# ENABLE GAS TRANSMISSION, LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 420131018
- **title:** ENABLE GAS TRANSMISSION, LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2013-11-05
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 192.303, 192.467(d), 192.491(a), 192.605(a), 192.709(b), 192.719(a), 192.731(c), 192.739(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-420131018.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-420131018.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-420131018
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420131018
**body:**

Notice of Probable Violation involving ENABLE GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.303,  192.467(d),  192.491(a),  192.605(a),  192.709(b),  192.719(a),  192.731(c),  192.739(a). The case was opened on 2013-11-05 and is reported as closed as of 2016-04-25. Proposed civil penalty: $118,200. Assessed civil penalty: $118,200. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420131018_Closure Letter_04252016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420131018/420131018_Closure%20Letter_04252016.pdf

420131018_Closure Letter_04252016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420131018/420131018_Closure%20Letter_04252016_text.pdf

420131018_Final Order_01292015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420131018/420131018_Final%20Order_01292015.pdf

420131018_Final Order_01292015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420131018/420131018_Final%20Order_01292015_text.pdf

420131018_NOPV PCP PCO_11052013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420131018/420131018_NOPV%20PCP%20PCO_11052013.pdf

420131018_NOPV PCP PCO_11052013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420131018/420131018_NOPV%20PCP%20PCO_11052013_text.pdf

420131018_Operator Response to Notice_ 01202014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420131018/420131018_Operator%20Response%20to%20Notice_%2001202014.pdf

420131018_Final Order_01292015_text.pdf

January 29, 2015
Mr. Lynn L. Bourdon III
President and CEO
Enable Midstream Partners, LP
One Leadership Square
211 N Robinson Ave., Suite 950
Oklahoma City, OK 73102
Re: CPF No. 4-2013-1018
Dear Mr. Bourdon:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation, assesses a civil penalty of $118,200, and specifies actions that need to be taken by your
subsidiary, Enable Gas Transmission, LLC, to comply with the pipeline safety regulations. The
penalty payment terms are set forth in the Final Order. When the civil penalty has been paid and
the terms of the compliance order completed, as determined by the Director, Southwest Region,
OPS, this enforcement action will be closed. Service of the Final Order by certified mail is
deemed effective upon the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Rodrick M. Seeley, Director, Southwest Region, OPS
Mr. Chris Bullock, Director, DOT Compliance, Enable Midstream Partners, LP
CERTIFIED MAIL - RETURN RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
)
In the Matter of )
)
Enable Gas Transmission, LLC, ) CPF No. 4-2013-1018
)
Respondent. )
____________________________________)
FINAL ORDER
On multiple dates in February and March, 2013, pursuant to 49 U.S.C. § 60117, representatives
of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline
Safety (OPS), conducted an on-site pipeline safety inspection of the facilities and records of
Centerpoint Energy Gas Transmission Company, LLC (CEGT), in Arkansas, Louisiana, and
Oklahoma. Since the date of that inspection, CEGT has been renamed Enable Gas Transmission,
LLC (EGT or Respondent).1 EGT is one of two wholly-owned subsidiaries of Enable
Midstream Partners, LP, which operates more than 8,000 miles of interstate pipeline located in
Arkansas, Illinois, Kansas, Louisiana, Mississippi, Missouri, Oklahoma, Tennessee and Texas.
2
As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to
Respondent, by letter dated November 5, 2013, a Notice of Probable Violation, Proposed Civil
Penalty, and Proposed Compliance Order (Notice), which also included warnings pursuant to
49 C.F.R. § 190.205. In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that
EGT had committed various violations of 49 C.F.R. Part 192 and assessing a civil penalty of
$118,200 for the alleged violations. The Notice also proposed ordering Respondent to take
certain measures to correct the alleged violations. The warning items required no further action,
but warned the operator to correct the probable violations or face future potential enforcement
action.
EGT responded to the Notice by letter dated January 20, 2014 (Response). The company
contested some of the allegations, offered additional information in response to the Notice, and
requested that the proposed civil penalty be reduced. Respondent did not request a hearing and
therefore has waived its right to one.
1 Centerpoint Energy Inc., Annual Report (Form 10-K), at 78 (Feb. 26, 2014), available at
http://investors.centerpointenergy.com/annuals.cfm.
2 http://www.centerpointenergy.com/services/pipelines/egt/ (last accessed on July 28, 2014).



CPF No: 4-2013-1018
Page 2
FINDINGS OF VIOLATION
The Notice alleged that Respondent violated 49 C.F.R. Part 192, as follows:
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 192.467(d), which states:
§ 192.467 External corrosion control: Electrical isolation.
(a) Each buried or submerged pipeline must be electrically isolated
from other underground metallic structures, unless the pipeline and the
other structures are electrically interconnected and cathodically protected
as a single unit.
(b) . . . .
(d) Inspection and electrical tests must be made to assure that electrical
isolation is adequate.
The Notice alleged that Respondent violated 49 C.F.R. § 192.467(d) by failing to inspect and
electrically test each buried pipeline to assure that electrical isolation was adequate. Specifically,
the Notice alleged that EGT’s corrosion control program procedure required testing of insulating
devices at custody-transfer locations on both the foreign side and the EGT side of the line, but
that the company had failed to take readings on the foreign side of insulating devices at 11
different locations for a total of 29 times during 2010, 2011, and 2012.
In its Response, EGT stated that the company missed only eight of the required readings, and
requested that PHMSA reduce the level of the proposed civil penalty and the scope of the
proposed compliance order accordingly. EGT stated that 13 of the readings were at test points
“categorized as ‘Normal’ rather than ‘Insulated’ and thus no ‘foreign side’ electric potential
reading was required.”3 EGT stated that the eight missing readings were at test points that “had
been mistakenly identified as ‘Insulated’ in EGT’s Maintenance Management System,” that EGT
had already identified and corrected the data error prior to PHMSA’s inspection, and that
therefore these missing readings should not be considered violations of the regulation. In
support of this argument, EGT provided a report listing test-point inspection results.4
EGT’s Response and attached report, however, do not explicitly identify which test readings the
company believes fall into each category. My review of the report shows the following:
Test Point Location Dates of tests with test-point
type listed as “Insulated”
Dates of tests with test-point
type listed as “Normal”
TP 21250 5/6/2010 and 5/11/2011
TP 24316 5/6/2010 and 5/11/2011 5/15/2012
TP 26318 4/28/2010 and 4/18/2011
TP 27667 12/21/2010 and 4/18/2011 4/10/2012
TP 27668 12/21/2010 and 4/18/2011 4/10/2012
TP 27669 12/21/2010 4/18/2011 and 4/10/2012
3 Response at 5.
4 Response Attachment 2-1.



CPF No: 4-2013-1018
Page 3
TP 27671 12/21/2010 4/18/2011 and 4/10/2012
TP 27672 12/21/2010 4/18/2011 and 4/10/2012
TP 27673 12/21/2010 4/18/2011 and 4/10/2012
TP 4085 6/18/2010 6/13/2011 and 6/14/2012
TP 8242 8/7/2010
This review does show eight locations where the test-point type was changed from “Insulated” to
“Normal.” However, EGT did not provide an explanation as to why the test points that had been
mistakenly identified as “Insulated” were later changed to “Normal” and why they were not
corrected on the report at the time of the inspections if they were not, in fact, insulated. If EGT
discovered during a test that a test point was identified incorrectly, the test record should have
made a note of this data error.
At least one test was conducted at each of the 11 test-point locations that had been identified as
“Insulated,” but EGT neither conducted a “foreign-side” test at these sites nor corrected the
identification of the test point. In each of these 11 locations, the company’s records fail to
demonstrate that EGT was able to assure that electrical isolation was indeed adequate.
Accordingly, based upon a review of all of the evidence and the legal issues presented, I find that
Respondent violated 49 C.F.R. § 192.467(d) by failing to inspect and electrically test each buried
pipeline to assure that electrical isolation was adequate.
Item 7: The Notice alleged that Respondent violated 49 C.F.R. § 192.605(a), which states:
§ 192.605 Procedural manual for operations, maintenance, and
emergencies.
(a) General. Each operator shall prepare and follow for each pipeline, a
manual of written procedures for conducting operations and maintenance
activities and for emergency response. For transmission lines, the manual
must also include procedures for handling abnormal operations. This
manual must be reviewed and updated by the operator at intervals not
exceeding 15 months, but at least once each calendar year. This manual
must be prepared before operations of a pipeline system commence.
Appropriate parts of the manual must be kept at locations where operations
and maintenance activities are conducted.
The Notice alleged that Respondent violated 49 C.F.R. § 192.605(a) by failing to follow its own
manual of written procedures for conducting operations and maintenance activities. Specifically,
the Notice alleged that EGT’s procedures required it to periodically evaluate pipeline “dead legs”
for corrosivity through gas sampling, coupons, and liquid sampling, but that the company failed
to conduct evaluations at five such locations, at facilities with piping that was defined as “U-
shaped” or “L-shaped.”
In its Response, EGT stated that it had “complied with its procedures for evaluating the risk of
corrosion in dead legs identified” in the Notice.
5 EGT explained that its Corrosion Control
5 Response at 8.



CPF No: 4-2013-1018
Page 4
Program Procedure PS-03-02-002 did not require that the company inspect each dead leg.
Rather, it argued that its procedure required that EGT “evaluate the risk of internal corrosion
based on multiple factors and the presence of corrosive gas…. Applying these procedures, EGT
‘evaluates’ its entire system, of which the dead legs addressed in the [Notice] would be a part of
[sic], based on these factors.”6 EGT went on to explain that the procedure also referenced the
company’s Integrity Management Program to assess and evaluate the risk of internal corrosion.
Finally, EGT stated that its “systematic evaluations showed no corrosive gas conditions upstream
of the dead leg locations addressed in [the Notice], so no further evaluation within those dead leg
locations was required by EGT’s procedures.”7
I disagree, for two reasons. First, EGT did not provide a copy of its evaluation or analysis of
upstream conditions that supposedly determined there were no corrosive conditions and that the
dead legs in question here did not need to be evaluated for internal corrosion. In fact, the
procedure that was available during the OPS inspection and the version that EGT provided in its
Response could readily support the opposite conclusion. It identified several factors that
influence the formation of internal corrosion, including dead legs, and stated: “Because of the
above factors, the Company will periodically evaluate gas pipelines for corrosivity through gas
sampling, coupons, and liquid sampling as required.”
Second, EGT stated that it complied with its procedure by performing system-wide evaluations,
but did not identify how the company evaluated the “U-shaped” and “L-shaped” dead legs
identified in the Notice. In its Response, EGT provided a copy of its 2009 Dead Leg Inspection
Program – Final Summary Report, which states: “The typical dead leg configuration we are
trying to evaluate is one of the following where a section of pipe has been stubbed or capped
such that there is no/low flow gas conditions.” The report goes on: “Five or 6 representative
dead legs were selected from each region with the intention of developing a diversified sampling
of the dead legs across the company pipeline system. The location of these dead legs was
identified based on feedback from personnel from each region.”8
While such a systematic approach is commendable, EGT still failed to follow its own procedures
for evaluating each type of dead leg that existed on its system. Notably, the dead legs that were
identified in the Notice were all oriented in the vertical plane, and there is no indication that EGT
evaluated other dead legs with similar characteristics or considered the orientation of the dead
legs as a factor to be considered in its inspection program
As a consequence, EGT failed to demonstrate that it had evaluated all types of dead legs in its
system, including “U-shaped” and “L-shaped” dead legs and those oriented in the vertical plane,
for internal corrosion through gas sampling, coupons, and liquid sampling as required by its
Corrosion Control Program Procedure PS-03-02-001. Accordingly, after considering all of the
evidence and the legal issues presented, I find that Respondent violated 49 C.F.R. § 192.605(a)
by failing to follow its manual of written procedures for conducting operations and maintenance
6 Response at 9.
7 Id.
8 Response, Attachment 7-4, at 1.



CPF No: 4-2013-1018
Page 5
activities.
Item 10: The Notice alleged that Respondent violated 49 C.F.R. § 192.739(a), which states:
§ 192.739 Pressure limiting and regulating stations: Inspection and
testing.
(a) Each pressure limiting station, relief device (except rupture discs),
and pressure regulating station and its equipment must be subjected at
intervals not exceeding 15 months, but at least once each calendar year, to
inspections and tests to determine that it is—
(1) In good mechanical condition;
(2) Adequate from the standpoint of capacity and reliability of
operation for the service in which it is employed;
(3) Except as provided in paragraph (b) of this section, set to control or
relieve at the correct pressure consistent with the pressure limits of
§ 192.201(a); and
(4) Properly installed and protected from dirt, liquids, or other
conditions that might prevent proper operation.
The Notice alleged that Respondent violated 49 C.F.R. § 192.739(a) by failing to inspect and test
each pressure regulating station at least once each calendar year to determine that it is set to
control or relieve at the correct pressure consistent with the pressure limits of § 192.201(a).
Specifically, the Notice alleged that from 2007 to 2011, EGT failed to inspect regulating station
MSM11007 to ensure it was set to control or relieve pressure consistent with the pressure limits
of the downstream plastic pipeline RM-5.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 192.739(a) by failing to inspect and
test each pressure regulating station to determine that it is set to control or relieve at the correct
pressure consistent with the pressure limits of § 192.201(a).
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed
$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any
related series of violations.9 In determining the amount of a civil penalty under 49 U.S.C.
§ 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature,
circumstances, and gravity of the violation, including adverse impact on the environment; the
degree of Respondent’s culpability; the history of Respondent’s prior offenses; and any effect
9 The Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011, Pub. L. No. 112-90, § 2(a)(1), 125 Stat.
1904, January 3, 2012, increased the civil penalty liability for violating a pipeline safety standard to $200,000 per
violation for each day of the violation, up to a maximum of $2,000,000 for any related series of violations.



CPF No: 4-2013-1018
Page 6
that the penalty may have on its ability to continue doing business; and the good faith of
Respondent in attempting to comply with the pipeline safety regulations. In addition, I may
consider the economic benefit gained from the violation without any reduction because of
subsequent damages, and such other matters as justice may require. The Notice proposed a total
civil penalty of $118,200 for the violations cited above.
Item 2: The Notice proposed a civil penalty of $72,700 for Respondent’s violation of
49 C.F.R. § 192.467(d), for failing to inspect and electrically test each buried pipeline to assure
that electrical isolation was adequate. The Notice alleged that Respondent failed to take readings
on the foreign side of insulating devices at 11 different locations a total of 29 times, and
accordingly proposed a civil penalty based on 11 violations of the regulation.
In its Response, EGT stated that the company missed only eight of the required readings and
requested that the civil penalty be reduced accordingly. However, as discussed above, I found
that at all 11 test point locations, at least one test was conducted during a time when it was
identified as “Insulated,” yet neither a “foreign-side” test was conducted nor was the
identification of the test point corrected. I have reviewed the original penalty that was proposed
and find that it was reasonably based on the 11 test sites in question, not the total number of tests
that were allegedly missed.
Electrical isolation is necessary to protect against external corrosion, which can cause pipeline
failure if left unchecked. Respondent was fully culpable for its failure to conduct the tests
according to its own procedures and records. Accordingly, having reviewed the record and
considered the assessment criteria, I assess Respondent a civil penalty of $72,700 for violation of
49 C.F.R. § 192.467(d).
Item 10: The Notice proposed a civil penalty of $45,500 for Respondent’s violation of
49 C.F.R. § 192.739(a), for failing to inspect and test each pressure regulating station to
determine that it is set to control or relieve at the correct pressure consistent with the pressure
limits of § 192.201(a). Respondent did not contest either the allegation or the proposed penalty.
Pressure limiting devices are necessary to prevent over-pressurization, which can cause a
pipeline failure. Respondent’s failure to inspect this pressure regulating station for five years
could have resulted in a serious pipeline accident. Respondent was fully aware of the
requirement and fully culpable for the violation. Accordingly, having reviewed the record and
considered the assessment criteria, I assess Respondent a civil penalty of $45,500 for violation of
49 C.F.R. § 192.739(a).
In summary, having reviewed the record and considered the assessment criteria for each of the
Items cited above, I assess Respondent a total civil penalty of $118,200.
Payment of the civil penalty must be made within 20 days of service. Federal regulations
(49 C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer through the Federal
Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed
instructions are contained in the enclosure. Questions concerning wire transfers should be
directed to: Financial Operations Division (AMK-325), Federal Aviation Administration, Mike
Monroney Aeronautical Center, P. O. Box 269039, Oklahoma City, Oklahoma 73125. The



CPF No: 4-2013-1018
Page 7
Financial Operations Division telephone number is (405) 954-8845.
Failure to pay the $118,200 civil penalty will result in accrual of interest at the current annual
rate in accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to
those same authorities, a late penalty charge of six percent (6%) per annum will be charged if
payment is not made within 110 days of service. Furthermore, failure to pay the civil penalty
may result in referral of the matter to the Attorney General for appropriate action in a district
court of the United States.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Items 2 and 7 in the Notice for
violations of 49 C.F.R. §§ 192.467(d) and 192.605(a), respectively. Under 49 U.S.C.
§ 60118(a), each person who engages in the transportation of gas or who owns or operates a
pipeline facility is required to comply with the applicable safety standards established under
chapter 601. Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217,
Respondent is ordered to take the following actions to ensure compliance with the pipeline safety
regulations applicable to its operations:
1. With respect to the violation of § 192.467(d) (Item 2), Respondent must evaluate
its pipeline system and locate all custody-transfer electrical isolation points. At each
such location, Respondent must confirm that electrical isolation is adequate and take
prompt action to correct any deficiencies. Respondent must complete this item and
provide a report detailing any deficiencies and remediation to the Director within 180
days after receipt of this Final Order.
2. With respect to the violation of § 192.605(a) (Item 7), Respondent must develop a
plan to locate and evaluate all types of dead legs within its pipeline system for
internal corrosion, and must submit this plan to the Director within 90 days after
receipt of this Final Order. Respondent must document the evaluation of each dead
leg location and any corrective actions taken as a result of these evaluations, and
submit the results to the Director within one year after receipt of this Final Order.
The Director may grant an extension of time to comply with any of the required items upon a
written request timely submitted by the Respondent and demonstrating good cause for an
extension.
Failure to comply with this Order may result in the administrative assessment of civil penalties
not to exceed $200,000 for each violation for each day the violation continues or in referral to the
Attorney General for appropriate relief in a district court of the United States.



CPF No: 4-2013-1018
Page 8
WARNING ITEMS
With respect to Items 1, 3, 4, 5, 6, 8, and 9, the Notice alleged probable violations of Part 192 but
did not propose a civil penalty or compliance order for these items. Therefore, these are
considered to be warning items. The warnings were for:
49 C.F.R. § 192.476(d) (Item 1) ─ Respondent’s alleged failure to maintain
records demonstrating compliance with § 192.476(d) regarding internal corrosion
control in the design and construction of transmission lines; and
49 C.F.R. § 192.491(a) (Item 3) ─ Respondent’s alleged failure to maintain
records or maps showing the location of anodes used to provide cathodic
protection to an isolated section of its pipeline; and
49 C.F.R. § 192.731(c) (Item 4) ─ Respondent’s alleged failure to inspect and
test each remote control shutdown device at intervals not exceeding 15 months,
but at least once each calendar year; and
49 C.F.R. § 192.605(a) (Items 5 and 6) ─ Respondent’s alleged failure to follow
its manual of written procedures for conducting operations and maintenance
activities;10
49 C.F.R. § 192.709(b) (Item 8) ─ Respondent’s alleged failure to maintain
records associated with the replacement of a safety valve for at least five years;
and
49 C.F.R. § 192.719(a) (Item 9) ─ Respondent’s alleged failure to test
replacement pipe used to repair a segment of transmission line, to the pressure
required for a new line installed in the same location.
EGT presented information in its Response showing that it had taken certain actions to address
the cited items. If OPS finds a violation of any of these items in a subsequent inspection,
Respondent may be subject to future enforcement action.
Under 49 C.F.R. § 190.215, Respondent has a right to submit a Petition for Reconsideration of
this Final Order. The petition must be sent to: Associate Administrator, Office of Pipeline
Safety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC
20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address. PHMSA
will accept petitions received no later than 20 days after receipt of service of this Final Order by
the Respondent, provided they contain a brief statement of the issue(s) and meet all other
requirements of 49 C.F.R. § 190.215. The filing of a petition automatically stays the payment of
any civil penalty assessed. Unless the Associate Administrator, upon request, grants a stay, all
10 In its Response to Item 6, EGT noted that it had identified and corrected this violation prior to the OPS
inspection, and requested that PHMSA take such efforts into account as a mitigating factor to reduce a proposed
civil penalty or proposed compliance order requirement. The NOPV did not propose a civil penalty or compliance
order for this alleged violation, so no mitigation or revision is needed. See Response at 2-3.



CPF No: 4-2013-1018
Page 9
other terms and conditions of this Final Order are effective upon service in accordance with
49 C.F.R. § 190.5.
___________________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

420131018_Closure Letter_04252016_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
April 25, 2016
Mr. Paul Brewer
Senior VP Operations and EH&S
Enable Gas Transmission, LLC
One Leadership Square
211 N Robinson Ave., Suite 150
Oklahoma City, OK 7310
CPF 4-2013-1018
Dear Mr. Brewer:
From February through March 2013, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) issued to Enable Gas Transmission, LLC a Final Order in the above-
referenced case. This Order included a Compliance Order and Civil Penalty assessment. Based
on our review of the documentation you provided and confirmation of payment of the civil
penalty, it has been determined that you have complied with the terms of this Order.
Accordingly, this case is now closed and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
R. M. Seeley
Director, SW Region
Pipeline and Hazardous Materials Safety Administration

420131018_NOPV PCP PCO_11052013_text.pdf

NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPLIANCE ORDER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
November 5, 2013
Mr. Pete Kirsch
Sr. VP - Pipeline Operations and Engineering
Enable Gas Transmission, LLC
1111 Louisiana Street
Houston, TX 77002
CPF 4-2013-1018
Dear Mr. Kirsch:
On multiple dates in February and March, 2013, representatives of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter
601 of 49 United States Code inspected portions of Centerpoint Energy Gas Transmission Co
(CEGT) pipeline system located in Arkansas, Louisiana, and Oklahoma. PHMSA understands
that CEGT is now known as Enable Gas Transmission, LLC.
As a result of the inspections, 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 violations are:
1. §192.303 Compliance with specifications or standards.
Each transmission line or main must be constructed in accordance with
comprehensive written specifications or standards that are consistent with this part.
§192.476 Internal corrosion control: Design and construction of transmission line.
(d) Records. An operator must maintain records demonstrating compliance with this
section. Provided the records show why incorporating design features addressing
paragraph (a)(1), (a)(2), or (a)(3) of this section is impracticable or unnecessary, an



2. operator may fulfill this requirement through written procedures supported by as-
built drawings or other construction records.
Centerpoint Energy Gas Transmission Co. (CEGT) failed to demonstrate compliance
with their procedure and did not complete Form PS8256 (9-2009) or file the form in the
design and line files.
CEGT Corrosion Control Program Procedure PS-06-01-205 Design and Construction of
New Pipeline or Replacement Sections - to Reduce the Risk of Internal Corrosion, section
2.7 Record Keeping states,
“The design for new gas transmission and/or new gas transmission
pipeline segments shall be documented on Form PS8256 Design and
Construction of New Pipeline or Replacement Sections - to reduce the risk
of internal corrosion, including at least one selection under each of the
following parts -...”
It further states,
“This documentation will be filed in the design file and line file…”
While reviewing CEGT project AFE #11583, Line F-625, the PHMSA inspector learned
that CEGT did not complete the Form PS8256 (9-2009). CEGT completed and provided
this document on 2/6/2013 only after the PHMSA inspector requested a copy at the time
of the inspection.
§192.467 External corrosion control: Electrical isolation.
(d) Inspection and electrical tests must be made to assure that electrical isolation is
adequate.
CEGT failed to conduct electrical tests on the foreign pipeline side at custody transfer
points to assure adequate electrical isolation.
According to the CEGT Corrosion Control Program, Procedure PS-03-02-232
Installation of Insulating Devices, section 2.2 Locations states,
“Typical locations where electrical insulating devices may be installed
include the following:
…
Point at which facilities change ownership, such as meter stations and
well heads.
…”
Section 2.4 Compressor Station Piping, Insulating flanges and Solid State Decouplers
(SSD): states,
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“… The required monitoring of cathodic protection systems and the
evaluation of test data is sufficient to ensure that electrical isolation is
adequate and the SSD are functioning properly…
… If the potentials are more than 100 mv apart, this is generally an
indication that the device is functioning properly. If the potentials are
within 100mv of each other, additional evaluations are required to
determine the condition of the insulation and for possible repair.”
The CEGT Corrosion Control Program Procedure PS-03-02-230 Pipe-to-Soil Potential
Survey, revised date 02/02/2011, section 2.5 Electrode Placement states,
“… Insulating devices: (See Figure 4)
- Place the electrode in a position where both the foreign-side and the
pipeline side of the insulating fittings can be reached to ensure isolation.
Do not move the electrode during this test. Take and document the
potential readings for storage in the MMS.…”
During the inspection, the PHMSA inspector noted CEGT failed to take potential
readings on the foreign-side of insulating devices at the following sites during the
calendar years 2010, 2011, and 2012:
TP 21250 on 5/6/2010 and 5/11/2011 - STEEL SCAPE.
TP 24316 on 5/6/2010, 5/11/2011, 5/15/2012 - PRAT.
TP 26318 on 4/28/2010, 4/18/2011 - REGENCY.
TP 27667 on 12/21/2010, 4/18/2011, 4/10/2012 - SWEPCO POWER PLANT.
TP 27668 on 12/21/2010, 4/18/2011, 4/10/2012 - SWEPCO POWER PLANT.
TP 27669 on 12/21/2010, 4/18/2011, 4/10/2012 - SWEPCO POWER PLANT.
TP 27671 on 12/21/2010, 4/18/2011, 4/10/2012 - SWEPCO POWER PLANT.
TP 27672 on 12/21/2010, 4/18/2011, 4/10/2012 - SWEPCO POWER PLANT.
TP 27673 on 12/21/2010, 4/18/2011, 4/10/2012 - SWEPCO POWER PLANT.
TP 4085 on 6/18/2010, 6/13/2011, 6/14/2012 - LIEBERMAN POWER PLANT.
TP 8242 on 8/7/2010 - IP DOMINO.
3. §192.491 Corrosion control records.
(a) Each operator shall maintain records or maps to show the location of
cathodically protected piping, cathodic protection facilities, galvanic anodes,
and neighboring structures bonded to the cathodic protection system. Records
or maps showing a stated number of anodes, installed in a stated manner or
spacing, need not show specific distances to each buried anode.
CEGT did not maintain maps or records showing the anode locations or note the number
of anodes and the spacing used to provide cathodic protection to an isolated section of
Line 634-2.
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4. 5. CEGT’s Line 634-2 has a section of 2 inch steel pipeline that is isolated from the
impressed current cathodic protection system by a section of 2 inch plastic pipe. The
isolated section of Line 634-2 is protected by galvanic anodes. CP records for 2009,
2010, 2011, and 2012 verified that the isolated section of pipeline had adequate cathodic
protection. Per §192.491(a), CEGT records and/or maps should state the number of
anodes installed in a stated manner or spacing.
§192.731 Compressor stations: Inspection and testing of relief devices.
(c) Each remote control shutdown device must be inspected and tested at intervals
not exceeding 15 months, but at least once each calendar year, to determine that
it functions properly.
CEGT personnel failed to inspect and test at intervals not exceeding 15 months, but at
least once each calendar year, the Remote Control Shutdown devices (ESD) at the Allen
Compressor Station in calendar year 2010.
PHMSA reviewed the ESD maintenance and testing records for Allen Compressor
Station for the years 2008 through 2012 during this inspection of the Ada Team area.
The 2008 and 2009 ESD maintenance was performed in December of each year. The
2010 ESD maintenance should have been completed by December 31, 2010. No
maintenance was performed in the calendar year 2010 for the 9 ESD activation locations
at the compressor station. The 2011 ESD maintenance was performed in January and the
2012 ESD maintenance was performed in February.
§192.605 Procedural manual for operations, maintenance, and emergencies
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and
for emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed
and updated by the operator at intervals not exceeding 15 months, but at least
one each calendar year. This manual must be prepared before operations of a
pipeline system commence. Appropriate parts of the manual must be kept at
locations where operations and maintenance activities are conducted.
CEGT failed to follow their procedure and ensure that no permanent structure will be
allowed on the Company’s pipeline right-of-ways that may obstruct maintenance or
immediate access to the pipeline. There are two (2) permanent structures on the pipeline
right-of-way placed directly over Line JM-19.
CEGT Operating and Maintenance Plan Procedure No.: 244 Encroachment, section A.
Permanent Structures states,
“No permanent structure will be allowed on the Company’s pipeline right-
of-ways that may obstruct maintenance or immediate access to the
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6. pipeline. These structures include (but are not limited to) houses, trailer
houses, mobile homes, camp houses, camping structures, patios, carports,
sheds, barns, silos, chicken houses, water wells and non-skidded auxiliary
buildings.”
Furthermore section J. Reimbursement, 3. states,
“The following form shall be completed where applicable: Form PS-7989
– Report of Encroachment on Pipeline Right of Way.”
During the Wynne Team area inspection, PHMSA visited a small commercial/industrial
area along Line JM-19, a 12 inch pipeline. At 334 Phillips Road 311, the pipeline
traverses the parking lot in front of NORAC, one of the businesses in the area. The
pipeline is approximately 15 feet to the east side of Phillips Road 311. Situated on
NORAC property along each side property line (perpendicular to Phillips Rd 311) and
directly over Line JM-19, there are two enclosed structures housing water metering
facilities.
On March 11, 2013, the PHMSA inspector checked with the CEGT Compliance
Specialist for the Northern Business area to see if past patrolling records would have
noted the sheds. CEGT personnel stated that the structures were in place for
approximately 8 years. Patrolling records from 2004 to the present date were checked
and did not note the structures over the pipeline. Also, CEGT was unable to locate
completed forms 7989, Report of Encroachment on Pipeline Right of Way, for these
locations. Report of Encroachment on Pipeline Right of Way forms were initiated for the
two encroachments along Phillips Road 311 on March 4, 2013 following this inspection.
§192.605 Procedural manual for operations, maintenance, and emergencies
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and
for emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed
and updated by the operator at intervals not exceeding 15 months, but at least
one each calendar year. This manual must be prepared before operations of a
pipeline system commence. Appropriate parts of the manual must be kept at
locations where operations and maintenance activities are conducted.
§192.745 Valve maintenance: Transmission lines.
(a) Each transmission line valve that might be required during any emergency must be
inspected and partially operated at intervals not exceeding 15 months, but at least
once each calendar year.
CEGT failed to follow their procedures and maintain valve BV82309 as required by
§192.745(a). According to CEGT, this valve is an essential valve that would be
necessary in an emergency situation.
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7. CEGT Operations and Maintenance Plan Procedure No. 232, Emergency Valve
Operation and Maintenance, A. Requirement, states
“1. The following are designated as emergency valves:
…
d. Valves at branches or intracompany pipeline connections.
…
Each of these valves shall be partially operated at intervals not exceeding
15 months, but at least once each calendar year.”
During this inspection, PHMSA noted that CEGT failed to maintain valve BV82309 (4”
tie-in for Line 1-F-7) and could not provide the records indicating the valve was
inspected prior to 2011. According to the documents provided, the valve was first
inspected on 3/1/2011. CEGT advised the PHMSA inspector that the valve was operated
numerous times since the valve was installed, but could not provide any documentation to
indicate that it was inspected.
§192.605 Procedural manual for operations, maintenance, and emergencies
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and
for emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed
and updated by the operator at intervals not exceeding 15 months, but at least
one each calendar year. This manual must be prepared before operations of a
pipeline system commence. Appropriate parts of the manual must be kept at
locations where operations and maintenance activities are conducted.
§192.605 Procedural manual for operations, maintenance, and emergencies
(b) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the f
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