GRANITE STATE GAS TRANSMISSION INC — Warning Letter

120071009w_warning letter_09242007_text.pdf, page 1Official PDFu 5 Department of Transportation Pipeline and Hazardous Materials Safety Administration 409 3rd Street, SW, Suite 300 Washington, DC 20024 WARNING LETTER CERTIFIED MAIL - RETURN RECEIPT RE UESTED September 24, 2007 Mr Reed Robinson Vice President, Pipehne Engineering Services Columbia Gas Transnussion Corporation 1700 MacCorkle Avenue, SE Charleston, West Virgnua 25314 CPF I-2007-1009W Dear Robinson Dunng the week of July 17, 2006, a representative of the Pipehne and Hazardous Matenals Safety Administration (PHMSA) pursuant to Chapter 601 of 49 Uruted States Code inspected Gramte State Gas Transmission Corporation (Gramte State) m Portsmouth, New Hampshire As a result of the inspection, it appears that you have committed probable violations of the Pipehne Safety Regulations, Title 49, Code of Federal Regulations The items inspected and the probable violations are#

120071009w_warning letter_09242007_text.pdf, page 21. I)192. 605 Procedural manual for operations, maintenance, and emergencies (a) General. Each operator shall prepare and follow for each pipeline, a manual of written procedures for conductmg operations and mamtenance activities and for emergency response. For transmission lines, the manual must also include procedures for handling abnormal operations. The operator's procedures require that odorant level readings be taken monthly not to exceed 40 days Dunng 2004 and 2005, there were two odorant level reading intervals in wluch the operator fatled to meet the procedure reqmrement Odorant level readings were taken on March 2 and April 13, 2004, 44 days between readings, and on November 29, 2005 and January 11, 2006, 43 days between readings, with no readings taken in December 2005 The probable violation was based on the PHMSA inspector's review of the operator's procedures, the work orders and odorant test records for the relevant months I'1192. 709 Transmission lines: Record keeping. Each operator shall mamtam the following records for transnussion hne for the periods specified: (c) A record of each patrol, survey, inspection, and test required by subparts L and M of this part must be retained for at least 5 years or until the next patrol, survey, inspection, or test is completed, whichever is longer. Grarute State maintains records to document the monthly odorant level tests performed by its techmctans Odorant level test record information was not consistent with respect to the test dates, the test technician, the test locations, the rotameter readings and percent (%) gas-in-air concentrations for the following A January 2004 There are two separate dates on the Work Order (WO) Completion Data Block on the Distnbution Work Order completion date of I/23/04 and start date of I/21/04 The corresponding Odor Test Form (OTF) has a date of I/23/04 for the two New Hampshire test sites and the two Mame test sites It is uncertain wtuch work was done on I/21/04 and I/23/04 In addition, the two gas-m-air readings in Maine do not correspond with any rotameter float (glass or metal) readings on either of the operator's two odorometers B February 2004 Two tndkvtduals signed the WO, only one signed the OTF It is uncertain wluch individuals performed the odorometer readings at the four sites The Maine readings have non-credible gas m iur concentrations (two decimal points) recorded ( 4 5% and I 5%) The Maine readings do not correspond to the recorded rotameter readings on either of the odorometer conversion charts#

120071009w_warning letter_09242007_text.pdf, page 3C March 2004 Two different individuals signed the WO with no name on the OTF where the four tests were recorded None of the rotameter readings corresponded with a recorded gas-in-air readmg on the rotameter conversion chart D May 2004 There are two dates and two names on the WO mdhcating a start date of 5/10/04 and a completion date of 5/21/04, with only one name on the OTF malung it questionable as to who performed the tests and when the tests were performed E October 2004 There is a start date of 10/6/04 and a completed date of 10/16/04 with one signature on the WO There is another signature on the OTF for 10/6/04 The New Hampshire readings are non- credible with gas-in-au' concentrations recorded as 1 5'/o and 1 5'10 F November 2004 WO has two signatures and two dates wlnle the OTF has only one signature and one date The readings (rotameter readmg/ '/0 gas-in-air) going down the form are 4/ 6'/o, 3/ 2 5'/o, 35/ 2 6'/o, and 4 / 3'/0 These readings are not credible G March 2005 A rotameter readmg of 4 0 was recorded as 3 5'/0 gas-in-au concentration Readings of 0 4 and 0 45 were recorded as 3 5'/0 and 3 75'/0 gas-m-air concentrations H May 2005 I August 2005 The rotameter readings are recorded as 38 and 42 The rotameter scale only goes &om 0 to 10 There are apparently erased gas-in-air readings with no rotameter readings recorded for Maine Dunng August 2005 There are two names on the WO wlule only one name is on the OTF 3 September 2005 The rotameter readings for Debbie Lane in Maine, converts a 0 35 rotameter readmg to 3 25'/0 gas-in-air concentration This is not consistent with either mtameter conversion chart Two names are on the WO, no name is on the OTF The probable violation is based upon the operator's odorant test records for the above months and the rotameter conversion charts employed by Granite State Under 49 United States Code, $ 60122, you are sub3ect to a civil penalty not to exceed $100, 000 for each violation for each day the violation persists up to a maximum of $1, 000, 000 for any related senes of violations. We have reviewed the circumstances and supporting documents involved in this case, and have decided not to conduct additional enforcement action or penalty assessment proceedings at this time We advise you to correct the items identified in this letter Failure to do so will result in Gramte State being sublect to additional enforcement action#

120071009w_warning letter_09242007_text.pdf, page 4No reply to this letter is required If you choose to reply, in your correspondence please refer to CPF I-2007-1009W. Be advised that all matenal you submit in response to this enforcement action is subJect to being made pubhcly available If you beheve that any portion of your responsive matenal qualifies for confidential treatment under 5 U S C 552(b), along with the complete ongmal document you must provide a second copy of the document with the portions you beheve quahfy for confidential treatment redacted and an explanation of why you beheve the redacted information quahfies for confidential treatment under 5 U S C 552(b) Byron Coy, PE Director, Eastern Region Pipehne and Hazardous Materials Safety Administration#