[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"doc-seo-240057-105":3,"detail-sidebar-cat-1-en-105":81,"doc-detail-240057-en":127},{"code":4,"msg":5,"data":6},0,"ok",{"site_id":7,"language":8,"slug":9,"title":10,"keywords":11,"description":12,"schema_data":13,"social_meta":74,"head_meta":76,"extra_data":78,"updated_unix":80},105,"en","enbridge-pipelines-response-to-phmsa-notice-of-probable-violation-proposed-civil-penalty-mitigation","Enbridge Pipelines Response to PHMSA Notice of Probable Violation - Proposed Civil Penalty Mitigation","","Written response from Enbridge Pipelines North Dakota LLC addressing a PHMSA Notice of Probable Violation and Proposed Civil Penalty for CPF-3-2007-5022. The submission outlines incident response and cleanup effectiveness, prompt mitigative and corrective actions, minimal impact to public safety and the environment, and a cooperative relationship with PHMSA. It describes containment, recovery of free product, proper disposal of impacted soil, and installation of groundwater monitoring wells, along with corrective actions, manual revisions, and facility integrity risk assessments, requesting mitigation or elimination of the proposed 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Locust Street,Room 462Kansas City MO 64106-2641  \nRE:  CPF-3-2007-5022  \nDear Mr.Huntoon:  \nJay Johnson  \nSenior Compliance CoordinatorTel 7153941512Fax 7153941500jay.johnson@enbridge.com  \nPursuant to the above mentioned Pipeline and Hazardous Materials Safety Administration(PHMSA)Notice of Probable Violation and Proposed Civil Penalty,Enbridge PipelinesNorth Dakota LLC(EPND)is submitting written explanations,information and othermaterials regarding the merits of the allegations.EPND is seeking mitigation or eliminationof the proposed civil penalty as outlined in the Response Options for Pipeline Operators inCompliance Proceedings.  \nEPND's request to mitigate the proposed civil penalty is based on:  \n1.EPND's effective response to incident and cleanup,  \n2.EPND's prompt and effective mitigative and corrective actions,  \n3.Minimal impact to Public Safety and the Environment,  \n4.EPND's cooperative response and open relationship with PHMSA,  \n5.EPND's excellent operational history.  \nAs detailed in the post mortem template,(previously submitted)EPND responded quicklyand effectively to isolate and limit the release.Ensuing containment,all free product wasrecovered and all impacted soil was properly disposed.The release was totally containedon EPND property and therefore did not pose any threats to public safety.However,groundwater monitoring wells were installed in the vicinity to ensure no product escaped thecontainment area.  \nFollowing the incident,a committee comprised of subject matter experts from Operations,Engineering and Management developed a list of corrective actions and lessons learnedutilizing the Det Norske Veritas Systematic Cause Analysis Technique.Both root causeand non-critical improvements were identified.From this a revision to the Operating andMaintenance Manual was issued which was immediately reviewed by all engineering andfield personnel.The Incident Report was also circulated for review.In addition,EPND hascompleted a Facility Integrity Risk Assessment on all station facilities and has focusedefforts to address dead leg,idle and low flow piping.  \nDuring the course of investigating this incident,EPND kept Central Region PHMSA updatedvia phone and electronic communications such as;photographs,thermal calculations andthe root cause analysis.It is our policy to determine the cause and communicate thecorrective measures within the Enbridge companies to avert any possible reoccurrences.As part of our investigations,we value the comments and concerns expressed by PHMSAand take them all into consideration.  \nMaterials attached for your review are:  \n·Operating and Maintenance Procedures Manual revision  \n·Incident Investigation corrective action status list  \n·Facility Integrity Assessment Program  \nIn conclusion,EPND is committed to operating in full regulatory compliance and has anexcellent record of working jointly with PHMSA to ensure pipeline safety.Therefore,werespectfully request that PHMSA review our request to mitigate or eliminate the proposedcivil penalties.If you have any questions or require additional information please contactJay Johnson in our Superior office at 715/394-1512.  \nSincerely,  \nSteve Irving  \nDirector,System Integrity and Compliance  \nJanet Holder  \nCC:  \nBrian Johnson  \nJay Johnson  \nTerry McGill  \nMark Willoughby  \nGathering Systems O&MP  \nREVISION REQUEST  \nManual  \nENBRIDGE  \nDate:  \n 02/21/07     \n  Matt Faith                     \nName:  \nSubject Title:Overview of Pipeline Repair/Replacement/Relocation/Abandonment       \n 11.1 (page 141)  \nSubject No.:  \nExisting wording:  \n  None                                  \n Considerations when modifying station or above ground piping:          \n# Proposed wording:\n\n1.Does modification create a section of dead leg below ground piping that could result in a corrosion risk?  Mo","cbCaimI1FcVmb20F","https://ap.wps.com/l/cbCaimI1FcVmb20F","pdf",462719,28,"English","# Response Overview\n## Basis for Mitigation Request\n## Incident Response and Corrective Actions\n## Attached Materials\n## Facility Integrity Assessment Program\n## Problem Statement","[{\"question\":\"What is the purpose of this PHMSA response submission?\",\"answer\":\"It provides written explanations and information addressing the merits of PHMSA’s allegations and requests mitigation or elimination of the proposed civil penalty.\"},{\"question\":\"How did EPND describe its incident response and cleanup actions?\",\"answer\":\"EPND stated it responded quickly to isolate and limit the release, recovered free product, disposed impacted soil properly, and installed groundwater monitoring wells to ensure no product escaped containment.\"},{\"question\":\"What factors does the response cite to support mitigation or elimination of the civil penalty?\",\"answer\":\"The response cites effective incident response and cleanup, prompt corrective actions, minimal impact to public safety and the environment, cooperative engagement with PHMSA, and an excellent operational history.\"}]","Enbridge Pipelines Response to PHMSA Notice of Probable Violation - Proposed Civil Penalty Mitigation | PDF",1789156745,10]