{"operation":"document","citation":"CPF 42023046NOA","title":"ENABLE GAS TRANSMISSION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2023-10-18","effective_on":null,"summary":"CLOSED notice of amendment citing 192.515(a), 192.605(b)(1), 192.605(b)(4), 192.607(c), 192.607(f)(1), 192.607(f)(2), 192.609, 192.619(a)(1), 192.619(a)(2), 192.624(b), 192.710(b)(3), 192.712(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42023046noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42023046noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42023046noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42023046NOA","body":"Notice of Amendment involving ENABLE GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.515(a),  192.605(b)(1),  192.605(b)(4),  192.607(c),  192.607(f)(1),  192.607(f)(2),  192.609,  192.619(a)(1),  192.619(a)(2),  192.624(b),  192.710(b)(3),  192.712(e). The case was opened on 2023-10-18 and is reported as closed as of 2026-01-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42023046NOA_Closure Letter_01202026_(22-241127).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023046NOA/42023046NOA_Closure%20Letter_01202026_(22-241127).pdf\n\n42023046NOA_Closure Letter_01202026_(22-241127)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023046NOA/42023046NOA_Closure%20Letter_01202026_(22-241127)_text.pdf\n\n42023046NOA_Notice of Amendment_10182023_(22-241127).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023046NOA/42023046NOA_Notice%20of%20Amendment_10182023_(22-241127).pdf\n\n42023046NOA_Notice of Amendment_10182023_(22-241127)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023046NOA/42023046NOA_Notice%20of%20Amendment_10182023_(22-241127)_text.pdf\n\n42023046NOA_Operator Response to Notice_01152024_(22-241127).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023046NOA/42023046NOA_Operator%20Response%20to%20Notice_01152024_(22-241127).pdf\n\n42023046NOA_Order Directing Amendment_08292025_(22-241127).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023046NOA/42023046NOA_Order%20Directing%20Amendment_08292025_(22-241127).pdf\n\n42023046NOA_Order Directing Amendment_08292025_(22-241127)_txt.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023046NOA/42023046NOA_Order%20Directing%20Amendment_08292025_(22-241127)_txt.pdf\n\n42023046NOA_Order Directing Amendment_08292025_(22-241127)_txt.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nAugust 29, 2025\nVIA ELECTRONIC MAIL TO: tom.long@energytransfer.com\nThomas Long\nChief Executive Officer\nEnergy Transfer Company\n8111 Westchester Drive\nDallas, Texas 75227\nRe: CPF No. 4-2023-046-NOA\nDear Mr. Long:\nEnclosed please find the Order Directing Amendment issued in the above-referenced case. It\nmakes findings of inadequate procedures, finds that certain amended procedures are adequate,\nand requires Enable Gas Transmission, LLC, to amend certain procedures. When the\namendment of procedures has been completed, as determined by the Director, Southwest Region,\nthis enforcement action will be closed. Service of the Order Directing Amendment by e-mail is\neffective upon the date of transmission and acknowledgement of receipt as provided under 49\nCFR § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nLinda Daugherty\nActing Associate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Bryan Lethcoe, Director, PHMSA Southwest Region, Office of Pipeline Safety\nHeidi Murchison, Chief Counsel, Energy Transfer, LP, heidi.murchison@energytransfer.com\nTodd Nardozzi, Director, Regulatory Compliance, Energy Transfer, LP,\n\n\n\ntodd.nardozzi@energytransfer.com\nSusie Sjulin, Director, Regulatory Compliance, Energy Transfer, LP,\nsusie.sjulin@energytransfer.com\nCONFIRMATION OF RECEIPT REQUESTED\n2\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\nIn the Matter of )\nEnable Gas Transmission, LLC, ) CPF No. 4-2023-046-NOA\nRespondent. )\n)\n)\n)\n)\nORDER DIRECTING AMENDMENT\nFrom September 19, 2022, to January 12, 2023, 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.) inspected Enable Gas Transmission, LLC’s (Enable or\nRespondent) procedures for operations and maintenance in Oklahoma City, Oklahoma.\nAs a result of the inspection, the Director, PHMSA Southwest Region, OPS, issued to\nRespondent by letter dated October 18, 2023, a Notice of Amendment (Notice). In accordance\nwith 49 CFR § 190.206, the Notice alleged certain inadequacies in Respondent’s operating and\nmaintenance procedures and proposed that Enable amend its procedures.\nEnable responded to the Notice on January 15, 2024 (Response). In its Response, Enable\nsubmitted additional documentation and contested certain allegations in the Notice. Respondent\ndid not request a hearing and therefore waived its right to one.\nFINDING OF INADEQUATE PROCEDURES\nItem 1: The Notice alleged that Respondent’s procedures for conducting operations and\nmaintenance activities were inadequate to ensure safe operation of a pipeline facility in\naccordance with section 192.605(b)(1). The Notice alleged specifically that Enable’s pressure\ntesting procedure failed to adequately detail all reasonable precautions that may be taken to\nprotect employees and the public during the pressure testing pursuant to section 192.515(a).\nThe Notice stated that Respondent’s procedure C4.0105-Pressure Testing Execution, revision\ndate April 1, 2022, section 4.1, Safety, failed to provide sufficient detail regarding what\nconstitutes a safe distance away from the testing area when performing hydrotesting. Enable’s\nprocedures listed a minimum distance of fifty feet, but failed to detail how much additional\ndistance might be necessary where the minimum distance does not suffice.\nIn its Response, Enable did not contest Item 1. Enable stated that it revised it procedure to\n\n\n\n2\nincorporate industry guidance and include additional language for safe distance determination.\nRespondent provided a draft of the revised procedure with its response. In accordance with\nsection 190.209(b)(7), the Director submitted a written evaluation of the Response and a\nrecommendation for final action dated July 1, 2025 (hereinafter Region Recommendation),\nwhich reviewed the draft revised procedure and determined that Enable corrected the alleged\nprocedural inadequacy.\nAccordingly, based on a review of the evidence, I find that Respondent needs to take no further\naction regarding Item 1.\nItem 2: The Notice alleged that Respondent’s procedures for conducting nondestructive or\ndestructive tests, examinations, and assessments to verify the material properties of aboveground\nline pipe and components, and of buried line pipe and components, when excavations occur were\ninadequate to ensure safe operation of a pipeline facility in accordance with section 192.607(c).\nSpecifically, the Notice alleged that Enable’s procedure I.43 Material Verification, Rev. 1, July\n1, 2021, section 7.2, Track Opportunistic Digs, failed to provide sufficient details regarding\nopportunistic digs. The coordination between various work groups and the responsibilities of\neach group were not discussed with adequate specificity. The Notice proposed Respondent must\nrevise its procedure to describe the approach used to track locations needing material\nverification, the methods to acquire needed data, the communication methods used to exchange\nneeded and gathered information between work groups and safeguards in place to ensure\ncompliance with section 192.607(c).\nIn its Response, Enable contested the allegation. It stated that the roles of the various work\ngroups in the coordination of work to comply with section 192.607(c) are detailed in I.43\nMaterial Verification, section 5.0, Governance. Respondent then listed six bullet-points detailing\nspecific tasks and the group responsible.\nThe Director reviewed Enable’s Response and the procedures cited therein and, per the Region\nRecommendation, recommended ordering amendment of the procedure as proposed in the\nNotice.\nHaving considered the record, Enable is correct that the roles of the various work groups in the\ncoordination of work to comply with section 192.607(c) are detailed in I.43 Material\nVerification, section 5.0, Governance. However, the Notice did not allege that Respondent’s\nprocedures did not include the roles of the various work groups in the coordination of work to\ncomply with section 192.607(c). Rather, the Notice alleged that Enable’s procedures did not\nadequately address the coordination between these groups – and it proposed that Respondent\nrevise its procedures to “describe the approach used to track locations needing material\nverification, the methods to acquire needed data, the communication methods used to exchange\nneeded and gathered information between work groups and safeguards in place to ensure\ncompliance with § 192.607(c).” The listing of each work group’s role and tasks in I.43 Material\nVerification, section 5.0, Governance, does not address the concerns expressed in the Notice\nregarding location tracking, data acquisition, communication methods, and safeguarding. These\ndetails are not present in Enable’s I.43 Material Verification procedure. Enable, in its Response,\ndid not address how its I.43 Material Verification procedure adequately addresses these concerns.\n\n\n\n3\nAccordingly, after reviewing the evidence, I find that Respondent’s procedure for conducting\nnondestructive or destructive tests, examinations, and assessments to verify the material\nproperties of aboveground line pipe and components, and of buried line pipe and components,\nwhen excavations occur were inadequate to ensure safe operation of a pipeline facility in\naccordance with section 192.607(c). Enable is hereby ordered to revise its procedures as\nspecified above. Finalized procedures must be provided to the Southwest Region for review and\napproval.\nItem 3: The Notice alleged that Respondent’s procedures for establishing and documenting the\nAmerican National Standards Institute rating or pressure rating were inadequate to ensure safe\noperation of a pipeline facility in accordance with section 192. 607(f). Specifically, the Notice\nalleged that Enable’s procedure I.43 Material Verification, Rev. 1, July 1, 2021, section 7.3.3,\nComponents, failed to provide adequate details regarding the material verification of non-line\npipe components. The Notice stated that the procedure failed to adequately describe how Enable\nwill verify non-line components that cannot be isolated from mainline pipeline pressures and\nmethods it will use to gather needed information.\nIn its response, Enable contested the allegation. It stated that verification of non-line pipe\ncomponents that cannot be isolated from mainline pressure is evaluated in the same manner as\nthose that can be isolated from mainline pressure. Respondent stated this is detailed in its\nprocedure I.43 Material Verification, section 7.3.3. The Director reviewed Enable’s Response\nand the procedures cited therein and, per the Region Recommendation, determined that no\nfurther procedural revisions are necessary.\nAccordingly, after reviewing the evidence, I find that Respondent needs to take no further action\nregarding Item 3.\nItem 4: The Notice alleged that Enable’s procedures for conducting operations and maintenance\nactivities were inadequate to ensure safe operation of a pipeline facility in accordance with\nsection 192.605(b)(1). Specifically, the Notice stated that Respondent’s procedure B.12\nEvaluating Class Location Changes (June 28, 2022), section 7.1, GIS Review, did not include\nadequate detail regarding incorporating updated or new GIS data into existing class locations.\nThe procedure failed to adequately detail how Enable incorporated newly acquired pipeline\nassets and assets with updated pipeline and structure attributes into the geographic information\nsystem (GIS) to determine if a class location study is required under section 192.609.\nIn its Response, Enable stated that it revised the GIS process for management of Class location\nchanges and it described the new process. The Director reviewed Enable’s Response and the\nrevised process and, per the Region Recommendation, determined that no further procedural\nrevisions are necessary.\nAccordingly, after reviewing the evidence, I find that Respondent needs to take no further action\nregarding Item 4.\nItem 5: The Notice alleged that Respondent’s procedures for conducting operations and\nmaintenance activities were inadequate to ensure safe operation of a pipeline facility in\n\n\n\n4\naccordance with section 192.605(b)(1). Specifically, the Notice alleged that Enable’s procedure\nB.10 Determination of MAOP, revision date February 1, 20220, Appending B, List of Hydro Test\nFactors for Class Location, and Appendix C, Process Flow for Determination of MAOP, failed to\ninclude all required information and contained errors. Appendix B failed to include column three\nof Table 1 from section 192.619(a)(2)(ii) and Appendix C referenced an affidavit referred to as a\n“Gold Sheet.”\nIn its Response, Enable stated that it revised its procedures, to include revisions to Appendices B\nand C. The Director reviewed Enable’s Response and the revised procedures and, per the\nRegion Recommendation, determined that no further procedural revisions are necessary.\nAccordingly, after reviewing the evidence, I find that Respondent needs to take no further action\nregarding Item 5.\nItem 6: The Notice alleged that Enable’s procedures for reconfirming maximum alloawable\noperating pressure (MAOP) were inadequate to ensure safe operation of a pipeline facility in\naccordance with section 192.624(b). Specifically, the Notice alleged Enable’s procedure MAOP\nReconfirmation Plan, Revision 1 (August 26, 2022), section 2, MAOP Reconfirmation\nCommittee, did not include adequate detail regarding Reconfirmation Committee activities. The\nprocedure did not adequately describe how the committee decides on an appropriate\nreconfirmation method, timing of segments, appropriate intermediate reconfirmation goals,\nadjustments for acquisitions and divestitures, and record keeping for associated decision making.\nIn its Response, Enable contested the allegation. It asserted that it is not necessary under\nsection 192.624 to have the details described in the Notice. Respondent further stated that in\n2023 its MAOP Reconfirmation Committee approved several changes to Enable’s MAOP\nReconfirmation Plan. It described the details of those changes. The Director reviewed Enable’s\nResponse and the information therein and, per the Region Recommendation, determined that no\nfurther procedural revisions are necessary.\nAccordingly, after reviewing the evidence, I find that Respondent needs to take no further action\nregarding Item 6.\nItem 7: The Notice alleged that Enable’s procedures for conducting operations and maintenance\nactivities were inadequate to ensure safe operation of a pipeline facility in accordance with section\n192.605(b)(1). Specifically, the Notice alleged that procedure 192.710 ETC Gas Plan, revision 3\n(April 15, 2022), section 6.2, Periodic Reassessment, failed to include adequate detail regarding\nthe use and documentation of prior assessments. The procedure failed to identify who will make\nthe determination to use a prior assessment, the associated timelines, how this determination will\nbe made, and what records will be generated to document this process in accordance with section\n192.710(b)(3).\nIn its Response, Enable did not contest the allegation and explained that it prepared redline\nrevisions to its procedures to include who will make the determination to use a prior assessment\nas the initial assessment and how the determination will be made per section 192.710(b)(3).\nRespondent provided a copy of those redlined procedures with its Response.\n\n\n\n5\nThe Director, per the Region Recommendation, indicated that while the draft revised procedures\nwere reviewed, it could not be verified whether Enable has cured the alleged procedural\ninadequacy because Respondent did not provide the finalized version of the procedure.\nAccordingly, after reviewing the evidence, I find that Respondent’s procedure was inadequate to\nensure safe operation of a pipeline facility in accordance with section 192.605(b)(1). Enable is\nhereby ordered to revise its procedures as specified above. Finalized procedures must be\nprovided to the Southwest Region for review and approval.\nItem 8: The Notice alleged that Enable’s procedures for conducting operations and maintenance\nactivities were inadequate to ensure safe operation of a pipeline facility in accordance with\nsection 192.605(b)(1). Specifically, the Notice alleged that procedure D.47 Evaluation of\nRemaining Strength Pipeline, revision date September 1, 2022, section 3, Applicability, did not\ninclude adequate detail to conduct an accurate analysis of predicted failure pressure. The\nprocedure failed to address measurement uncertainties such as tool tolerance, detection threshold,\ntool verification, and other potentially relevant data features in accordance with section\n192.712(e).\nIn its Response, Enable contested the allegation. Respondent stated that its procedure is used\nonly for in situ or in-the-ditch measurements of metal loss to determine remaining strength of\nthe pipe. Enable noted that section 192.712(e)(1) states that an operator must account for\nuncertainties in reported assessment results in identifying and characterizing the defects used in\npredicted failure pressure analyses unless the defect dimensions have been verified using in situ\ndirect measurements. Respondent asserted that since the procedure uses in situ or in-the-ditch\nmeasurements to determine remaining strength, uncertainties or tolerances are not required.\nThe Director reviewed Enable’s Response and the procedures cited therein and, per the Region\nRecommendation, recommended ordering amendment of the procedure as proposed in the\nNotice.\nHaving considered the record, Enable is correct that if defect dimensions are verified using in\nsitu direct measurements, uncertainties in reported assessment results in identifying and\ncharacterizing the defects used in predicted failure pressure analyses is not required. See section\n192.712(e)(1). Had Respondent’s procedures included provisions for using in-line inspection\n(ILI) tools to size defects, or if evidence suggested Respondent intended to use ILI tools to size\ndefects, then the procedures would need to include processes for accounting for tool tolerances\nand other measurement uncertainties. However, since the procedures cited in the Notice only\nprovide for the use of in situ measurements, provisions accounting for uncertainties in reported\nassessment results are not necessary. Because Enable’s procedures only provide for in situ or in-\nthe-ditch measurements of metal loss to determine remaining strength of the pipe, I find the\nprocedures in place are not inadequate as alleged in the Notice for the currently used method.\nAccordingly, after reviewing the evidence, I find that no further action is required.\nItem 9: The Notice alleged that Enable’s procedures for the gathering of data needed for annual\nand incident reporting under Part 191 in a timely and effective manner were inadequate to ensure\nsafe operation of a pipeline facility in accordance with section 192.605(b)(4). Specifically, the\n\n\n\n6\nNotice alleged procedure A.15 PHMSA-States-Incident Reporting failed to detail identifying all\nModerate Consequence Areas (MCAs). MCAs must be identified and included in the annual\nand incident reporting. In addition, MCAs must be identified to comply with sections 192.624\nand 192.710.\nIn its Response, Enable contested this allegation and asserted that its procedure is intended to\nmeet the requirements of Part 191, specifically sections 191.3, 191.5, and 191.15. It stated that\nprocedure MAOP Reconfirmation Plan and 192.710 Plan also address the requirements of\nsections 192.624 and 192.710. In addition, Respondent stated that its procedures A.15 PHMSA-\nStates-Incident Reporting and A.16 Annual Reporting adhere to and refer to PHMSA’s reporting\ninstructions, which address MCAs. It further stated that procedure A.15 PHMSA-States-Incident\nReporting defines MCA. Enable provided exhibits showing this information with its Response.\nThe Director reviewed Enable’s Response and the information provided and, per the Region\nRecommendation, determined that no further procedural revisions are necessary.\nAccordingly, after reviewing the evidence, I find that Respondent needs to take no further action\nregarding Item 9.\nUnder 49 CFR section 190.243, Respondent may submit a Petition for Reconsideration of this\nFinal Order to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey\nAvenue, SE, East Building, 2nd Floor, Washington, DC, 20590. The written petition must\ncontain a statement of the issue(s) and meet all other requirements of 49 CFR § 190.243. The\nterms of the Order remain in effect until the Associate Administrator, upon request, grants a stay.\nThe terms and conditions of this Order are effective upon service in accordance with 49 CFR §\n190.5.\nRespondent must amend its procedures, as required above, and submit them to the Director,\nPHMSA Southwest Region, OPS, within 30 days following receipt of this Order. The Director\nmay grant an extension of time to comply with any of the required items upon a written request\ntimely submitted by the Respondent and demonstrating good cause for an extension. Failure to\ncomply with this Order may result in administrative assessment of civil penalties exceeding\n$200,000, as adjusted for inflation (see 49 CFR § 190.223 for adjusted amounts), for each\nviolation for each day the violation continues or in referral to the Attorney General for\nappropriate relief in a district court of the United States.\nLinda Daugherty Date Issued\nActing Associate Administrator\nfor Pipeline Safety\n\n42023046NOA_Order Directing Amendment_08292025_(22-241127).pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nAugust 29, 2025\nVIA ELECTRONIC MAIL TO: tom.long@energytransfer.com\nThomas Long\nChief Executive Officer\nEnergy Transfer Company\n8111 Westchester Drive\nDallas, Texas 75227\nRe: CPF No. 4-2023-046-NOA\nDear Mr. Long:\nEnclosed please find the Order Directing Amendment issued in the above-referenced case. It\nmakes findings of inadequate procedures, finds that certain amended procedures are adequate,\nand requires Enable Gas Transmission, LLC, to amend certain procedures. When the\namendment of procedures has been completed, as determined by the Director, Southwest Region,\nthis enforcement action will be closed. Service of the Order Directing Amendment by e-mail is\neffective upon the date of transmission and acknowledgement of receipt as provided under 49\nCFR § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nLINDA GAIL\nDAUGHERTY\nDigitally signed by LINDA\nGAIL DAUGHERTY\nDate: 2025.08.28\n19:06:53 -04'00'\nLinda Daugherty\nActing Associate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Bryan Lethcoe, Director, PHMSA Southwest Region, Office of Pipeline Safety\nHeidi Murchison, Chief Counsel, Energy Transfer, LP, heidi.murchison@energytransfer.com\nTodd Nardozzi, Director, Regulatory Compliance, Energy Transfer, LP,\n\n\n\ntodd.nardozzi@energytransfer.com\nSusie Sjulin, Director, Regulatory Compliance, Energy Transfer, LP,\nsusie.sjulin@energytransfer.com\nCONFIRMATION OF RECEIPT REQUESTED\n2\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nEnable Gas Transmission, LLC, ) CPF No. 4-2023-046-NOA\n)\n)\n)\nRespondent. )\n____________________________________)\nORDER DIRECTING AMENDMENT\nFrom September 19, 2022, to January 12, 2023, 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.) inspected Enable Gas Transmission, LLC’s (Enable or\nRespondent) procedures for operations and maintenance in Oklahoma City, Oklahoma.\nAs a result of the inspection, the Director, PHMSA Southwest Region, OPS, issued to\nRespondent by letter dated October 18, 2023, a Notice of Amendment (Notice). In accordance\nwith 49 CFR § 190.206, the Notice alleged certain inadequacies in Respondent’s operating and\nmaintenance procedures and proposed that Enable amend its procedures.\nEnable responded to the Notice on January 15, 2024 (Response). In its Response, Enable\nsubmitted additional documentation and contested certain allegations in the Notice. Respondent\ndid not request a hearing and therefore waived its right to one.\nFINDING OF INADEQUATE PROCEDURES\nItem 1: The Notice alleged that Respondent’s procedures for conducting operations and\nmaintenance activities were inadequate to ensure safe operation of a pipeline facility in\naccordance with VHFWLRQ 192.605(b)(1). The Notice alleged specifically that Enable’s pressure\ntesting procedure failed to adequately detail all reasonable precautions that may be taken to\nprotect employees and the public during the pressure testing pursuant to VHFWLRQ 192.515(a).\nThe Notice stated that Respondent’s procedure C4.0105-Pressure Testing Execution, revision\ndate April 1, 2022, section 4.1, Safety, failed to provide sufficient detail regarding what\nconstitutes a safe distance away from the testing area when performing hydrotesting. Enable’s\nprocedures listed a minimum distance of fifty feet, but failed to detail how much additional\ndistance might be necessary where the minimum distance does not suffice.\nIn its Response, Enable did not contest Item 1. Enable stated that it revised it procedure to\n\n\n\n2\nincorporate industry guidance and include additional language for safe distance determination.\nRespondent provided a draft of the revised procedure with its response. In accordance with\nVHFWLRQ 190.209(b)(7), the Director submitted a written evaluation of the Response and a\nrecommendation for final action dated July 1, 2025 (hereinafter Region Recommendation),\nwhich reviewed the draft revised procedure and determined that Enable corrected the alleged\nprocedural inadequacy.\nAccordingly, based on a review of the evidence, I find that Respondent needs to take no further\naction regarding Item 1.\nItem 2: The Notice alleged that Respondent’s procedures for conducting nondestructive or\ndestructive tests, examinations, and assessments to verify the material properties of aboveground\nline pipe and components, and of buried line pipe and components, when excavations occur were\ninadequate to ensure safe operation of a pipeline facility in accordance with VHFWLRQ 192.607(c).\nSpecifically, the Notice alleged that Enable’s procedure I.43 Material Verification, Rev. 1, July\n1, 2021, section 7.2, Track Opportunistic Digs, failed to provide sufficient details regarding\nopportunistic digs. The coordination between various work groups and the responsibilities of\neach group were not discussed with adequate specificity. The Notice proposed Respondent must\nrevise its procedure to describe the approach used to track locations needing material\nverification, the methods to acquire needed data, the communication methods used to exchange\nneeded and gathered information between work groups and safeguards in place to ensure\ncompliance with VHFWLRQ 192.607(c).\nIn its Response, Enable contested the allegation. It stated that the roles of the various work\ngroups in the coordination of work to comply with VHFWLRQ 192.607(c) are detailed in I.43\nMaterial Verification, section 5.0, Governance. Respondent then listed six bullet-points detailing\nspecific tasks and the group responsible.\nThe Director reviewed Enable’s Response and the procedures cited therein and, per the Region\nRecommendation, recommended ordering amendment of the procedure as proposed in the\nNotice.\nHaving considered the record, Enable is correct that the roles of the various work groups in the\ncoordination of work to comply with VHFWLRQ 192.607(c) are detailed in I.43 Material\nVerification, section 5.0, Governance. However, the Notice did not allege that Respondent’s\nprocedures did not include the roles of the various work groups in the coordination of work to\ncomply with VHFWLRQ 192.607(c). Rather, the Notice alleged that Enable’s procedures did not\nadequately address the coordination between these groups – and it proposed that Respondent\nrevise its procedures to “describe the approach used to track locations needing material\nverification, the methods to acquire needed data, the communication methods used to exchange\nneeded and gathered information between work groups and safeguards in place to ensure\ncompliance with † 192.607(c).” The listing of each work group’s role and tasks in I.43 Material\nVerification, section 5.0, Governance, does not address the concerns expressed in the Notice\nregarding location tracking, data acquisition, communication methods, and safeguarding. These\ndetails are not present in Enable’s I.43 Material Verification procedure. Enable, in its Response,\ndid not address how its I.43 Material Verification procedure adequately addresses these concerns.\n\n\n\n3\nAccordingly, after reviewing the evidence, I find that Respondent’s procedure for conducting\nnondestructive or destructive tests, examinations, and assessments to verify the material\nproperties of aboveground line pipe and components, and of buried line pipe and components,\nwhen excavations occur were inadequate to ensure safe operation of a pipeline facility in\naccordance with VHFWLRQ 192.607(c). Enable is hereby ordered to revise its procedures as\nspecified above. Finalized procedures must be provided to the Southwest Region for review and\napproval.\nItem 3: The Notice alleged that Respondent’s procedures for establishing and documenting the\n$PHULFDQ 1DWLRQDO 6WDQGDUGV ,QVWLWXWH rating or pressure rating were inadequate to ensure safe\noperation of a pipeline facility in accordance with VHFWLRQ 192. 607(f). Specifically, the Notice\nalleged that Enable’s procedure I.43 Material Verification, Rev. 1, July 1, 2021, section 7.3.3,\nComponents, failed to provide adequate details regarding the material verification of non-line\npipe components. The Notice stated that the procedure failed to adequately describe how Enable\nwill verify non-line components that cannot be isolated from mainline pipeline pressures and\nmethods it will use to gather needed information.\nIn its response, Enable contested the allegation. It stated that verification of non-line pipe\ncomponents that cannot be isolated from mainline pressure is evaluated in the same manner as\nthose that can be isolated from mainline pressure. Respondent stated this is detailed in its\nprocedure I.43 Material Verification, section 7.3.3. The Director reviewed Enable’s Response\nand the procedures cited therein and, per the Region Recommendation, determined that no\nfurther procedural revisions are necessary.\nAccordingly, after reviewing the evidence, I find that Respondent needs to take no further action\nregarding Item 3.\nItem 4: The Notice alleged that Enable’s procedures for conducting operations and maintenance\nactivities were inadequate to ensure safe operation of a pipeline facility in accordance with\nVHFWLRQ 192.605(b)(1). Specifically, the Notice stated that Respondent’s procedure B.12\nEvaluating Class Location Changes (June 28, 2022), section 7.1, GIS Review, did not include\nadequate detail regarding incorporating updated or new GIS data into existing class locations.\nThe procedure failed to adequately detail how Enable incorporated newly acquired pipeline\nassets and assets with updated pipeline and structure attributes into the JHRJUDSKLF LQIRUPDWLRQ\nV\\VWHP GIS to determine if a class location study is required under VHFWLRQ 192.609.\nIn its Response, Enable stated that it revised the GIS process for management of Class location\nchanges and it described the new process. The Director reviewed Enable’s Response and the\nrevised process and, per the Region Recommendation, determined that no further procedural\nrevisions are necessary.\nAccordingly, after reviewing the evidence, I find that Respondent needs to take no further action\nregarding Item 4.\nItem 5: The Notice alleged that Respondent’s procedures for conducting operations and\nmaintenance activities were inadequate to ensure safe operation of a pipeline facility in\n\n\n\n4\naccordance with VHFWLRQ 192.605(b)(1). Specifically, the Notice alleged that Enable’s procedure\nB.10 Determination of MAOP, revision date February 1, 20220, Appending B, List of Hydro Test\nFactors for Class Location, and Appendix C, Process Flow for Determination of MAOP, failed to\ninclude all required information and contained errors. Appendix B failed to include column three\nof Table 1 from VHFWLRQ 192.619(a)(2)(ii) and Appendix C referenced an affidavit referred to as a\n“Gold Sheet.”\nIn its Response, Enable stated that it revised its procedures, to include revisions to Appendices B\nand C. The Director reviewed Enable’s Response and the revised procedures and, per the\nRegion Recommendation, determined that no further procedural revisions are necessary.\nAccordingly, after reviewing the evidence, I find that Respondent needs to take no further action\nregarding Item 5.\nItem 6: The Notice alleged that Enable’s procedures for reconfirming PD[LPXP DOORDZDEOH\nRSHUDWLQJ SUHVVXUH MAOP were inadequate to ensure safe operation of a pipeline facility in\naccordance with VHFWLRQ 192.624(b). Specifically, the Notice alleged Enable’s procedure MAOP\nReconfirmation Plan, Revision 1 (August 26, 2022), section 2, MAOP Reconfirmation\nCommittee, did not include adequate detail regarding Reconfirmation Committee activities. The\nprocedure did not adequately describe how the committee decides on an appropriate\nreconfirmation method, timing of segments, appropriate intermediate reconfirmation goals,\nadjustments for acquisitions and divestitures, and record keeping for associated decision making.\nIn its Response, Enable contested the allegation. It asserted that it is not necessary under\nVHFWLRQ 192.624 to have the details described in the Notice. Respondent further stated that in\n2023 its MAOP Reconfirmation Committee approved several changes to Enable’s MAOP\nReconfirmation Plan. It described the details of those changes. The Director reviewed Enable’s\nResponse and the information therein and, per the Region Recommendation, determined that no\nfurther procedural revisions are necessary.\nAccordingly, after reviewing the evidence, I find that Respondent needs to take no further action\nregarding Item 6.\nItem 7: The Notice alleged that Enable’s procedures for conducting operations and maintenance\nactivities were inadequate to ensure safe operation of a pipeline facility in accordance with VHFWLRQ\n192.605(b)(1). Specifically, the Notice alleged that procedure 192.710 ETC Gas Plan, revision 3\n(April 15, 2022), section 6.2, Periodic Reassessment, failed to include adequate detail regarding\nthe use and documentation of prior assessments. The procedure failed to identify who will make\nthe determination to use a prior assessment, the associated timelines, how this determination will\nbe made, and what records will be generated to document this process in accordance with VHFWLRQ\n192.710(b)(3).\nIn its Response, Enable did not contest the allegation and explained that it prepared redline\nrevisions to its procedures to include who will make the determination to use a prior assessment\nas the initial assessment and how the determination will be made per VHFWLRQ 192.710(b)(3).\nRespondent provided a copy of those redlined procedures with its Response.\n\n\n\n5\nThe Director, per the Region Recommendation, indicated that while the draft revised procedures\nwere reviewed, it could not be verified whether Enable has cured the alleged procedural\ninadequacy because Respondent did not provide the finalized version of the procedure.\nAccordingly, after reviewing the evidence, I find that Respondent’s procedure was inadequate to\nensure safe operation of a pipeline facility in accordance with VHFWLRQ 192.605(b)(1). Enable is\nhereby ordered to revise its procedures as specified above. Finalized procedures must be\nprovided to the Southwest Region for review and approval.\nItem 8: The Notice alleged that Enable’s procedures for conducting operations and maintenance\nactivities were inadequate to ensure safe operation of a pipeline facility in accordance with\nVHFWLRQ 192.605(b)(1). Specifically, the Notice alleged that procedure D.47 Evaluation of\nRemaining Strength Pipeline, revision date September 1, 2022, section 3, Applicability, did not\ninclude adequate detail to conduct an accurate analysis of predicted failure pressure. The\nprocedure failed to address measurement uncertainties such as tool tolerance, detection threshold,\ntool verification, and other potentially relevant data features in accordance with VHFWLRQ\n192.712(e).\nIn its Response, Enable contested the allegation. Respondent stated that its procedure is used\nonly for in situ or in-the-ditch measurements of metal loss to determine remaining strength of\nthe pipe. Enable noted that VHFWLRQ 192.712(e)(1) states that an operator must account for\nuncertainties in reported assessment results in identifying and characterizing the defects used in\npredicted failure pressure analyses unless the defect dimensions have been verified using in situ\ndirect measurements. Respondent asserted that since the procedure uses in situ or in-the-ditch\nmeasurements to determine remaining strength, uncertainties or tolerances are not required.\nThe Director reviewed Enable’s Response and the procedures cited therein and, per the Region\nRecommendation, recommended ordering amendment of the procedure as proposed in the\nNotice.\nHaving considered the record, Enable is correct that if defect dimensions are verified using in\nsitu direct measurements, uncertainties in reported assessment results in identifying and\ncharacterizing the defects used in predicted failure pressure analyses is not required. See VHFWLRQ\n192.712(e)(1). Had Respondent’s procedures included provisions for using LQOLQH LQVSHFWLRQ\nILI tools to size defects, or if evidence suggested Respondent intended to use ILI tools to size\ndefects, then the procedures would need to include processes for accounting for tool tolerances\nand other measurement uncertainties. However, since the procedures cited in the Notice only\nprovide for the use of in situ measurements, provisions accounting for uncertainties in reported\nassessment results are not necessary. Because Enable’s procedures only provide for in situ or in-\nthe-ditch measurements of metal loss to determine remaining strength of the pipe, I find the\nprocedures in place are not inadequate as alleged in the Notice for the currently used method.\nAccordingly, after reviewing the evidence, I find that no further action is required.\nItem 9: The Notice alleged that Enable’s procedures for the gathering of data needed for annual\nand incident reporting under Part 191 in a timely and effective manner were inadequate to ensure\nsafe operation of a pipeline facility in accordance with VHFWLRQ 192.605(b)(4). Specifically, the\n\n\n\n6\n1RWLFH alleged procedure A.15 PHMSA-States-Incident Reporting failed to detail identifying all\nModerate Consequence Areas (MCAs). MCAs must be identified and included in the annual\nand incident reporting. In addition, MCAs must be identified to comply with VHFWLRQV 192.624\nand 192.710.\nIn its Response, Enable contested this allegation and asserted that its procedure is intended to\nmeet the requirements of Part 191, specifically VHFWLRQV 191.3, 191.5, and 191.15. It stated that\nprocedure MAOP Reconfirmation Plan and 192.710 Plan also address the requirements of\nVHFWLRQV 192.624 and 192.710. In addition, Respondent stated that its procedures A.15 PHMSA-\nStates-Incident Reporting and A.16 Annual Reporting adhere to and refer to PHMSA’s reporting\ninstructions, which address MCAs. It further stated that procedure A.15 PHMSA-States-Incident\nReporting defines MCA. Enable p","truncated":true,"body_characters":71878}