{"operation":"document","citation":"CPF 320091022W","title":"ENABLE MISSISSIPPI RIVER TRANSMISSION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2009-12-14","effective_on":null,"summary":"CLOSED warning letter citing 192.203(b)(9), 192.615(b)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320091022w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320091022w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320091022w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320091022W","body":"Warning Letter involving ENABLE MISSISSIPPI RIVER TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.203(b)(9),  192.615(b)(3). The case was opened on 2009-12-14 and is reported as closed as of 2009-12-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320091022W_Warning Letter_12142009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320091022W/320091022W_Warning%20Letter_12142009.pdf\n\n320091022W_Warning Letter_12142009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320091022W/320091022W_Warning%20Letter_12142009_text.pdf\n\n320091022W_Warning Letter_12142009_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 14, 2009\nMr. Pete Kirsch\nDivision Sr. Vice President\nCenterPoint Energy / Mississippi River Transmission Corporation\n1111 Louisiana, Suite 1120\nHouston, TX 77002\nCPF 3-2009-1022W\nDear Mr. Kirsch:\nOn August 17-27, 2009, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your\nrecords and facilities in Illinois and Missouri.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violation(s) are:\n1. §192.203 Instrument, control, and sampling pipe and components.\n(b) Materials and design. All materials employed for pipe and components must be\ndesigned to meet the particular conditions of service and the following:\n(9) Each control line must be protected from anticipated causes of damage and\nmust be designed and installed to prevent damage to any one control line from\nmaking both the regulator and the over-pressure protective device inoperative.\n\n\n\nMississippi River Transmission Corporation (MRT) personnel did not install individual\nsensing taps for the operator and monitor regulators at two town border stations. The\nstations identified with the operator and monitor on the same tap were Red Bud Station\nand Chester Station. Failure of the one tap would cause both the operator and monitor to\nfully open and possibly over-pressure the downstream piping.\nMRT personnel indicated that this issue was noted in one of their own pre-audits and\nwere in the process of identifying these company-wide. The two stations noted were not\nyet identified.\n2. §192.615 Emergency plans.\n(b) Each operator shall:\n(3) Review employee activities to determine whether the procedures were\neffectively followed in each emergency.\nMRT personnel did not conduct a post-incident review of the incident that occurred at the\nPiedmont Station in MO in 2008. During a heavy storm, lightning struck the town border\nstation and caused a fire which resulted in significant damage to the station. As a result,\nemergency procedures were initiated to respond to the incident.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of $1,000,000\nfor any related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement\naction or penalty assessment proceedings at this time. We advise you to correct the item(s)\nidentified in this letter. Failure to do so will result in Mississippi River Transmission\nCorporation being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 3-2009-1022W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any portion\nof your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along\nwith the complete original document you must provide a second copy of the document with\nthe portions you believe qualify for confidential treatment redacted and an explanation of why\nyou believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nIvan A. Huntoon\nDirector, Central Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":4303}