ENABLE GAS TRANSMISSION, LLC — Warning Letter

220071012w_warning letter_06062007_text.pdf, page 1Official PDFU 5 Department oi Transportation Pipeline and Hazardous Materials Safettr Administration 233 Peachtree Street Ste 600 Aiiahta, GA 30303 WARNING LETTER CERTIFIED MAIL - RETURN RECEIPT RE UESTED June 6, 2007 Mr Walter Ferguson Sr Vice President and Chief Operatmg Officer Centerpoint Energy Gas Transnussion 1111 Loissian, Suite 1120 Houston, TX 77002 CPF 2-2007-1012W Dear Mr Ferguson Between August 21, 2006 and November 3, 2006, a representanve of the Pipehne and Hazardous Matenals Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your Centerpoint Energy Gas Transmission pipeline facilities and records in the Malvern, Russellville, and Carhsle Team areas in Arkansas As a result of the inspection, it appears that you have committed a probable violation of the Pipeline Safety Regulanons, Title 49, Code of Federal Regulations The item inspected and the probable violation are tl192. 805 Qualification program. Each operator shall have and follow a written quahfication program. The program shall include provisions to: (a) Identify covered tasks. . . Your wntten operator quahfication program (OQ program) is not adequate in that an activity bemg performed by maintenance employees that meets the four part test requirements of $192 801(b)(1-4) has not been identified as a covered task#

220071012w_warning letter_06062007_text.pdf, page 2The activity of conducting performance tests on compressor station gas detection and alarm systems required of $192 736(c) is not included in your DOT Operator Quahficarion Acnvines Summary document, which hsts the covered tasks included in your OQ program This activity meets the four part test in that it (I) is performed on a pipeline facihty, (2) is an operations or mamtenance task, (3) is performed as a requirement of this part, and (4) affects the operation or integrity of the pipehne PHMSA understands that the referenced activity is included m your Mechanical Skill Level quahfication program, and that it is to be added to your OQ program later tlus year Under 49 United States Code, f 60122, you are sub) ect to a civil penalty not to exceed $100, 000 for each violation for each day the violation persists up to a maxunum of $1, 000, 000 for any related series of violations We have reviewed the circumstances and supportmg documents involved in this case, and have decided not to conduct additional enforcement action or penalty assessment proceechngs at this time We advise you to correct the item(s) identifie in this letter Fadure to do so will result in Centerpoint Energy Gas Transmission being sub)ect to additional enforcement action No reply to this letter is required If you choose to reply, in your correspondence please refer to CPF 2-2007-1012W. Be advised that all matenal you submit in response to this enforcement action is sublect to being made pubhcly avadable If you beheve that any portion of your responsive material quahfies for confidential ueatment 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 believe quahfy for confidential treatment redacted and an explanation of why you beheve the redacted information qualifies for confidential treatment under 5 U S C 552(b) Linda Daugherty Director, Southern Region Pipeline and Hazardous Matenals Safety Administration Enclosure Response Opnons for Pipehne Operators m Comphance Proceedmgs#