{"operation":"document","citation":"CPF 120071009W","title":"GRANITE STATE GAS TRANSMISSION INC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-09-24","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a), 192.709(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120071009w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120071009w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120071009w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120071009W","body":"Warning Letter involving GRANITE STATE GAS TRANSMISSION INC. PHMSA's enforcement data identifies the cited regulations as 192.605(a),  192.709(c). The case was opened on 2007-09-24 and is reported as closed as of 2007-09-24. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120071009W_Warning Letter_09242007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120071009W/120071009W_Warning%20Letter_09242007.pdf\n\n120071009w_warning letter_09242007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120071009W/120071009w_warning%20letter_09242007_text.pdf\n\n120071009w_warning letter_09242007_text.pdf\n\nu 5 Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n409 3rd Street, SW, Suite 300\nWashington, DC 20024\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nSeptember 24, 2007\nMr Reed Robinson\nVice President, Pipehne Engineering Services\nColumbia Gas Transnussion Corporation\n1700 MacCorkle Avenue, SE\nCharleston, West Virgnua 25314\nCPF I-2007-1009W\nDear Robinson\nDunng the week of July 17, 2006, a representative of the Pipehne and Hazardous Matenals\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 Uruted States Code inspected\nGramte State Gas Transmission Corporation (Gramte State) m Portsmouth, New Hampshire\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipehne Safety Regulations, Title 49, Code of Federal Regulations The items inspected and the\nprobable violations are\n\n\n\n1. I)192. 605 Procedural manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conductmg operations and mamtenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations.\nThe operator's procedures require that odorant level readings be taken monthly not to exceed 40\ndays Dunng 2004 and 2005, there were two odorant level reading intervals in wluch the\noperator fatled to meet the procedure reqmrement Odorant level readings were taken on March\n2 and April 13, 2004, 44 days between readings, and on November 29, 2005 and January 11,\n2006, 43 days between readings, with no readings taken in December 2005\nThe probable violation was based on the PHMSA inspector's review of the operator's\nprocedures, the work orders and odorant test records for the relevant months\nI'1192. 709 Transmission lines: Record keeping.\nEach operator shall mamtam the following records for transnussion hne for the\nperiods specified:\n(c) A record of each patrol, survey, inspection, and test required by subparts L and\nM of this part must be retained for at least 5 years or until the next patrol, survey,\ninspection, or test is completed, whichever is longer.\nGrarute State maintains records to document the monthly odorant level tests performed by its\ntechmctans Odorant level test record information was not consistent with respect to the test\ndates, the test technician, the test locations, the rotameter readings and percent (%) gas-in-air\nconcentrations for the following\nA January 2004\nThere are two separate dates on the Work Order (WO) Completion Data Block on the\nDistnbution Work Order completion date of I/23/04 and start date of I/21/04 The\ncorresponding Odor Test Form (OTF) has a date of I/23/04 for the two New Hampshire test sites\nand the two Mame test sites It is uncertain wtuch work was done on I/21/04 and I/23/04 In\naddition, the two gas-m-air readings in Maine do not correspond with any rotameter float (glass\nor metal) readings on either of the operator's two odorometers\nB February 2004\nTwo tndkvtduals signed the WO, only one signed the OTF It is uncertain wluch individuals\nperformed the odorometer readings at the four sites The Maine readings have non-credible gas\nm iur concentrations (two decimal points) recorded ( 4 5% and I 5%) The Maine readings do\nnot correspond to the recorded rotameter readings on either of the odorometer conversion charts\n\n\n\nC March 2004\nTwo different individuals signed the WO with no name on the OTF where the four tests were\nrecorded None of the rotameter readings corresponded with a recorded gas-in-air readmg on the\nrotameter conversion chart\nD May 2004\nThere are two dates and two names on the WO mdhcating a start date of 5/10/04 and a completion\ndate of 5/21/04, with only one name on the OTF malung it questionable as to who performed the\ntests and when the tests were performed\nE October 2004\nThere is a start date of 10/6/04 and a completed date of 10/16/04 with one signature on the WO\nThere is another signature on the OTF for 10/6/04 The New Hampshire readings are non-\ncredible with gas-in-au' concentrations recorded as 1 5'/o and 1 5'10\nF November 2004\nWO has two signatures and two dates wlnle the OTF has only one signature and one date The\nreadings (rotameter readmg/ '/0 gas-in-air) going down the form are 4/ 6'/o, 3/ 2 5'/o, 35/ 2 6'/o,\nand 4 / 3'/0 These readings are not credible\nG March 2005\nA rotameter readmg of 4 0 was recorded as 3 5'/0 gas-in-au concentration Readings of 0 4 and\n0 45 were recorded as 3 5'/0 and 3 75'/0 gas-m-air concentrations\nH May 2005\nI August 2005\nThe rotameter readings are recorded as 38 and 42 The rotameter scale only goes &om 0 to 10\nThere are apparently erased gas-in-air readings with no rotameter readings recorded for Maine\nDunng August 2005 There are two names on the WO wlule only one name is on the OTF\n3 September 2005\nThe rotameter readings for Debbie Lane in Maine, converts a 0 35 rotameter readmg to 3 25'/0\ngas-in-air concentration This is not consistent with either mtameter conversion chart Two\nnames are on the WO, no name is on the OTF\nThe probable violation is based upon the operator's odorant test records for the above months\nand the rotameter conversion charts employed by Granite State\nUnder 49 United States Code, $ 60122, you are sub3ect to a civil penalty not to exceed $100, 000\nfor each violation for each day the violation persists up to a maximum of $1, 000, 000 for any\nrelated senes of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time We advise you to correct the items identified in this letter\nFailure to do so will result in Gramte State being sublect to additional enforcement action\n\n\n\nNo reply to this letter is required If you choose to reply, in your correspondence please refer to\nCPF I-2007-1009W. Be advised that all matenal you submit in response to this enforcement\naction is subJect to being made pubhcly available If you beheve that any portion of your\nresponsive matenal qualifies for confidential treatment under 5 U S C 552(b), along with the\ncomplete ongmal document you must provide a second copy of the document with the portions\nyou beheve quahfy for confidential treatment redacted and an explanation of why you beheve\nthe redacted information quahfies for confidential treatment under 5 U S C 552(b)\nByron Coy, PE\nDirector, Eastern Region\nPipehne and Hazardous Materials Safety Administration","truncated":false,"body_characters":7243}