# ENABLE GAS TRANSMISSION, LLC — Warning Letter

- **operation:** document
- **citation:** CPF 420081006W
- **title:** ENABLE GAS TRANSMISSION, LLC — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2008-04-03
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.317(b), 192.479, 192.707(a)(1).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420081006W
**body:**

Warning Letter involving ENABLE GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.317(b),  192.479,  192.707(a)(1). The case was opened on 2008-04-03 and is reported as closed as of 2008-04-03. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420081006W_warning_04032008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420081006W/420081006W_warning_04032008.pdf

420081006W_warning_04032008.pdf

u.s. Deportment Houston, TX 77074
8701 South Gessner, Suite 1110
of Transportafion
Pipeline and
Hazardous Materials Sat ty
Admlnl 'ratlon
ARNING LETTER
CE TIFIEMAIL - RETURN RECEIPT REQUESTED
April 3, 2008
Mr. Walter Ferguson
Senior Vice President
CenterPoint Energy
1111 Louisiana, Suite 1120
Houston, TX 77002
CPF 4-2008-1006W
Dear Mr. Ferguson
On June 25-29, September 24-28 and October 29 thru November 02, 2007 a representative of
the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601
of 49 United States Code inspected your AR, TX (Emmet Team and AR 4 (Eldorado Team) in
Emmet and EI Dorado, AR..
As a result of the inspection, it appears that you have committed probable violations as noted
below of the Pipeline Safety Regulations, Title 49. Code of Federal Regulations. The items
inspected and the probable violation(s) are:
1. §192.479 Atmospheric corrosion control: General
(a) Eac operator must clean and coat each pipeline or portion of pipeline that is
exposed to the atmosphere, except pipelines under paragraph (c) of this
ection.
(b) Coating material must be uitable for the prevention of atmospheric corrosion.
(c) Except portions of pipelines in offshore splash zones or soil-to-air interfaces,
the operator need not protect from atmospheric corrosion any pipeline for
which the operator demonstrates by test, investigation, or experience
appropriate to t e environment of the pipeline that corrosion will(1)
Only be a light surface oxide; or
(2) Not affect the safe operation of the pipeline before the next scheduled
inspection.



Extensive atmospheric corrosion was evident at several locations including:
1. Pipe supports on line AM 159 outlet meter tubes at Emmet Station.
2. MLV A1 at M.P. 63.59 (Bobo Valve Site).
3. Transition zone on discharge piping at Taylor Compressor Station.
4. MLV site A-3 at EOL LT1 and BOL AM45 and 129.
5. Block valve KM6 #41883.
6. Exposed pipe (approximately 60') in North EI Dorado area.
7. Camden separator yard on pig trap pipe supports and at transition zone.
8. Cement pipe supports on line S at MLV #43830 & 43826 on North side of Little
Missouri River.
2. §192.317 Protection from hazards.
(b) Each boveground transmis ion line or main, not located offshore or in inland
navigable water area , must be protected from accidental damage by vehicular
traffic or other similar causes, either by being placed at a safe distance from the
traffic or by installing barricades.
CenterPoint Energy Gas Transmission does not have adequate distance from traffic or
barricades around numerous main line valve sites and town border stations to prevent damage
from outside forces or vandalism.
1. New boston town border station.
2. Kingsland town border station.
3. Fordyce town border station.
4. Main line bv km6, #41883.
5. East camden town border station.
6. KT-1 MLV @ K2H regular station.
7. KT-1 Parkers Chaple MLV, and RRE 440 station.
8. KT-1 Laney BV & Rectifier had no protective barrier.
9. HM 3 MLV @ Columbia Chemical station.
10. Ouachita Power Plant meter station & relief valve.
11. Old Hamilton Plant regulator & meter station.
12. KM-19 BV to line 134 Jct.
13. Hope west town border station.
14. MLV SM-23 junction relief valve.
3. §192.707 Line markers for mains and transmission lines.
(a) Buried pipelines. Except as provided in paragraph (b) of this sectlo , a line
marker must b placed and maintained a close as practical over each buried
main and transmission line:
(1) At each crossing of a public road and railroad; and
2



(2) Wherever necessary to identify the location of the transmission line or main to
reduce the pos ibility of damage or interference.
CenterPoint Energy does not have an adequate number of pipeline markers along the right-ofway
to clearly identify the location of the transmission line.
1. Line crossing at highway 53 right-of-way had no visible line markers except at each
side of the road.
2. Kingsland Town Border Station's main line valve assembly is offset from main line
with no offset directional markers.
3. Line crossing at highway RE 858 line markers not visible due to heavy growth on
right-of-way.
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 CenterPoint Energy being subject to additional
enforcement action.
No reply to this Ie ter is required. If you choose to reply, in your correspondence please refer to
CPF 4-2008-1006W. 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, ;(/1(4
R. M. Seeley
Director, Southwest
Pipeline and Hazardous
Materials Safety Administration
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