{"operation":"document","citation":"CPF 220071017","title":"ENABLE GAS TRANSMISSION, LLC — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-10-17","effective_on":null,"summary":"CLOSED notice of probable violation citing 192.465(a), 192.465(d), 192.491(c), 192.605, 192.625, 192.625(b)(1), 192.625(b)(3), 192.625(f), 192.736, 192.743(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220071017.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220071017.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220071017","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220071017","body":"Notice of Probable Violation involving ENABLE GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.465(a),  192.465(d),  192.491(c),  192.605,  192.625,  192.625(b)(1),  192.625(b)(3),  192.625(f),  192.736,  192.743(b). The case was opened on 2007-10-17 and is reported as closed as of 2010-03-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220071017_ Final Order_03172010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071017/220071017_%20Final%20Order_03172010.pdf\n\n220071017_ Final Order_03172010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071017/220071017_%20Final%20Order_03172010_text.pdf\n\n220071017_nopv letter_10172007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071017/220071017_nopv%20letter_10172007.pdf\n\n220071017_nopv letter_10172007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071017/220071017_nopv%20letter_10172007_text.pdf\n\n220071017_operator_response_to_notice_and_request_extension_11162007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071017/220071017_operator_response_to_notice_and_request_extension_11162007.pdf\n\n220071017_ Final Order_03172010_text.pdf\n\nMAR 17 2010\nMr. Walter Ferguson\nSr. Vice President and Chief Operating Officer\nCenterPoint Energy Gas Transmission Company\n1111 Louisiana, Suite 1120\nHouston, TX 77002\nRE: CPF No. 2-2007-1017\nDear Mr. Ferguson:\nEnclosed is the Final Order issued in the above-referenced case. It makes findings of violation\nand finds that CenterPoint Energy Gas Transmission has completed the actions specified in the\nNotice to comply with the pipeline safety regulations. Therefore, this case is now closed.\nService of the Final Order by certified mail is deemed effective upon the date of mailing, or as\notherwise provided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. John Cavitt, Manager of DOT Compliance, CenterPoint Energy\nMr. Mohammed Shoaib, Acting Director, Southern Region, PHMSA\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED [7009 1410 0000 2472 5187]\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n________________________________________________\nIn the Matter of )\nCenterPoint Energy Gas Transmission Company, ) CPF No. 2-2007-1017\n)\n)\n)\nRespondent. )\n________________________________________________)\nFINAL ORDER\nBetween August 21 and November 3, 2006, pursuant to 49 U.S.C. § 60117, a representative of\nthe Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS), conducted an on-site pipeline safety inspection of the facilities and records of\nCenterPoint Energy Gas Transmission Company (CEGT or Respondent) in the company’s\nMalvern, Russellville, and Carlisle Team Areas in Arkansas. Respondent, a subsidiary of\nCenterPoint Energy, Inc., operates two interstate natural gas pipeline systems consisting of\napproximately 8,000 miles of pipe.\nAs a result of the inspection, the Director, Southern Region, OPS (Director), issued to\nRespondent, by letter dated October 17, 2007, a Notice of Probable Violation and Proposed\nCompliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed\nfinding that Respondent had committed various violations of 49 C.F.R. Part 192. The Notice\nalso proposed ordering Respondent to take certain measures to correct the alleged violations.\nIn a letter dated November 16, 2007, Respondent requested a 30-day extension of time to\nrespond to the Notice. Respondent was granted an extension and responded to the Notice by\nletter dated December 19, 2007 (Response). Respondent did not contest the allegations of\nviolation but provided information concerning the corrective actions it had taken. Respondent\ndid not request a hearing and therefore has waived its right to one.\nFINDINGS OF VIOLATION\nIn its Response, CEGT did not contest the allegations in the Notice that it violated 49 C.F.R. Part\n\n\n\n192, as follows:\nItem 1A: The Notice alleged that Respondent violated 49 C.F.R. § 192.465(a), which states:\n§ 192.465 External corrosion control: Monitoring.\n(a) Each pipeline that is under cathodic protection must be tested at\nleast once each calendar year, but with intervals not exceeding 15 months,\nto determine whether the cathodic protection meets the requirements of\n§ 192.463.\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.465(a) by failing to test\ncathodically protected pipelines at least once each calendar year, with intervals not exceeding 15\nmonths. Cathodic protection survey records indicated the following:\n- Cathodic protection tests were conducted on 7/7/04 and 12/19/05 at Piney\nCompressor Station and Tates Island Compressor Station, exceeding the 15-\nmonth maximum time interval by 2 months, 12 days.\n- Cathodic protection tests were not conducted at the Tates Island compressor\ndischarge header test point in calendar years 2004 and 2005.\n- The underground piping in the Clarksville compressor yard (includes a 500 hp\ncompressor and a glycol dehydration unit) was not monitored for cathodic\nprotection. No survey test point(s) had been established for these locations.\n- The underground heater piping at the Vilonia Town Border Station, the nearby\n(to Vilonia TBS) buried main line valve, and multiple underground piping\nlocations inside the North Little Rock (Bobbitt Lane) meter station yard\n(downstream of the inlet side of the station) were not monitored for cathodic\nprotection. No survey test point(s) had been established for these locations.\nIn its Response, CEGT explained that its Tates Island Compressor, the Piney Compressor\nStation, and the Russellville Team Compressor Stations had been set up in its Maintenance\nManagement System (MMS). The Tates Island Compressor now had 8 test points in its MMS\nand the Piney Compressor had 16 test points in its MMS. Respondent advised that its Clarksville\nCompressor now had 8 test points and that it was taking a pipe-to-soil reading on Line BT-3 at\nthe Clarksville compressor site. The Morrison Bluff Compressor now had 8 tests points.\nRespondent’s Moreland Compressor now had 10 test points in the MMS and the Round\nMountain Compressor had 17 test points. Respondent also advised that all readings now met the\n100mV criterion.\nRespondent also advised that the underground heater piping at the Vilonia Town Border Station\nwas now set up as a test point in its MMS, along with 4 additional tests points. The nearby main\nline valve to the Vilonia Town Border was also set up as a test point. The North Little Rock\n(Bobbitt Lane) meter station had an additional 6 test points. In addition, 11 tests points had been\n\n\n\n2\nset up for the JM-30/A-294/BT-14 interconnects. A deep-well ground bed was installed at the\nJM-30/A-294/BT-14 interconnect, which brought the readings at the Vilonia Town Border\nStation above criteria. A piping re-coat and anode installation at the North Little Rock (Bobbitt\nLane) meter station brought the pipe-to-soil readings at that station above criteria.\nRespondent did not contest this allegation of violation. Failure to perform the proper monitoring\non pipelines could result in inadequate protection of the pipe and future leaks. Accordingly, after\nconsidering all the evidence, I find that Respondent violated 49 C.F.R. 192.465(a) by failing to\ntest cathodically protected pipelines at least once each calendar year, with intervals not\nexceeding 15 months.\nItem 1B: The Notice alleged that Respondent violated 49 C.F.R. § 192.465(d), which states:\n§ 192.465 External corrosion control: Monitoring.\n(a) . . .\n(d) Each operator shall take prompt remedial action to correct any\ndeficiencies indicated by the monitoring.\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.465(d) by failing to take prompt\nremedial action to correct indicated deficiencies. Specifically, the Notice alleged that CEGT had\nfailed to take remedial action with regard to the following Tates Island facilities that had not\nbeen under cathodic protection. Tates Island is in a remote location. Those facilities included:\n- Tates Island suction 4” riser (Test point added to survey list in 2004. The 2004\ndepolarization survey indicated “static” p/s = -0.435v). The below readings failed\nto indicate that the pipeline met the cathodic protection 100 mV criterion:\n- 07/07/04: p/s = -0.509v(on), -0.484v(off). This indicates that the\n100mV cathodic protection criterion was not achieved.\n- 12/19/05: p/s = -0.61v(on). This reading by itself does not indicate\nthat the 100mV criterion was achieved.\n- Tates Island 2” U-shape (2004 depolarization survey indicated “static” p/s = -\n0.447v).\n- 07/07/04: p/s = -0.544v(on), -0.516v(off). This indicates that the\n100mV cathodic protection criterion was not achieved.\n- 12/19/05: p/s = -0.59v(on). This reading by itself does not\nindicate that the 100mV criterion was achieved.\nIn its Response, CEGT explained that anodes had been installed near the suction 4” riser at Tates\nIsland. Respondent also set up the 4” riser in its MMS as a monitoring test point. Respondent\nadvised that the current readings now met the 100mV criterion. Respondent also indicated that\nwith its installation of anodes at the Tates Island Compressor, the 2” U-shape fuel gas measuring\nand regulator (M&R) now complied with the 100mV criterion. Respondent added the\nmonitoring point to its MMS.\n\n\n\n3\nRespondent did not contest this allegation of violation. The risk of corrosion on a pipeline\nsignificantly increases when the line lacks proper cathodic protection systems. Preventive\nmaintenance is critical to the safety of the public, environment and property. Failure to identify\nand correctly manage potential threats could increase the risk of avoidable incidents and harm to\npublic safety. Accordingly, after considering all the evidence, I find that Respondent violated 49\nC.F.R. § 192.465(d) by failing to take prompt remedial action to correct indicated cathodic\nprotection deficiencies.\nItem 1C: The Notice alleged that Respondent violated 49 C.F.R. § 192.491(c), which states:\n§ 192.491 Corrosion control records.\n(a) . . .\n(c) Each operator shall maintain a record of each test, survey, or\ninspection required by this subpart in sufficient detail to demonstrate the\nadequacy of corrosion control measures or that a corrosive condition does\nnot exist. These records must be retained for at least 5 years, except that\nrecords related to §§ 192.465(a) and (e) and 192.475(b) must be retained\nfor as long as the pipeline remains in service.\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.491(c) by failing to maintain\nannual corrosion survey records. Specifically, the Notice alleged that numerous pipeline\ninspection test point records reviewed at the Malvern Office did not reflect correct survey data.\nRespondent’s original survey records had been retained and were available during the review.\nA review of the original survey records and the company’s MMS records further highlighted\ndiscrepancies in the annual corrosion survey records.\nIn its Response, CEGT did not contest the allegation of violation but explained that it had\ndiscovered an MMS programming error in the records provided to PHMSA during the\ninspection. The records had incorrect “depolarized off” readings for the 100mV-criteria\npipelines. The MMS had apparently been changing the “depolarized off” readings for the\n100mV-criteria pipeline test points for the preceding years. Respondent advised that it had\ncorrected the problem after the PHMSA inspection. CEGT implemented a process change\nshortly after the inspection with Procedure PS-03-02-100,\n“External Corrosion Control-Buried\nPipe,\n” and Procedure PS-03-02-212,\n“Cathodic Protection-Data Evaluation.\n” Respondent also\nadvised that it had developed a 100mV data graph evaluation tool for technicians and specialists\nto use in the internal audit oversight of the 100mV-criteria pipelines.\nCorrosion, both external and internal, is one of the conditions most threatening to the integrity of\npipelines; if left undetected, corrosion can result in the rupture of a pipeline. Respondent is\nresponsible for compliance with the pipeline safety regulations, which includes sound record\nkeeping. Without such historical records, an operator would have difficulty determining areas\nwhere there are problems that need to be addressed. Accordingly, after considering all the\nevidence, I find that Respondent violated 49 C.F.R. § 192.491(c) by failing to maintain annual\ncorrosion survey records.\n\n\n\n4\nItem 2: The Notice alleged that Respondent violated 49 C.F.R. § 192.605(b)(3), which states:\n§ 192.605 Procedural manual for operations, maintenance, and\nemergencies.\n(a) . . .\n(b) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following, if\napplicable, to provide safety during maintenance and operations. . .\n(1) . . .\n(3) Making construction records, maps, and operating history\navailable to appropriate operating personnel.\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.605(b)(3) by failing to make\nadequate maps and operating history available to appropriate operating personnel. Specifically,\nthe Notice alleged that Respondent had failed to update certain records as follows:\n- An Emergency Plan Book issued to one of the employees at Carlisle\nStation was not up to date. The listed MAOP of Line BM-21 was 500 psig,\nbut it had been lowered from 500 psig to 400 psig on 8/17/05.\n- There was no pipeline schematic in the Emergency Plan Book for the\npipeline facilities at the Conway Town Border station site. There are two\nmeter stations and a pipeline inter-connect (Lines BT-19 and BM-1) at the\nsite.\n- The Perla operating schematic was incorrect. A relief valve located on\nvalve A-48 was not indicated, valves A-47 and A-48 were numbered\nincorrectly, and a relief valve indicated on top of valve S-19 did not exist.\nThe Notice did not propose a civil penalty or compliance order for this item. Therefore, this is\nconsidered to be a warning item. Respondent presented information in its Response showing\nthat it had taken certain actions to address this item. Having considered such information, I find,\npursuant to 49 C.F.R. § 190.205, that a probable violation of 49 C.F.R. § 192.605(b)(3) has\noccurred and Respondent is hereby advised to correct such conditions. In the event that OPS\nfinds a violation of this provision in a subsequent inspection, Respondent may be subject to\nfuture enforcement action.\nItem 3: The Notice alleged that Respondent violated 49 C.F.R. § 192.625(b)(1) and (b)(3),\nwhich state:\n§ 192.625 Odorization of gas.\n(a) A combustible gas in a distribution line must contain a natural\nodorant or be odorized so that at a concentration in air of one-fifth of the\nlower explosive limit, the gas is readily detectable by a person with a\nnormal sense of smell.\n\n\n\n5\n(b) After December 31, 1976, a combustible gas in a transmission line\nin a Class 3 or Class 4 location must comply with the requirements of\nparagraph (a) of this section unless:\n(1) At least 50 percent of the length of the line downstream from that\nlocation is in a Class 1 or Class 2 location; . . .\n(3) In the case of a lateral line which transports gas to a distribution\ncenter, at least 50 percent of the length of that line is in a Class 1 or Class\n2 location . . . .\nItem 3A: The Notice alleged that Respondent violated 49 C.F.R. § 192.625(b)(1) by failing to\nhave a natural odorant in or to odorize certain pipeline segments on Line BT-14 and Line BT-1.\nSpecifically, it alleged that CEGT’s class location and pipeline odorization status records\nindicated that three pipeline segments were not odorized. The line segments that did not have\nodorant were as follows:\n- Line BT-14, Sta. 5843+21 to Sta. 6205+42 (~ 36, 221 feet);\n- Line BT-14, Sta. 6774+71 to Sta. 6800+22 (~ 2,551 feet); and\n- Line BT-1, Sta. 4902 +05 to end of line at Sta. 4994+56 (~ 9,251 feet).\nIn its Response, CEGT advised that odorizing equipment had been installed on BT-14 at Sta.\n#5843+31 near Plummerville, Arkansas, and that, as a result, Line BT-14, Sta. 5843+21 to Sta.\n6205+42 and Line BT-14, Sta. 6774+71 to Sta. 6800+22, were odorized. Respondent further\nexplained that equipment had been ordered for the odorization of the BT-1 system. Respondent\nexpected to have the equipment installed and operational at Line BT-1, Sta. 4902 +05 to end of\nline at Sta. 4994+56, by the end of the first quarter in 2008.\nFailure to ensure that combustible gas is odorized in populated areas jeopardizes public safety, as\na person with a normal sense of smell cannot readily detect a release of un-odorized gas. Line\nBT-14 traverses very congested areas of the University of Central Arkansas-Conway campus.\nOdorization is required specifically to address certain line segments located in Class 3 areas.\nRespondent did not contest these allegations of violation. Accordingly, after considering all the\nevidence, I find that Respondent violated 49 C.F.R. § 192.625(b)(1) by failing to have a natural\nodorant in or to odorize combustible gas in transmission pipelines, as more fully set forth above.\nItem 3B: The Notice alleged that Respondent violated 49 C.F.R. § 192.625(b)(3) by failing to\nhave a natural odorant in or to odorize combustible gas in certain pipeline segments on Line BT-\n19, Line BM-28, and Line BM-28A. Odorization is required on a lateral line which transports\ngas to a distribution center, unless at least 50 percent of the length of that line is in Class 1 or\nClass 2 locations. Specifically, the Notice alleged that CEGT’s class location and odorization\nstatus records indicated the following lines lacked odorization:\n- Line BT-19 (100% Class 3; 1032 feet);\n- Line BM-28 (100% Class 3; 4,200 feet); and\n- Line BM-28A (100% Class 3; 3,846 feet).\n\n\n\n6\nIn its Response, CEGT advised that its installation of odorizing equipment on BT-14 at Sta.\n#5843+31 near Plummerville, Arkansas, had odorized the entire Line BT-19. Respondent\nfurther explained that when it installed odorizing equipment on the BT-1 system, it would\nodorize the entire length of Line BM-28 (100% Class 3; 4,200 feet). Respondent stated that the\ninstallation of odorizing equipment on the BT-1 system would also odorize the entire length of\nLine BM-28A (100% Class 3; 3,846 feet).\nFailure to ensure that combustible gas is odorized could result in undetected leaking natural gas,\nthus delaying or negating the recognition of and response to a potentially hazardous condition to\nthe public and property. Respondent did not contest these allegations of violation. Accordingly,\nafter considering all the evidence, I find that Respondent violated 49 C.F.R. § 192.625(b)(3) by\nfailing to have a natural odorant in or to odorize combustible gas lines in certain pipeline\nsegments on Line BT-19, Line BM-28, and Line BM-28A.\nItem 4: The Notice alleged that Respondent violated 49 C.F.R. § 192.625(f), which states:\n§ 192.625 Odorization of gas.\n(a) . . .\n(f) To assure the proper concentration of odorant in accordance with\nthis section, each operator must conduct periodic sampling of combustible\ngases using an instrument capable of determining the percentage of gas in\nair at which the odor becomes readily detectable.\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.625(f) by failing to adequately\nperform periodic sampling of odorized gas to assure the proper concentration of odorant.\nSpecifically, it alleged that Respondent’s periodic sampling of odorized gas transported in Line\nAM-145 (Pine Bluff area) was not adequate to assure proper odorant concentration. The Notice\nalleged that odorant intensity level tests were performed by an affiliate company at a downstream\ndistribution company warehouse location. Because Respondent delivered gas to the distribution\nsystem from multiple odorized (required by § 192.625) pipelines, including Line AM-145, the\ngas being sampled at the distribution company warehouse was not necessarily indicative of the\nodorant concentration in Line AM-145.\nIn its Response, CEGT advised that it had performed an odorant concentration test on AM-148,\nwhich is downstream of AM-14, and that the test had given a direct indication of odorant\nconcentration on AM-145.\nThe Notice did not propose a civil penalty or compliance order for this item. Therefore, this is\nconsidered to be a warning item. Respondent presented information in its Response showing\nthat it had taken certain actions to address this item. Accordingly, having considered such\ninformation, I find, pursuant to 49 C.F.R. § 190.205, that a probable violation of 49 C.F.R.\n§ 192.625(f) has occurred and Respondent is hereby advised to correct such conditions. In the\nevent that OPS finds a violation of this provision in a subsequent inspection, Respondent may be\nsubject to future enforcement action.\nItem 5: The Notice alleged that Respondent violated 49 C.F.R. § 192.736(b)(2), which states:\n\n\n\n7\n§ 192.736 Compressor stations: Gas detection.\n(a) . . .\n(b) Except when shutdown of the system is necessary for maintenance\nunder paragraph (c) of this section, each gas detection and alarm system\nrequired by this section must-\n. . .\n(2) If that concentration of gas is detected, warn persons about to enter\nthe building and persons inside the building of the danger. . . .\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.736(b)(2) by failing to have a gas\ndetection and alarm system that warned persons inside the compressor station building of the\ndanger of a gas leak when a certain concentration of gas was detected. Specifically, it alleged\nthat a person wearing ear protection inside the Round Mountain Compressor building would not\nlikely hear the audible gas detector alarm if such person were near a running unit. The gas\ndetector alarm does not have lights inside the compressor building to warn of gas detected in the\nbuilding.\nIn its Response, CEGT explained that the audible alarm was tested for DB level at Round\nMountain Compressor and met the current procedure 310-Gas Detection. However, Respondent\nadvised it would install a “Blue Warning” light inside the building at Round Mountain\nCompressor that would alarm in conjunction with the audible alarm inside the building.\nThe Notice did not propose a civil penalty or compliance order for this item. Therefore, this is\nconsidered to be a warning item. Respondent presented information in its Response showing\nthat it had taken certain actions to address this item. Having considered such information, I find,\npursuant to 49 C.F.R. § 190.205, that a probable violation of 49 C.F.R. § 192.736 (b)(2) has\noccurred and Respondent is hereby advised to correct such conditions. In the event that OPS\nfinds a violation of this provision in a subsequent inspection, Respondent may be subject to\nfuture enforcement action.\nItem 6: The Notice alleged that Respondent violated 49 C.F.R. § 192.743(b), which states:\n§ 192.743 Pressure limiting and regulating stations: Capacity of\nrelief devices.\n(a) …\n(b) If review and calculations are used to determine if a device has\nsufficient capacity, the calculated capacity must be compared with the\nrated or experimentally determined relieving capacity of the device for the\nconditions under which it operates. After the initial calculations,\nsubsequent calculations need not be made if the annual review documents\nthat parameters have not changed to cause the rated or experimentally\ndetermined relieving capacity to be insufficient.\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.743(b) by failing to correctly\ndetermine if a relief device had sufficient capacity. Specifically, it alleged that Respondent used\nan incorrect upstream pressure in the 08/19/06 regulator failure capacity calculations for the Line\nB to Line BM-21 mainline regulator station. The upstream pressure used was 400 psig,\nindicating a regulator failure capacity of zero (0) mcfh. The correct upstream pressure was 500\n\n\n\n8\npsig. PHMSA’s review and calculation, performed during the inspection using correct\ninformation, revealed that the capacities of the existing relief valves were adequate.\nThe Notice also alleged that CEGT used an incorrect relief valve inlet pressure of 550 psig in the\n05/13/06 relief valve calculation for the Line J to Line BM-21 mainline regulator station. The\ncorrect pressure was 440 psig. The Notice further alleged that Respondent used an incorrect\nupstream pressure in the 08/09/06 regulator failure capacity calculations for the Carlisle\ncompressor station fuel gas regulator station. The upstream pressure used was 450 psig. The\ncorrect upstream pressure was 720 psig. In addition, the capacity calculation review sheet\nindicated an unprotected (from overpressure) 300 psig-rated meter existed in the station.\nPHMSA determined during the inspection that the meter was rated for 720 psig and additional\npressure relief was not required.\nThe Notice did not propose a civil penalty or compliance order for this item. Therefore, this is\nconsidered to be a warning item. Respondent presented information in its Response showing\nthat it had taken certain actions to address this item. Having considered such information, I find,\npursuant to 49 C.F.R. § 190.205, that a probable violation of 49 C.F.R. § 192.743(b) has\noccurred and Respondent is hereby advised to correct such conditions. In the event that OPS\nfinds a violation of this provision in a subsequent inspection, Respondent may be subject to\nfuture enforcement action.\nThese findings of violation will be considered prior offenses in any subsequent enforcement\naction taken against Respondent.\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Items 1A, 1B, 1C and 3 in the Notice for\nviolations of 49 C.F.R. Part 192. Under 49 U.S.C. § 60118(a), each person who engages in the\ntransportation of gas or who owns or operates a pipeline facility is required to comply with the\napplicable safety standards established under chapter 601. The Director has indicated that\nRespondent has taken the following actions to address the cited violations:\n1. CenterPoint Energy Gas Transmission (CEGT) submitted an improvement and\ncorrection plan to address external corrosion control monitoring and corrosion\ncontrol records to achieve compliance. The plan addresses program\nmanagement oversight and accountability, as well as needed procedural and\nprocess changes.\n2. CEGT submitted documentation to show it did odorize gas in the five pipelines.\n3. CEGT provided documentation of the safety improvement costs associated with\nfulfilling this Compliance Order and submitted the total to Linda Daugherty, Director,\nSouthern Region, Pipeline and Hazardous Materials Safety Administration. Costs\nwere reported in two categories: 1) total cost associated with preparation/revision of\nplans, procedures, studies and analyses; and 2) total cost associated with replacements,\nadditions and other changes to pipeline infrastructure.\n\n\n\nAccordingly, I find that compliance has been achieved with respect to these violations.\nTherefore, the compliance terms proposed in the Notice are not included in this Order.\nThe terms and conditions of this Final Order are effective upon receipt of service.\n___________________________________ ________________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n9","truncated":false,"body_characters":27586}