{"operation":"document","citation":"CPF 42024031NOA","title":"ENABLE GAS TRANSMISSION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-05-02","effective_on":null,"summary":"CLOSED notice of amendment citing 192.493, 192.605(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42024031noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42024031noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42024031noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42024031NOA","body":"Notice of Amendment involving ENABLE GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.493,  192.605(b)(2). The case was opened on 2024-05-02 and is reported as closed as of 2025-01-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42024031NOA_Closure Letter_01142025_(23-264807).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024031NOA/42024031NOA_Closure%20Letter_01142025_(23-264807).pdf\n\n42024031NOA_Closure Letter_01142025_(23-264807)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024031NOA/42024031NOA_Closure%20Letter_01142025_(23-264807)_text.pdf\n\n42024031NOA_Notice of Amendment_05022024_(23-264807).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024031NOA/42024031NOA_Notice%20of%20Amendment_05022024_(23-264807).pdf\n\n42024031NOA_Notice of Amendment_05022024_(23-264807)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024031NOA/42024031NOA_Notice%20of%20Amendment_05022024_(23-264807)_text.pdf\n\n42024031NOA_Notice of Amendment_05022024_(23-264807)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: tom.long@energytransfer.com\nMay 2, 2024\nThomas Long\nChief Executive Officer\nEnergy Transfer, LP\n8111 Westchester Drive,\nDallas, Texas 75225\nCPF 4-2024-031-NOA\nDear Mr. Long:\nFrom March 6 to October 17, 2023, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49\nUnited States Code (U.S.C.) conducted an on-site inspection of Enable Gas Transmission, LLC’s\n(Enable)1 integrity management plan in Oklahoma City, Oklahoma.\nAs a result of the inspection, PHMSA has identified the apparent inadequacy found within\nEnable’s plans or procedures. The item inspected and the inadequacy are described below:\n1. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) . . . .\n(b) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following,\nif applicable, to provide safety during maintenance and operations.\n(1) . . . .\n(2) Controlling corrosion in accordance with the operations and\nmaintenance requirements of Subpart I of this part.\n§ 192.493 In-line inspection of pipelines.\nWhen conducting in-line inspections of pipelines required by this\npart, an operator must comply with API STD 1163, ANSI/ASNT ILI–\nPQ, and NACE SP0102, (incorporated by reference, see § 192.7).\n1 Enable Gas Transmission, LLC is a subsidiary of Energy Transfer, LP.\n\n\n\nAssessments may be conducted using tethered or remotely\ncontrolled tools, not explicitly discussed in NACE SP0102, provided\nthey comply with those sections of NACE SP0102 that are applicable.\nEnable’s written procedures for conducting operations and maintenance activities were inadequate\nto assure the safe operation of a pipeline facility in accordance with § 192.605(b)(2). Specifically,\nEnable’s Pipeline Integrity Management Plan (Revision No. 17; Dated 05/24/2023) section 7.2.3\nand In-Line Inspection Specification – PI-1.3 (Revision Date: 05/25/2022) section 6.1 failed to\ninclude in-line inspection (ILI) survey acceptance criteria as required by section 5.1.5 in NACE\nSP0102 in accordance with § 192.493.\nSection 5.1.5 in NACE SP0102 requires that operators and ILI vendors develop and agree to a set\nof ILI survey-acceptance criteria, such as physical damage to sensors after an ILI run, lost sensor\nchannels on data, sensor noise, distance inaccuracy, missed or not recorded features, and velocity\noverruns, prior to the start of an ILI run.\nEnable’s procedures failed to include the requirement to develop and agree to a set of survey-\nacceptance criteria that define when a rerun survey is required in accordance with section 5.1.5 of\nNACE SP0102.\nTherefore, Enable’s written procedures for controlling corrosion were inadequate to assure the safe\noperation of a pipeline facility in accordance with § 192.605(b)(2). Enable must revise its\nprocedures to require the development of ILI survey-acceptance criteria as required by NACE\nSP0102.\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 Enforcement\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. § 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 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\nNotice, we propose that you submit your amended procedures to my office within 30 days of\n\n\n\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 Gas Transmission, LLC maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Bryan Lethcoe, Director,\nSouthwest, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 4-2024-031-NOA and, for each document you submit,\nplease provide a copy in electronic format whenever possible.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: Greg McIlwain, Executive Vice President of Operations, Energy Transfer, LP,\ngregory.mcilwain@energytransfer.com\nEric Amundsen, Senior Vice President of Operations, Energy Transfer, LP,\neric.amundsen@energytransfer.com\nTodd Stamm, Senior Vice President of Operations, Energy Transfer, LP,\ntodd.stamm@energytransfer.com\nJennifer Street, Senior Vice President of Operations Services, Energy Transfer, LP,\njennifer.street@energytransfer.com\nHeidi Murchison, Chief Counsel, Energy Transfer, LP,\nheidi.murchison@energytransfer.com\nLeif Jensen, Vice President of Tech Services, Energy Transfer, LP,\nleif.jensen@energytransfer.com\nTodd Nardozzi, Director, Regulatory Compliance, Energy Transfer, LP,\ntodd.nardozzi@energytransfer.com\nSusie Sjulin, Director, Regulatory Compliance, Energy Transfer, LP,\nsusie.sjulin@energytransfer.com\nJimmy Cross, Senior Manager, DOT Compliance Primary, Energy Transfer, LP,\njimmy.cross@energytransfer.com\n\n42024031NOA_Closure Letter_01142025_(23-264807)_text.pdf\n\nVIA ELECTRONIC MAIL TO: tom.long@energytransfer.com\nJanuary 14, 2025\nThomas Long\nChief Executive Officer\nEnergy Transfer, LP\n8111 Westchester Drive,\nDallas, Texas 75225\nRE: CPF 4-2024-031-NOA\nDear Mr. Long:\nFrom March 6 to October 17, 2023, a representative of the Pipeline and Hazardous Materials\nSafety Administration, Officed of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.) conducted an on-site inspection of Enable Gas Transmission, LLC’s (Enable)\nintegrity management plan in Oklahoma City, Oklahoma. Enable Gas Transmission, LLC is a\nsubsidaiary of Energy Transfer, LP.\nAs a result of the inspection, Enable was issued a Notice of Amendment on May 2, 2024, which\nproposed amendment of its procedures. Enable submitted its amended procedures on December 4,\n2024. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in\nthis Notice of Amendment have been corrected.\nThis letter is to inform you no further action is necessary, and this case is now closed.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Greg McIlwain, Executive Vice President of Operations, Energy Transfer, LP,\ngregory.mcilwain@energytransfer.com\nEric Amundsen, Senior Vice President of Operations, Energy Transfer, LP,\neric.amundsen@energytransfer.com\nTodd Stamm, Senior Vice President of Operations, Energy Transfer, LP,\ntodd.stamm@energytransfer.com\n\n\n\nJennifer Street, Senior Vice President of Operations Services, Energy Transfer, LP,\njennifer.street@energytransfer.com\nKeegan Pieper, Assistant General Counsel, Energy Transfer, LP,\nkeegan.pieper@energytransfer.com\nMathew Stork, Vice President of Tech Services, Energy Transfer, LP,\nMathew.stork@energytransfer.com\nTodd Nardozzi, Director, DOT Compliance, Energy Transfer, LP,\ntodd.nardozzi@energytransfer.com\nSusie Sjulin, Director, DOT Compliance, Energy Transfer, LP,\nsusie.sjulin@energytransfer.com","truncated":false,"body_characters":9665}