{"operation":"document","citation":"CPF 420155004W","title":"ENABLE GAS TRANSMISSION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-02-23","effective_on":null,"summary":"CLOSED warning letter citing 195.230, 195.561.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420155004w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420155004w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420155004w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420155004W","body":"Warning Letter involving ENABLE GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 195.230,  195.561. The case was opened on 2015-02-23 and is reported as closed as of 2015-02-23. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420155004W_Warning_02232015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155004W/420155004W_Warning_02232015.pdf\n\n420155004W_Warning_02232015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155004W/420155004W_Warning_02232015_text.pdf\n\n420155004W_Warning_02232015_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 23, 2015\nMr. Pete Kirsch\nVice President Operations and Engineering\nEnable Gas Transmission, LLC\n1111 Louisiana Street\nHouston, TX 77002\nCPF 4-2015-50004W\nDear Mr. Kirsch:\nOn multiple occasions between Dec. 15, 2014 and Feb. 6, 2015, representatives of the Pipeline\nand Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United\nStates Code were onsite and inspected your Enable Gas Transmission LLC (Enable, the\nOperator) pipeline construction project in Arkansas. This construction project is still ongoing.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violation(s) are:\n1. §195.230 Welds: Repair or removal of defects\n(a) Each weld that is unacceptable under §195.228 must be removed or repaired.\nExcept for welds on an offshore pipeline being installed from a pipe lay vessel, a\nweld must be removed if it has a crack that is more than 8 percent of the weld\nlength.\n(b) Each weld that is repaired must have the defect removed down to sound metal and\nthe segment to be repaired must be preheated if conditions exist which would\n\n\n\nadversely affect the quality of the weld repair. After repair, the segment of the\nweld that was repaired must be inspected to ensure its acceptability.\n(b) Repair of a crack, or of any defect in a previously repaired area must be in\naccordance with written weld repair procedures that have been qualified under\n§195.214. Repair procedures must provide that the minimum mechanical\nproperties specified for the welding procedure used to make the original weld are\nmet upon completion of the final weld repair.\nEnable failed to repair a branch weld made on the BT-39 12-inch pipeline construction near\nLittle Rock, AR that should not have passed visual examination. A visual examination would\nshow that this weld had poor fit-up, excessive weld reinforcement and weld passes were not\nmade according to the qualified welding procedure.\n2. §195.561 When must I inspect pipe coating used for external corrosion control?\n(a) You must inspect all external pipe coating required by Sec. 195.557 just prior to\nlowering the pipe into the ditch or submerging the pipe.\n(b) You must repair any coating damage discovered.\nEnable failed to completely repair, by removal and re-application, coating damaged by pre-\nheating the pipe in preparation for application of the field joint coating. Enable did not\ncompletely remove the factory applied FBE coating adjacent to the cutback that was damaged\nwhen inductively heating the pipe. The pipe was being heated inductively in preparation for the\napplication of the 3M Skotchkote 6233 FBE coating being used to coat the field joints. The\napplication procedures for this coating require that the pipe be pre-heated to a temperature of\n425o F to 488o F, not to exceed 500o F, prior to application. Visual examination of the coating\nadjacent to the field joints showed blistering and flaking, indicating that it was damaged by the\nheating process. Failure to completely remove the blistered, flaking coating adjacent to the field\njoint prior to application of the coating may prevent complete bonding of the coating to the\nsurface of the pipe, may result in shielding of the cathodic protection current, and allow the onset\nof corrosion. Enable has since changed the field joint coating to SCP SP-2888, a two-part epoxy\nthat does not require the pipe to be heated to high temperatures prior to application. However,\nPHMSA remains concerned that the coating applied by the previous process over damaged\ncoating adjacent to the field joint may result in corrosion in the area of the field joints.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\n2\n\n\n\nassessment proceedings at this time. We advise you to correct the item(s) identified in this letter.\nFailure to do so will result in Enable being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2015-5004W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment 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":5944}