{"operation":"document","citation":"CPF 420111016W","title":"ENABLE GAS TRANSMISSION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2011-12-08","effective_on":null,"summary":"CLOSED warning letter citing 192.605.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420111016w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420111016w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420111016w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420111016W","body":"Warning Letter involving ENABLE GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.605. The case was opened on 2011-12-08 and is reported as closed as of 2011-12-08. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420111016W_Warning Letter_12082011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420111016W/420111016W_Warning%20Letter_12082011.pdf\n\n420111016W_Warning Letter_12082011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420111016W/420111016W_Warning%20Letter_12082011_text.pdf\n\n420111016W_Warning Letter_12082011_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 8, 2011\nMr. Pete Kirsch\nSenior VP Pipeline Operations & Engineering\nCenterpoint Energy Gas Transmission\n1111 Louisiana Street\nHouston, TX 77002\nCPF 4-2011-1016W\nDear Mr. Kirsch:\nOn various days between February 28 and June 10, 2011, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter\n601 of 49 United States Code inspected your natural gas pipeline system.\nAs a result of the inspection, it appears that you have committed a probable violation of\nthe Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item\ninspected and the probable violation is:\n1. § 192.605 Procedural manual for operations, maintenance, and\nemergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a\nmanual of written procedures for conducting operations and maintenance\nactivities and for emergency response. For transmission lines, the manual\nmust also include procedures for handling abnormal operations. This\nmanual must be reviewed and updated by the operator at intervals not\nexceeding 15 months, but at least once each calendar year. This manual\nmust be prepared before operations of a pipeline system commence.\nAppropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\n\n\n\nCenterpoint Energy Gas Transmission (CEGT) personnel did not follow procedures as\ndescribed in the following paragraphs.\nIn regards to monitoring internal corrosion coupons CEGT’s “Internal Corrosion\nCoupons” procedures, Document Number PS-03-02-294, page 4 of 5, requires the\nexamination of coupons at least twice each calendar year, but with intervals not\nexceeding 7 ½ months. CEGT’s maintenance records indicated internal corrosion\ncoupon monitoring exceeded 7 ½ months for those coupons located in Waskum on Line\nS, and in Caddo Pine Island on Line ST-15. Coupon on Line S went 9 ½ months in\n2009, and coupon on Line ST-15 went 11 ½ months in 2010 between monitoring cycles.\nAlso, during the inspection PHMSA asked CEGT personnel to perform a covered task to\ndemonstrate the necessary knowledge, skill and ability. We refer to this as a Protocol 9\n– Operator Qualification (OQ) Field Inspection. CEGT personnel did not follow\ncompany Operations and Maintenance (O&M) procedures. CEGT Rectifier Inspection\nprocedure, Document Number PS-03-02-242, Section 2.4, requires personnel to check\nthe rectifier cabinet with a multi-meter referenced to ground before grasping the padlock\nto ensure there is not an electrical short through the rectifier cabinet. Once it has been\nestablished that there is not a short, unlock the rectifier and open the cabinet. The\nCEGT Technician failed to use a multi-meter to check for shorts on the rectifier cabinet,\nprior to grasping the padlock. This indicates that CEGT personnel failed to follow O&M\nprocedures while conducting an O&M activity. This is important as the procedure was\nestablished to protect the employee and not following the procedure places\nunnecessary risk on the employee.\nCEGT Compressor Station Gas Detection Testing procedures, Procedure Number 310,\nPart B, requires that 50% lower explosive limit (LEL) calibration gas be applied to\ndetection cells for verification that siren and blue lights are activated at 20% LEL. This\nwill also verify cells are properly calibrated. During an OQ protocol 9 observation of a\nCEGT O&M Technician, he used his mouth to blow on the tube used to attach\ncalibration tank to gas detection sensor. CEGT procedures do not indicate where\nblowing on tube is allowed or required to test gas detection equipment. This indicates\nthat CEGT personnel failed to follow O&M procedures while conducting an O&M\nactivity.\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\n$1,000,000 for any related series of violations. We have reviewed the circumstances\nand supporting documents involved in this case, and have decided not to conduct\nadditional enforcement action or penalty assessment proceedings at this time. We\nadvise you to correct the item(s) identified in this letter. Failure to do so will result in\nCenterpoint Energy Gas Transmission being subject to additional enforcement action.\n2\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please\nrefer to CPF 4-2011-1016W. 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\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C.\n552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted\nand an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous\nMaterials Safety Administration\n3","truncated":false,"body_characters":5789}