{"operation":"document","citation":"CPF 420131009W","title":"ENABLE GAS TRANSMISSION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-04-25","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420131009w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420131009w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420131009w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420131009W","body":"Warning Letter involving ENABLE GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2013-04-25 and is reported as closed as of 2013-04-25. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420131009W_Warning_04252013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420131009W/420131009W_Warning_04252013.pdf\n\n420131009W_Warning_04252013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420131009W/420131009W_Warning_04252013_text.pdf\n\n420131009W_Warning_04252013_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 25, 2013\nMr. Pete Kirsch\nSr. VP - Pipeline Operations and Engineering\nCenterpoint Energy Gas Transmission Co\n1111 Louisiana Street\nHouston, TX 77002\nCPF 4-2013-1009W\nDear Mr. Kirsch:\nDuring August - October 2012, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the Centerpoint\nEnergy Gas Transmission Co. (CEGT) Construction Project for pipeline AM-204 located in Saratoga, AR\nand the surrounding area.\nAs a result of the inspections, it appears that you have committed probable violations of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable\nviolation(s) are:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of written\nprocedures for conducting operations and maintenance activities and for emergency\nresponse. For transmission lines, the manual must also include procedures for handling\nabnormal operations. This manual must be reviewed and updated by the operator at\nintervals not exceeding 15 months, but at least once each calendar year. This manual\nmust be prepared before operations of a pipeline system commence. Appropriate parts\nof the manual must be kept at locations where operations and maintenance activities are\nconducted.\n\n\n\n§192.225 Welding Procedures\n(a) Welding must be performed by a qualified welder in accordance with welding procedures\nqualified under section 5 of API 1104 (incorporated by reference, see §192.7) or section IX of\nthe ASME Boiler and Pressure Vessel Code \"Welding and Brazing Qualifications\"\n(incorporated by reference, see §192.7) to produce welds meeting the requirements of this\nsubpart. The quality of the test welds used to qualify welding procedures shall be determined\nby destructive testing in accordance with the applicable welding standard(s).\nCEGT failed to follow their welding procedures, Specification Nos. 102, 139, 200 and 201B when\nqualifying welders for the Line AM-204 construction project.\nCEGT Construction Specification No. 102, Welder Qualification, dated 6/01/2011, section D.1 states:\n“Normally, welders qualifying under ASME Section IX shall be qualified by performing\nbutt weld tests. Depending upon the scope of the work, a welder may be required to take\nand pass two to five weld tests as described below. Welder Qualification Tests numbers 1\nand 2 are the basic test given for most welding situations. Welder Qualifications Test\nnumber 3, 4, and 5 are test given to qualify welders for low-hydrogen electrode or heavy\nwall thickness welding. Welder Qualification Test Number 6 is given to those welders\nwho will weld on API 5LX-80 pipe on the SESH Joint Venture Pipeline. Welder\nQualification Test Number 7 is given to any welder who will be performing in-service\nwelding.”\nFor this construction project, 13 welders were qualified to ASME Section IX using Welder Qualification\nTests 1 and 2. These qualification tests did not meet the requirements of either Specification No. 102 or\nSpecification No. 200. Two of the welders also qualified using Welder Qualification Tests 3, 5 and 7.\nTests 3 and 5 reference Specification No. 201B and Test 7 references Specification No. 139. The\nqualification tests for 3 and 7 did not meet the requirements of Specification No. 201B and Specification\nNo. 139 respectively. In all the testing, CEGT did not document the travel speed, voltage and amperage\nused for each weld pass.\nPHMSA informed CEGT of the welder qualification issues and the operator stated that the electrode sizes\nand classifications used during the welder qualification testing are allowed by ASME Section IX Boiler\nand Pressure Vessel Code. PHMSA agreed and stated that the integrity of the welds were not in question.\nCEGT had failed to follow their written procedures when qualifying the welders\n2. §192.605 Procedural manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least one each\ncalendar year. This manual must be prepared before operations of a pipeline\nsystem commence. Appropriate parts of the manual must be kept at locations\nwhere operations and maintenance activities are conducted.\n2\n\n\n\n§192.461 External corrosion control: Protective coating.\n(c) Each external protective coating must be inspected just prior to lowering the pipe into the\nditch and backfilling, and any damage detrimental to effective corrosion control must be\nrepaired.\nCEGT failed to follow their procedure Construction Specification No. 53 while conducting detailed\ninspection of the coating of the pipe preceding the lowering of the pipe into the trench.\nThe CEGT Construction Specification No. 53, Field Coating of Below Ground Field Joints and Short\nSections, dated 7/31/2010, section G: Inspection states:\n“Contractor shall electronic holiday detector capable of adjusting voltage to permit 150\nvolts/mil coating thickness inspection. Contractor shall furnish one man per pipeline\ncrew to operate the detector as directed by the Inspector. In addition, Contractor shall\nfurnish other labor and equipment that, in the opinion of the Inspector, is needed to\noperate and move the holiday detector along the line.”\nOn two occasions, the PHMSA inspector observed contract personnel performing the ‘jeeping’ process\nusing a holiday detector. In both instances the holiday detector settings were checked and found to be\nincorrect for the coating thickness being inspected. The holiday detector settings were immediately\ncorrected once the settings were identified as incorrect.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per\nviolation per day the violation persists up to a maximum of $2,000,000 for a related series of violations.\nFor violations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per\nviolation per day, with a maximum penalty not to exceed $1,000,000 for a related series of violations.\nWe have reviewed the circumstances and supporting documents involved in this case, and have decided\nnot to conduct additional enforcement action or penalty assessment proceedings at this time. We advise\nyou to correct the item(s) identified in this letter. Failure to do so will result in Centerpoint Energy Gas\nTransmission Co. being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 4-\n2013-1009W. Be advised that all material you submit in response to this enforcement action is subject to\nbeing made publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you must\nprovide a second copy of the document with the portions you believe qualify for confidential treatment\nredacted and 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 Materials Safety Administration\n3","truncated":false,"body_characters":8211}