# ENABLE GAS TRANSMISSION, LLC — Notice of Amendment

**Citation:** CPF 42023046NOA  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2023-10-18

CLOSED notice of amendment citing 192.515(a), 192.605(b)(1), 192.605(b)(4), 192.607(c), 192.607(f)(1), 192.607(f)(2), 192.609, 192.619(a)(1), 192.619(a)(2), 192.624(b), 192.710(b)(3), 192.712(e).

## Document text

Notice of Amendment involving ENABLE GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.515(a),  192.605(b)(1),  192.605(b)(4),  192.607(c),  192.607(f)(1),  192.607(f)(2),  192.609,  192.619(a)(1),  192.619(a)(2),  192.624(b),  192.710(b)(3),  192.712(e). The case was opened on 2023-10-18 and is reported as closed as of 2026-01-20. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

42023046NOA_Closure Letter_01202026_(22-241127).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023046NOA/42023046NOA_Closure%20Letter_01202026_(22-241127).pdf

42023046NOA_Closure Letter_01202026_(22-241127)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023046NOA/42023046NOA_Closure%20Letter_01202026_(22-241127)_text.pdf

42023046NOA_Notice of Amendment_10182023_(22-241127).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023046NOA/42023046NOA_Notice%20of%20Amendment_10182023_(22-241127).pdf

42023046NOA_Notice of Amendment_10182023_(22-241127)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023046NOA/42023046NOA_Notice%20of%20Amendment_10182023_(22-241127)_text.pdf

42023046NOA_Operator Response to Notice_01152024_(22-241127).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023046NOA/42023046NOA_Operator%20Response%20to%20Notice_01152024_(22-241127).pdf

42023046NOA_Order Directing Amendment_08292025_(22-241127).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023046NOA/42023046NOA_Order%20Directing%20Amendment_08292025_(22-241127).pdf

42023046NOA_Order Directing Amendment_08292025_(22-241127)_txt.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023046NOA/42023046NOA_Order%20Directing%20Amendment_08292025_(22-241127)_txt.pdf

42023046NOA_Order Directing Amendment_08292025_(22-241127)_txt.pdf

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Avenue, SE
Washington, DC 20590
August 29, 2025
VIA ELECTRONIC MAIL TO: tom.long@energytransfer.com
Thomas Long
Chief Executive Officer
Energy Transfer Company
8111 Westchester Drive
Dallas, Texas 75227
Re: CPF No. 4-2023-046-NOA
Dear Mr. Long:
Enclosed please find the Order Directing Amendment issued in the above-referenced case. It
makes findings of inadequate procedures, finds that certain amended procedures are adequate,
and requires Enable Gas Transmission, LLC, to amend certain procedures. When the
amendment of procedures has been completed, as determined by the Director, Southwest Region,
this enforcement action will be closed. Service of the Order Directing Amendment by e-mail is
effective upon the date of transmission and acknowledgement of receipt as provided under 49
CFR § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Linda Daugherty
Acting Associate Administrator
for Pipeline Safety
Enclosure
cc: Bryan Lethcoe, Director, PHMSA Southwest Region, Office of Pipeline Safety
Heidi Murchison, Chief Counsel, Energy Transfer, LP, heidi.murchison@energytransfer.com
Todd Nardozzi, Director, Regulatory Compliance, Energy Transfer, LP,



todd.nardozzi@energytransfer.com
Susie Sjulin, Director, Regulatory Compliance, Energy Transfer, LP,
susie.sjulin@energytransfer.com
CONFIRMATION OF RECEIPT REQUESTED
2



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
In the Matter of )
Enable Gas Transmission, LLC, ) CPF No. 4-2023-046-NOA
Respondent. )
)
)
)
)
ORDER DIRECTING AMENDMENT
From September 19, 2022, to January 12, 2023, representatives of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter
601 of 49 United States Code (U.S.C.) inspected Enable Gas Transmission, LLC’s (Enable or
Respondent) procedures for operations and maintenance in Oklahoma City, Oklahoma.
As a result of the inspection, the Director, PHMSA Southwest Region, OPS, issued to
Respondent by letter dated October 18, 2023, a Notice of Amendment (Notice). In accordance
with 49 CFR § 190.206, the Notice alleged certain inadequacies in Respondent’s operating and
maintenance procedures and proposed that Enable amend its procedures.
Enable responded to the Notice on January 15, 2024 (Response). In its Response, Enable
submitted additional documentation and contested certain allegations in the Notice. Respondent
did not request a hearing and therefore waived its right to one.
FINDING OF INADEQUATE PROCEDURES
Item 1: The Notice alleged that Respondent’s procedures for conducting operations and
maintenance activities were inadequate to ensure safe operation of a pipeline facility in
accordance with section 192.605(b)(1). The Notice alleged specifically that Enable’s pressure
testing procedure failed to adequately detail all reasonable precautions that may be taken to
protect employees and the public during the pressure testing pursuant to section 192.515(a).
The Notice stated that Respondent’s procedure C4.0105-Pressure Testing Execution, revision
date April 1, 2022, section 4.1, Safety, failed to provide sufficient detail regarding what
constitutes a safe distance away from the testing area when performing hydrotesting. Enable’s
procedures listed a minimum distance of fifty feet, but failed to detail how much additional
distance might be necessary where the minimum distance does not suffice.
In its Response, Enable did not contest Item 1. Enable stated that it revised it procedure to



2
incorporate industry guidance and include additional language for safe distance determination.
Respondent provided a draft of the revised procedure with its response. In accordance with
section 190.209(b)(7), the Director submitted a written evaluation of the Response and a
recommendation for final action dated July 1, 2025 (hereinafter Region Recommendation),
which reviewed the draft revised procedure and determined that Enable corrected the alleged
procedural inadequacy.
Accordingly, based on a review of the evidence, I find that Respondent needs to take no further
action regarding Item 1.
Item 2: The Notice alleged that Respondent’s procedures for conducting nondestructive or
destructive tests, examinations, and assessments to verify the material properties of aboveground
line pipe and components, and of buried line pipe and components, when excavations occur were
inadequate to ensure safe operation of a pipeline facility in accordance with section 192.607(c).
Specifically, the Notice alleged that Enable’s procedure I.43 Material Verification, Rev. 1, July
1, 2021, section 7.2, Track Opportunistic Digs, failed to provide sufficient details regarding
opportunistic digs. The coordination between various work groups and the responsibilities of
each group were not discussed with adequate specificity. The Notice proposed Respondent must
revise its procedure to describe the approach used to track locations needing material
verification, the methods to acquire needed data, the communication methods used to exchange
needed and gathered information between work groups and safeguards in place to ensure
compliance with section 192.607(c).
In its Response, Enable contested the allegation. It stated that the roles of the various work
groups in the coordination of work to comply with section 192.607(c) are detailed in I.43
Material Verification, section 5.0, Governance. Respondent then listed six bullet-points detailing
specific tasks and the group responsible.
The Director reviewed Enable’s Response and the procedures cited therein and, per the Region
Recommendation, recommended ordering amendment of the procedure as proposed in the
Notice.
Having considered the record, Enable is correct that the roles of the various work groups in the
coordination of work to comply with section 192.607(c) are detailed in I.43 Material
Verification, section 5.0, Governance. However, the Notice did not allege that Respondent’s
procedures did not include the roles of the various work groups in the coordination of work to
comply with section 192.607(c). Rather, the Notice alleged that Enable’s procedures did not
adequately address the coordination between these groups – and it proposed that Respondent
revise its procedures to “describe the approach used to track locations needing material
verification, the methods to acquire needed data, the communication methods used to exchange
needed and gathered information between work groups and safeguards in place to ensure
compliance with § 192.607(c).” The listing of each work group’s role and tasks in I.43 Material
Verification, section 5.0, Governance, does not address the concerns expressed in the Notice
regarding location tracking, data acquisition, communication methods, and safeguarding. These
details are not present in Enable’s I.43 Material Verification procedure. Enable, in its Response,
did not address how its I.43 Material Verification procedure adequately addresses these concerns.



3
Accordingly, after reviewing the evidence, I find that Respondent’s procedure for conducting
nondestructive or destructive tests, examinations, and assessments to verify the material
properties of aboveground line pipe and components, and of buried line pipe and components,
when excavations occur were inadequate to ensure safe operation of a pipeline facility in
accordance with section 192.607(c). Enable is hereby ordered to revise its procedures as
specified above. Finalized procedures must be provided to the Southwest Region for review and
approval.
Item 3: The Notice alleged that Respondent’s procedures for establishing and documenting the
American National Standards Institute rating or pressure rating were inadequate to ensure safe
operation of a pipeline facility in accordance with section 192. 607(f). Specifically, the Notice
alleged that Enable’s procedure I.43 Material Verification, Rev. 1, July 1, 2021, section 7.3.3,
Components, failed to provide adequate details regarding the material verification of non-line
pipe components. The Notice stated that the procedure failed to adequately describe how Enable
will verify non-line components that cannot be isolated from mainline pipeline pressures and
methods it will use to gather needed information.
In its response, Enable contested the allegation. It stated that verification of non-line pipe
components that cannot be isolated from mainline pressure is evaluated in the same manner as
those that can be isolated from mainline pressure. Respondent stated this is detailed in its
procedure I.43 Material Verification, section 7.3.3. The Director reviewed Enable’s Response
and the procedures cited therein and, per the Region Recommendation, determined that no
further procedural revisions are necessary.
Accordingly, after reviewing the evidence, I find that Respondent needs to take no further action
regarding Item 3.
Item 4: The Notice alleged that Enable’s procedures for conducting operations and maintenance
activities were inadequate to ensure safe operation of a pipeline facility in accordance with
section 192.605(b)(1). Specifically, the Notice stated that Respondent’s procedure B.12
Evaluating Class Location Changes (June 28, 2022), section 7.1, GIS Review, did not include
adequate detail regarding incorporating updated or new GIS data into existing class locations.
The procedure failed to adequately detail how Enable incorporated newly acquired pipeline
assets and assets with updated pipeline and structure attributes into the geographic information
system (GIS) to determine if a class location study is required under section 192.609.
In its Response, Enable stated that it revised the GIS process for management of Class location
changes and it described the new process. The Director reviewed Enable’s Response and the
revised process and, per the Region Recommendation, determined that no further procedural
revisions are necessary.
Accordingly, after reviewing the evidence, I find that Respondent needs to take no further action
regarding Item 4.
Item 5: The Notice alleged that Respondent’s procedures for conducting operations and
maintenance activities were inadequate to ensure safe operation of a pipeline facility in



4
accordance with section 192.605(b)(1). Specifically, the Notice alleged that Enable’s procedure
B.10 Determination of MAOP, revision date February 1, 20220, Appending B, List of Hydro Test
Factors for Class Location, and Appendix C, Process Flow for Determination of MAOP, failed to
include all required information and contained errors. Appendix B failed to include column three
of Table 1 from section 192.619(a)(2)(ii) and Appendix C referenced an affidavit referred to as a
“Gold Sheet.”
In its Response, Enable stated that it revised its procedures, to include revisions to Appendices B
and C. The Director reviewed Enable’s Response and the revised procedures and, per the
Region Recommendation, determined that no further procedural revisions are necessary.
Accordingly, after reviewing the evidence, I find that Respondent needs to take no further action
regarding Item 5.
Item 6: The Notice alleged that Enable’s procedures for reconfirming maximum alloawable
operating pressure (MAOP) were inadequate to ensure safe operation of a pipeline facility in
accordance with section 192.624(b). Specifically, the Notice alleged Enable’s procedure MAOP
Reconfirmation Plan, Revision 1 (August 26, 2022), section 2, MAOP Reconfirmation
Committee, did not include adequate detail regarding Reconfirmation Committee activities. The
procedure did not adequately describe how the committee decides on an appropriate
reconfirmation method, timing of segments, appropriate intermediate reconfirmation goals,
adjustments for acquisitions and divestitures, and record keeping for associated decision making.
In its Response, Enable contested the allegation. It asserted that it is not necessary under
section 192.624 to have the details described in the Notice. Respondent further stated that in
2023 its MAOP Reconfirmation Committee approved several changes to Enable’s MAOP
Reconfirmation Plan. It described the details of those changes. The Director reviewed Enable’s
Response and the information therein and, per the Region Recommendation, determined that no
further procedural revisions are necessary.
Accordingly, after reviewing the evidence, I find that Respondent needs to take no further action
regarding Item 6.
Item 7: The Notice alleged that Enable’s procedures for conducting operations and maintenance
activities were inadequate to ensure safe operation of a pipeline facility in accordance with section
192.605(b)(1). Specifically, the Notice alleged that procedure 192.710 ETC Gas Plan, revision 3
(April 15, 2022), section 6.2, Periodic Reassessment, failed to include adequate detail regarding
the use and documentation of prior assessments. The procedure failed to identify who will make
the determination to use a prior assessment, the associated timelines, how this determination will
be made, and what records will be generated to document this process in accordance with section
192.710(b)(3).
In its Response, Enable did not contest the allegation and explained that it prepared redline
revisions to its procedures to include who will make the determination to use a prior assessment
as the initial assessment and how the determination will be made per section 192.710(b)(3).
Respondent provided a copy of those redlined procedures with its Response.



5
The Director, per the Region Recommendation, indicated that while the draft revised procedures
were reviewed, it could not be verified whether Enable has cured the alleged procedural
inadequacy because Respondent did not provide the finalized version of the procedure.
Accordingly, after reviewing the evidence, I find that Respondent’s procedure was inadequate to
ensure safe operation of a pipeline facility in accordance with section 192.605(b)(1). Enable is
hereby ordered to revise its procedures as specified above. Finalized procedures must be
provided to the Southwest Region for review and approval.
Item 8: The Notice alleged that Enable’s procedures for conducting operations and maintenance
activities were inadequate to ensure safe operation of a pipeline facility in accordance with
section 192.605(b)(1). Specifically, the Notice alleged that procedure D.47 Evaluation of
Remaining Strength Pipeline, revision date September 1, 2022, section 3, Applicability, did not
include adequate detail to conduct an accurate analysis of predicted failure pressure. The
procedure failed to address measurement uncertainties such as tool tolerance, detection threshold,
tool verification, and other potentially relevant data features in accordance with section
192.712(e).
In its Response, Enable contested the allegation. Respondent stated that its procedure is used
only for in situ or in-the-ditch measurements of metal loss to determine remaining strength of
the pipe. Enable noted that section 192.712(e)(1) states that an operator must account for
uncertainties in reported assessment results in identifying and characterizing the defects used in
predicted failure pressure analyses unless the defect dimensions have been verified using in situ
direct measurements. Respondent asserted that since the procedure uses in situ or in-the-ditch
measurements to determine remaining strength, uncertainties or tolerances are not required.
The Director reviewed Enable’s Response and the procedures cited therein and, per the Region
Recommendation, recommended ordering amendment of the procedure as proposed in the
Notice.
Having considered the record, Enable is correct that if defect dimensions are verified using in
situ direct measurements, uncertainties in reported assessment results in identifying and
characterizing the defects used in predicted failure pressure analyses is not required. See section
192.712(e)(1). Had Respondent’s procedures included provisions for using in-line inspection
(ILI) tools to size defects, or if evidence suggested Respondent intended to use ILI tools to size
defects, then the procedures would need to include processes for accounting for tool tolerances
and other measurement uncertainties. However, since the procedures cited in the Notice only
provide for the use of in situ measurements, provisions accounting for uncertainties in reported
assessment results are not necessary. Because Enable’s procedures only provide for in situ or in-
the-ditch measurements of metal loss to determine remaining strength of the pipe, I find the
procedures in place are not inadequate as alleged in the Notice for the currently used method.
Accordingly, after reviewing the evidence, I find that no further action is required.
Item 9: The Notice alleged that Enable’s procedures for the gathering of data needed for annual
and incident reporting under Part 191 in a timely and effective manner were inadequate to ensure
safe operation of a pipeline facility in accordance with section 192.605(b)(4). Specifically, the



6
Notice alleged procedure A.15 PHMSA-States-Incident Reporting failed to detail identifying all
Moderate Consequence Areas (MCAs). MCAs must be identified and included in the annual
and incident reporting. In addition, MCAs must be identified to comply with sections 192.624
and 192.710.
In its Response, Enable contested this allegation and asserted that its procedure is intended to
meet the requirements of Part 191, specifically sections 191.3, 191.5, and 191.15. It stated that
procedure MAOP Reconfirmation Plan and 192.710 Plan also address the requirements of
sections 192.624 and 192.710. In addition, Respondent stated that its procedures A.15 PHMSA-
States-Incident Reporting and A.16 Annual Reporting adhere to and refer to PHMSA’s reporting
instructions, which address MCAs. It further stated that procedure A.15 PHMSA-States-Incident
Reporting defines MCA. Enable provided exhibits showing this information with its Response.
The Director reviewed Enable’s Response and the information provided and, per the Region
Recommendation, determined that no further procedural revisions are necessary.
Accordingly, after reviewing the evidence, I find that Respondent needs to take no further action
regarding Item 9.
Under 49 CFR section 190.243, Respondent may submit a Petition for Reconsideration of this
Final Order to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey
Avenue, SE, East Building, 2nd Floor, Washington, DC, 20590. The written petition must
contain a statement of the issue(s) and meet all other requirements of 49 CFR § 190.243. The
terms of the Order remain in effect until the Associate Administrator, upon request, grants a stay.
The terms and conditions of this Order are effective upon service in accordance with 49 CFR §
190.5.
Respondent must amend its procedures, as required above, and submit them to the Director,
PHMSA Southwest Region, OPS, within 30 days following receipt of this Order. The Director
may grant an extension of time to comply with any of the required items upon a written request
timely submitted by the Respondent and demonstrating good cause for an extension. Failure to
comply with this Order may result in administrative assessment of civil penalties exceeding
$200,000, as adjusted for inflation (see 49 CFR § 190.223 for adjusted amounts), for each
violation for each day the violation continues or in referral to the Attorney General for
appropriate relief in a district court of the United States.
Linda Daugherty Date Issued
Acting Associate Administrator
for Pipeline Safety

42023046NOA_Order Directing Amendment_08292025_(22-241127).pdf

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Avenue, SE
Washington, DC 20590
August 29, 2025
VIA ELECTRONIC MAIL TO: tom.long@energytransfer.com
Thomas Long
Chief Executive Officer
Energy Transfer Company
8111 Westchester Drive
Dallas, Texas 75227
Re: CPF No. 4-2023-046-NOA
Dear Mr. Long:
Enclosed please find the Order Directing Amendment issued in the above-referenced case. It
makes findings of inadequate procedures, finds that certain amended procedures are adequate,
and requires Enable Gas Transmission, LLC, to amend certain procedures. When the
amendment of procedures has been completed, as determined by the Director, Southwest Region,
this enforcement action will be closed. Service of the Order Directing Amendment by e-mail is
effective upon the date of transmission and acknowledgement of receipt as provided under 49
CFR § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
LINDA GAIL
DAUGHERTY
Digitally signed by LINDA
GAIL DAUGHERTY
Date: 2025.08.28
19:06:53 -04'00'
Linda Daugherty
Acting Associate Administrator
for Pipeline Safety
Enclosure
cc: Bryan Lethcoe, Director, PHMSA Southwest Region, Office of Pipeline Safety
Heidi Murchison, Chief Counsel, Energy Transfer, LP, heidi.murchison@energytransfer.com
Todd Nardozzi, Director, Regulatory Compliance, Energy Transfer, LP,



todd.nardozzi@energytransfer.com
Susie Sjulin, Director, Regulatory Compliance, Energy Transfer, LP,
susie.sjulin@energytransfer.com
CONFIRMATION OF RECEIPT REQUESTED
2



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Enable Gas Transmission, LLC, ) CPF No. 4-2023-046-NOA
)
)
)
Respondent. )
____________________________________)
ORDER DIRECTING AMENDMENT
From September 19, 2022, to January 12, 2023, representatives of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter
601 of 49 United States Code (U.S.C.) inspected Enable Gas Transmission, LLC’s (Enable or
Respondent) procedures for operations and maintenance in Oklahoma City, Oklahoma.
As a result of the inspection, the Director, PHMSA Southwest Region, OPS, issued to
Respondent by letter dated October 18, 2023, a Notice of Amendment (Notice). In accordance
with 49 CFR § 190.206, the Notice alleged certain inadequacies in Respondent’s operating and
maintenance procedures and proposed that Enable amend its procedures.
Enable responded to the Notice on January 15, 2024 (Response). In its Response, Enable
submitted additional documentation and contested certain allegations in the Notice. Respondent
did not request a hearing and therefore waived its right to one.
FINDING OF INADEQUATE PROCEDURES
Item 1: The Notice alleged that Respondent’s procedures for conducting operations and
maintenance activities were inadequate to ensure safe operation of a pipeline facility in
accordance with VHFWLRQ 192.605(b)(1). The Notice alleged specifically that Enable’s pressure
testing procedure failed to adequately detail all reasonable precautions that may be taken to
protect employees and the public during the pressure testing pursuant to VHFWLRQ 192.515(a).
The Notice stated that Respondent’s procedure C4.0105-Pressure Testing Execution, revision
date April 1, 2022, section 4.1, Safety, failed to provide sufficient detail regarding what
constitutes a safe distance away from the testing area when performing hydrotesting. Enable’s
procedures listed a minimum distance of fifty feet, but failed to detail how much additional
distance might be necessary where the minimum distance does not suffice.
In its Response, Enable did not contest Item 1. Enable stated that it revised it procedure to



2
incorporate industry guidance and include additional language for safe distance determination.
Respondent provided a draft of the revised procedure with its response. In accordance with
VHFWLRQ 190.209(b)(7), the Director submitted a written evaluation of the Response and a
recommendation for final action dated July 1, 2025 (hereinafter Region Recommendation),
which reviewed the draft revised procedure and determined that Enable corrected the alleged
procedural inadequacy.
Accordingly, based on a review of the evidence, I find that Respondent needs to take no further
action regarding Item 1.
Item 2: The Notice alleged that Respondent’s procedures for conducting nondestructive or
destructive tests, examinations, and assessments to verify the material properties of aboveground
line pipe and components, and of buried line pipe and components, when excavations occur were
inadequate to ensure safe operation of a pipeline facility in accordance with VHFWLRQ 192.607(c).
Specifically, the Notice alleged that Enable’s procedure I.43 Material Verification, Rev. 1, July
1, 2021, section 7.2, Track Opportunistic Digs, failed to provide sufficient details regarding
opportunistic digs. The coordination between various work groups and the responsibilities of
each group were not discussed with adequate specificity. The Notice proposed Respondent must
revise its procedure to describe the approach used to track locations needing material
verification, the methods to acquire needed data, the communication methods used to exchange
needed and gathered information between work groups and safeguards in place to ensure
compliance with VHFWLRQ 192.607(c).
In its Response, Enable contested the allegation. It stated that the roles of the various work
groups in the coordination of work to comply with VHFWLRQ 192.607(c) are detailed in I.43
Material Verification, section 5.0, Governance. Respondent then listed six bullet-points detailing
specific tasks and the group responsible.
The Director reviewed Enable’s Response and the procedures cited therein and, per the Region
Recommendation, recommended ordering amendment of the procedure as proposed in the
Notice.
Having considered the record, Enable is correct that the roles of the various work groups in the
coordination of work to comply with VHFWLRQ 192.607(c) are detailed in I.43 Material
Verification, section 5.0, Governance. However, the Notice did not allege that Respondent’s
procedures did not include the roles of the various work groups in the coordination of work to
comply with VHFWLRQ 192.607(c). Rather, the Notice alleged that Enable’s procedures did not
adequately address the coordination between these groups – and it proposed that Respondent
revise its procedures to “describe the approach used to track locations needing material
verification, the methods to acquire needed data, the communication methods used to exchange
needed and gathered information between work groups and safeguards in place to ensure
compliance with † 192.607(c).” The listing of each work group’s role and tasks in I.43 Material
Verification, section 5.0, Governance, does not address the concerns expressed in the Notice
regarding location tracking, data acquisition, communication methods, and safeguarding. These
details are not present in Enable’s I.43 Material Verification procedure. Enable, in its Response,
did not address how its I.43 Material Verification procedure adequately addresses these concerns.



3
Accordingly, after reviewing the evidence, I find that Respondent’s procedure for conducting
nondestructive or destructive tests, examinations, and assessments to verify the material
properties of aboveground line pipe and components, and of buried line pipe and components,
when excavations occur were inadequate to ensure safe operation of a pipeline facility in
accordance with VHFWLRQ 192.607(c). Enable is hereby ordered to revise its procedures as
specified above. Finalized procedures must be provided to the Southwest Region for review and
approval.
Item 3: The Notice alleged that Respondent’s procedures for establishing and documenting the
$PHULFDQ 1DWLRQDO 6WDQGDUGV ,QVWLWXWH rating or pressure rating were inadequate to ensure safe
operation of a pipeline facility in accordance with VHFWLRQ 192. 607(f). Specifically, the Notice
alleged that Enable’s procedure I.43 Material Verification, Rev. 1, July 1, 2021, section 7.3.3,
Components, failed to provide adequate details regarding the material verification of non-line
pipe components. The Notice stated that the procedure failed to adequately describe how Enable
will verify non-line components that cannot be isolated from mainline pipeline pressures and
methods it will use to gather needed information.
In its response, Enable contested the allegation. It stated that verification of non-line pipe
components that cannot be isolated from mainline pressure is evaluated in the same manner as
those that can be isolated from mainline pressure. Respondent stated this is detailed in its
procedure I.43 Material Verification, section 7.3.3. The Director reviewed Enable’s Response
and the procedures cited therein and, per the Region Recommendation, determined that no
further procedural revisions are necessary.
Accordingly, after reviewing the evidence, I find that Respondent needs to take no further action
regarding Item 3.
Item 4: The Notice alleged that Enable’s procedures for conducting operations and maintenance
activities were inadequate to ensure safe operation of a pipeline facility in accordance with
VHFWLRQ 192.605(b)(1). Specifically, the Notice stated that Respondent’s procedure B.12
Evaluating Class Location Changes (June 28, 2022), section 7.1, GIS Review, did not include
adequate detail regarding incorporating updated or new GIS data into existing class locations.
The procedure failed to adequately detail how Enable incorporated newly acquired pipeline
assets and assets with updated pipeline and structure attributes into the JHRJUDSKLF LQIRUPDWLRQ
V\VWHP GIS to determine if a class location study is required under VHFWLRQ 192.609.
In its Response, Enable stated that it revised the GIS process for management of Class location
changes and it described the new process. The Director reviewed Enable’s Response and the
revised process and, per the Region Recommendation, determined that no further procedural
revisions are necessary.
Accordingly, after reviewing the evidence, I find that Respondent needs to take no further action
regarding Item 4.
Item 5: The Notice alleged that Respondent’s procedures for conducting operations and
maintenance activities were inadequate to ensure safe operation of a pipeline facility in



4
accordance with VHFWLRQ 192.605(b)(1). Specifically, the Notice alleged that Enable’s procedure
B.10 Determination of MAOP, revision date February 1, 20220, Appending B, List of Hydro Test
Factors for Class Location, and Appendix C, Process Flow for Determination of MAOP, failed to
include all required information and contained errors. Appendix B failed to include column three
of Table 1 from VHFWLRQ 192.619(a)(2)(ii) and Appendix C referenced an affidavit referred to as a
“Gold Sheet.”
In its Response, Enable stated that it revised its procedures, to include revisions to Appendices B
and C. The Director reviewed Enable’s Response and the revised procedures and, per the
Region Recommendation, determined that no further procedural revisions are necessary.
Accordingly, after reviewing the evidence, I find that Respondent needs to take no further action
regarding Item 5.
Item 6: The Notice alleged that Enable’s procedures for reconfirming PD[LPXP DOORDZDEOH
RSHUDWLQJ SUHVVXUH MAOP were inadequate to ensure safe operation of a pipeline facility in
accordance with VHFWLRQ 192.624(b). Specifically, the Notice alleged Enable’s procedure MAOP
Reconfirmation Plan, Revision 1 (August 26, 2022), section 2, MAOP Reconfirmation
Committee, did not include adequate detail regarding Reconfirmation Committee activities. The
procedure did not adequately describe how the committee decides on an appropriate
reconfirmation method, timing of segments, appropriate intermediate reconfirmation goals,
adjustments for acquisitions and divestitures, and record keeping for associated decision making.
In its Response, Enable contested the allegation. It asserted that it is not necessary under
VHFWLRQ 192.624 to have the details described in the Notice. Respondent further stated that in
2023 its MAOP Reconfirmation Committee approved several changes to Enable’s MAOP
Reconfirmation Plan. It described the details of those changes. The Director reviewed Enable’s
Response and the information therein and, per the Region Recommendation, determined that no
further procedural revisions are necessary.
Accordingly, after reviewing the evidence, I find that Respondent needs to take no further action
regarding Item 6.
Item 7: The Notice alleged that Enable’s procedures for conducting operations and maintenance
activities were inadequate to ensure safe operation of a pipeline facility in accordance with VHFWLRQ
192.605(b)(1). Specifically, the Notice alleged that procedure 192.710 ETC Gas Plan, revision 3
(April 15, 2022), section 6.2, Periodic Reassessment, failed to include adequate detail regarding
the use and documentation of prior assessments. The procedure failed to identify who will make
the determination to use a prior assessment, the associated timelines, how this determination will
be made, and what records will be generated to document this process in accordance with VHFWLRQ
192.710(b)(3).
In its Response, Enable did not contest the allegation and explained that it prepared redline
revisions to its procedures to include who will make the determination to use a prior assessment
as the initial assessment and how the determination will be made per VHFWLRQ 192.710(b)(3).
Respondent provided a copy of those redlined procedures with its Response.



5
The Director, per the Region Recommendation, indicated that while the draft revised procedures
were reviewed, it could not be verified whether Enable has cured the alleged procedural
inadequacy because Respondent did not provide the finalized version of the procedure.
Accordingly, after reviewing the evidence, I find that Respondent’s procedure was inadequate to
ensure safe operation of a pipeline facility in accordance with VHFWLRQ 192.605(b)(1). Enable is
hereby ordered to revise its procedures as specified above. Finalized procedures must be
provided to the Southwest Region for review and approval.
Item 8: The Notice alleged that Enable’s procedures for conducting operations and maintenance
activities were inadequate to ensure safe operation of a pipeline facility in accordance with
VHFWLRQ 192.605(b)(1). Specifically, the Notice alleged that procedure D.47 Evaluation of
Remaining Strength Pipeline, revision date September 1, 2022, section 3, Applicability, did not
include adequate detail to conduct an accurate analysis of predicted failure pressure. The
procedure failed to address measurement uncertainties such as tool tolerance, detection threshold,
tool verification, and other potentially relevant data features in accordance with VHFWLRQ
192.712(e).
In its Response, Enable contested the allegation. Respondent stated that its procedure is used
only for in situ or in-the-ditch measurements of metal loss to determine remaining strength of
the pipe. Enable noted that VHFWLRQ 192.712(e)(1) states that an operator must account for
uncertainties in reported assessment results in identifying and characterizing the defects used in
predicted failure pressure analyses unless the defect dimensions have been verified using in situ
direct measurements. Respondent asserted that since the procedure uses in situ or in-the-ditch
measurements to determine remaining strength, uncertainties or tolerances are not required.
The Director reviewed Enable’s Response and the procedures cited therein and, per the Region
Recommendation, recommended ordering amendment of the procedure as proposed in the
Notice.
Having considered the record, Enable is correct that if defect dimensions are verified using in
situ direct measurements, uncertainties in reported assessment results in identifying and
characterizing the defects used in predicted failure pressure analyses is not required. See VHFWLRQ
192.712(e)(1). Had Respondent’s procedures included provisions for using LQOLQH LQVSHFWLRQ
ILI tools to size defects, or if evidence suggested Respondent intended to use ILI tools to size
defects, then the procedures would need to include processes for accounting for tool tolerances
and other measurement uncertainties. However, since the procedures cited in the Notice only
provide for the use of in situ measurements, provisions accounting for uncertainties in reported
assessment results are not necessary. Because Enable’s procedures only provide for in situ or in-
the-ditch measurements of metal loss to determine remaining strength of the pipe, I find the
procedures in place are not inadequate as alleged in the Notice for the currently used method.
Accordingly, after reviewing the evidence, I find that no further action is required.
Item 9: The Notice alleged that Enable’s procedures for the gathering of data needed for annual
and incident reporting under Part 191 in a timely and effective manner were inadequate to ensure
safe operation of a pipeline facility in accordance with VHFWLRQ 192.605(b)(4). Specifically, the



6
1RWLFH alleged procedure A.15 PHMSA-States-Incident Reporting failed to detail identifying all
Moderate Consequence Areas (MCAs). MCAs must be identified and included in the annual
and incident reporting. In addition, MCAs must be identified to comply with VHFWLRQV 192.624
and 192.710.
In its Response, Enable contested this allegation and asserted that its procedure is intended to
meet the requirements of Part 191, specifically VHFWLRQV 191.3, 191.5, and 191.15. It stated that
procedure MAOP Reconfirmation Plan and 192.710 Plan also address the requirements of
VHFWLRQV 192.624 and 192.710. In addition, Respondent stated that its procedures A.15 PHMSA-
States-Incident Reporting and A.16 Annual Reporting adhere to and refer to PHMSA’s reporting
instructions, which address MCAs. It further stated that procedure A.15 PHMSA-States-Incident
Reporting defines MCA. Enable provided exhibits showing this information with its Response.
The Director reviewed Enable’s Response and the information provided and, per the Region
Recommendation, determined that no further procedural revisions are necessary.
Accordingly, after reviewing the evidence, I find that Respondent needs to take no further action
regarding Item 9.
Under 49 CFR VHFWLRQ 190.243, Respondent may submit a Petition for Reconsideration of this
Final Order to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey
Avenue, SE, East Building, 2nd Floor, Washington, DC, 20590. The written petition must
contain a statement of the issue(s) and meet all other requirements of 49 CFR § 190.243. The
terms of the Order remain in effect until the Associate Administrator, upon request, grants a stay.
The terms and conditions of this Order are effective upon service in accordance with 49 CFR §
190.5.
Respondent must amend its procedures, as required above, and submit them to the Director,
PHMSA Southwest Region, OPS, within 30 days following receipt of this Order. The Director
may grant an extension of time to comply with any of the required items upon a written request
timely submitted by the Respondent and demonstrating good cause for an extension. Failure to
comply with this Order may result in administrative assessment of civil penalties exceeding
$200,000, as adjusted for inflation (see 49 CFR § 190.223 for adjusted amounts), for each
violation for each day the violation continues or in referral to the Attorney General for
appropriate relief in a district court of the United States.
LINDA GAIL
Digitally signed by LINDA
GAIL DAUGHERTY
DAUGHERTY
Date: 2025.08.28
19:08:52 -04'00' August 29, 2025___________________________________ ______________________
Linda Daugherty Date Issued
Acting Associate Administrator
for Pipeline Safety

42023046NOA_Closure Letter_01202026_(22-241127)_text.pdf

U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration 8701 S. Gessner, Suite 630
Houston TX 77074
VIA ELECTRONIC MAIL TO: tom.long@energytransfer.com
January 20, 2026
Thomas Long
Chief Executive Officer
Energy Transfer, LP
8111 Westchester Drive
Dallas, Texas 75225
CPF 4-2023-046 NOA
Dear Mr. Long:
From September 19, 2022 through January 12, 2023, representatives from the Pipeline and
Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States
Code, inspected Energy Transfer, LP (ET), Enable Gas Transmission, LLC (Enable) and Enable
Mississippi River Transmission, LLC (EMRT) in Oklahoma City, OK. As a result of the
inspection, ET was issued a Notice of Amendment (NOA) October 18, 2023, which proposed
actions to be taken.
ET submitted submitted required documentation on January 15, 2024 and September 25, 2025.
My staff reviewed the required documentation, and it appears that all requirements have been
satisfied.
This letter is to inform you that no further action is necessary and this case is now closed. Thank
you for your cooperation.
Sincerely,
Bryan Lethcoe
Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Greg McIlwain, Executive Vice President of Operations, Energy Transfer, LP,
gregory.mcilwain@energytransfer.com
Eric Amundsen, Senior Vice President of Operations, Energy Transfer, LP,
eric.amundsen@energytransfer.com



Todd Stamm, Senior Vice President of Operations, Energy Transfer, LP,
todd.stamm@energytransfer.com
Daniel Wentworth, Senior Vice President of Operations, Energy Transfer, LP,
daniel.wentworth@energytransfer.com
Jennifer Street, Senior Vice President of Operations Services, Energy Transfer, LP,
jennifer.street@energytransfer.com
Keegan Pieper, Deputy General Counsel, Energy Transfer, LP,
keegan.pieper@energytransfer.com
Matthew Stork, Vice President of Tech Services, Energy Transfer, LP,
matthew.stork@energytransfer.com
Todd Nardozzi, Director, DOT Compliance, Energy Transfer, LP,
todd.nardozzi@energytransfer.com
Susie Sjulin, Director, DOT Compliance, Energy Transfer, LP,
susie.sjulin@energytransfer.com
2

42023046NOA_Notice of Amendment_10182023_(22-241127)_text.pdf

NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: tom.long@energytransfer.com
October 18, 2023
Thomas Long
Chief Executive Officer
Energy Transfer Company
8111 Westchester Drive
Dallas, Texas 75225
CPF 4-2023-046-NOA
Dear Mr. Long:
From September 19, 2022, to January 12, 2023, representatives of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter
601 of 49 United States Code (U.S.C.) inspected Enable Gas Transmission, LLC procedures for
operations and maintenance in Oklahoma City, OK.
As a result of the inspection, PHMSA has identified the apparent inadequacies found within Enable
Gas Transmission, LLC’s procedures. The items inspected and the inadequacies are described
below:
1. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) . . . .
(b) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following,
if applicable, to provide safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in
accordance with each of the requirements of this subpart and subpart
M of this part.
§ 192.515 Environmental protection and safety requirements.
(a) In conducting tests under this subpart, each operator shall
insure that every reasonable precaution is taken to protect its
employees and the general public during the testing. Whenever the
hoop stress of the segment of the pipeline being tested will exceed 50



percent of SMYS, the operator shall take all practicable steps to
keep persons not working on the testing operation outside of the testing
area until the pressure is reduced to or below the proposed maximum
allowable operating pressure.
Enable’s written procedures for conducting operations and maintenance activities were inadequate
to assure safe operation of a pipeline facility in accordance with § 192.605(b)(1). Specifically,
Enable’s pressure testing procedure failed to adequately detail all reasonable precautions that may
be taken to protect employees and the general public during the testing in accordance with §
192.515(a).
C4.0105-Pressure Testing Execution, revision date April 1, 2022, Section 4.1 Safety, failed to
provide sufficient detail regarding safe distance. Enable listed a minimum distance of fifty feet,
but failed to detail how much additional distance might be necessary, and the analysis required to
establish a safe distance on pipelines where the listed minimum distance does not suffice in
accordance with § 192.515(a).
Therefore, Enable’s written procedures for conducting operations and maintenance activities were
inadequate to assure safe operation of a pipeline facility in accordance with § 192.605(b)(1).
Enable must revise its procedures as specified above.
2. § 192.607 Verification of Pipeline Material Properties and Attributes:
Onshore steel transmission pipelines.
(a) . . . .
(c) Verification of material properties and attributes. If an operator
does not have traceable, verifiable, and complete records required by
paragraph (b) of this section, the operator must develop and implement
procedures for conducting nondestructive or destructive tests,
examinations, and assessments in order to verify the material
properties of aboveground line pipe and components, and of buried line
pipe and components when excavations occur at the following
opportunities: Anomaly direct examinations, in situ evaluations,
repairs, remediations, maintenance, and excavations that are
associated with replacements or relocations of pipeline segments that
are removed from service. The procedures must also provide for the
following:
(1) For nondestructive tests, at each test location, material
properties for minimum yield strength and ultimate tensile strength
must be determined at a minimum of 5 places in at least 2
circumferential quadrants of the pipe for a minimum total of 10 test
readings at each pipe cylinder location.
(2) For destructive tests, at each test location, a set of material
properties tests for minimum yield strength and ultimate tensile
strength must be conducted on each test pipe cylinder removed from
each location, in accordance with API Specification 5L.
(3) Tests, examinations, and assessments must be appropriate for



verifying the necessary material properties and attributes.
(4) If toughness properties are not documented, the procedures
must include accepted industry methods for verifying pipe material
toughness.
(5) Verification of material properties and attributes for non-line
pipe components must comply with paragraph (f) of this section.
Enable’s written procedures for conducting nondestructive or destructive tests, examinations, and
assessments in order to verify the material properties of aboveground line pipe and components,
and of buried line pipe and components when excavations occur were inadequate to assure safe
operation of a pipeline facility in accordance with § 192.607(c). Specifically, Enable’s procedure,
I.43 Material Verification, (Rev. 1 - July 1, 2021), Section 7.2 Track Opportunistic Digs, failed to
include sufficient details regarding opportunistic digs. The coordination between various work
groups and responsibilities that groups have is not discussed with adequate specificity.
Therefore, Enable’s written procedures for conducting nondestructive or destructive tests,
examinations, and assessments in order to verify the material properties of aboveground line pipe
and components, and of buried line pipe and components when excavations occur were inadequate
to assure safe operation of a pipeline facility in accordance with § 192.607(c). Enable must revise
its procedure to describe the approach used to track locations needing material verification, the
methods to acquire needed data, the communication methods used to exchange needed and
gathered information between work groups and safeguards in place to ensure compliance with §
192.607(c).
3. § 192.607 Verification of Pipeline Material Properties and Attributes: Onshore steel
transmission pipelines.
(a) . . . .
(f) Components. For mainline pipeline components other than line
pipe, an operator must develop and implement procedures in
accordance with paragraph (c) of this section for establishing and
documenting the ANSI rating or pressure rating (in accordance with
ASME/ANSI B16.5 (incorporated by reference, see § 192.7)),
(1) Operators are not required to test for the chemical and
mechanical properties of components in compressor stations, meter
stations, regulator stations, separators, river crossing headers,
mainline valve assemblies, valve operator piping, or cross-connections
with isolation valves from the mainline pipeline.
(2) Verification of material properties is required for non-line pipe
components, including valves, flanges, fittings, fabricated assemblies,
and other pressure retaining components and appurtenances that are:
(i) Larger than 2 inches in nominal outside diameter,
(ii) Material grades of 42,000 psi (Grade X-42) or greater, or
(iii) Appurtenances of any size that are directly installed on the
pipeline and cannot be isolated from mainline pipeline pressures.



Enable’s written procedures for establishing and documenting the ANSI rating or pressure rating
were inadequate to assure safe operation of a pipeline facility in accordance with § 192.607(f).
Specifically, Enable’s procedure, I.43 Material Verification, (Rev. 1 - July 1, 2021), Section 7.3.3
Components, failed to provide adequate details regarding the material verification of non-line pipe
components. Enable failed to adequately describe how it will verify non-line components that
cannot be isolated from mainline pipeline pressures and methods it will use to gather information
needed in accordance with § 192.607(f).
Therefore, Enable’s written procedures for establishing and documenting the ANSI rating or
pressure rating were inadequate to assure safe operation of a pipeline facility in accordance with §
192.607(f). Enable must revise its procedures as specified above.
4. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) . . . .
(b) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following,
if applicable, to provide safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in
accordance with each of the requirements of this subpart and subpart
M of this part.
§ 192.609 Change in class location: Required study.
Whenever an increase in population density indicates a change in
class location for a segment of an existing steel pipeline operating at
hoop stress that is more than 40 percent of SMYS, or indicates that the
hoop stress corresponding to the established maximum allowable
operating pressure for a segment of existing pipeline is not
commensurate with the present class location, the operator shall
immediately make a study to determine:
(a) The present class location for the segment involved.
(b) The design, construction, and testing procedures followed in the
original construction, and a comparison of these procedures with those
required for the present class location by the applicable provisions of
this part.
(c) The physical condition of the segment to the extent it can be
ascertained from available records;
(d) The operating and maintenance history of the segment;
(e) The maximum actual operating pressure and the corresponding
operating hoop stress, taking pressure gradient into account, for the
segment of pipeline involved; and
(f) The actual area affected by the population density increase, and
physical barriers or other factors which may limit further expansion of
the more densely populated area.



Enable’s written procedures for conducting operations and maintenance activities were inadequate
to assure safe operation of a pipeline facility in accordance with § 192.605(b)(1). Specifically,
Enable’s procedure, B.12-Evaluating Class Location Changes, (June 28, 2022), Section 7.1 GIS
Review, failed to include adequate detail regarding incorporating updated or new GIS data into
existing class locations. The procedure failed to adequately detail how Enable incorporates newly
acquired pipeline assets and assets with updated pipeline and structure attributes into the GIS
system to determine if a class location study is required under § 192.609.
Therefore, Enable’s written procedures for conducting operations and maintenance activities were
inadequate to assure safe operation of a pipeline facility in accordance with § 192.605(b)(1).
Enable must revise its procedures as specified above.
5. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) . . . .
(b) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following,
if applicable, to provide safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in
accordance with each of the requirements of this subpart and subpart
M of this part.
§ 192.619 Maximum allowable operating pressure: Steel or plastic pipelines.
(a) No person may operate a segment of steel or plastic pipeline at a
pressure that exceeds a maximum allowable operating pressure
(MAOP) determined under paragraph (c), (d), or (e) of this section, or
the lowest of the following:
(1) The design pressure of the weakest element in the segment,
determined in accordance with subparts C and D of this part. However,
for steel pipe in pipelines being converted under § 192.14 or uprated
under subpart K of this part, if any variable necessary to determine the
design pressure under the design formula (§ 192.105) is unknown, one
of the following pressures is to be used as design pressure:
(i) Eighty percent of the first test pressure that produces yield
undersection N5 of Appendix N of ASME B31.8 (incorporated by
reference, see § 192.7), reduced by the appropriate factor in paragraph
(a)(2)(ii) of this section; or
(ii) If the pipe is 123⁄4 inches (324 mm) or less in outside diameter
and is not tested to yield under this paragraph, 200 p.s.i. (1379 kPa).
(2) The pressure obtained by dividing the pressure to which the
pipeline segment was tested after construction as follows:
(i) For plastic pipe in all locations, the test pressure is divided by a
factor of 1.5.
(ii) For steel pipe operated at 100 psi (689 kPa) gage or more, the
test pressure is divided by a factor determined in accordance with the
Table 1 to paragraph (a)(2)(ii):
Table 1 to Paragraph (a)(2)(ii)



Factors,1 2 segment -
Installed before
(Nov. 12, 1970)
Installed after
(Nov. 11, 1970)
and before
July 1, 2020
Installed on or
after July 1, 2020
Converted under
§ 192.14
1 1.1 1.1 1.25 1.25
2 1.25 1.25 1.25 1.25
3 1.4 1.5 1.5 1.5
4 1.4 1.5 1.5 1.5
1 For offshore pipeline segments installed, uprated or converted after
July 31, 1977, that are not located on an offshore platform, the factor
is 1.25. For pipeline segments installed, uprated or converted after July
31, 1977, that are located on an offshore platform or on a platform in
inland navigable waters, including a pipe riser, the factor is 1.5.
2 For a component with a design pressure established in accordance
with § 192.153(a) or (b) installed after July 14, 2004, the factor is 1.3.
Enable’s written procedures for conducting operations and maintenance activities were inadequate
to assure safe operation of a pipeline facility in accordance with § 192.605(b)(1). Specifically,
Enable’s procedure, B.10-Determination of MAOP, revision date February 1, 2020, Appendix B:
List of Hydro Test Factors for Class Location and Appendix C: Process Flow for Determination
of MAOP, failed to include all required information and contained errors.1 Appendix B failed to
include column three of Table 1 from § 192.619(a)(2)(ii) and Appendix C referenced an affidavit
referred to as a “Gold Sheet.”
Therefore, Enable’s written procedures for conducting operations and maintenance activities were
inadequate to assure safe operation of a pipeline facility in accordance with § 192.605(b)(1).
Enable must revise its procedures as specified above.
6. § 192.624 Maximum allowable operating pressure reconfirmation: Onshore steel
transmission pipelines.
(a) . . . .
(b) Procedures and completion dates. Operators of a pipeline subject
to this section must develop and document procedures for completing
all actions required by this section by July 1, 2021. These procedures
must include a process for reconfirming MAOP for any pipelines that
meet a condition of § 192.624(a), and for performing a spike test or
material verification in accordance with §§ 192.506 and 192.607, if
applicable. All actions required by this section must be completed
according to the following schedule:
(1) Operators must complete all actions required by this section on
1 Although Enable implemented this procedure prior to the effective date of the revisions to Table 1 §
192.619(a)(2)(ii), Enable indicated during the inspection that this version of the procedure is the most current and
has been used since the changes have been in effect.



at least 50% of the pipeline mileage by July 3, 2028.
(2) Operators must complete all actions required by this section on
100% of the pipeline mileage by July 2, 2035 or as soon as practicable,
but not to exceed 4 years after the pipeline segment first meets a
condition of § 192.624(a) (e.g., due to a location becoming a high
consequence area), whichever is later.
(3) If operational and environmental constraints limit an operator
from meeting the deadlines in § 192.624, the operator may petition for
an extension of the completion deadlines by up to 1 year, upon
submittal of a notification in accordance with § 192.18. The notification
must include an up-to-date plan for completing all actions in
accordance with this section, the reason for the requested extension,
current status, proposed completion date, outstanding remediation
activities, and any needed temporary measures needed to mitigate the
impact on safety.
Enable’s written procedures for reconfirming MAOP were inadequate to assure safe operation of
a pipeline facility in accordance with § 192.624(b). Specifically, Enable’s procedure, MAOP
Reconfirmation Plan, revision 1 (August 26, 2022), Section 2 MAOP Reconfirmation Committee,
failed to include adequate detail regarding Reconfirmation Committee activities. Enable failed to
adequately describe how the committee decides on an appropriate reconfirmation method, timing
of segments, appropriate intermediate reconfirmation goals, adjustments for acquisitions and
divestitures, and record keeping for associated decision making in accordance with § 192.624(b).
Therefore, Enable’s written procedures for reconfirming MAOP were inadequate to assure safe
operation of a pipeline facility in accordance with § 192.624(b). Enable must revise its procedures
as specified above.
7. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) . . . .
(b) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following,
if applicable, to provide safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in
accordance with each of the requirements of this subpart and subpart
M of this part.
§ 192.710 Transmission lines: Assessments outside of high consequence areas.
(a) . . . .
(b) General -
(1) . . . .
(3) Prior assessment. An operator may use a prior assessment
conducted before July 1, 2020 as an initial assessment for the pipeline
segment, if the assessment met the subpart O requirements of part 192
for in-line inspection at the time of the assessment. If an operator uses
this prior assessment as its initial assessment, the operator must



reassess the pipeline segment according to the reassessment interval
specified in paragraph (b)(2) of this section calculated from the date of
the prior assessment.
Enable’s written procedures for conducting operations and maintenance activities were inadequate
to assure safe operation of a pipeline facility in accordance with § 192.605(b)(1). Specifically,
Enable’s procedure, 192.710 ETC Gas Plan, revision 03 (April 15, 2022), Section 6.2 Periodic
Reassessments, failed to include adequate detail regarding the use and documentation of prior
assessments. The procedure failed to identify who will make the determination to use a prior
assessment, the associated timelines, how this determination will be made, and what records will
be generated to document this process in accordance with § 192.710(b)(3).
Therefore, Enable’s written procedures for conducting operations and maintenance activities were
inadequate to assure safe operation of a pipeline facility in accordance with § 192.605(b)(1).
Enable must revise its procedures as specified above.
8. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) . . . .
(b) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following,
if applicable, to provide safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in
accordance with each of the requirements of this subpart and subpart
M of this part.
§ 192.712 Analysis of predicted failure pressure.
(a) . . . .
(e) Data. In performing the analyses of predicted or assumed
anomalies or defects in accordance with this section, an operator must
use data as follows.
(1) An operator must explicitly analyze and account for
uncertainties in reported assessment results (including tool tolerance,
detection threshold, probability of detection, probability of
identification, sizing accuracy, conservative anomaly interaction
criteria, location accuracy, anomaly findings, and unity chart plots or
equivalent for determining uncertainties and verifying tool
performance) in identifying and characterizing the type and
dimensions of anomalies or defects used in the analyses, unless the
defect dimensions have been verified using in situ direct measurements.
(2) The analyses performed in accordance with this section must
utilize pipe and material properties that are documented in traceable,
verifiable, and complete records. If documented data required for any
analysis is not available, an operator must obtain the undocumented
data through § 192.607. Until documented material properties are
available, the operator shall use conservative assumptions as follows:
(i) Material toughness. An operator must use one of the following



for material toughness:
(A) Charpy v-notch toughness values from comparable pipe with
known properties of the same vintage and from the same steel and pipe
manufacturer;
(B) A conservative Charpy v-notch toughness value to determine
the toughness based upon the ongoing material properties verification
process specified in § 192.607;
(C) If the pipeline segment does not have a history of reportable
incidents caused by cracking or crack-like defects, maximum Charpy
v-notch toughness values of 13.0 ft.-lbs. for body cracks and 4.0 ft.-lbs.
for cold weld, lack of fusion, and selective seam weld corrosion defects;
(D) If the pipeline segment has a history of reportable incidents
caused by cracking or crack-like defects, maximum Charpy v-notch
toughness values of 5.0 ft.-lbs. for body cracks and 1.0 ft.-lbs. for cold
weld, lack of fusion, and selective seam weld corrosion; or
(E) Other appropriate values that an operator demonstrates can
provide conservative Charpy v-notch toughness values of crack-related
conditions of the pipeline segment. Operators using an assumed
Charpy v-notch toughness value must notify PHMSA in advance in
accordance with § 192.18 and include in the notification the bases for
demonstrating that the Charpy v-notch toughness values proposed are
appropriate and conservative for use in analysis of crack-related
conditions.
(ii) Material strength. An operator must assume one of the following
for material strength:
(A) Grade A pipe (30,000 psi), or
(B) The specified minimum yield strength that is the basis for the
current maximum allowable operating pressure.
(iii) Pipe dimensions and other data. Until pipe wall thickness,
diameter, or other data are determined and documented in accordance
with § 192.607, the operator must use values upon which the current
MAOP is based.
Enable’s written procedures for conducting operations and maintenance activities were inadequate
to ensure safe operation of a pipeline facility in accordance with § 192.605(b)(1). Specifically,
Enable’s procedure, D.47 Evaluation of Remaining Strength Pipeline, revision September 1, 2022,
Section 3.0 Applicability, failed to include adequate detail to conduct an accurate analysis of
predicted failure pressure. The procedure failed to address measurement uncertainties such as tool
tolerance, detection threshold, tool verification, and other potentially relevant data features in
accordance with § 192.712(e).
Therefore, Enable’s written procedures for conducting operations and maintenance activities were
inadequate to assure safe operation of a pipeline facility in accordance with § 192.605(b)(1).
Enable must revise its procedures as specified above.



9. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) . . . .
(b) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following,
if applicable, to provide safety during maintenance and operations.
(1) . . . .
(4) Gathering of data needed for reporting incidents under Part 191
of this chapter in a timely and effective manner.
Enable’s written procedures for the gathering of data needed for reporting incidents under Part 191
of this chapter in a timely and effective manner were inadequate to ensure safe operation of a
pipeline facility in accordance with § 192.605(b)(4). Specifically, Enable’s procedure A.15
PHMSA-States-Incident Reporting failed to detail identifying all Moderate Consequence Areas
(MCAs). MCAs must be identified and included in the annual and incident reporting.
Additionally, MCAs must be identified to comply with §§ 192.624 and 192.710.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as
part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance
Proceedings.
Please refer to this document and note the response options. 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. § 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 qualifies for confidential treatment under
5 U.S.C. § 552(b).
Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of
receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice
and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice
without further notice to you and to issue an Order Directing Amendment. If your plans or
procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans
or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this
Notice, we propose that you submit your amended procedures to my office within 90 days of
receipt of this Notice. This period may be extended by written request for good cause. Once the
inadequacies identified herein have been addressed in your amended procedures, this enforcement
action will be closed.



It is requested (not mandated) that Enable Gas Transmission, LLC maintain documentation of the
safety improvement costs associated with fulfilling this Notice of Amendment
(preparation/revision of plans, procedures) and submit the total to Bryan Lethcoe, Director,
Southwest Region, Pipeline and Hazardous Materials Safety Administration. In correspondence
concerning this matter, please refer to CPF 4-2023-046-NOA and, for each document you submit,
please provide a copy in electronic format whenever possible.
Sincerely,
Bryan Lethcoe
Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
cc: Mr. Greg McIlwain, Executive Vice President of Operations, Energy Transfer, LP,
gregory.mcilwain@energytransfer.com
Mr. Eric Amundsen, Senior Vice President of Operations, Energy Transfer, LP,
eric.amundsen@energytransfer.com
Mr. Todd Stamm, Senior Vice President of Operations, Energy Transfer, LP,
todd.stamm@energytransfer.com
Ms. Jennifer Street, Senior Vice President of Operations Services, Energy Transfer, LP,
jennifer.street@energytransfer.com
Ms. Heidi Murchison, Chief Counsel, Energy Transfer, LP,
heidi.murchison@energytransfer.com
Mr. Leif Jensen, Vice President of Tech Services, Energy Transfer, LP,
leif.jensen@energytransfer.com
Mr. Todd Nardozzi, Director, Regulatory Compliance, Energy Transfer, LP,
todd.nardozzi@energytransfer.com
Ms. Susie Sjulin, Director, Regulatory Compliance, Energy Transfer, LP,
susie.sjulin@energytransfer.com

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/42023046NOA>
- Source ID: `phmsa-enforcement`
- SHA-256: `bf0388ea774d8f5c5087afa25f585d9c2ee4e860e224daa2cb16f1c67f84971c`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-24T04:36:16.257Z
- Document slug: `phmsa-enforcement-42023046noa`

### Source metadata

```json
{
  "cpf": "42023046NOA",
  "operator": "ENABLE GAS TRANSMISSION, LLC",
  "region": "Southwest",
  "pipelineType": "INTERSTATE GAS TRANSMISSION",
  "caseStatus": "CLOSED",
  "citedSections": [
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    "192.609",
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    "192.624(b)",
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  "dataAsOf": "08/04/2026 12PM",
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  "jurisdiction": "US",
  "operatorName": "ENABLE GAS TRANSMISSION, LLC"
}
```