# SOUTHEAST SUPPLY HEADER, LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 220111008
- **title:** SOUTHEAST SUPPLY HEADER, LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2011-10-04
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 191.15(b), 191.5(a), 192.167(a)(2), 192.243(b)(1), 192.303, 192.305, 192.317(a), 192.709(c), 192.745(a).
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**body:**

Notice of Probable Violation involving SOUTHEAST SUPPLY HEADER, LLC. PHMSA's enforcement data identifies the cited regulations as 191.15(b),  191.5(a),  192.167(a)(2),  192.243(b)(1),  192.303,  192.305,  192.317(a),  192.709(c),  192.745(a). The case was opened on 2011-10-04 and is reported as closed as of 2012-06-15. Proposed civil penalty: $174,500. Assessed civil penalty: $174,500. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220111008_Final Order_06152012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220111008/220111008_Final%20Order_06152012.pdf

220111008_Final Order_06152012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220111008/220111008_Final%20Order_06152012_text.pdf

220111008_nopv_pcp_pco_10042011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220111008/220111008_nopv_pcp_pco_10042011.pdf

220111008_nopv_pcp_pco_10042011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220111008/220111008_nopv_pcp_pco_10042011_text.pdf

220111008_Operator Response to Notice_11022011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220111008/220111008_Operator%20Response%20to%20Notice_11022011.pdf

220111008_Final Order_06152012_text.pdf

JUNE 15, 2012
Mr. Pete M. Kirsch
Division Senior Vice-President
Pipeline Operations & Engineering
Southeast Supply Header, LLC
P. O. Box 4567
Houston, TX 77210
Re: CPF No. 2-2011-1008
Dear Mr. Kirsch:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation and assesses a civil penalty of $174,500. This is to acknowledge receipt of payment
of the full penalty amount, by wire transfer, dated November 4, 2011. It further finds that
Southeast Supply Header, LLC has completed the actions specified in the Notice to comply
with the pipeline safety regulations. Therefore, this case is now closed. Service of the Final
Order by certified mail is deemed effective upon the date of mailing, or as otherwise provided
under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. David M. McClanahan, President, CenterPoint Energy, Inc., P. O. Box
4567, Houston, TX 77210
Mr. Wayne T. Lemoi, Director Southern Region, OPS
Mr. Alan Mayberry, Deputy Associate Administrator for Field Operations, OPS
CERTIFIED MAIL - RETURN RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Southeast Supply Header, LLC, ) CPF No. 2-2011-1008
)
)
)
Respondent. )
____________________________________)
FINAL ORDER
On May 3-7, 2010, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline and
Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),
conducted an on-site pipeline safety inspection of Southeast Supply Header, LLC’s (SESH or
Respondent) records in Shreveport, Louisiana. On August 2-5, 2010, OPS conducted a second
inspection of the company’s pipeline facilities from Delhi, Louisiana, to Coden, Alabama. The
274-mile natural gas transmission pipeline system, generally known as “Line 100,” consists of
36-inch and 42-inch diameter pipe.
1 Line 100 is a joint venture between subsidiaries of
CenterPoint Energy, Inc., and Spectra Energy Corporation.
2
As a result of the inspection, the Director, Southern Region, OPS (Director), issued to
Respondent, by letter dated October 4, 2011, a Notice of Probable Violation, Proposed Civil
Penalty, and Proposed Compliance Order (Notice), which also included a warning pursuant to
49 C.F.R. § 190.205. In accordance with 49 C.F.R. § 190.207, the Notice proposed finding
that SESH had committed various violations of 49 C.F.R. Parts 191 and 192 and proposed
assessing a civil penalty of $174,500 for the alleged violations. The Notice also proposed
ordering Respondent to take certain measures to correct the alleged violations. The warning
items required no further action, but warned the operator to correct the probable violations or
face possible enforcement action.
SESH responded to the Notice by letter dated November 2, 2011 (Response). The company
did not contest the allegations of violation, but provided an explanation of its actions, and paid
the proposed civil penalty of $174,500, as provided in 49 C.F.R. § 190.227. Payment of the
penalty serves to close the case with prejudice to Respondent.
1 See http://www.spectraenergy.com and http://www.centerpointenergy.com (last assessed 5/4/2012).
2 Spectra Energy is responsible for gas control and commercial operations; CenterPoint Energy is responsible for
field operations.



2
FINDINGS OF VIOLATION
In its Response, SESH did not contest the allegations in the Notice that it violated
49 C.F.R. Parts 191 and 192, as follows:
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 191.15(b), which states:
§ 191.15 Transmission and gathering systems: Incident report.
(a) ….
(b) Where additional related information is obtained after a report is
submitted under paragraph (a) of this section, the operator shall make a
supplemental report as soon as practicable with a clear reference by date
and subject to the original report.
The Notice alleged that Respondent violated 49 C.F.R. § 191.15 by failing to make a
supplemental report, as soon as practicable, after obtaining additional information related to an
incident report submitted on February 19, 2010 for an incident that occurred on January 21,
2010, near Hazlehurst, MS. Specifically, the Notice alleged that on May 23, 2010, SESH
obtained additional information related to the pipeline incident and did not submit a
supplemental report until January 21, 2011, eight months later.
3
According to the Notice, SESH received a metallurgical analysis of the failure on May 23,
2010, that identified the cause of the leaking girth weld as Hydrogen Assisted Cracking.
4
However, SESH did not submit the supplemental report until January 21, 2011, eight months
after SESH obtained the information.5 Respondent did not contest this allegation of violation
but explained that no information was intentionally withheld from PHMSA and updating the
report was an oversight.
Respondent violated 49 C.F.R. § 191.15 by failing to submit a supplemental report as soon as
practicable after it had obtained additional information regarding the cause of a reportable
incident.
6 Accordingly, based upon a review of all of the evidence, I find that
Item 3: The Notice alleged that Respondent violated 49 C.F.R. § 192.167(a)(2), which states in
relevant part:
§ 192.167 Compressor stations: Emergency shutdown.
(a) Except for unattended field compressor stations of 1,000
horsepower (746 kilowatts) or less, each compressor station must have
an emergency shutdown system that meets the following:
(1) . . .
3 The Incident Report (IR) number is 20100010-15010 (dated February 19, 2010).
4 Pipeline Safety Violation Report (September 30, 2011) (Violation Report), Attachment A, Kiefner &
Associates, Inc. (Final Report No. 10-031).
5 IR 20100010-15162 (January 21, 2011).
6 Response at 3.



3
(2) It must discharge gas from the blowdown piping at a location
where the gas will not create a hazard.
The Notice alleged that Respondent violated 49 C.F.R. § 192.167 by failing to place the
blowdown piping vents for the SESH Emergency Shutdown Device (ESD) systems at a
location where the discharge gas would not create a hazard. Specifically, the Notice alleged
that Respondent’s ESD blowdown piping vents were found near the compressor buildings and
at other locations where vented natural gas would create a hazard to individuals if the ESD was
activated. Respondent did not contest this allegation of violation but explained that the
company is modifying the ESD trip station blowdown piping to direct the vented gas vertically
to eliminate the hazard.
Respondent violated 49 C.F.R. § 192.167(a)(2) by failing to have emergency shutdown device
blowdown piping vents located where the discharge of gas would not create a hazard.
7 Accordingly, based upon a review of all of the evidence, I find that
Item 4: The Notice alleged that Respondent violated 49 C.F.R. § 192.243(b)(1), which states
in relevant part:
§ 192.243 Nondestructive testing.
(a)….
(b) Nondestructive testing of welds must be performed:
(1) In accordance with written procedures; and…
The Notice alleged that Respondent violated 49 C.F.R. § 192.243(b)(1) by failing to
nondestructively test (NDT) girth welds in accordance with SESH’s written procedures.
Specifically, the Notice alleged that Respondent failed to comply with its written procedures
requiring that all welds (excluding Engineering Critical Assessment welds), including repairs,
are evaluated to the workmanship standards of acceptability of API Standard 1104, Section 9.
8
According to the Notice, although SESH’s construction radiographs of two girth welds showed
a crack in each weld, Respondent did not identify and reject either of the girth welds during
radiographic reviews, but installed the two girth welds in Line 100,
9 failing to follow its
written procedures or meet API 1104 workmanship standards of acceptability.
10
7 Response at 4.
8 Violation Report, Attachment A at 34, SESH General Construction- Welding and Tie-Ins Procedures (Spec.
Number: CS-GC 8.2), pipe Weld Examination, Section 4D.
9 Girth weld no. XRA-078 at station #4616+78 was discovered to be leaking on January 21, 2010. The source of
the leak was a longitudinal crack. Upon discovery of the leak, SESH and PHMSA used independent NDT
consultants to re-review the construction radiographs. Both NDT consultants identified the crack and concluded
the crack should have been identified and rejected by the NDT technician at the time of the original construction
radiographic NDT evaluation.
Girth weld no. XRA-047 at station #4366+51 was identified as having a transverse crack upon re-examination of
the construction radiograph by SESH's NDT consultant and by PHMSA's NDT consultant. The crack was
confirmed by examination of the girth weld by SESH's contract metallurgical consultant after the girth weld was
removed from the pipeline.
10 Am. Petroleum Inst., Standard 1104, Section 11, Procedures for Nondestructive testing (19th ed. 1999, errata
October 31, 2001).



4
The Notice further alleged two other instances of Respondent’s failure to follow written NDT
examination procedures by not adequately recording NDT inspections and tests, and not
correctly completing SESH Form TS-406 NDE Report of Field Welds (TS-406). Respondent’s
Form TS-406, dated January 21, 2008 and February 14, 2008, had incorrect radiographic
procedure numbers and incorrect dimensions for two girth welds. The January 21, 2008 form
incorrectly recorded Girth weld no. XRA-047 as a 42” x 0.720” x 0.750” transition weld when
the correct dimensions were 42” x 0.600” x 0.750.
” The February 14, 2008 form incorrectly
recorded dimensions for four inspected girth welds as 42” x 0.750” x 0.600” transition welds
when the correct dimensions were 42” x 1.000” x 0.600.” Although the February TS-406 form
also indicated that a Radiographic Procedure 42 x 600 x 750 GI was used, Respondent was
unable to provide to PHMSA any procedure qualification records related to this weld.
Respondent did not contest this allegation of violation but explained that it has enhanced its
existing Quality Assurance/Quality Control (QA/QC) practices.
review of all of the evidence, I find that Respondent violated 49 C.F.R. § 192.243(b)(1) by
failing to nondestructively test (NDT) girth welds in accordance with its written procedures.
11 Accordingly, based upon a
Item 5: The Notice alleged that Respondent violated 49 C.F.R. § 192.303, which states:
§ 192.303 Compliance with specifications or standards.
Each transmission line or main must be constructed in accordance
with comprehensive written specifications or standards that are
consistent with this part.
The Notice alleged that Respondent violated 49 C.F.R. § 192.303 by failing to construct its
Line 100, a transmission pipeline, in accordance with comprehensive written specifications or
standards. Specifically, the Notice alleged that Respondent had two procedures requiring the
use of Class I or GI radiographic film for NDT girth of welds, but SESH’s records showed that
different radiographic procedures were used during the construction of its Line 100.12
The Notice further alleged that SESH’s records showed that it approved the contractor’s use of
the procedures that allowed Class II (D7 Agfa) radiographic film (not Class I or GI film) in the
gamma-sourced radiographic inspection of manually produced girth welds on Line 100 where
penetration and/or wall thicknesses were less than 0.750 inches.
13 PHMSA asserted that the
11 The company requires NDE suppliers to have an established QA/QC Procedure and/or Quality Management
System with a continuous improvement process. SESH also explained that it has enhanced its inspector training
program and documentation process. Response at 4.
12 SESH procedure, Construction Specification, Spec. Number: CS-GC31.2 Radiography (CS-GC31.2), required
the use of Class I or GI film with gamma radiation sources for penetration thicknesses (excluding weld build-up)
less than 0.750 inches (18mm). SESH procedure, Radiographic Inspection Procedure, required Class I film to be
used on wall thicknesses up to and including 0.750 inches.
13 Radiographic inspection is a nondestructive testing method of producing images on film through the use of
gamma rays to inspect materials for hidden flaws or defects.



5
Class II film is inferior to Class I film in the ability to detect or capture images of some
actionable defects and imperfections when inspecting girth welds in pipe with the wall
thicknesses less than 0.750 inches. Respondent acknowledged that the use of Class II film for
penetration thickness less than 0.750 inches did not meet SESH Specification CS-GC31.2 and
explained that it has enhanced its QA/QC practices.
The Notice also alleged that SESH failed to ensure that its pipeline was constructed in
accordance with its comprehensive written Specification Number: CS-GC 8.2 Item 3G, that
required the internal transition slope on transition welds to be a minimum of 1:4 (14 degree
angle) and maximum of 1:2.6 (21 degree angle). SESH’s contracted investigation report14
indicated the two induction bend-end welds on the bend located at construction survey station
no. 4583+53 (failed weld bend) had maximum transition angles that exceeded 21 degrees. The
report indicated maximum transition angles of 37 degrees and 34 degrees for these bend welds.
Respondent did not contest the allegation of violation but explained that the company has
enhanced its QA/QC practices. Accordingly, based upon a review of all of the evidence, I find
that Respondent violated 49 C.F.R. § 192.303 by failing to construct Line 100 in accordance
with its written specifications and standards.
Item 6: The Notice alleged that Respondent violated 49 C.F.R. § 192.305, which states:
§ 192.305 Inspections: General.
Each transmission line or main must be inspected to ensure that it is
constructed in accordance with this part.
The Notice alleged that Respondent violated 49 C.F.R. § 192.305 by failing to adequately
inspect Line 100, a transmission pipeline, to ensure that it was constructed in accordance with
comprehensive written specifications as required by Part 192. Specifically, the Notice alleged
two instances where the Respondent failed to follow construction inspection Specification
Number: CS-GC 8.2, Item 3D, Transition Report and SESH form TS-713 for girth weld XRA-
078. SESH’s construction inspection specification CS-GC 8.2 required wall thickness readings
to be taken on the quarter points of the transitioned pipe, that the information be recorded on
Form TS-713, and then submitted for company approval of the method of measurement. Form
TS-713 also required the recording of the minimum and maximum transition slopes and
signature/date of the Chief Inspector.
The first instance alleged was that Form TS-713 for girth weld XRA-078, dated February 18,
2008, recorded measured transition slope angles of 16 degrees (min) and of 20 degrees (max),
yet these min/max angles were inconsistent with the angles measured and reported in the
quarter points were all recorded as nominal size numbers, which showed that the actual wall
thicknesses were not measured. The form was also not signed by the chief inspector.
company’s failure investigation report.15 Further the wall thickness measurements taken at the
14 Violation Report, Attachment A, Spectra Energy Final Report No. 10-031, dated May 18, 2010, at 37.
15 Violation Report, Attachment A, Spectra Energy Final Report No. 10-031, dated May 18, 2010, at 37.



6
The second instance alleged was that on August 3, 2010, PHMSA inspected and photographed
Girth weld XRA-075 (42” x 1.000” x 0.600” bend/pup transition weld) and found that it did
not comply with weld specifications.
misalignment was not evenly distributed around the circumference of the pipe; indicating that
the weld was either inadequately inspected, or not inspected, for internal pipe misalignment to
ensure that it was constructed in accordance with comprehensive written specifications.
16 The measurements indicated that the internal pipe
Respondent did not contest this allegation of violation but explained that it has enhanced its
existing QA/QC practices to prevent a reoccurrence. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 192.305 by failing to adequately
inspect the Line 100 transmission pipeline to ensure that it was constructed in accordance with
comprehensive written specifications as required by Part 192.
Item 7: The Notice alleged that Respondent violated 49 C.F.R. § 192.317, which states in
relevant part:
§ 192.317 Protection from hazards.
(a) The operator must take all practicable steps to protect each
transmission line or main from washouts, floods, unstable soil,
landslides, or other hazards that may cause the pipeline to move or to
sustain abnormal loads.
The Notice alleged that Respondent violated 49 C.F.R. § 192.317(a) by failing to take all
practicable steps to protect its Line 100 from hazards during construction that caused the
pipeline to sustain abnormal loads. Specifically, the Notice alleged that Respondent
discovered a buckle in the pipe at survey station no. 4389+68 during an unrelated excavation
approximately 19 months after the pipeline was placed in service. SESH’s investigation report
stated that the buckle “was caused by excessive bending loads applied to the pipeline during
some phase of the construction of the pipeline.”17
The report also stated that the “
... mode of
buckling is associated with little or no pressure in the pipeline at the time the buckle formed.
This implies that the buckle was probably present when the pipeline was hydrostatically
tested.” The Notice further alleged that based on these reports an actionable anomaly (5.3%
dent) existed at the buckle location approximately one month after the construction hydrostatic
test; therefore, Respondent failed to take steps during construction of the pipeline to prevent
the buckle from occurring. Respondent did not contest this allegation of violation.
Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49
C.F.R. § 192.317(a) by failing to take all practicable steps to protect its Line 100 from hazards
during construction that caused the pipeline to sustain abnormal loads.
16 The girth weld had a (scaled) outside diameter (OD) misalignment of approximately 0.40 inches at one position
and essentially zero misalignment directly opposite (180 degrees circumferentially from) the misalignment, which
is consistent with the OD misalignment measurements taken by SESH on the weld. Violation Report at 23.
17 Violation Report, Attachment A, Spectra Energy Final Report No. 10-069R, dated November 5, 2010 at 37.



7
ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to
exceed $100,000 per violation for each day of the violation, up to a maximum of $1,000,000
for any related series of violations. In determining the amount of a civil penalty under
49 U.S.C. § 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature,
circumstances, and gravity of the violation, including adverse impact on the environment; the
degree of Respondent’s culpability; the history of Respondent’s prior offenses; the
Respondent’s ability to pay the penalty and any effect that the penalty may have on its ability
to continue doing business; and the good faith of Respondent in attempting to comply with the
pipeline safety regulations. In addition, I may consider the economic benefit gained from the
violation without any reduction because of subsequent damages, and such other matters as
justice may require. The Notice proposed a total civil penalty of $174,500 for the violations
cited above.
Item 2: The Notice proposed a civil penalty of $5,000 for Respondent’s violation of
49 C.F.R. § 191.15(b), for failing to submit a supplemental report regarding the cause of a
reportable incident as soon as practicable, after it obtained additional related information.
SESH obtained additional information related to a reportable pipeline incident but did not
submit a supplemental report until eight months later. SESH neither contested the allegation
nor presented any evidence or argument justifying a reduction in the proposed civil penalty.
Accordingly, having reviewed the record and considered the assessment criteria, I assess
Respondent a civil penalty of $5,000, which has already been paid by Respondent.
Item 3: The Notice proposed a civil penalty of $35,000 for Respondent’s violation of
49 C.F.R. § 192.167(a)(2), for failing to have emergency shutdown device blowdown piping
vents located where the discharge of gas would not create a hazard. SESH neither contested
the allegation nor presented any evidence or argument justifying a reduction in the proposed
civil penalty. Accordingly, having reviewed the record and considered the assessment criteria,
I assess Respondent a civil penalty of $35,000, which has already been paid by Respondent.
Item 4: The Notice proposed a civil penalty of $85,600 for Respondent’s violation of
49 C.F.R. § 192.243(b)(1), for failing to nondestructively test (NDT) girth welds in accordance
with its written procedures, which required that all welds (excluding ECA welds) including
repairs are evaluated to the workmanship standards of acceptability of API Standard 1104,
Section 9. SESH neither contested the allegation nor presented any evidence or argument
justifying a reduction in the proposed civil penalty. Accordingly, having reviewed the record
and considered the assessment criteria, I assess Respondent a civil penalty of $85,600, which
has already been paid by Respondent.
Item 5: The Notice proposed a civil penalty of $16,500 for Respondent’s violation of
49 C.F.R. § 192.303, for failing to construct its Line 100, a transmission pipeline, in
accordance with comprehensive written specifications or standards requiring the use of Class I
or GI radiographic film for NDT of girth welds. SESH neither contested the allegation nor
presented any evidence or argument justifying a reduction in the proposed civil penalty.
Accordingly, having reviewed the record and considered the assessment criteria, I assess
Respondent a civil penalty of $16,500, which has already been paid by Respondent.



8
Item 6: The Notice proposed a civil penalty of $16,200 for Respondent’s violation of
49 C.F.R. § 192.305, for failing to adequately inspect the Line 100 transmission pipeline to
ensure that it was constructed in accordance with comprehensive written specifications as
required by Part 192. SESH neither contested the allegation nor presented any evidence or
argument justifying a reduction in the proposed civil penalty. Accordingly, having reviewed
the record and considered the assessment criteria, I assess Respondent a civil penalty of
$16,200, which has already been paid by Respondent.
Item 7: The Notice proposed a civil penalty of $16,200 for Respondent’s violation of
49 C.F.R. § 192.317(a), for failing to take all practicable steps to protect its Line 100 pipeline
from hazards during construction that caused the pipeline to sustain abnormal loads. SESH
neither contested the allegation nor presented any evidence or argument justifying a reduction
in the proposed civil penalty. Accordingly, having reviewed the record and considered the
assessment criteria, I assess Respondent a civil penalty of $16,200, which has already been
paid by Respondent.
In summary, having reviewed the record and considered the assessment criteria, I assess
Respondent a total civil penalty of $174,500, which has already been paid by Respondent.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Item 3 in the Notice for violation of
49 C.F.R. § 192.167(a)(2). Under 49 U.S.C. § 60118(a), each person who engages in the
transportation of gas or who owns or operates a pipeline facility is required to comply with the
applicable safety standards established under Chapter 601. The Director indicates that
Respondent has taken the following actions specified in the proposed compliance order:
1. With respect to the violation of § 192.167(a)(2) (Item 3), Respondent has
reconfigured the Emergency Shutdown system blowdown piping vents at each of
the five compressor stations on Line 100 to ensure that any discharged gas will not
create a hazard.
Accordingly, I find that compliance has been achieved with respect to this violation.
Therefore, the compliance terms proposed in the Notice are not included in this Order.



9
WARNING ITEMS
With respect to Items 1, 8, and 9, the Notice alleged probable violations of Parts 191 and 192
but did not propose a civil penalty or compliance order for these items. Therefore, these are
considered to be warning items. The warnings were for:
49 C.F.R. § 191.5 (Item 1) ─ Respondent’s alleged failure to give notice of a
pipeline incident that occurred on its SESH Line 100 on January 21, 2010, near
Hazlehurst, MS, at the earliest practicable moment following discovery;
49 C.F.R. § 192.709(c) (Item 8) ─ Respondent’s alleged failure to retain a
record of each required patrol, survey, inspection, and test for at least five years
or until the next patrol, survey, inspection, or test was completed, whichever
was longer. Specifically, Respondent did not have records documenting the
inspection and the Discharge Pressure Shutdown Setpoint test of the Delhi
compressor station, performed on November 3, 2009; and
49 C.F.R. § 192.745(a) (Item 9) ─ Respondent’s alleged failure to inspect and
partially operate three remotely controlled transmission line mainline valves that
might be required during an emergency, at required intervals. Specifically,
SESH failed to test the functionality of its SCADA remote control system to
assure the three valves operated when remotely activated and failed to test the
gas-powered operator component to assure that gas power would operate the
valve. The three mainline valves, located at MP 55.79 (BV65685), MP 155.9
(BV65774), and MP 166.7 (BV 65789) are also required to be remotely
controlled per the Special Permit Order, dated July 17, 2008, Condition No. 23.
SESH presented information in its Response showing that it had taken certain actions to
address the cited items. Accordingly, having considered such information, I find, pursuant to
49 C.F.R. § 190.205, that probable violations of 49 C.F.R. § 191.5(a) (Notice Item 1),
49 C.F.R. § 192.709(c) (Notice Item 8), and 49 C.F.R. § 192.745(a) (Notice Item 9) have
occurred. If OPS finds a violation of any of these items in a subsequent inspection,
Respondent may be subject to future enforcement action.
The terms and conditions of this Final Order are effective upon service in accordance with
49 C.F.R. § 190.5.
_________________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety
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