|
1 | | -(1) Use inhibitors in sufficient quantity to protect the entire part ofthe pipeline |
| 1 | +(1) Use inhibitors in sufficient quantity to protect the entire part of the pipeline |
2 | 2 | system that the inhibitors are designed to protect; |
3 | | -(2) Use coupons or other monitoring equipment to determine the effectiveness of |
| 3 | +(2) Use coupons or other monitoring equipment to determine the effectiveness oi' |
4 | 4 | the inhibitors in mitigating internal corrosion; and |
5 | 5 | (3) Examine the coupons or other monitoring equipment at least twice each |
6 | 6 | calendar year, but with intervals not exceeding 7 1/2 months. |
7 | | -Internal corrosion monitoring was discontinued on the five hydrogen permeation monitors |
8 | | -(Beta oils) installed on Line Two manually-interrogated monitors were discontinued in |
9 | | -May 2006. One remotely-interro gated monitor was discontinued in Januaiy 2006, and the |
10 | | -other two remotely-interro gated monitors were discontinued in October 2007. Enbridge |
| 7 | +Internal corrosion monitoring was _discontinued on the tive hydrogen permeation monitors |
| 8 | +(Beta Foils) installed on Line 6B. Two manually-interrogated monitors were discontinued in |
| 9 | +May 2006. One remotely-interrogated monitor was discontinued in January 2006, and the |
| 10 | +other two remotely-interrogated monitors were discontinued in October 2007. Enbridge |
11 | 11 | representatives stated the monitoring was discontinued due to |
12 | 12 | "communication/instrumentation problems." |
13 | 13 | Enbridge is in the process of implementing an alternative method of internal corrosion |
14 | 14 | monitoring on Line 6B utilizing a technology referred to as Electrical Resistance Tomography |
15 | 15 | (FSM-IT), however, it is not expected to be implemented on Line 6B until sometime during |
16 | | -the iirst half of 2010. ln the interim, Enbridge provided the following information as |
17 | | -demonstration that the internal corrosion threat is being properly managed: |
18 | | -0 a comprehensive report related to the internal corrosion mitigation and |
| 16 | +the iirst half of 2010. In the interim, Enbridge provided the following information as |
| 17 | +demonstration that the intemal corrosion threat is being properly managed: |
| 18 | +^0 a comprehensive report related to the internal corrosion mitigation and |
19 | 19 | monitoring program for their heavy oil pipeline system |
20 | | -^0 repair sleeve installations (which require circumferential non-destructive |
| 20 | +repair sleeve installations (which require circumferential non-destructive |
21 | 21 | testing) |
22 | | -inspection of the Line 6B Pig Sending Trap at Griffith Station (which included |
23 | | -ultrasonic inspection of the trap floor between the 5:00 and 7:00 positions) |
24 | | -9 detailed pipe examinations at in-line inspection indications |
25 | | -records for a weight loss coupon at the Stockbridge Ptunping Station (Line 17), |
26 | | -which sees only fluid flow from Line 6B |
| 22 | +6 inspection of the Line 6B Pig Sending Trap at Griffith Station (which included |
| 23 | +ultrasonic inspection of the trap iloor between the 5:00 and 7:00 positions) |
| 24 | +^0 detailed pipe examinations at in-line inspection indications |
| 25 | +^0 records for a weight loss coupon at the Stockbridge Pumping Station (Line 17), |
| 26 | +which sees only iluid ilow from Line 6B |
27 | 27 | The 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 Line 6B must have coupons or other monitoring |
| 28 | +6B has been ect to a batch chemical treatment program to inhibit intemal corrosion for |
| 29 | +several years. As required by Line 6B must have coupons or other monitoring |
30 | 30 | equipment to determine the effectiveness of the inhibitor program, and the coupons or other |
31 | | -monitoring equipment nlust be examined at least twice each calendar year, at intervals not to |
32 | | -exceed 7-l/2 months. PHMSA acknowledges the positive steps being taken to improve |
| 31 | +monitoring equipment maust be examined at least twice each calendar year, at intervals not to |
| 32 | +exceed 7~l/2 months. PHMSA acknowledges the positive steps being taken to improve |
33 | 33 | Enbridge's internal corrosion mitigation and monitoring program. However, the transition |
34 | | -from one technology to another must be implemented in a manner that ensures continued |
| 34 | +from one technology to another must be implemented in a manner that ensnres continued |
35 | 35 | compliance with the regulations. |
36 | | -Under 49 United States Code, SS 60122, you are subject to a civil penalty not to exceed |
| 36 | +Under 49 United States Code, SS 60122, you are ect to a civil penalty not to exceed |
37 | 37 | $100,000 for each violation for each day the violation persists up to a maximum of $1,000,000 |
38 | 38 | for any related series of violations. We have reviewed the circumstances and supporting |
39 | 39 | documents involved in this case, and have decided not to conduct additional enforcement |
|
0 commit comments