# ENTERPRISE PRODUCTS OPERATING LLC — Corrective Action Order

- **operation:** document
- **citation:** CPF 42025058CAO
- **title:** ENTERPRISE PRODUCTS OPERATING LLC — Corrective Action Order
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** current
- **official:** true
- **published on:** 2025-12-04
- **effective on:** Not available
- **summary:** OPEN corrective action order.
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/42025058CAO
**body:**

Corrective Action Order involving ENTERPRISE PRODUCTS OPERATING LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2025-12-04 and is reported as open. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

42025058CAO_Corrective Action Order (Amended)_01062026_(25-358672).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025058CAO/42025058CAO_Corrective%20Action%20Order%20(Amended)_01062026_(25-358672).pdf

42025058CAO_Corrective Action Order (Amended)_01062026_(25-358672)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025058CAO/42025058CAO_Corrective%20Action%20Order%20(Amended)_01062026_(25-358672)_text.pdf

42025058CAO_Corrective Action Order_12042025_(25-358672).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025058CAO/42025058CAO_Corrective%20Action%20Order_12042025_(25-358672).pdf

42025058CAO_Corrective Action Order_12042025_(25-358672)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025058CAO/42025058CAO_Corrective%20Action%20Order_12042025_(25-358672)_text.pdf

42025058CAO_Corrective Action Order_12042025_(25-358672)_text.pdf

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Avenue, SE
Washington, DC 20590
December 4, 2025
VIA ELECTRONIC MAIL TO: gbacon@eprod.com
Graham Bacon
Executive Vice President, Chief Operating Officer
Enterprise Products Operating, LLC
1100 Louisiana Street
Houston, TX 77002
Re: CPF No. 4-2025-058-CAO
Dear Mr. Bacon,
Enclosed please find a Corrective Action Order (Order) issued by the Pipeline and Hazardous
Materials Safety Administration, Office of Pipeline Safety. It requires Enterprise Products
Operating, LLC, to take certain corrective actions with respect to a pipeline failure which
occurred on November 27, 2025, on the Enterprise East Leg Mainline pipeline in Jefferson
County, Kansas.
Service by electronic mail is effective upon the date of transmission and acknowledgment of
receipt as provided under 49 CFR § 190.5. The terms and conditions of this Order are effective
upon completion of service.
Sincerely,
Linda Daugherty
Acting Associate Administrator
for Pipeline Safety
Enclosure: Corrective Action Order
cc: Mr. Bryan Lethcoe, Director, Southwest Region, Office of Pipeline Safety, PHMSA
Suzie Davis, Senior Manager, Compliance, Enterprise Products Operating, LLC,
smdavis@eprod.com
CONFIRMATION OF RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
)
In the Matter of )
)
Enterprise Products Operating, LLC ) CPF No. 4-2025-058-CAO
)
Respondent. )
)
____________________________________)
CORRECTIVE ACTION ORDER
Purpose and Background
The Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
(OPS), is issuing this Corrective Action Order (CAO or Order) pursuant to the authority provided
in 49 U.S.C. § 60112, to require Enterprise Products Operating, LLC (Enterprise or Respondent),
to take necessary corrective actions to protect the public, property, and the environment from
potential hazards associated with the pipeline failure that occurred on the East Leg Mainline
pipeline (East Leg Pipeline or Pipeline)1 in McLouth, Jeferson County, Kansas (Failure) on
November 27, 2025. The East Leg Pipeline is a hazardous liquid pipeline facility that is subject
to PHMSA’s jurisdiction pursuant to the Pipeline Safety Act, 49 U.S.C. § 60101 et seq., and
Pipeline Safety Regulations, 49 CFR Parts 190 to 199.
The Enterprise MAPCO pipeline system is composed of two parallel pipelines (8” East Leg
Mainline and the 10” East Leg Loop) that transports liquified petroleum gas (LPG) in a northeast
direction from Conway, Kansas to Janesville, Wisconsin. The East Leg Pipeline includes 9 pump
stations and one water navigable crossing. The Failure occurred at Aerial Marker (AM) 158.4 in
an agricultural field within 0.5 mile of State Highway 16.
On November 27, 2025, Enterprise detected the Failure when it observed a pressure drop on the
East Leg Pipeline and received a public report of a vapor cloud near State Highway 16 in Jefferson
County, Kansas.
After detecting the Failure, Enterprise isolated a segment of the East Leg Pipeline, closing valves
at McLouth Station (AM 156.1) and AM 168. Enterprise used flares to reduce the pressure on the
1 Enterprise Products Operating, LLC's East Leg Mainline pipeline is part of the MAPCO pipeline system present in
13 states. The MAPCO pipeline system is a Liquified Petroleum Gas (LPG) pipeline system consisting of four primary
segments, totaling approximately 8,074 miles in length. The 2,113-mile Conway North pipelines (East Red and Blue
lines) link the NGL hub at Conway, Kansas, to refineries, petrochemical plans and propane markets in the upper-
Midwest.



pipeline segment. Enterprise located the Failure at AM 158.4, cut out the failed section, and
transported that section to Magnolia, Texas for inspection and metallurgical analysis by a third
party, Acuren. The pipe at the location of the failure is pre-1970 low-frequency electric resistance
welded (LF-ERW). The failure was along the longitudinal seam.
Enterprise notified the National Response Center (NRC) of the release on the East Leg Pipeline at
21:59 Eastern Time on November 27, 2025. A second report to the NRC was made on November
29, 2025, at 11:45 Eastern Time. Enterprise provided an estimated release amount of 3900 barrels
of propane.
The segment of the East Leg Pipeline remains shut-in and not in operation.
Pursuant to 49 U.S.C. § 60117, PHMSA has initiated an investigation of the Failure. The
preliminary findings of the Agency’s ongoing investigation are as follows:
Preliminary Findings
• The 8” East Leg Pipeline is an 8-inch diameter pipeline that transports liquified petroleum gas
(LPG) from Conway, Kansas to Janesville, Wisconsin. The East Leg Pipeline includes 9 pump
stations and one navigable water crossing.
• The East Leg Pipeline was originally constructed in 1960. The pipe at the failure location is
0.219 inches thick, API 5L grade X-52, with low frequency electric resistance welding (LF-
ERW) seams, and was manufactured by Bethlehem Steel. The Pipeline has coal tar enamel
(CTE) coating and cathodic protection. The maximum operating pressure (MOP) of the
Pipeline is 1650 psig. When the Failure occurred, the operating pressure was 1562 psig.
• On the evening of November 27, 2025, Enterprise observed a pressure drop on the East Leg
Pipeline and received a public report of a vapor cloud near State Highway 16. After detecting
the Failure, Enterprise shut in a segment of the East Leg Pipeline, closing valves at McLouth
Station (AM 156.1) and AM 168. Enterprise used flares to reduce the pressure on the pipeline
segment.
• Enterprise notified the National Response Center (NRC) of the Failure at 21:59 Eastern Time
on November 27, 2025.
• Enterprise provided a supplemental NRC notification at 11:45 Eastern Time on November 29,
2025. In its second NRC report, Enterprise estimated a release of 3900 barrels of propane.
• The Failure occurred around AM 158.4, about 1.3 miles southeast of McLouth, Kansas, in an
agricultural field within 0.5 mile of State Highway 16. The 2020 United States census counted
859 people, 346 households, and 232 families in McLouth.
• At the point of failure, the pipe was observed to have a 12-foot-long fish-mouth rupture along
the longitudinal seam.



• Enterprise cut out the failed section of the East Leg Pipeline and transported the pipe to Acuren
in Magnolia, Texas, for inspection and metallurgical analysis.
• The release of LPG poses a risk to public safety, property, and the environment. The Failure
caused the creation of a vapor cloud over State Highway 16 which passers-by drove through,
risking ignition of the vapor and severe harm to people in the vicinity. Emergency responders
established an evacuation zone of one-half mile requiring the evacuation of 15-20 residences
and the closure of State Highway 16.
• Previously, on November 29, 2016, a failure occurred on Enterprise’s 10-inch East Leg Loop
pipeline, which runs parallel to the East Leg Mainline pipeline, resulting in the release of
approximately 5,000 barrels of ethane-propane mixture in Platte County, Missouri. The
released product ignited and caused a fire. The cause of the failure was determined to be
external near-neutral stress corrosion cracking along and adjacent to the ERW seam.
• The failed East Leg Pipeline segment is currently shut-in and not operating.
• The investigation of the Failure is on-going, and information could change. These preliminary
findings may be amended based on further findings during the investigation.
Determination of Necessity for Corrective Action Order and Right to Hearing
Section 60112 of title 49, United States Code, authorizes PHMSA to determine that a pipeline
facility is or would be hazardous to life, property, or the environment and if there is a likelihood
of serious harm, to expeditiously order the operator of the facility to take necessary corrective
action, including suspended or restricted use of the facility, physical inspection, testing, repair,
replacement, or other appropriate action. An order issued expeditiously must provide an
opportunity for a hearing as soon as practicable after the order is issued.
In deciding whether to issue an order, PHMSA must consider the following, if relevant: (1) the
characteristics of the pipe and other equipment used in the pipeline facility, including the age,
manufacture, physical properties, and method of manufacturing, constructing, or assembling the
equipment; (2) the nature of the material the pipeline facility transports, the corrosive and
deteriorative qualities of the material, the sequence in which the material is transported, and the
pressure required for transporting the material; (3) the aspects of the area in which the pipeline
facility is located, including climatic and geologic conditions and soil characteristics; (4) the
proximity of the area in which the hazardous liquid pipeline facility is located to environmentally
sensitive areas; (5) the population density and population and growth patterns of the area in which
the pipeline facility is located; (6) any recommendation of the National Transportation Safety
Board made under another law; and (7) any other factors PHMSA may consider as appropriate.
After evaluating the foregoing preliminary findings of fact, and having considered age of the pipe,
the circumstances surrounding the Failure, the hazardous nature of the product being transported,
the pressure required for transporting the material, the method of manufacture, the uncertainties as
to the cause of the Failure, the prior failure on the pipeline system, the ongoing investigations to
determine the cause of the Failure, and the possibility that the same condition(s) that may have



caused the failure remain present in the pipeline and could lead to additional failures, it appears
that the continued operation of the pipeline without corrective measures would pose a pipeline
integrity risk to public safety, property, or the environment. Accordingly, corrective measures are
necessary to mitigate the pipeline integrity risk of the pipeline system to protect public safety,
property, and the environment.
Accordingly, this Order mandating immediate corrective action is issued expeditiously without
prior notice and opportunity for a hearing. The terms and conditions of this Order are effective
upon receipt.
Within 10 days of receipt of this Order, Respondent may request a hearing, to be held as soon as
practicable, by notifying the Associate Administrator for Pipeline Safety in writing, with a copy
to the Director, PHMSA, OPS Southwest Region. If a hearing is requested, it will be held in
accordance with 49 CFR § 190.211.
After receiving and analyzing additional data in the course of this investigation, PHMSA may
identify other corrective measures that need to be taken. Respondent will be notified of any
additional measures required and, if appropriate, PHMSA will consider amending this Order. To
the extent consistent with safety, Respondent will be afforded notice and an opportunity for a
hearing prior to the imposition of any additional corrective measures.
Required Corrective Actions
Definitions:
Affected Segment – “Affected Segment” means the segment of Respondent's 8-inch East Leg
Mainline pipeline running from Conway, Kansas to Bosworth, Missouri.
Isolated Segment – “Isolated Segment” means the segment of Respondent's 8-inch East Leg
Mainline Pipeline running from McLouth Station (AM 156.1) to AM 168.
Failure Site – “Failure Site” means the pipeline section on the Affected Segment where the failure
occurred on November 27, 2025, at AM 158.4.
Director – “Director” means the Director, PHMSA, Office of Pipeline Safety, Southwest Region.
The Director’s address is 8701 South Gessner Road, Suite 630, Houston, TX 77074.
Pursuant to 49 U.S.C. 60112, Enterprise is ordered to immediately take the following corrective
actions:
1. Shutdown of the Isolated Segment. The 8" Enterprise East Leg Pipeline from the valve
at McLouth Station (AM 156.1) to AM 168 is currently out of service. This Isolated
Segment must remain shut down until the Director has provided written approval to
Enterprise to resume operations. The Affected Segment is subject to the pressure
restriction set forth in Item 2 below.
2. Operating Pressure Restriction. Enterprise must reduce and maintain a twenty percent



(20%) pressure reduction in the operating pressure on the Affected Segment, such that
the operating pressure does not exceed eighty percent (80%) of the actual operating
pressure in effect immediately prior to the Failure on November 27, 2025.
a. This pressure restriction is to remain in effect until written approval to increase
the pressure or return the pipeline to its pre-Failure operating pressure is
obtained from the Director.
b. Prior to resuming operation, Enterprise must provide the Director the actual
operating pressures of each pump station and each main line pressure regulating
station on the Affected Segment at the time of the Failure and the reduced pressure
restriction set-points at these same locations. Since portions of the Affected
Segment are capable of bi-directional operation, the reduced pressure pump
station set-points should be specified for both directions of flow where
applicable.
c. This pressure restriction requires any relevant remote or local alarm limits,
software programming set-points or control points, and mechanical over-pressure
devices to be adjusted accordingly.
d. When determining the pressure restriction set-points, Enterprise must take into
account any in-line inspection (ILI) features or anomalies present in the Affected
Segment to provide for continued safe operation while further corrective actions
are completed. A description of how any ILI features or anomalies were
accounted for in the determination of pressure restriction set-points shall be
provided with the information .
e. Enterprise must review the pressure restriction monthly by analyzing the
operating pressure data, taking into account any ILI features or anomalies present
in the Affected Segment. Enterprise must immediately reduce the operating
pressure to maintain the safe operations of the Affected Segment, if warranted by
the monthly review. Enterprise must submit the results of the monthly review to
the Director including, at a minimum, the current discharge set-points (including
any additional pressure reductions), and any pressure exceedance at discharge set-
points.
3. Restart Plan. Prior to resuming operation of the Isolated Segment, Enterprise must
develop and submit a written Restart Plan to the Director for prior approval.
a. The Director may approve the Restart Plan incrementally without approving the
entire plan, but the Isolated Segment cannot resume operation until the Restart Plan
is approved in its entirety.
b. Once approved by the Director, the Restart Plan will be incorporated by reference
into this Order.
c. The Restart Plan must provide for adequate patrolling of the Isolated Segment
during the restart process and must include incremental pressure increases during
start up, with each increment to be held for at least two (2) hours.
d. The Restart Plan must include sufficient surveillance of the pipeline during each
pressure increment to ensure that no leaks are present when operation of the line
resumes.
e. The Restart Plan must specify a daylight restart and include advance
communications with local emergency response officials.
f. The Restart Plan must also include documentation of the completion of all



mandated actions, and a management of change plan to ensure that all procedural
modifications are incorporated into Enterprise’s O&M procedures manual.
4. Return to Service. After the Director approves the Restart Plan, Enterprise may return
the Isolated Segment to service, but the operating pressure must not exceed eighty percent
(80%) of the actual operating pressure in effect immediately prior to the Failure on
November 27, 2025 in accordance with Item 2 above.
5. Removal of Pressure Restriction. The Director may allow the removal or modification
of the pressure restriction upon a written request from Enterprise demonstrating that
restoring the pipeline to its pre-Failure operating pressure is justified based on a reliable
engineering analysis showing that the pressure increase is safe considering all known
defects, anomalies, and operating parameters of the pipeline.
6. Mechanical and Metallurgical Testing. Within 45 days after this Order is issued,
Enterprise must complete mechanical and metallurgical testing and failure analysis of the
failed pipe, including an analysis of soil samples and any foreign materials. Mechanical
and metallurgical testing must be conducted by an independent third-party acceptable to
the Director and must document the decision-making process and all factors contributing
to the failure. Respondent must complete the testing and analysis as follows:
a. Document the chain-of-custody when handling and transporting the failed pipe
section and other evidence from the Failure site.
b. Within 10 days of receipt of this Order, develop and submit the testing protocol
and the proposed testing laboratory to the Director for prior approval.
c. Prior to beginning the mechanical and metallurgical testing, provide the Director
with the scheduled date, time, and location of the testing to allow for an OPS
representative to witness the testing.
d. Ensure the testing laboratory distributes all reports whether draft or final in their
entirety to the Director at the same time they are made available to Respondent.
7. Remedial Work Plan (RWP).
a. Within 90 days after this Order is issued, Enterprise must submit a Remedial Work
Plan (RWP) to the Director for prior approval.
b. The Director may approve the RWP incrementally without approving the entire
RWP.
c. Upon approval by the Director, the RWP becomes incorporated by reference into
this Order.
d. The RWP must include qualification of the Welding Procedure Specification(s)
used in the repair of the failed pipe.
e. The RWP must specify the tests, inspections, assessments, evaluations, and
remedial measures Respondent will use to verify the integrity of the Affected
Segment. It must address all known or suspected factors and causes of the Failure.
Enterprise must consider the risks and consequences of another failure to develop
a prioritized schedule for RWP- related work along the Affected Segment.



f. The RWP must include a procedure or process to:
i. Identify pipe in the Affected Segment with characteristics similar to
the contributing factors identified for the Failure.
ii. Gather all data necessary to review the failure history (in service
and pressure test failures) of the Affected Segment and to prepare a
written report containing all the available information such as the
locations, dates, and causes of leaks and failures.
iii. Integrate the results of the metallurgical testing, root cause failure
analysis, and other corrective actions required by this Order with all
relevant pre-existing operational and assessment data for the Affected
Segment. Pre-existing operational data includes, but is not limited to,
design, construction, operations, maintenance, testing, repairs, prior
metallurgical analyses, and any third-party consultation information.
Pre-existing assessment data includes, but is not limited to, ILI tool
runs, hydrostatic pressure testing, direct assessments, close interval
surveys, and DCVG/ACVG surveys.
iv. Determine if conditions similar to those contributing to the Failure
are likely to exist elsewhere on the Affected Segment.
v. Conduct additional field tests, inspections, assessments, and
evaluations to determine whether, and to what extent, the conditions
associated with the Failure and other failures from the failure history
(see (e)(ii) above) or any other integrity threats are present elsewhere
on the Affected Segment. At a minimum, this process must consider
all failure causes and specify the use of one or more of the following:
1) ILI tools that are technically appropriate for assessing the
pipeline system based on the cause of Failure and that can
reliably detect and identify anomalies,
2) Hydrostatic pressure testing,
3) Close-interval surveys,
4) Cathodic protection surveys, to include interference surveys
in coordination with other utilities (e.g., underground
utilities, overhead power lines, etc.) in the area,
5) Coating surveys,
6) Stress corrosion cracking surveys,
7) Selective seam corrosion surveys; and
8) Other tests, inspections, assessments, and evaluations
appropriate for the failure causes.
Note: Enterprise may use the results of previous tests, inspections,
assessments, and evaluations if approved by the Director, provided the results
of the tests, inspections, assessments, and evaluations are analyzed with regard
to the factors known or suspected to have caused the Failure.
vi. Describe the inspection and repair criteria Enterprise will use to
prioritize, excavate, evaluate, and repair anomalies, imperfections,



and other identified integrity threats. Include a description of how any
defects will be graded and a schedule for repairs or replacement.
vii. Based on the known history and condition of the Affected Segment,
describe the methods Enterprise will use to repair, replace, or take
other corrective measures to remediate the conditions associated with
the Failure, and to address other known integrity threats along the
Affected Segment. The repair, replacement, or other corrective
measures must meet the criteria specified in (e)(vi) above.
viii. Implement continuing long-term periodic testing and integrity
verification measures to ensure the ongoing safe operation of the
Affected Segment considering the results of the analyses, inspections,
evaluations, and corrective measures undertaken pursuant to the
Order.
g. Enterprise must include a proposed schedule for completion of the RWP.
h. Enterprise must revise the RWP as necessary to incorporate new information
obtained during the failure investigation and remedial activities, to incorporate
the results of actions undertaken pursuant to this Order, and/or to incorporate
modifications required by the Director.
i. Enterprise must submit any plan revisions to the Director for prior
approval.
ii. The Director may approve plan revisions incrementally.
i. Enterprise must implement the RWP as it is approved by the Director,
including any revisions to the plan.
8. Root Cause Failure Analysis. Within 180 days after this Order is issued, Enterprise must
complete a root cause failure analysis (RCFA) and submit a final report of this RCFA to
the Director. The RCFA must be supplemented or facilitated by an independent third-
party approved by the Director. Enterprise must ensure that all reports, whether draft or
final, are made available in their entirety to the Director at the same time they are made
available to Enterprise. The final report must include findings and any lessons learned and
whether the findings and lessons learned are applicable to other locations within
Enterprise’s pipeline system.
9. Public Awareness Program Review. Within 180 days after this Order is issued,
Enterprise must review and assess the effectiveness of its Public Awareness program with
regards to the Failure. Enterprise must amend its Public Awareness Program, if necessary,
to reflect the results of this review. The documentation of this Public Awareness Plan
Program Review must be available for inspection by OPS or provided to the Director, if
requested.
Other Requirements:
10. Approvals. With respect to each submission under this Order that requires the approval
of the Director, the Director may: (a) approve, in whole or part, the submission; (b)



approve the submission on specified conditions; (c) modify the submission to cure any
deficiencies; (d) disapprove in whole or in part, the submission, directing that Respondent
modify the submission, or (e) any combination of the above. In the event of approval,
approval upon conditions, or modification by the Director, Respondent shall proceed to
take all action required by the submission as approved or modified by the Director. If the
Director disapproves all or any portion of the submission, Respondent must correct all
deficiencies within the time specified by the Director and resubmit it for approval.
11. Extensions of Time. The Director may grant an extension of time for compliance with
any of the terms of this Order upon a written request timely submitted demonstrating good
cause for an extension.
12. Reporting. Submit quarterly reports to the Director that: (1) include all available data
and results of the testing and evaluations required by this Order; and (2) describe the
progress of the repairs or other remedial actions being undertaken. The first quarterly
report is due on March 1, 2026. The Director may change the interval for the submission
of these reports.
13. Documentation of the Costs. It is requested that Respondent maintain documentation of
the costs associated with implementation of this Order. Include in each monthly report
submitted, the to-date total costs associated with: (1) preparation and revision of
procedures, studies and analyses; (2) physical changes to pipeline infrastructure, including
repairs, replacements and other modifications; and (3) environmental remediation.
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).
In your correspondence on this matter, please refer to “CPF No. 4-2025-058-CAO” and for each
document you submit, please provide a copy in electronic format whenever possible. The actions
required by this Order are in addition to and do not waive any requirements that apply to
Respondent’s pipeline system under 49 CFR Parts 190 through 199, under any other order issued
to Respondent under authority of 49 U.S.C. Chapter 601, or under any other provision of federal
or state law.
Respondent may appeal any decision of the Director to the Associate Administrator for Pipeline
Safety. Decisions of the Associate Administrator shall be final.
Failure to comply with this Order may result in the assessment of civil penalties and in referral
to the Attorney General for appropriate relief in United States District Court pursuant to
49 U.S.C. § 60120.
The terms and conditions of this Order are effective upon service in accordance with 49 CFR §
190.5.



_____________________________ __________________________
Linda Daugherty Date Issued
Acting Associate Administrator
for Pipeline Safety

42025058CAO_Corrective Action Order (Amended)_01062026_(25-358672)_text.pdf

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Avenue, SE
Washington, DC 20590
January 06, 2026
VIA ELECTRONIC MAIL TO: gbacon@eprod.com
Graham Bacon
Executive Vice President, Chief Operating Officer
Enterprise Products Operating, LLC
1100 Louisiana Street
Houston, TX 77002
Re: CPF No. 4-2025-058-CAO
Dear Mr. Bacon,
Enclosed please find an Amended Corrective Action Order (Order) issued by the Pipeline and
Hazardous Materials Safety Administration, Office of Pipeline Safety. It requires Enterprise
Products Operating, LLC, to take certain corrective actions with respect to a pipeline failure
which occurred on November 27, 2025, on the Enterprise East Leg Mainline pipeline in
Jefferson County, Kansas.
Service by electronic mail is effective upon the date of transmission and acknowledgment of
receipt as provided under 49 CFR § 190.5. The terms and conditions of this Order are effective
upon completion of service.
Sincerely,
Linda Daugherty
Acting Associate Administrator
for Pipeline Safety
Enclosure: Corrective Action Order
cc: Mr. Bryan Lethcoe, Director, Southwest Region, Office of Pipeline Safety, PHMSA
Suzie Davis, Senior Manager, Compliance, Enterprise Products Operating, LLC,
smdavis@eprod.com
CONFIRMATION OF RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
)
In the Matter of )
)
Enterprise Products Operating, LLC ) CPF No. 4-2025-058-CAO
)
Respondent. )
)
____________________________________)
AMENDED CORRECTIVE ACTION ORDER
Purpose and Background
The Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
(OPS), is issuing this Amended Corrective Action Order (ACAO or Order)1 pursuant to the
authority provided in 49 U.S.C. § 60112, to require Enterprise Products Operating, LLC
(Enterprise or Respondent), to take necessary corrective actions to protect the public, property,
and the environment from potential hazards associated with the pipeline failure that occurred on
the East Leg Mainline pipeline (East Leg Pipeline or Pipeline)2 in McLouth, Jeferson County,
Kansas (Failure) on November 27, 2025. The East Leg Pipeline is a hazardous liquid pipeline
facility that is subject to PHMSA’s jurisdiction pursuant to the Pipeline Safety Act, 49 U.S.C. §
60101 et seq., and Pipeline Safety Regulations, 49 CFR Parts 190 to 199.
The Enterprise MAPCO pipeline system is composed of two parallel pipelines (8” East Leg
Mainline and the 10” East Leg Loop) that transports liquified petroleum gas (LPG) in a northeast
direction from Conway, Kansas to Janesville, Wisconsin. The East Leg Pipeline includes 9 pump
stations and one water navigable crossing. The Failure occurred at Aerial Marker (AM) 158.4 in
an agricultural field within 0.5 mile of State Highway 16.
1 To the extent this ACAO is modified from the original CAO issued to Respondent under CPF No. 4-2025-058-
CAO on December 4, 2025, this ACAO supersedes and replaces the original CAO. To the extent this ACAO is
unmodified from the original CAO, this ACAO retains the full force and effect of the original CAO. All deadlines
noted in the order which refer to the date “this Order is issued” or “receipt of this Order” refer to the issuance of the
original CAO on December 4, 2025.
2 Enterprise Products Operating, LLC's East Leg Mainline pipeline is part of the MAPCO pipeline system present in
13 states. The MAPCO pipeline system is a Liquified Petroleum Gas (LPG) pipeline system consisting of four primary
segments, totaling approximately 8,074 miles in length. The 2,113-mile Conway North pipelines (East Red and Blue
lines) link the NGL hub at Conway, Kansas, to refineries, petrochemical plans and propane markets in the upper-
Midwest.



On November 27, 2025, Enterprise detected the Failure when it observed a pressure drop on the
East Leg Pipeline and received a public report of a vapor cloud near State Highway 16 in Jefferson
County, Kansas.
After detecting the Failure, Enterprise isolated a segment of the East Leg Pipeline, closing valves
at McLouth Station (AM 156.1) and AM 168. Enterprise used flares to reduce the pressure on the
pipeline segment. Enterprise located the Failure at AM 158.4, cut out the failed section, and
transported that section to Magnolia, Texas for inspection and metallurgical analysis by a third
party, Acuren. The pipe at the location of the failure is pre-1970 low-frequency electric resistance
welded (LF-ERW). The failure was along the longitudinal seam.
Enterprise notified the National Response Center (NRC) of the release on the East Leg Pipeline at
21:59 Eastern Time on November 27, 2025. A second report to the NRC was made on November
29, 2025, at 11:45 Eastern Time. Enterprise provided an estimated release amount of 3900 barrels
of propane.
The segment of the East Leg Pipeline remains shut-in and not in operation.
Pursuant to 49 U.S.C. § 60117, PHMSA has initiated an investigation of the Failure. The
preliminary findings of the Agency’s ongoing investigation are as follows:
Preliminary Findings
• The 8” East Leg Pipeline is an 8-inch diameter pipeline that transports liquified petroleum gas
(LPG) from Conway, Kansas to Janesville, Wisconsin. The East Leg Pipeline includes 9 pump
stations and one navigable water crossing.
• The East Leg Pipeline was originally constructed in 1960. The pipe at the failure location is
0.219 inches thick, API 5L grade X-52, with low frequency electric resistance welding (LF-
ERW) seams, and was manufactured by Bethlehem Steel. The Pipeline has coal tar enamel
(CTE) coating and cathodic protection. The maximum operating pressure (MOP) of the
Pipeline is 1650 psig. When the Failure occurred, the operating pressure was 1562 psig.
• On the evening of November 27, 2025, Enterprise observed a pressure drop on the East Leg
Pipeline and received a public report of a vapor cloud near State Highway 16. After detecting
the Failure, Enterprise shut in a segment of the East Leg Pipeline, closing valves at McLouth
Station (AM 156.1) and AM 168. Enterprise used flares to reduce the pressure on the pipeline
segment.
• Enterprise notified the National Response Center (NRC) of the Failure at 21:59 Eastern Time
on November 27, 2025.
• Enterprise provided a supplemental NRC notification at 11:45 Eastern Time on November 29,
2025. In its second NRC report, Enterprise estimated a release of 3900 barrels of propane.



• The Failure occurred around AM 158.4, about 1.3 miles southeast of McLouth, Kansas, in an
agricultural field within 0.5 mile of State Highway 16. The 2020 United States census counted
859 people, 346 households, and 232 families in McLouth.
• At the point of failure, the pipe was observed to have a 12-foot-long fish-mouth rupture along
the longitudinal seam.
• Enterprise cut out the failed section of the East Leg Pipeline and transported the pipe to Acuren
in Magnolia, Texas, for inspection and metallurgical analysis.
• The release of LPG poses a risk to public safety, property, and the environment. The Failure
caused the creation of a vapor cloud over State Highway 16 which passers-by drove through,
risking ignition of the vapor and severe harm to people in the vicinity. Emergency responders
established an evacuation zone of one-half mile requiring the evacuation of 15-20 residences
and the closure of State Highway 16.
• Previously, on November 29, 2016, a failure occurred on Enterprise’s 10-inch East Leg Loop
pipeline, which runs parallel to the East Leg Mainline pipeline, resulting in the release of
approximately 5,000 barrels of ethane-propane mixture in Platte County, Missouri. The
released product ignited and caused a fire. The cause of the failure was determined to be
external near-neutral stress corrosion cracking along and adjacent to the ERW seam.
• The failed East Leg Pipeline segment is currently shut-in and not operating.
• The investigation of the Failure is on-going, and information could change. These preliminary
findings may be amended based on further findings during the investigation.
Amended Determination of Necessity for Corrective Action Order and Right to Hearing
Section 60112 of title 49, United States Code, authorizes PHMSA to determine that a pipeline
facility is or would be hazardous to life, property, or the environment and if there is a likelihood
of serious harm, to expeditiously order the operator of the facility to take necessary corrective
action, including suspended or restricted use of the facility, physical inspection, testing, repair,
replacement, or other appropriate action. An order issued expeditiously must provide an
opportunity for a hearing as soon as practicable after the order is issued.
In deciding whether to issue an order, PHMSA must consider the following, if relevant: (1) the
characteristics of the pipe and other equipment used in the pipeline facility, including the age,
manufacture, physical properties, and method of manufacturing, constructing, or assembling the
equipment; (2) the nature of the material the pipeline facility transports, the corrosive and
deteriorative qualities of the material, the sequence in which the material is transported, and the
pressure required for transporting the material; (3) the aspects of the area in which the pipeline
facility is located, including climatic and geologic conditions and soil characteristics; (4) the
proximity of the area in which the hazardous liquid pipeline facility is located to environmentally
sensitive areas; (5) the population density and population and growth patterns of the area in which



the pipeline facility is located; (6) any recommendation of the National Transportation Safety
Board made under another law; and (7) any other factors PHMSA may consider as appropriate.
After evaluating the foregoing preliminary findings of fact, and having considered age of the pipe,
the circumstances surrounding the Failure, the hazardous nature of the product being transported,
the pressure required for transporting the material, the method of manufacture, the uncertainties as
to the cause of the Failure, the ongoing investigations to determine the cause of the Failure, and
the possibility that the same condition(s) that may have caused the failure remain present in the
pipeline and could lead to additional failures, it appears that the continued operation of the pipeline
without corrective measures would pose a pipeline integrity risk to public safety, property, or the
environment. Accordingly, corrective measures are necessary to mitigate the pipeline integrity
risk of the pipeline system to protect public safety, property, and the environment.
Accordingly, this Order mandating immediate corrective action is issued expeditiously without
prior notice and opportunity for a hearing. The terms and conditions of this Order are effective
upon receipt.
Within 10 days of receipt of this Order, Respondent may request a hearing, to be held as soon as
practicable, by notifying the Associate Administrator for Pipeline Safety in writing, with a copy
to the Director, PHMSA, OPS Southwest Region. If a hearing is requested, it will be held in
accordance with 49 CFR § 190.211.
After receiving and analyzing additional data in the course of this investigation, PHMSA may
identify other corrective measures that need to be taken. Respondent will be notified of any
additional measures required and, if appropriate, P
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