{"operation":"document","citation":"CPF 12021042WL","title":"GREAT LAKES GAS TRANSMISSION CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-05-06","effective_on":null,"summary":"CLOSED warning letter citing 192.161(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021042wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021042wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021042wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12021042WL","body":"Warning Letter involving GREAT LAKES GAS TRANSMISSION CO. PHMSA's enforcement data identifies the cited regulation as 192.161(e). The case was opened on 2021-05-06 and is reported as closed as of 2021-05-06. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12021042WL_Warning Letter_05062021_(20-174444).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021042WL/12021042WL_Warning%20Letter_05062021_(20-174444).pdf\n\n12021042WL_Warning Letter_05062021_(20-174444)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021042WL/12021042WL_Warning%20Letter_05062021_(20-174444)_text.pdf\n\n12021042WL_Warning Letter_05062021_(20-174444)_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nMay 6, 2021\nMr. Stanley Chapman\nExecutive VP and President, U.S. Natural Gas Pipelines\nGreat Lakes Gas Transmission Co\n7000 Louisiana Street\nHouston, TX 77002\nCPF 1-2021-042-WL\nDear Mr. Chapman:\nFrom February 2, 2020 - May 21, 2020, representative from Michigan Public Service Commission\n(MI-PSC), acting as Agent for the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.) investigated Great Lakes\nGas Transmission Co (GLGT).\nOn February 2, 2020, an incident occurred during normal operation of the Farewell Compressor\nStation in Clare County, MI. The pipeline and Farewell Compressor Station is owned and operated\nby GLGT. A technician responded to the sound of a presumed natural gas release and isolated the\nstation by activating an Emergency Shut Down.\nThe failure resulted in estimated cost of property damage and repairs exceeding the reportable\nthreshold of $50,000. The pipeline was operating at 826 psig when the failure occurred, resulting\nin a release of approximately 1,500 standard cubic feet (mcf) of natural gas in total, with 672 mcf\nbeing unintended and 852 mcf being via controlled release. The failed 2-inch siphon drain line\nassembly and 36-inch header were examined via ultrasonic testing and magnetic particle non-\ndestructive testing, and were later shipped to Texas for laboratory analysis. Metallurgical analysis\ndetermined that reversed bending fatigue from thermal lateral, and thermal expansion and\ncontraction, caused the pipe to crack. The damage was isolated to the 2-inch siphon drain line\nassembly and associated 36-inch header. Farewell Compressor Station was returned to service on\nFebruary 12, 2020 with permanent repairs completed on March 24, 2020.\n\n\n\nCPF 1-2021-042-WL\nAs a result of the investigation, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item investigated\nand the probable violation is:\n1. § 192.161 Supports and anchors.\n(a) …\n(e) Each underground pipeline that is connected to a relatively\nunyielding line or other fixed object must have enough flexibility to\nprovide for possible movement, or it must have an anchor that will limit\nthe movement of the pipeline.\nGLGT failed to have enough flexibility to provide for possible movement or have an anchor that\nwill limit the movement of an underground pipeline that is connected to a relatively unyielding\nline or other fixed object. Specifically, GLGT failed to provide enough flexibility within the 2-\ninch siphon drain line or restrain a 36-inch header at the inlet to the gas aftercooler at Farwell\nCompressor Station.\nDuring the investigation, the MI-PSC investigator reviewed GLGT’s as-built plans dated 1998. A\nconcrete foundation was installed below the 36-inch header that encased a two-inch siphon’s weld-\no-let connection. The 36-inch header was restrained vertically, but not restrained laterally to\nprevent thermal expansion and contraction, which resulted in failure of the fixed 2-inch siphon\ndrain line weld-o-let.\nTherefore, GLGT failed to have enough flexibility to provide for possible movement or have an\nanchor that will limit the movement as prescribed in § 192.161(e).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for a related\nseries of violations. For violation occurring on or after July 31, 2019 and before January 11, 2021,\nthe maximum penalty may not exceed $218,647 per violation per day the violation persists, up to\na maximum of $2,186,465 for a related series of violations. For violation occurring on or after\nNovember 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per\nviolation per day, with a maximum penalty not to exceed $2,132,679. For violation occurring on\nor after November 2, 2015 and before November 27, 2018, the maximum penalty may not exceed\n$209,002 per violation per day, with a maximum penalty not to exceed $2,090,022.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the item identified in this letter. Failure to do so will result in\nGreat Lakes Gas Transmission Co being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2021-042-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\n12021042WL_Warning Letter_05062021_(20-174444)_text Page 2 of 3\n\n\n\nCPF 1-2021-042-WL\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n12021042WL_Warning Letter_05062021_(20-174444)_text Page 3 of 3","truncated":false,"body_characters":6169}