosion.
iii. Define and implement preventative measures to detect corrosion and
take corresponding action.
iv. Implement a comprehensive monitoring program using coupons and
testing of the commodity for residuals of injected chemicals to ensure

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