{"operation":"document","citation":"CPF 120181010W","title":"GRANITE STATE GAS TRANSMISSION INC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-05-07","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181010w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181010w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181010w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120181010W","body":"Warning Letter involving GRANITE STATE GAS TRANSMISSION INC. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2018-05-07 and is reported as closed as of 2018-05-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120181010W_Warning Letter_05072018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181010W/120181010W_Warning%20Letter_05072018.pdf\n\n120181010W_Warning Letter_05072018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181010W/120181010W_Warning%20Letter_05072018_text.pdf\n\n120181010W_Warning Letter_05072018_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nMay 7, 2018\nThomas Meissner\nSenior Vice President\nGranite State Gas Transmission Inc.\n325 West Road\nPortsmouth, NH 03801\nCPF 1-2018-1010W\nDear Mr. Meissner:\nFrom June 26-30, 2017, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nGranite State Gas Transmission Inc.’s (Granite) pipeline system in Maine, New Hampshire and\nMassachusetts.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violation(s) are:\n1. § 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 conducting operations and maintenance activities and for\nemergency response…\nGranite failed to follow its manual of written procedures for leakage survey. Specifically, Granite\nfailed to follow its 220.001.005 Leakage inspection – Instrumented, Version 6, Section 2.3.1, dated\nDecember 2015 (Procedure), by failing to document the gas detection equipment utilized during\nits leakage surveys.\nGranite’s Procedure stated in Section 2.3.1:\nRecord the leak detector equipment number (Required).\n\n\n\nCPF 1-2018-1010W\nDuring the inspection, the PHMSA inspector reviewed Granite’s records of instrumented leakage\nsurveys performed during 2015. The work order records from Granite’s Compliancy Management\nSystem failed to contain documentation of the leak detector equipment number. Granite supplied\nLeak Survey Calibration Sheets that demonstrated that leak detection equipment was being\ncalibrated, but could not demonstrate that this calibrated equipment was what was utilized during\nits leakage surveys.\nTherefore, Granite failed to follow its written procedures regarding documentation of instrumental\nleakage surveys.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$209,002 per violation per day the violation persists, up to a maximum of $2,090,022 for a related\nseries of violations. For violations occurring prior to November 2, 2015, the maximum penalty\nmay not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000\nfor a related series 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 item identified in this letter.\nFailure to do so will result in Granite being subject to additional enforcement action.\nPlease be advised that all material you submit in response to this enforcement action is subject to\nbeing made publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for confidential\ntreatment redacted and an explanation of why you believe the redacted information qualifies for\nconfidential treatment under 5 U.S.C. 552(b).\nNo reply to this letter is required. If you choose to reply, please submit all correspondence in this\nmatter to Robert Burrough, Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103,\nWest Trenton, NJ 08628. Please refer to CPF 1-2018-1010W on each document you submit, and\nwhenever possible provide a signed PDF copy in electronic format. Smaller files may be emailed\nto robert.burrough@dot.gov. Larger files should be sent on a CD accompanied by the original\npaper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120181010W_Warning Letter_05072018 Page 2 of 2","truncated":false,"body_characters":4637}