# ENABLE GAS TRANSMISSION, LLC — Notice of Amendment - **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:** Not available - **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. Official case documents: 42024031NOA_Closure Letter_01142025_(23-264807).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024031NOA/42024031NOA_Closure%20Letter_01142025_(23-264807).pdf 42024031NOA_Closure Letter_01142025_(23-264807)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024031NOA/42024031NOA_Closure%20Letter_01142025_(23-264807)_text.pdf 42024031NOA_Notice of Amendment_05022024_(23-264807).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024031NOA/42024031NOA_Notice%20of%20Amendment_05022024_(23-264807).pdf 42024031NOA_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 42024031NOA_Notice of Amendment_05022024_(23-264807)_text.pdf NOTICE OF AMENDMENT VIA ELECTRONIC MAIL TO: tom.long@energytransfer.com May 2, 2024 Thomas Long Chief Executive Officer Energy Transfer, LP 8111 Westchester Drive, Dallas, Texas 75225 CPF 4-2024-031-NOA Dear Mr. Long: From March 6 to October 17, 2023, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code (U.S.C.) conducted an on-site inspection of Enable Gas Transmission, LLC’s (Enable)1 integrity management plan in Oklahoma City, Oklahoma. As a result of the inspection, PHMSA has identified the apparent inadequacy found within Enable’s plans or procedures. The item inspected and the inadequacy are described below: 1. § 192.605 Procedural manual for operations, maintenance, and emergencies. (a) . . . . (b) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following, if applicable, to provide safety during maintenance and operations. (1) . . . . (2) Controlling corrosion in accordance with the operations and maintenance requirements of Subpart I of this part. § 192.493 In-line inspection of pipelines. When conducting in-line inspections of pipelines required by this part, an operator must comply with API STD 1163, ANSI/ASNT ILI– PQ, and NACE SP0102, (incorporated by reference, see § 192.7). 1 Enable Gas Transmission, LLC is a subsidiary of Energy Transfer, LP. Assessments may be conducted using tethered or remotely controlled tools, not explicitly discussed in NACE SP0102, provided they comply with those sections of NACE SP0102 that are applicable. Enable’s written procedures for conducting operations and maintenance activities were inadequate to assure the safe operation of a pipeline facility in accordance with § 192.605(b)(2). Specifically, Enable’s Pipeline Integrity Management Plan (Revision No. 17; Dated 05/24/2023) section 7.2.3 and In-Line Inspection Specification – PI-1.3 (Revision Date: 05/25/2022) section 6.1 failed to include in-line inspection (ILI) survey acceptance criteria as required by section 5.1.5 in NACE SP0102 in accordance with § 192.493. Section 5.1.5 in NACE SP0102 requires that operators and ILI vendors develop and agree to a set of ILI survey-acceptance criteria, such as physical damage to sensors after an ILI run, lost sensor channels on data, sensor noise, distance inaccuracy, missed or not recorded features, and velocity overruns, prior to the start of an ILI run. Enable’s procedures failed to include the requirement to develop and agree to a set of survey- acceptance criteria that define when a rerun survey is required in accordance with section 5.1.5 of NACE SP0102. Therefore, Enable’s written procedures for controlling corrosion were inadequate to assure the safe operation of a pipeline facility in accordance with § 192.605(b)(2). Enable must revise its procedures to require the development of ILI survey-acceptance criteria as required by NACE SP0102. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement Proceedings. Please refer to this document and note the response options. Be advised that all material you submit in response to this enforcement action is subject to being made publicly available. If you believe that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. § 552(b), along with the complete original document you must provide a second copy of the document with the portions you believe qualify for confidential treatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatment under 5 U.S.C. § 552(b). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that Enable Gas Transmission, LLC maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Bryan Lethcoe, Director, Southwest, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 4-2024-031-NOA and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Bryan Lethcoe Director, Southwest Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings cc: Greg McIlwain, Executive Vice President of Operations, Energy Transfer, LP, gregory.mcilwain@energytransfer.com Eric Amundsen, Senior Vice President of Operations, Energy Transfer, LP, eric.amundsen@energytransfer.com Todd Stamm, Senior Vice President of Operations, Energy Transfer, LP, todd.stamm@energytransfer.com Jennifer Street, Senior Vice President of Operations Services, Energy Transfer, LP, jennifer.street@energytransfer.com Heidi Murchison, Chief Counsel, Energy Transfer, LP, heidi.murchison@energytransfer.com Leif Jensen, Vice President of Tech Services, Energy Transfer, LP, leif.jensen@energytransfer.com Todd Nardozzi, Director, Regulatory Compliance, Energy Transfer, LP, todd.nardozzi@energytransfer.com Susie Sjulin, Director, Regulatory Compliance, Energy Transfer, LP, susie.sjulin@energytransfer.com Jimmy Cross, Senior Manager, DOT Compliance Primary, Energy Transfer, LP, jimmy.cross@energytransfer.com 42024031NOA_Closure Letter_01142025_(23-264807)_text.pdf VIA ELECTRONIC MAIL TO: tom.long@energytransfer.com January 14, 2025 Thomas Long Chief Executive Officer Energy Transfer, LP 8111 Westchester Drive, Dallas, Texas 75225 RE: CPF 4-2024-031-NOA Dear Mr. Long: From March 6 to October 17, 2023, a representative of the Pipeline and Hazardous Materials Safety Administration, Officed of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code (U.S.C.) conducted an on-site inspection of Enable Gas Transmission, LLC’s (Enable) integrity management plan in Oklahoma City, Oklahoma. Enable Gas Transmission, LLC is a subsidaiary of Energy Transfer, LP. As a result of the inspection, Enable was issued a Notice of Amendment on May 2, 2024, which proposed amendment of its procedures. Enable submitted its amended procedures on December 4, 2024. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary, and this case is now closed. Sincerely, Bryan Lethcoe Director, Southwest Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration cc: Greg McIlwain, Executive Vice President of Operations, Energy Transfer, LP, gregory.mcilwain@energytransfer.com Eric Amundsen, Senior Vice President of Operations, Energy Transfer, LP, eric.amundsen@energytransfer.com Todd Stamm, Senior Vice President of Operations, Energy Transfer, LP, todd.stamm@energytransfer.com Jennifer Street, Senior Vice President of Operations Services, Energy Transfer, LP, jennifer.street@energytransfer.com Keegan Pieper, Assistant General Counsel, Energy Transfer, LP, keegan.pieper@energytransfer.com Mathew Stork, Vice President of Tech Services, Energy Transfer, LP, Mathew.stork@energytransfer.com Todd Nardozzi, Director, DOT Compliance, Energy Transfer, LP, todd.nardozzi@energytransfer.com Susie Sjulin, Director, DOT Compliance, Energy Transfer, LP, susie.sjulin@energytransfer.com - **truncated:** false - **body characters:** 9665