ENABLE GAS TRANSMISSION, LLC — Warning Letter

220071007w_ warning letter_04182007_text.pdf, page 1Official PDF233 peachtree Street Ste 600 Atlanta GA 30303 u 5 Department of Transportation Pipeline and Hazardous Materials Safety Administration WARNING LETTER CERTIFIED MAIL - RETURN RECEIPT RE UESTKD April 18, 2007 Mr Walter Ferguson Sensor Vtce President CenterPoint Energy Gas Transmission 1100 Loiusiana Street, Suite 1120 Houston, Texas 77002 CPF 2-2007-1007W Dear Mr Ferguson On September 25 — 28, 2006, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your records in Wynne, Arkansas and pipeline facilities in Arkansas, Tennessee, and Mississippi As a result of the inspection, it appears that you have committed a probable violation of the Pipehne Safety Regulations Title 49, Code of Federal Regulations The item inspected and the probable violation is f1192. 491 Corrosion control records. (c) Each operator shall maintain a record of each test, survey, or mspection required by this subpart in sufficient detad to demonstrate the adequacy of corrosion control measures or that a corrosive condition does not exist. These records must be retained for at least 5 years, except that records related to @192. 465(a) and (e) and 192. 475(b) must be retained for as long as the pipehne remains m service. f1192. 481 Atmospheric corrosion control: Monitoring (a) Each operator must inspect each pipehne or portion of pipeline that is exposed to the atmosphere for evidence of atmospheric corrosion, as follows:#

220071007w_ warning letter_04182007_text.pdf, page 2If the i ehne is located: Onshore Offshore Then the fre uenc of ins ection is: At least once every 3 calendar years, but with intervals not exceedin 39 months At least once ach calendar year, but with mtervals not exceedm 15 months CenterPoint did not have a record of an atmospheric corrosion inspection of the aboveground piping at the Helena, Arkansas compressor station witlun the required inspection penod at the time of the inspection The last documented atmosphenc corrosion inspection of Helena Compressor Station's above ground piping was on February 20, 2003 wluch exceeded the required interval by 4 months and 15 days on September 25, 2006 CenterPoint's procedures specify that the compressor station aboveground yard piping will be inspected annually dunng the annual block valve maintenance, the block valve maintenance records did not document an atmospheric corrosion inspection Under 49 United States Code, $ 60122, you are sublect to a civil penalty not to exceed $100, 000 for each violation for each day the violations 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 action or penalty assessment proceedings at this time We advise you to correct the item(s) identified in tlus letter Be advised that fiulure to do so will result in CenterPoint being sublect to additional enforcement action No reply to this letter is required If you choose to reply, in your correspondence please refer to CPF 2-2007-1007W Be advised that all material you submit in response to this enforcement action is sublect to being made publicly avadable If you believe that any portion of your responsive matenal quahfies for confidential treatment under 5 U S C 552(b), along with the complete onginal document you must provide a second copy of the document with the portions you beheve qualify for confidential treatment redacted and an explanation of why you believe the redacted information quahfies for confidential treatment under 5 U S C 552(b) Linda Daugherty Director, Southern Region Pipeline and Hazardous Matenals Safety Administration#