{"operation":"document","citation":"CPF 420191014M","title":"ENABLE GAS TRANSMISSION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-12-30","effective_on":null,"summary":"CLOSED notice of amendment citing 192.631(a)(1), 192.911(k).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420191014m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420191014m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420191014m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420191014M","body":"Notice of Amendment involving ENABLE GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.631(a)(1),  192.911(k). The case was opened on 2019-12-30 and is reported as closed as of 2020-07-08. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420191014M_Closure Letter_07082020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420191014M/420191014M_Closure%20Letter_07082020.pdf\n\n420191014M_Closure Letter_07082020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420191014M/420191014M_Closure%20Letter_07082020_text.pdf\n\n420191014M_Notice of Amendment_12302019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420191014M/420191014M_Notice%20of%20Amendment_12302019.pdf\n\n420191014M_Notice of Amendment_12302019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420191014M/420191014M_Notice%20of%20Amendment_12302019_text.pdf\n\n420191014M_Operator Response to Notice_01302020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420191014M/420191014M_Operator%20Response%20to%20Notice_01302020.pdf\n\n420191014M_Closure Letter_07082020_text.pdf\n\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nJuly 8, 2020\nCary Watson\nVice President, Safety, Environmental and Technical Programs\nEnable Midstream Partners\n499 W. Sheridan, Ste 1500 M/760\nOklahoma City, Oklahoma 73102\nCPF-4-2019-1014M\nDear Mr. Watson:\nFrom June 3, 2019 to September 27, 2019, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of Enable Gas Transmission’s (Enable) procedures\nin Oklahoma City, Oklahoma. As a result of the inspection, Enable was issued a Notice of\nAmendment on December 30, 2019, which proposed amendment of your procedures.\nEnable submitted its amended procedures on June 24, 2020. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n\n420191014M_Notice of Amendment_12302019_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 30, 2019\nPaul Brewer\nExecutive Vice President of Operations\nEnable Midstream Partners\n499 W. Sheridan, Ste 1500\nOklahoma City, Oklahoma 73102\nCPF 4-2019-1014M\nDear Mr. Brewer:\nFrom June 3, 2019 to September 27, 2019, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nEnable Gas Transmission (Enable) procedures for Operations and Maintenance, Control Room\nManagement, and Integrity Management in Oklahoma City, Oklahoma. Enable Midstream\nPartners operate under the Enable Gas Transmission procedures.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nEnable’s plans or procedures, as described below:\n1. §192.631 Control room management.\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline\nfacility through a SCADA system. Each operator must have and follow written\ncontrol room management procedures that implement the requirements of\nthis section, except that for each control room where an operator's activities\nare limited to either or both of:\n(i) Distribution with less than 250,000 services, or\n\n\n\n(ii) Transmission without a compressor station, the operator must have and\nfollow written procedures that implement only paragraphs (d) (regarding\nfatigue), (i) (regarding compliance validation), and (j) (regarding compliance\nand deviations) of this section.\nEnable’s Control Room Management Program, Chapter CR-001, Section 5.0: Deviations, was\nfound to be inadequate and must be amended to provide adequate guidance on documentation to\ndemonstrate that any deviation from the procedures required by §192.631(j)(2). Enable’s\nprocedure did not include a time frame of when deviations should be documented after the\ndeviation occurred.\nPHMSA inspectors reviewed five GT8259: Deviation from Procedure forms. The deviations\noccurred in January 2018, March 2018, and April 2018, but documentation was not completed\nuntil July 2019. The procedure should include specific guidance on when documentation should\nbe completed after a deviation from the Control Room Management Program has occurred.\n2. §192.911 What are the elements of an integrity management program?\n(k) A management of change process as outlined in ASME/ASNI B31.8S, section 11.\nEnable’s Integrity Management Program Manual, PS-165: Management of Change Procedure and\nMC-100: Management of Change Procedure were found to be inadequate and must be amended\nto include a management of change process as outlined in ASME B31.8S, Section 11. Enable’s\nprocedures do not include all required elements of a management of change (MOC) process: reason\nfor change, authority for approving changes, analysis of implications, acquisition of required work\npermits, documentation, communication of change to affected parties, time limitations, and\nqualification of staff. The MOC shall address technical, physical, procedural, and organizational\nchanges to the system, whether permanent or temporary. Enable’s procedure should incorporate\nplanning for each of these situations and consider the unique circumstances of each.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond 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).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\n2\n\n\n\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 60 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Enable Gas Transmission maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Mary L. McDaniel, Director, Southwest Region, Pipeline\nand Hazardous Materials Safety Administration. In correspondence concerning this matter, please\nrefer to CPF 4-2019-1014M and, for each document you submit, please provide a copy in\nelectronic format whenever possible.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n3","truncated":false,"body_characters":8172}