ENABLE GAS TRANSMISSION, LLC — Notice of Amendment

420161016M_Closure Letter_03302017_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED March 30, 2017 Mr. Paul M. Brewer Executive Vice President of Operations Enable Gas Transmission, LLC 211 North Robinson Avenue, Room 150 Oklahoma City, OK 73102 CPF 4-2016-1016M Dear Mr. Brewer: On February 2016 to October 2016, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Enable Gas Transmission, LLC (Enable) procedures for Operations and Maintenance, and Integrity Management in Oklahoma City, Oklahoma. As a result of the inspection, Enable was issued a Notice of Amendment (NOA) on December 20, 2016, which proposed amendment of your procedures. Enable submitted its amended procedures on February 22, 2017. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, R. M. Seeley Director, Southwest Region Pipeline and Hazardous Materials Safety Administration#

420161016M_Notice of Amendment_12202016_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED December 20, 2016 Mr. Pete Kirsch Sr. VP-Pipelines Operations and Engineering Enable Gas Transmission, LLC 211 North Robinson Avenue, Room 150 Oklahoma City, OK 73102 CPF 4-2016-1016M Dear Mr. Kirsch: On February 2016 to October 2016, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Enable Gas Transmission, LLC’s (Enable) procedures for Operations and Maintenance; and for Integrity Management in Oklahoma City, OK. On the basis of the inspection, PHMSA has identified the apparent inadequacies found within Enable’s plans or procedures, as described below:#

420161016M_Notice of Amendment_12202016_text.pdf, page 21. §191.605 Procedural manual for operations, maintenance, and emergencies. Each operator shall include the following in its operating and maintenance plan: (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. §191.25 Filing safety-related condition reports. (a) Each report of a safety-related condition under §191.23(a) must be filed (received by OPS within five working days, not including Saturday, Sunday, or Federal Holidays) after the day a representative of the operator first determines that the condition exists, but not later than 10 working days after the day a representative of the operator discovers the condition. Separate conditions may be described in a single report if they are closely related. Reports may be transmitted by electronic mail to InformationResourcesManager@dot.gov or by facsimile at (202) 366-7128. Enable’s Operating & Maintenance Plan, Procedure 108, Identifying and Reporting Safety Related Conditions did not address when a SRCR fell within an HCA. When a SRCR falls within an HCA, the Operator's procedures should address or reference procedures addressing the IMP requirements for making repairs including the provision that when a reduction in operating pressure exceeds 365 days, the operator must notify PHMSA and explain the reasons for the remediation delay. Enable also needs to define when discovery and determination dates are established. On several occasions during the inspection, Enable would establish the discovery date when personnel went to the field location and excavated, when in fact the discovery date was established when Enable had enough information to categorize the anomaly as an immediate condition. 2#

420161016M_Notice of Amendment_12202016_text.pdf, page 32. §192.907 What must an operator do to implement this subpart? (a) General. No later than December 17, 2004, an operator of a covered pipeline segment must develop and follow a written integrity management program that contains all the elements described in § 192.911 and that addresses the risks on each covered transmission pipeline segment. The initial integrity management program must consist, at a minimum, of a framework that describes the process for implementing each program element, how relevant decisions will be made and by whom, a time line for completing the work to implement the program element, and how information gained from experience will be continuously incorporated into the program. The framework will evolve into a more detailed and comprehensive program. An operator must make continual improvements to the program. §192.935 take? What additional preventive and mitigative measures must an operator (a) General requirements. An operator must take additional measures beyond those already required by Part 192 to prevent a pipeline failure and to mitigate the consequences of a pipeline failure in a high consequence area. An operator must base the additional measures on the threats the operator has identified to each pipeline segment. (See §192.917) An operator must conduct, in accordance with one of the risk assessment approaches in ASME/ANSI B31.8S (incorporated by reference, see §192.7), section 5, a risk analysis of its pipeline to identify additional measures to protect the high consequence area and enhance public safety. Such additional measures include, but are not limited to, installing Automatic Shut-off Valves or Remote Control Valves, installing computerized monitoring and leak detection systems, replacing pipe segments with pipe of heavier wall thickness, providing additional training to personnel on response procedures, conducting drills with local emergency responders and implementing additional inspection and maintenance programs. Enable’s Integrity Management Program, PS-258 Preventive & Mitigative Measures procedure, paraphrases regulation 192.935(a) and fails to consider other preventive or mitigative measures not specifically referenced by §192.935 (a). PS-258 lacks details and does not give adequate guidance. 3#

420161016M_Notice of Amendment_12202016_text.pdf, page 43. §192.907 What must an operator do to implement this subpart? (a) General. No later than December 17, 2004, an operator of a covered pipeline segment must develop and follow a written integrity management program that contains all the elements described in § 192.911 and that addresses the risks on each covered transmission pipeline segment. The initial integrity management program must consist, at a minimum, of a framework that describes the process for implementing each program element, how relevant decisions will be made and by whom, a time line for completing the work to implement the program element, and how information gained from experience will be continuously incorporated into the program. The framework will evolve into a more detailed and comprehensive program. An operator must make continual improvements to the program. §192.935 take? What additional preventive and mitigative measures must an operator (b) Third party damage and outside force damage-General. An operator must document any change to its program and the reasons for the change before implementing the change. (1) Third party damage. An operator must enhance its damage prevention program, as required under §192.614 of this part, with respect to a covered segment to prevent and minimize the consequences of a release due to third party damage. Enhanced measures to an existing damage prevention program include, at a minimum- (iv) Monitoring of excavations conducted on covered pipeline segments by pipeline personnel. If an operator finds physical evidence of encroachment involving excavation that the operator did not monitor near a covered segment, an operator must either excavate the area near the encroachment or conduct an above ground survey using methods defined in NACE SP0502-2008 (incorporated by reference, see §192.7). An operator must excavate, and remediate, in accordance with ANSI/ASME B31.8S and §192.933 any indication of coating holidays or discontinuity warranting direct examination. Enable’s Integrity Management Program, PS-258 Preventive & Mitigative Measures procedure does not require Enable to either excavate the area near the encroachment or conduct an above ground survey when Enable finds physical evidence of encroachment involving excavation that Enable did not monitor near a covered segment. This section lacks details to meet the requirements in §192.935(b). 4#

420161016M_Notice of Amendment_12202016_text.pdf, page 54. §192.907 What must an operator do to implement this subpart? (a) General. No later than December 17, 2004, an operator of a covered pipeline segment must develop and follow a written integrity management program that contains all the elements described in § 192.911 and that addresses the risks on each covered transmission pipeline segment. The initial integrity management program must consist, at a minimum, of a framework that describes the process for implementing each program element, how relevant decisions will be made and by whom, a time line for completing the work to implement the program element, and how information gained from experience will be continuously incorporated into the program. The framework will evolve into a more detailed and comprehensive program. An operator must make continual improvements to the program. §192.935 take? What additional preventive and mitigative measures must an operator (d) Pipelines operating below 30% SMYS. An operator of a transmission pipeline operating below 30% SMYS located in a high consequence area must follow the requirements in paragraphs (d)(1) and (d)(2) of this section. An operator of a transmission pipeline operating below 30% SMYS located in a Class 3 or Class 4 area but not in a high consequence area must follow the requirements in paragraphs (d)(1), (d)(2) and (d)(3) of this section. (2) Either monitor excavations near the pipeline, or conduct patrols as required by §192.705 of the pipeline at bi-monthly intervals. If an operator finds any indication of unreported construction activity, the operator must conduct a follow up investigation to determine if mechanical damage has occurred. Enable’s Integrity Management Program, , PS-258 Preventive & Mitigative Measures, Section 4.4 Low Stress Pipelines does not require Enable to either monitor excavations near the pipeline, or conduct patrols as required of the pipeline at bi-monthly intervals and if Enable finds any indication of unreported construction activity, the Enable must conduct a follow up investigation to determine if mechanical damage has occurred. This part of PS-258 also paraphrases the code and lacks details. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings. Please refer to this document and note the response options. 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). 5#

420161016M_Notice of Amendment_12202016_text.pdf, page 6Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that Enable Gas Transmission, LLC maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to R.M. Seeley, Director, Southwest Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 4-2016-1016M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, R.M. Seeley Director, Southwest Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings 6#