{"operation":"document","citation":"CPF 220071012W","title":"ENABLE GAS TRANSMISSION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-06-06","effective_on":null,"summary":"CLOSED warning letter citing 192.805(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220071012w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220071012w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220071012w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220071012W","body":"Warning Letter involving ENABLE GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.805(a). The case was opened on 2007-06-06 and is reported as closed as of 2007-06-06. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220071012W_warning letter_06062007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071012W/220071012W_warning%20letter_06062007.pdf\n\n220071012w_warning letter_06062007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071012W/220071012w_warning%20letter_06062007_text.pdf\n\n220071012w_warning letter_06062007_text.pdf\n\nU 5 Department\noi Transportation\nPipeline and\nHazardous Materials Safettr\nAdministration\n233 Peachtree Street Ste 600\nAiiahta, GA 30303\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nJune 6, 2007\nMr Walter Ferguson\nSr Vice President and Chief Operatmg Officer\nCenterpoint Energy Gas Transnussion\n1111 Loissian, Suite 1120\nHouston, TX 77002\nCPF 2-2007-1012W\nDear Mr Ferguson\nBetween August 21, 2006 and November 3, 2006, a representanve of the Pipehne and\nHazardous Matenals Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United\nStates Code inspected your Centerpoint Energy Gas Transmission pipeline facilities and\nrecords in the Malvern, Russellville, and Carhsle Team areas in Arkansas\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulanons, Title 49, Code of Federal Regulations The item inspected and the\nprobable violation are\ntl192. 805 Qualification program.\nEach operator shall have and follow a written quahfication program. The\nprogram shall include provisions to:\n(a) Identify covered tasks. . .\nYour wntten operator quahfication program (OQ program) is not adequate in that an\nactivity bemg performed by maintenance employees that meets the four part test\nrequirements of $192 801(b)(1-4) has not been identified as a covered task\n\n\n\nThe activity of conducting performance tests on compressor station gas detection and\nalarm systems required of $192 736(c) is not included in your DOT Operator\nQuahficarion Acnvines Summary document, which hsts the covered tasks included in\nyour OQ program This activity meets the four part test in that it (I) is performed on a\npipeline facihty, (2) is an operations or mamtenance task, (3) is performed as a\nrequirement of this part, and (4) affects the operation or integrity of the pipehne\nPHMSA understands that the referenced activity is included m your Mechanical Skill\nLevel quahfication program, and that it is to be added to your OQ program later tlus\nyear\nUnder 49 United States Code, f 60122, you are sub) ect to a civil penalty not to exceed\n$100, 000 for each violation for each day the violation persists up to a maxunum of $1, 000, 000\nfor any related series of violations We have reviewed the circumstances and supportmg\ndocuments involved in this case, and have decided not to conduct additional enforcement action\nor penalty assessment proceechngs at this time We advise you to correct the item(s) identifie\nin this letter Fadure to do so will result in Centerpoint Energy Gas Transmission being sub)ect\nto additional enforcement action\nNo reply to this letter is required If you choose to reply, in your correspondence please refer to\nCPF 2-2007-1012W. Be advised that all matenal you submit in response to this enforcement\naction is sublect to being made pubhcly avadable If you beheve that any portion of your\nresponsive material quahfies for confidential ueatment under 5 U S C 552(b), along with the\ncomplete onginal document you must provide a second copy of the document with the portions\nyou believe quahfy for confidential treatment redacted and an explanation of why you beheve\nthe redacted information qualifies for confidential treatment under 5 U S C 552(b)\nLinda Daugherty\nDirector, Southern Region\nPipeline and Hazardous Matenals Safety Administration\nEnclosure Response Opnons for Pipehne Operators m Comphance Proceedmgs","truncated":false,"body_characters":4051}