{"operation":"document","citation":"CPF 42020001NOA","title":"ENABLE GAS TRANSMISSION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-11-03","effective_on":null,"summary":"CLOSED notice of amendment citing 192.631(a), 192.631(b)(1), 192.631(c)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42020001noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42020001noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42020001noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42020001NOA","body":"Notice of Amendment involving ENABLE GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.631(a),  192.631(b)(1),  192.631(c)(2). The case was opened on 2020-11-03 and is reported as closed as of 2021-01-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42020001NOA_Closure Letter_01202021_(20-173857).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42020001NOA/42020001NOA_Closure%20Letter_01202021_(20-173857).pdf\n\n42020001NOA_Closure Letter_01202021_(20-173857)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42020001NOA/42020001NOA_Closure%20Letter_01202021_(20-173857)_text.pdf\n\n42020001NOA_Notice of Amendment_11032020_(20-173857).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42020001NOA/42020001NOA_Notice%20of%20Amendment_11032020_(20-173857).pdf\n\n42020001NOA_Notice of Amendment_11032020_(20-173857)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42020001NOA/42020001NOA_Notice%20of%20Amendment_11032020_(20-173857)_text.pdf\n\n42020001NOA_Operator Response to Notice_01122021_(20-173857).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42020001NOA/42020001NOA_Operator%20Response%20to%20Notice_01122021_(20-173857).pdf\n\n42020001NOA_Closure Letter_01202021_(20-173857)_text.pdf\n\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nJanuary 20, 2021\nCary Watson\nVice President\nSafety, Environmental & Technical Programs\nEnable Gas Transmission, LLC\n499 West Sheridan Avenue, Suite 1500\nOklahoma City, Oklahoma 73102\nCPF 4-2020-001-NOA\nDear Mr. Watson:\nFrom March 2, 2020 through March 5, 2020, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code\n(U.S.C.), inspected Enable Gas Transmission, LLC’s (Enable) Control Room Management\nProgram and records in Houston, Texas. As a result of the inspection, Enable was issued a Notice\nof Amendment on November 3, 2020, which proposed amendment of your procedures.\nEnable submitted its amended procedures on January 12, 2021. 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\ncc: Jimmy Cross, Senior Manager, DOT Compliance\nEnable Midstream Partners, Jimmy.cross@enablemidstream.com\n\n42020001NOA_Notice of Amendment_11032020_(20-173857)_text.pdf\n\nNOTICE OF AMENDMENT\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nNovember 3, 2020\nCary Watson\nVice President\nSafety, Environmental & Technical Programs\nEnable Gas Transmission, LLC\n499 West Sheridan Avenue, Suite 1500\nOklahoma City, Oklahoma 73102\nCPF 4-2020-001-NOA\nDear Mr. Watson:\nFrom March 2, 2020 through March 5, 2020, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nEnable Gas Transmission, LLC’s (Enable) Control Room Management Program and records in Houston,\nTexas.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within Enable’s\nwritten plans or procedures, as described below:\n1. § 192.631 Control room management.\n(a) General. (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 facility through\na SCADA system. Each operator must have and follow written control room management\nprocedures that implement the requirements of this section, except that for each control\nroom where an operator's activities are limited to either or both of: . . .\n(b) Roles and responsibilities. Each operator must define the roles and responsibilities of a\ncontroller during normal, abnormal, and emergency operating conditions. To provide for a\ncontroller's prompt and appropriate response to operating conditions, an operator must\ndefine each of the following:\n(1) A controller's authority and responsibility to make decisions and take actions during\nnormal operations;\nEnable's written Control Room Management Procedure, System Control: Roles\nand Responsibilities (CR-242) version 6.0 dated April 23, 2020, does not define the roles and\nresponsibilities of the on-call controller monitoring its pipeline, and does not define the extreme\ncircumstances in which the on-call controller may log in to its SCADA remotely until a\nreplacement controller arrives at the control room.\n\n\n\n2\n2. Enable’s written procedure, Section 4.1.1.18 Additional responsibilities during normal operations,\nallows its on-call controllers to \"monitor the system remotely until a replacement can arrive.\"\nHowever, Enable’s written procedure neither defines the roles and responsibilities of the on-call\nremote controller nor defines what constitutes extreme circumstances.\nAdditionally, Section 4.2.1.13.b of CR-242 allows for its System Control Director, Manager and\nSupervisor of System Control (Manager) to \"monitor\" the system in \"extreme circumstances\"\nwhen a System Controller can no longer control Enable's pipeline on its assigned control room\nconsole until a replacement System Controller arrives in the Control room. However, Enable’s\nprocedures do not define the required qualifications of its Manager or whether the Manager must\nbe qualified as a System Controller in order to monitor the pipelines.\nTherefore, Enable must amend its written procedures to: (1) define the roles and responsibilities\nof the on-call controller and the extreme circumstances when the on-call controller may log in\nremotely to Enable’s SCADA until a replacement controller arrives to the control room; and (2)\ndefine the required qualifications of its Manager or whether the Manager must be qualified as a\nSystem Controller.\n§ 192.631 Control room management.\n(a) General. (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 facility through\na SCADA system. Each operator must have and follow written control room management\nprocedures that implement the requirements of this section, except that for each control\nroom where an operator's activities are limited to either or both of: . . .\n(c) Provide adequate information. Each operator must provide its controllers with the\ninformation, tools, processes and procedures necessary for the controllers to carry out the\nroles and responsibilities the operator has defined by performing each of the following: . . .\n(1) . . .\n(2) Conduct a point-to-point verification between SCADA displays and related field\nequipment when field equipment is added or moved and when other changes that affect\npipeline safety are made to field equipment or SCADA displays;\nEnable's written Control Room Management Procedure, System Control: Point-to-Point\nVerification (CR-200) version 4, dated April 23, 2020, was inadequate because it did not require\nits personnel to verify alarm limits and set points as part of its point-to-point process if \"System\nControl has operational concerns with doing so.\"\nSection 192.631(c)(2) requires the verification of point-to-point between SCADA displays and\nrelated field equipment. However, CR-200 permits the temporary delay of a point-to-point\nverification due to operational concerns with no indication of when Enable personnel would\neventually perform the required verification. Therefore, Enable must amend its procedures to\nensure that Enable personnel verify alarm limits and set points as part of the point-to-point process.\n\n\n\n3\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 part of\nthis Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings.\nPlease refer to this document and note the response options. Be advised that all material you submit in\nresponse to this enforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with\nthe complete original document you must provide a second copy of the document with the portions you\nbelieve qualify for confidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised procedures,\nor a request for a hearing under §190.211. If you do not respond within 30 days of receipt of this Notice,\nthis constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate\nAdministrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and\nto issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R.\n§ 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures\nto my office within 60 days of receipt of this Notice. This period may be extended by written request for\ngood cause. Once the inadequacies identified herein have been addressed in your amended procedures,\nthis enforcement action will be closed.\nIt is requested (not mandated) that Enable Gas Transmission, LLC maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Mary L. McDaniel, P.E., Director, Southwest Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF\n4-2020-001-NOA and, for each document you submit, please provide a copy in electronic format\nwhenever possible.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":10216}