@@ -5,35 +5,35 @@ the inhibitors in mitigating internal corrosion; and
55(3) Examine the coupons or other monitoring equipment at least twice each
66calendar year, but with intervals not exceeding 7 1/2 months.
77Internal corrosion monitoring was discontinued on the five hydrogen permeation monitors
8- (Beta F oils) installed on Line 6B. Two manuallydnterrogated monitors were discontinued in
9- May 2006. One remotely—interro gated monitor was discontinued in January 2006, and the
10- other two remotely—interro gated monitors were discontinued in October 2007. Enbridge
8+ (Beta oils) installed on Line 6B. Two monitors were discontinued in
9+ May 2006. One gated monitor was discontinued in January 2006, and the
10+ other two gated monitors were discontinued in October 2007. Enbridge
1111representatives stated the monitoring was discontinued due to
1212"communication/instrumentation problems."
1313Enbridge is in the process of implementing an alternative method of internal corrosion
1414monitoring on Line 6B utilizing a technology referred to as Electrical Resistance Tomography
1515(FSMPIT), however, it is not expected to be implemented on Line 6B until sometime during
1616the first half of 2010. In the interim, Enbridge provided the following information as
1717demonstration that the internal corrosion threat is being properly managed:
18- • a comprehensive report related to the internal corrosion mitigation and
18+ a comprehensive report related to the internal corrosion mitigation and
1919monitoring program for their heavy oil pipeline system
20- ¤ repair sleeve installations (which require circumferential non-destructive
20+ repair sleeve installations (which require circumferential non-destructive
2121testing)
22- ¤ inspection ofthe Line 6B Pig Sending Trap at Griffith Station (which included
22+ inspection ofthe Line 6B Pig Sending Trap at Griffith Station (which included
2323ultrasonic inspection of the trap floor between the 5:00 and 7:00 positions)
24- ¤ detailed pipe examinations at in-line inspection indications
25- e records for a weight loss coupon at the Stockbridge Ptunping Station (Line 17),
24+ detailed pipe examinations at in-line inspection indications
25+ records for a weight loss coupon at the Stockbridge Ptunping Station (Line 17),
2626which sees only fluid flow from Line 6B
2727The information provided does not demonstrate compliance with the above regulation. Line
28- 6B has been subject to a batch chemical treatment program to inhibit internal corrosion for ‘
29- several years. As required by l95.579(b), Line 6B must have coupons or other monitoring
28+ 6B has been subject to a batch chemical treatment program to inhibit internal corrosion for
29+ several years. As required by Line 6B must have coupons or other monitoring
3030equipment to determine the effectiveness of the inhibitor program, and the coupons or other
3131monitoring equipment nlust be examined at least twice each calendar year, at intervals not to
3232exceed 7-l/2 months. PHMSA acknowledges the positive steps being taken to improve
33- Enbridge’s internal corrosion mitigation and monitoring program. However, the transition
33+ internal corrosion mitigation and monitoring program. However, the transition
3434from one technology to another must be implemented in a manner that ensures continued
3535compliance with the regulations.
36- Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
36+ Under 49 United States Code, 60122, you are subject to a civil penalty not to exceed
3737$100,000 for each violation for each day the violation persists up to a maximum of $1,000,000
3838for any related series of violations. We have reviewed the circumstances and supporting
3939documents involved in this case, and have decided not to conduct additional enforcement
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