{"operation":"document","citation":"CPF 12021033NOA","title":"ENABLE GAS TRANSMISSION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-04-01","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(d)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021033noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021033noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021033noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12021033NOA","body":"Notice of Amendment involving ENABLE GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(d)(4). The case was opened on 2021-04-01 and is reported as closed as of 2021-05-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12021033NOA_Closure Letter_05202021_(20-173596).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021033NOA/12021033NOA_Closure%20Letter_05202021_(20-173596).pdf\n\n12021033NOA_Closure Letter_05202021_(20-173596)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021033NOA/12021033NOA_Closure%20Letter_05202021_(20-173596)_text.pdf\n\n12021033NOA_Notice of Amendment_04012021_(20-173596).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021033NOA/12021033NOA_Notice%20of%20Amendment_04012021_(20-173596).pdf\n\n12021033NOA_Notice of Amendment_04012021_(20-173596)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021033NOA/12021033NOA_Notice%20of%20Amendment_04012021_(20-173596)_text.pdf\n\n12021033NOA_Operator Response to Notice_05032021_(20-173596).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021033NOA/12021033NOA_Operator%20Response%20to%20Notice_05032021_(20-173596).pdf\n\n12021033NOA_Notice of Amendment_04012021_(20-173596)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nApril 1, 2021\nCary Watson\nVice President Technical Services\nEnable Gas Transmission, LLC\n499 W. Sheridan, Suite 1500\nOklahoma City, OK 73102\nCPF 1-2021-033-NOA\nDear Mr. Watson:\nOn November 4, 5 and 18, 2020, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Enable Gas\nTransmission, LLC’s (EGT) procedures for its Ruston underground natural gas storage operations\nin Lincoln County, Louisiana.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within EGT’s\nplans or procedures, as described below:\n1. § 192.12 Underground natural gas storage facilities.\n(a) …\n(d) Integrity management program—\n(1) …\n(4) Integrity management procedures and recordkeeping. Each\nUNGSF operator must establish and follow written procedures to carry\nout its integrity management program under API RP 1171\n(incorporated by reference, see § 192.7), section 8 (\"Risk Management\nfor Gas Storage Operations\"), and this paragraph (d). The operator\nmust also maintain, for the useful life of the UNGSF, records that\ndemonstrate compliance with the requirements of this paragraph (d).\nThis includes records developed and used in support of any\nidentification, calculation, amendment, modification, justification,\n\n\n\nCPF 1-2021-033-NOA\ndeviation, and determination made, and any action taken to\nimplement and evaluate any integrity management program element.\nEGT’s written procedures for carrying out its integrity management program under API RP 1171,\nSection 8 were inadequate. Specifically, EGT did not have a process to assess threat and hazard\ninteraction in accordance with API RP 1171, Section 8.3.2 (Section 8.3.2).\nSection 8.3.2 states in part:\nThe operator shall use available information such as performance data collected through the\nfield history, operations and maintenance (O&M) activities, geotechnical data such as well\nlogs, engineering data, and completion reports to determine susceptibility to threat and\nhazard-related events and to assess threat and hazard interaction.\nDuring the inspection, EGT reported that they had not established a procedure to assess threats\nand hazard interaction.\nTherefore, EGT’s written procedures required by § 192.12(d)(4) were inadequate. EGT must\nrevise its procedures to include how it will assess threat and hazard interaction in accordance with\nSection 8.3.2.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. 552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 30 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\n12021033NOA_Notice of Amendment_04012021_(20-173596)_text Page 2 of 3\n\n\n\nCPF 1-2021-033-NOA\nIt is requested (not mandated) that Enable Gas Transmission, LLC maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director,\nEastern Region, Pipeline and Hazardous Materials Safety Administration, 840 Bear Tavern Road,\nSuite 300, West Trenton, NJ 08628. In correspondence concerning this matter, please refer to CPF\n1-2021-033-NOA and, for each document you submit, please provide a copy in electronic format\nwhenever possible. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should\nbe sent on USB flash drive accompanied by the original paper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n12021033NOA_Notice of Amendment_04012021_(20-173596)_text Page 3 of 3\n\n12021033NOA_Closure Letter_05202021_(20-173596)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nMay 20, 2021\nMr. Cary Watson\nVice President Technical Services\nEnable Gas Transmission, LLC\n499 W. Sheridan, Suite 1500\nOklahoma City, OK 73102\nCPF 1-2021-033-NOA\nDear Mr. Watson:\nOn November 4, 5, and 18, 2020, representatives from the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an\nunderground natural gas storage inspection of Enable Gas Transmission, LLC’s (EGT) procedures\nin Lincoln County, Louisiana. As a result of the inspection, EGT was issued a Notice of\nAmendment on April 1, 2021, which proposed amendment of your procedures.\nEGT submitted its amended procedures on May 3, 2021. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":7797}