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updating test cases for new OCR settings.
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jashkenas committed Sep 13, 2011
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20 changes: 10 additions & 10 deletions test/fixtures/corrosion/corrosion_1.txt
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(R)
U.S. DSDCIITITISDT 901 Locust Street, Suite 462
of Tronsportotion Kansas City, Mo 64106-2641
Pipeline and
Hazardous Materials Safety
901 Locust Street Suite 462
Qi' Kansas City, MO 164106-2641
Pipetine and
Hazardous Materials Satety
Administration
WARNING LETTER
LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
January 21, 2010
Mr. Terry McGill, President
Enbridge Energy Partners,
1100 Louisiana, Suite 3300
Enbridge Energy Partners, L.P.
1100 Louisiana, Suite 3300 -
Houston, Texas 77002
CPF 3-2010-S002W
CPF
Dear Mr. McGill:
On October 6-8, 2008, October 28, 2008, and January 21-22, 2009, a representative of the
Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of
49 United States Code inspected your facilities associated with the Griffith Unit in Griffith,
49 United States Code inspected your facilities associated With the Griffith Unit in Griffith,
Indiana, and surrounding locations.
As a result ofthe inspection, it appears that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and
the probable violation(s) are:
1. 195.579 What must I do to mitigate internal corrosion?

Inhibitors. If you use corrosion inhibitors to mitigate internal corrosion, you
must--

42 changes: 21 additions & 21 deletions test/fixtures/corrosion/corrosion_2.txt
@@ -1,39 +1,39 @@
(1) Use inhibitors in sufficient quantity to protect the entire part ofthe pipeline
(1) Use inhibitors in sufficient quantity to protect the entire part of the pipeline
system that the inhibitors are designed to protect;
(2) Use coupons or other monitoring equipment to determine the effectiveness of
(2) Use coupons or other monitoring equipment to determine the effectiveness oi'
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 oils) installed on Line Two manually-interrogated monitors were discontinued in
May 2006. One remotely-interro gated monitor was discontinued in Januaiy 2006, and the
other two remotely-interro gated monitors were discontinued in October 2007. Enbridge
Internal corrosion monitoring was _discontinued on the tive hydrogen permeation monitors
(Beta Foils) installed on Line 6B. Two manually-interrogated monitors were discontinued in
May 2006. One remotely-interrogated monitor was discontinued in January 2006, and the
other two remotely-interrogated 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
(FSM-IT), however, it is not expected to be implemented on Line 6B until sometime during
the iirst half of 2010. ln the interim, Enbridge provided the following information as
demonstration that the internal corrosion threat is being properly managed:
0 a comprehensive report related to the internal corrosion mitigation and
the iirst half of 2010. In the interim, Enbridge provided the following information as
demonstration that the intemal corrosion threat is being properly managed:
^0 a comprehensive report related to the internal corrosion mitigation and
monitoring program for their heavy oil pipeline system
^0 repair sleeve installations (which require circumferential non-destructive
repair sleeve installations (which require circumferential non-destructive
testing)
inspection of the Line 6B Pig Sending Trap at Griffith Station (which included
ultrasonic inspection of the trap floor between the 5:00 and 7:00 positions)
9 detailed pipe examinations at in-line inspection indications
records for a weight loss coupon at the Stockbridge Ptunping Station (Line 17),
which sees only fluid flow from Line 6B
6 inspection of the Line 6B Pig Sending Trap at Griffith Station (which included
ultrasonic inspection of the trap iloor between the 5:00 and 7:00 positions)
^0 detailed pipe examinations at in-line inspection indications
^0 records for a weight loss coupon at the Stockbridge Pumping Station (Line 17),
which sees only iluid ilow 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 Line 6B must have coupons or other monitoring
6B has been ect to a batch chemical treatment program to inhibit intemal corrosion for
several years. As required by 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
monitoring equipment maust 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
from one technology to another must be implemented in a manner that ensnres continued
compliance with the regulations.
Under 49 United States Code, SS 60122, you are subject to a civil penalty not to exceed
Under 49 United States Code, SS 60122, you are ect 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
Expand Down
13 changes: 7 additions & 6 deletions test/fixtures/corrosion/corrosion_4.txt
Expand Up @@ -2,16 +2,17 @@ action or penalty assessment proceedings at this time. We advise you to correct
identified in this letter. Failure to do so will result in Enbridge being subject to additional
enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer
to CPF 3-2010-500ZW. Be advised that all material you submit in response to this
to CPF 3-2010-5002W. 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, 5 52(b), along
with the complete original document you must provide a second copy of the doctuneut With the
portions you believe qualify for confidential treatment redacted and an explanation you
believe the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).
of your responsive material qualifies for confidential treatment Linder 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 qualities for confidential treatment under 5 U.S.C. 552(b).
Sincerely,
'Jawa

Ivan A. Huntoon
Director, Central Region
Pipeline and Hazardous Materials Safety Administration
_-in
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