{"operation":"document","citation":"CPF 42023030WL","title":"GULF RUN TRANSMISSION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2023-01-12","effective_on":null,"summary":"CLOSED warning letter citing 192.225(a), 192.225(b), 192.235, 192.303, 192.461(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42023030wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42023030wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42023030wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42023030WL","body":"Warning Letter involving GULF RUN TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.225(a),  192.225(b),  192.235,  192.303,  192.461(c). The case was opened on 2023-01-12 and is reported as closed as of 2023-01-12. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42023030WL_Operator Response to Notice_04272023_(22-236599).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023030WL/42023030WL_Operator%20Response%20to%20Notice_04272023_(22-236599).pdf\n\n42023030WL_Warning Letter_01122023_(22-236599).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023030WL/42023030WL_Warning%20Letter_01122023_(22-236599).pdf\n\n42023030WL_Warning Letter_01122023_(22-236599)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023030WL/42023030WL_Warning%20Letter_01122023_(22-236599)_text.pdf\n\n42023030WL_Warning Letter_01122023_(22-236599)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL\nJanuary 12, 2023\nMr. Eric Amundsen\nSenior Vice President of Operations\nEnergy Transfer Company\n1300 Main Street,\nHouston, TX 77002\nCPF 4-2023-030-WL\nDear Mr. Amundsen:\nFrom May 2 through 5 and June 21 through 23, 2022 a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States\nCode (U.S.C.), conducted a field site construction inspection of Enable Gulf Run Transmission,\nLLC’s (Enable) Gulf Run Project in Natchitoches, Louisiana.\nAs a result of the inspection, it is alleged that Enable has committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. § 192.225 Welding procedures.\n(a) Welding must be performed by a qualified welder or welding\noperator in accordance with welding procedures qualified under\nsection 5, section 12, Appendix A or Appendix B of API Std 1104\n(incorporated by reference, see § 192.7), or section IX of the ASME\nBoiler and Pressure Vessel Code (ASME BPVC) (incorporated by\nreference, see § 192.7) to produce welds meeting the requirements of\nthis subpart. The quality of the test welds used to qualify welding\nprocedures must be determined by destructive testing in accordance\nwith the applicable welding standard(s).\n(b) Each welding procedure must be recorded in detail, including\nthe results of the qualifying tests. This record must be retained and\nfollowed whenever the procedure is used.\n\n\n\nEnable failed to perform welding in accordance with the qualified welding procedures as required\nby § 192.225(a) and (b) during construction of the Enable Gulf Run Pipeline.\nOn May 4, 2022, PHMSA observed welding on a field joint at mile post marker 29. When\nquestioned by PHMSA inspectors, the welders were not able to identify the welding procedure\nbeing used or describe the welding parameters they were required to follow as specified by the\nprocedure. Specifically, the welders were unable to identify any of the welding parameters\nspecified by the qualified welding procedure WPS GRP-M-WPS1, such as electrode specifications\nand sizes, pre-heat temperature requirements, voltage, amperage, and travel speed. Without\nknowledge of these parameters, the welders could not have been performing the welds according\nto the qualified welding procedure. Since Enable’s welding operators did not follow a qualified\nwelding procedure, Enable cannot verify that the completed welds have the required strength and\nmechanical properties.\nTherefore, Enable failed to perform welding in accordance with the qualified welding procedures\nas required by § 192.225(a).\n2. § 192.303 Compliance with specifications or standards.\nEach transmission line or main must be constructed in accordance\nwith comprehensive written specifications or standards that are\nconsistent with this part.\nEnable failed to follow its written specification for excavating in accordance with § 192.303 while\ninstalling the Gulf Run transmission line in the ditch. Enable’s construction specification\ndocument, CS-055: Excavation, includes specifications for the minimum width of the ditch as well\nas the spoil bank setback from the ditch. Section 1.0 states that “[a]dherence to this specification\nis required in an effort to ensure the safety of all employees and Contractors of the Company.”\nDuring inspection of the Enable Gulf Run Pipeline on May 4, 2022, PHMSA observed pipe laid\nin a ditch between mile markers 28 and 29 that did not meet the width specifications required by\nCS-055. The Enable specification states the minimum width requirement in section 2.2.2:\n“Unless otherwise specified by Company, the ditch shall be excavated to a width of not less than\ntwelve inches (12\") greater than nominal diameter of the pipe.” However, the sides of the\nexcavated ditch were bearing against the pipe, so the ditch was not 12 inches greater than the pipe\ndiameter. Failure to comply with this specification may result in damage to the pipeline and\ncoating.\nSection 2.2.2 of CS-055 requires that the edge of the excavated spoil bank be no closer than two\nfeet from the edge of the pipe ditch. During the PHMSA inspection on June 22, 2022, the spoil\nbank setback was less than two feet from the edge of the pipe ditch. Failure to comply with this\nspecification may result in rocks and debris falling back into the ditch potentially damaging the\npipeline and coating or potentially compromising the required depth of cover by reducing the depth\nof the ditch prior to lowering.\n\n\n\nTherefore, Enable failed to follow its written specification for excavating in accordance with §\n192.303 while installing the Gulf Run transmission line in the ditch.\n3. § 192.235 Preparation for welding.\nBefore beginning any welding, the welding surfaces must be clean\nand free of any material that may be detrimental to the weld, and the\npipe or component must be aligned to provide the most favorable\ncondition for depositing the root bead. This alignment must be\npreserved while the root bead is being deposited.\nEnable failed to properly align the pipe to provide the most favorable condition for depositing the\nroot bead during the Enable Gulf Run Pipeline construction project as required by § 192.235.\nEnable’s written specification CS-100, section 2.8.2.a states that “the offset between pipe surfaces\nof the same nominal wall thickness should not exceed 1/16 inch.” During a PHMSA inspection\non June 22, 2022, the alignment for welds of the 42-inch, 0.600-inch wall pipe exceeded the\nspecified maximum offset of 1/16 inch.\nIn addition, Enable failed to follow its written specification for pipe alignment in accordance with\n§ 192.303. PHMSA inspectors observed a 42-inch, 0.600-inch wall pipe being directly welded to\n42-inch, 0.720 wall pipe. The Enable CS-100 specification requires that pipes with wall thickness\ndifferences greater than 3/32 inch must be joined using a transition piece.\nEnable also failed to conduct adequate visual inspections to ensure that the welding is performed\nin accordance with the welding procedure as required by § 192.241(a). When PHMSA notified\nEnable of the excessive misalignment, Enable personnel were not visually inspecting the offset\nand seemed unaware of their own specifications to limit the offset, or the requirement to use a\ntransition piece for joining pipes with wall thicknesses that differ by more than 3/32 inch.\nThe Automated Ultrasonic Testing (AUT) nondestructive examination also detected the excessive\nmisalignment. The AUT results showed excessive offset (high-low) through geometric\nindications. Section 192.243(c) states that “[p]rocedures must be established for the proper\ninterpretation of each nondestructive test of a weld to ensure acceptability of the weld under §\n192.241(c).” When PHMSA raised the issue during the inspection, the AUT technician responded\nthat evaluating or reporting of high-low was not required for this project. Therefore, Enable failed\nto follow its misalignment specifications on the Gulf Run Pipeline construction project.\n4. § 192.461 External corrosion control: Protective coating.\n(a) . . . .\n(c) Each external protective coating must be inspected just prior to\nlowering the pipe into the ditch and backfilling, and any damage\ndetrimental to effective corrosion control must be repaired.\nEnable failed to properly inspect the protective coating just prior to lowering the pipeline in the\nditch as required by § 192.461(c). To conduct this inspection, Enable uses an electronic jeeping\ndevice designed to detect defects or holidays in the pipeline coating. This device must be properly\n\n\n\ncalibrated and the detection threshold set based on the thickness of the pipeline coating for coating\ndefects to be discovered and repaired.\nDuring the inspection, Enable’s technicians performing the inspections could not provide the\nspecifications for calibrating the jeeping device or state any of the factors, such as coating\nthickness, required to properly set the detection threshold. The manufacturer’s instruction manual\nfor the SPY Model 780 jeep used by Enable specified two methods for calibrating, properly setting\nthe detection threshold and testing the device to ensure coating holidays were being detected.\nTechnicians performing the inspections had not completed either method resulting in the\npossibility that defects in the pipeline coating were not being detected and repaired. Failure to\ndetect and repair pipeline coating defects could result in external corrosion and corrosion-related\nfailures of the pipeline.\nTherefore, Enable failed to properly inspect the protective coating just prior to lowering the\npipeline in the ditch as required by § 192.461(c).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$239,142 per violation per day the violation persists, up to a maximum of $2,391,142 for a related\nseries of violations. For violation occurring on or after May 3, 2021 and before March 21, 2022,\nthe maximum penalty may not exceed $225,134 per violation per day the violation persists, up to\na maximum of $2,251,334 for a related series of violations. For violation occurring on or after\nJanuary 11, 2021 and before May 3, 2021, the maximum penalty may not exceed $222,504 per\nviolation per day the violation persists, up to a maximum of $2,225,034 for a related series of\nviolations. For violation occurring on or after July 31, 2019 and before January 11, 2021, the\nmaximum penalty may not exceed $218,647 per violation per day the violation persists, up to a\nmaximum of $2,186,465 for a related series of violations. For violation occurring on or after\nNovember 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per\nviolation per day, with a maximum penalty not to exceed $2,132,679. For violation occurring on\nor after November 2, 2015 and before November 27, 2018, the maximum penalty may not exceed\n$209,002 per violation per day, with a maximum penalty not to exceed $2,090,022.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the items identified in this letter. Failure to do so may result in\nEnable Gulf Run Transmission, LLC being subject to additional enforcement actions.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2023-030-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. § 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. § 552(b).\n\n\n\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nCopy to: Todd Nardozzi - Director, Regulatory Compliance, todd.nardozzi@energytransfer.com","truncated":false,"body_characters":12274}