# ENABLE MISSISSIPPI RIVER TRANSMISSION, LLC — Warning Letter

- **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:** Not available
- **summary:** CLOSED warning letter citing 192.203(b)(9), 192.615(b)(3).
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- **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.

Official case documents:

320091022W_Warning Letter_12142009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320091022W/320091022W_Warning%20Letter_12142009.pdf

320091022W_Warning Letter_12142009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320091022W/320091022W_Warning%20Letter_12142009_text.pdf

320091022W_Warning Letter_12142009_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
December 14, 2009
Mr. Pete Kirsch
Division Sr. Vice President
CenterPoint Energy / Mississippi River Transmission Corporation
1111 Louisiana, Suite 1120
Houston, TX 77002
CPF 3-2009-1022W
Dear Mr. Kirsch:
On August 17-27, 2009, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your
records and facilities in Illinois and Missouri.
As a result of the inspection, it appears that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and
the probable violation(s) are:
1. §192.203 Instrument, control, and sampling pipe and components.
(b) Materials and design. All materials employed for pipe and components must be
designed to meet the particular conditions of service and the following:
(9) Each control line must be protected from anticipated causes of damage and
must be designed and installed to prevent damage to any one control line from
making both the regulator and the over-pressure protective device inoperative.



Mississippi River Transmission Corporation (MRT) personnel did not install individual
sensing taps for the operator and monitor regulators at two town border stations. The
stations identified with the operator and monitor on the same tap were Red Bud Station
and Chester Station. Failure of the one tap would cause both the operator and monitor to
fully open and possibly over-pressure the downstream piping.
MRT personnel indicated that this issue was noted in one of their own pre-audits and
were in the process of identifying these company-wide. The two stations noted were not
yet identified.
2. §192.615 Emergency plans.
(b) Each operator shall:
(3) Review employee activities to determine whether the procedures were
effectively followed in each emergency.
MRT personnel did not conduct a post-incident review of the incident that occurred at the
Piedmont Station in MO in 2008. During a heavy storm, lightning struck the town border
station and caused a fire which resulted in significant damage to the station. As a result,
emergency procedures were initiated to respond to the incident.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
$100,000 for each violation for each day the violation persists up to a maximum of $1,000,000
for any related series of violations. We have reviewed the circumstances and supporting
documents involved in this case, and have decided not to conduct additional enforcement
action or penalty assessment proceedings at this time. We advise you to correct the item(s)
identified in this letter. Failure to do so will result in Mississippi River Transmission
Corporation being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer
to CPF 3-2009-1022W. Be advised that all material you submit in response to this
enforcement action is subject to being made publicly available. If you believe that any portion
of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along
with the complete original document you must provide a second copy of the document with
the portions you believe qualify for confidential treatment redacted and an explanation of why
you believe the redacted information qualifies for confidential treatment under 5 U.S.C.
552(b).
Sincerely,
Ivan A. Huntoon
Director, Central Region
Pipeline and Hazardous Materials Safety Administration
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