# GRANITE STATE GAS TRANSMISSION INC — Warning Letter

- **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:** Not available
- **summary:** CLOSED warning letter citing 192.605(a).
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- **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.

Official case documents:

120181010W_Warning Letter_05072018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181010W/120181010W_Warning%20Letter_05072018.pdf

120181010W_Warning Letter_05072018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181010W/120181010W_Warning%20Letter_05072018_text.pdf

120181010W_Warning Letter_05072018_text.pdf

WARNING LETTER
OVERNIGHT EXPRESS DELIVERY
May 7, 2018
Thomas Meissner
Senior Vice President
Granite State Gas Transmission Inc.
325 West Road
Portsmouth, NH 03801
CPF 1-2018-1010W
Dear Mr. Meissner:
From June 26-30, 2017, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected
Granite State Gas Transmission Inc.’s (Granite) pipeline system in Maine, New Hampshire and
Massachusetts.
As a result of the inspection, it is alleged that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected
and the probable violation(s) are:
1. § 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 conducting operations and maintenance activities and for
emergency response…
Granite failed to follow its manual of written procedures for leakage survey. Specifically, Granite
failed to follow its 220.001.005 Leakage inspection – Instrumented, Version 6, Section 2.3.1, dated
December 2015 (Procedure), by failing to document the gas detection equipment utilized during
its leakage surveys.
Granite’s Procedure stated in Section 2.3.1:
Record the leak detector equipment number (Required).



CPF 1-2018-1010W
During the inspection, the PHMSA inspector reviewed Granite’s records of instrumented leakage
surveys performed during 2015. The work order records from Granite’s Compliancy Management
System failed to contain documentation of the leak detector equipment number. Granite supplied
Leak Survey Calibration Sheets that demonstrated that leak detection equipment was being
calibrated, but could not demonstrate that this calibrated equipment was what was utilized during
its leakage surveys.
Therefore, Granite failed to follow its written procedures regarding documentation of instrumental
leakage surveys.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$209,002 per violation per day the violation persists, up to a maximum of $2,090,022 for a related
series of violations. For violations occurring prior to November 2, 2015, the maximum penalty
may not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000
for a related series 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 item identified in this letter.
Failure to do so will result in Granite being subject to additional enforcement action.
Please 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).
No reply to this letter is required. If you choose to reply, please submit all correspondence in this
matter to Robert Burrough, Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103,
West Trenton, NJ 08628. Please refer to CPF 1-2018-1010W on each document you submit, and
whenever possible provide a signed PDF copy in electronic format. Smaller files may be emailed
to robert.burrough@dot.gov. Larger files should be sent on a CD accompanied by the original
paper copy to the Eastern Region Office.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
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