{"operation":"document","citation":"CPF 42021046NOA","title":"ENABLE GAS TRANSMISSION, LLC — 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 192.613(a), 192.613(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021046noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021046noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021046noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42021046NOA","body":"Notice of Amendment involving ENABLE GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.613(a),  192.613(b). The case was opened on 2021-08-11 and is reported as closed as of 2021-09-24. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42021046NOA_Closure Letter_09242021_(21-202129).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021046NOA/42021046NOA_Closure%20Letter_09242021_(21-202129).pdf\n\n42021046NOA_Closure Letter_09242021_(21-202129)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021046NOA/42021046NOA_Closure%20Letter_09242021_(21-202129)_text.pdf\n\n42021046NOA_Notice of Amendment_08112021_(21-202129).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021046NOA/42021046NOA_Notice%20of%20Amendment_08112021_(21-202129).pdf\n\n42021046NOA_Notice of Amendment_08112021_(21-202129)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021046NOA/42021046NOA_Notice%20of%20Amendment_08112021_(21-202129)_text.pdf\n\n42021046NOA_Operator Response to Notice_09092021_(21-202129).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021046NOA/42021046NOA_Operator%20Response%20to%20Notice_09092021_(21-202129).pdf\n\n42021046NOA_Notice of Amendment_08112021_(21-202129)_text.pdf\n\nNOTICE OF AMENDMENT\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nAugust 11, 2021\nRodney J. Sailor\nPresident & CEO\nEnable Gas Transmission, LLC\n499 West Sheridan, Suite 1500\nOklahoma City, Oklahoma 73102\nCPF 4-2021-046-NOA\nDear Mr. Sailor:\nFrom December 21, 2020 to March 2, 2021, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter\n601 of 49 United States Code (U.S.C.), conducted an investigation following the reportable natural\ngas release on Enable Gas Transmission, LLC’s (Enable) 16-inch Line A-South that occurred on\nDecember 18, 2020, in Caddo Parish, Louisiana. The investigation included a review of Enable’s\noperations and maintenance records and procedures.\nOn the basis of the investigation, PHMSA has identified an apparent inadquacy found within\nEnable’s procedures, as described below:\n1. § 192.613 Continuing surveillance.\n(a) Each operator shall have a procedure for continuing surveillance of its facilities\nto determine and take appropriate action concerning changes in class location,\nfailures, leakage history, corrosion, substantial changes in cathodic protection\nrequirements, and other unusual operating and maintenance conditions.\n(b) If a segment of pipeline is determined to be in unsatisfactory condition but no\nimmediate hazard exists, the operator shall initiate a program to recondition or phase\nout the segment involved, or, if the segment cannot be reconditioned or phased out,\nreduce the maximum allowable operating pressure in accordance with § 192.619 (a)\nand (b).\n\n\n\nEnable’s operation and maintenance (O&M) procedures are inadequate because they do not have\na procedure to initiate programs to address segments of pipeline that have been determined to be\nin an unsatisfactory condition, but remain non-immediate hazards in accordance with § 192.613.\nEnable's O&M procedures do not include a process to analyze integrated pipeline data over time\nto detect changes that could affect the overall condition of the pipeline. Enable’s current\nprocedures appear to react following a one-time event, and are not based on a continuing\nsurveillance of the operator’s facilities.\nEnable’s Operation and Maintenance Plan, Continuing Surveillance, OM-202, Section A:\nRequirements (Revision Date: 8/27/2020), contains inadequate language for initiation of\ncontinuing surveillance programs. Prior to the reportable incident, five known dresser coupling\nleaks were found on this same line that experienced the reportable incident, Line A-South, in\ncalendar years 2016, 2019, and 2020. The leaks were documented on Enable’s record titled, \"Leak\nCause and Analysis History, Line: A-SOUTH Team: 711 Date Range: >= 01/01/2015.”\nEnable does not have a program that specifically addresses the potential threat from dresser\ncoupling leaks. Enable has only provided comments from its “Natural Gas Integrity Management\nProgram Evaluation for calendar year 2017” and “Repair, Work on Dresser Coupled Pipelines”\n(OM-221, Version 3, 7-28-2020). Enable did not provide any evidence demonstrating the\ninitiation of continuing surveillance programs addressing areas outside of its High Consequence\nAreas (HCA); Enable only presented information for areas under its Integrity Management\nProgram. The lack of analysis and data integration to establish reconditioning or replacement\nprograms for areas outside an HCA is a result of the deficient continuing surveillance procedure.\nEnable must amend its O&M procedure for Continuing Surveillance to include a process to\nintegrate and analyze date and provide a process to recondition or phase out those segments\nidentified as unsatisfactory.\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\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\n2\n\n\n\nNotice, we propose that you submit your amended procedures to my office within 30 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 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, P.E., Director, Southwest Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please refer\nto CPF 4-2021-046-NOA and, for each document you submit, please provide a copy in electronic\nformat whenever possible.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n3\n\n42021046NOA_Closure Letter_09242021_(21-202129)_text.pdf\n\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nSeptember 24, 2021\nRodney J. Sailor\nPresident and CEO\nEnable Gas Transmission, LLC\n499 West Sheridan, Suite 1500\nOklahoma City, Oklahoma 73102\nCPF 4-2021-046 NOA\nDear Mr. Sailor:\nFrom December 21, 2020 to March 2, 2021, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code, conducted an\ninvestigation following the reportable gas release on Enable Gas Transmission, LLC’s (Enable) 16-inch\nLine A-South December 18, 2020, in Caddo Parish, Louisiana. The investigation included a review of\nEnable’s operations and maintenance records and procedures. As a result of the inspection, PHMSA issued\na Notice of Amendment (Notice) to Enable on August 11, 2021, which proposed amendments to its\nprocedures.\nEnable submitted its revised procedures on September 9, 2021. PHMSA 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: Rodney J. Sailor, rod.sailor@enablemidstream.com,\nCary Windler, cary.windler@enablemidstream.com\nCasey Roberts, casey.roberts@enablemidstream.com","truncated":false,"body_characters":8986}