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