{"operation":"document","citation":"CPF 42021045NOA","title":"ENABLE MIDSTREAM PARTNERS, LP — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-08-11","effective_on":null,"summary":"CLOSED notice of amendment citing 192.13(c), 192.493, 192.911(k).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021045noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021045noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021045noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42021045NOA","body":"Notice of Amendment involving ENABLE MIDSTREAM PARTNERS, LP. PHMSA's enforcement data identifies the cited regulations as 192.13(c),  192.493,  192.911(k). The case was opened on 2021-08-11 and is reported as closed as of 2021-09-11. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42021045NOA_Notice of Amendment_08112021_(21-201525).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021045NOA/42021045NOA_Notice%20of%20Amendment_08112021_(21-201525).pdf\n\n42021045NOA_Notice of Amendment_08112021_(21-201525)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021045NOA/42021045NOA_Notice%20of%20Amendment_08112021_(21-201525)_text.pdf\n\n42021045NOA_Notice of Amendment_08112021_(21-201525)_text.pdf\n\nNOTICE OF AMENDMENT\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nAugust 11, 2021\nCary Watson\nVice President Safety, Environmental & Technical Programs\nEnable Midstream Partners, LP\n499 West Sheridan Avenue, Suite 1500\nOklahoma City, Oklahoma 73102\nCPF 4-2021-045-NOA\nDear Mr. Watson:\nFrom May 18, 2021 through May 20, 2021, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\n(U.S.C.), virtually inspected Enable Midstream Partners, LP’s (Enable) Integrity Management\nplans and procedures.\nBased on the inspection, PHMSA has identified the apparent inadequacies found within Enable’s\nplans or procedures as described below:\n1. § 192.493 In-line inspection of pipelines.\nWhen conducting in-line inspections of pipelines required by this part, an operator\nmust comply with API STD 1163, ANSI/ASNT ILI - PQ, and NACE SP0102,\n(incorporated by reference, see § 192.7). Assessments may be conducted using\ntethered or remotely controlled tools, not explicitly discussed in NACE SP0102,\nprovided they comply with those sections of NACE SP0102 that are applicable.\nNACE SP0102 – 2017\n5.1.5 Survey-acceptance criteria\n5.1.5.1 A set of survey-acceptance criteria should be developed and agreed to\nby both parties prior to the start of the ILI survey. These criteria help to define\nwhen a rerun survey is required and include the following:\n5.1.5.1.1 Physical damage to sensors after run…\n5.1.5.1.6 Velocity underruns or overruns…\n\n\n\n2. 3. Enable’s written Integrity Management Program, PS-248, ILI Service Provider\nPerformance Specification (Effective Date 12/1/2020) is inadequate because it fails to\nprovide the requirement in NACE SP0102-2010, Section 5: Logistical Guidelines, 5.1.5\nSurvey-acceptance criteria. The procedure failed to include a set of survey-acceptance\ncriteria to define when a rerun survey was required.\nDuring the inspection, PHMSA reviewed Enable’s Integrity Management Program, PS-\n248, ILI Service Provider Performance Specification, 4.0 Procedure, which stated:\n“6. The Company shall review the ILI Service Provider's acceptance criteria\nto ensure the following are met to define ILI re-runs based on the selected\ntool(s) capabilities:\n Physical damage to sensors and sensor loss cannot exceed\nrequirements of vendor reporting specifications”\nOn May 21, 2021, Enable submitted to PHMSA a revised plan to address the requirements\nof § 192.493. Enable’s Integrity Management Program, PS-248, ILI Service Provider\nPerformance Specification (Effective Date 5/21/2021) was reviewed by PHMSA and\ndetermined to be adequate.\n§ 192.911 What are the elements of an integrity management program?\n(a)…\n(k) A management of change process as outlined in ASME/ANSI B31.8S, section 11.\nEnable did not have adequate procedures to address § 192.911(k) for its management of\nchange process. PHMSA reviewed Enable’s written Integrity Management Program, PS-\n165, IMP Management of Change (Effective Date 05/21/2020) and its Management of\nChange, MC-100 (Effective Date 11/19/2020) written procedures, which failed to include\na required item from ASME B31.8S-2004, 11 Management of Change, specifically item\n(a)(8) regarding the qualification of staff.\nOn May 28, 2021, Enable submitted to PHMSA a revised plan to address the requirements\nof § 192.911(k). Enable’s Integrity Management Program, PS-165, IMP Management of\nChange (Effective Date 5/27/2021) and Management of Change, MC-100 (Effective Date\n5/27/2021) were reviewed by PHMSA and determined to be adequate.\n§ 192.13 What general requirements apply to pipelines regulated under this part?\n(a)…\n(c) Each operator shall maintain, modify as appropriate, and follow the plans,\nprocedures, and programs that it is required to establish under this part.\n2\n\n\n\nEnable’s Corrosion Control, CC-262, Guided Wave Technology, Equipment Operation\n(Effective Date 5/9/2019) is inadequate because it fails to maintain, modify as appropriate,\nand follow the plans, procedures, and programs in accordance with § 192.13. Specifically,\nEnable failed to formally assign a procedure name and number for its Guided Wave\nTechnology (GWT) procedure in part of its Notification Concerning Use of Other\nTechnology: Application of guided wave ultrasound for integrity assessment of cased\ncrossings (Revision 10, 1/8/2008).\nPHMSA reviewed Enable’s Corrosion Control, CC-262, Guided Wave Technology,\nEquipment Operation (Effective Date 5/9/2019) and its Application of guided wave\nultrasound for integrity assessment of cased crossings (Revision 10, 1/8/2008) and found\nthat the GWT procedure in the notification was a closer to complete version of the whole\nGWT process, but it did not have a formally assigned name or procedure number. Enable’s\nCorrosion Control, CC-262, Guided Wave Technology, Equipment Operation only\naddresses GWT equipment operation.\nOn July 8, 2021, Enable submitted to PHMSA updated procedures: PS-278, Utilizing Other\nTechnology for IM Assessments (Effective Date 07/07/2021) and PS-276, Other\nTechnology – Guided Wave: Historic PHMSA Notification and Guidance Procedure\n(Effective Date 07/07/2021). Both procedures were reviewed by PHMSA and determined\nto be adequate.\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. As mentioned above, Enable Midstream\nPartners, LP has already submitted revised procedures to PHMSA that reflect the amendments\nrequired by this Notice. These submitted procedures were reviewed and found to be adequate by\nPHMSA, therefore, no further action or response is required. If no additional response is received\nwithin 30 days of receipt of this Notice, this enforcement will be automatically closed.\n3\n\n\n\nIt is requested (not mandated) that Enable maintain documentation of the safety improvement costs\nassociated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures)\nand submit the total to Mary L. McDaniel, Director, Southwest Region, Pipeline and Hazardous\nMaterials Safety Administration. In correspondence concerning this matter, please refer to CPF 4-\n2021-045-NOA and, for each document you submit, please provide a copy in electronic format\nwhenever possible.\nSincerely,\nMary McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: Jimmy Cross, Senior Manager, DOT Compliance, Enable Midstream Partners, LP,\njimmy.cross@enablemidstream.com\nCary Windler, Director, GIS and Integrity Management, Enable Midstream Partners, LP,\ncary.windler@enablemidstream.com\n4","truncated":false,"body_characters":8289}