{"operation":"document","citation":"CPF 12022074NOA","title":"GRANITE STATE GAS TRANSMISSION INC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-11-17","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(8), 192.605(c)(4), 192.605(d).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022074noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022074noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022074noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022074NOA","body":"Notice of Amendment involving GRANITE STATE GAS TRANSMISSION INC. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(8),  192.605(c)(4),  192.605(d). The case was opened on 2022-11-17 and is reported as closed as of 2023-01-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022074NOA_Closure Letter_01102023_(22-233000).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022074NOA/12022074NOA_Closure%20Letter_01102023_(22-233000).pdf\n\n12022074NOA_Closure Letter_01102023_(22-233000)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022074NOA/12022074NOA_Closure%20Letter_01102023_(22-233000)_text.pdf\n\n12022074NOA_Notice of Amendment_11172022_(22-233000).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022074NOA/12022074NOA_Notice%20of%20Amendment_11172022_(22-233000).pdf\n\n12022074NOA_Notice of Amendment_11172022_(22-233000)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022074NOA/12022074NOA_Notice%20of%20Amendment_11172022_(22-233000)_text.pdf\n\n12022074NOA_Operator Response to Notice_01032023_(22-233000).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022074NOA/12022074NOA_Operator%20Response%20to%20Notice_01032023_(22-233000).pdf\n\n12022074NOA_Closure Letter_01102023_(22-233000)_text.pdf\n\nVIA ELECTRONIC MAIL TO: meissner@unitil.com\nJanuary 10, 2023\nMr. Thomas Meissner\nPresident and Chief Executive Officer\nGranite State Gas Transmission Inc.\n6 Liberty Lane W\nHampton, New Hampshire 03842\nCPF 1-2022-074-NOA\nDear Mr. Meissner:\nOn July 11, 2022, through July 15, 2022, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of inspected Granite State Gas Transmission Inc.’s\n(Granite) procedures. As a result of the inspection, Granite was issued a Notice of Amendment on\nNovember 17, 2022, which proposed amendment of your procedures.\nGranite submitted its amended procedures on January 3, 2023. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n12022074NOA_Notice of Amendment_11172022_(22-233000)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nNovember 17, 2022\nMr. Thomas Meissner\nPresident and Chief Executive Officer\nGranite State Gas Transmission Inc.\n6 Liberty Lane W\nHampton, New Hampshire 03842\nCPF 1-2022-074-NOA\nDear Mr. Meissner:\nFrom July 11, 2022, through July 15, 2022, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\nvirtually inspected Granite State Gas Transmission Inc.’s (Granite) procedures for operations and\nmaintenance.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nGranite’s plans or procedures, as described below:\n1. § 192.605 Procedural manual for operations, maintenance, and emergencies\n(a) …\n(b) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following,\nif applicable, to provide safety during maintenance and operations.\n(1) …\n(8) Periodically reviewing the work done by operator personnel to\ndetermine the effectiveness, and adequacy of the procedures used in\nnormal operation and maintenance and modifying the procedures\nwhen deficiencies are found.\nGranite’s manual of written procedures was inadequate to ensure safe operation of a pipeline\nfacility. Specifically, Granite failed to include procedures for periodically reviewing the work\n\n\n\ndone by operator personnel to determine the effectiveness, and adequacy of the procedures used\nin normal operation and taking corrective action where deficiencies are found.\nDuring the inspection, PHMSA reviewed Granite’s Operations and Maintenance Manual Selected\nTopics Version 14.0, dated 06/17/2022 (O&M Manual). Granite’s O&M Manual, Section\n10.01.03 O&M - Plan Administration, subsection 3.1 – Plans: General, stated that observation of\npersonnel performing work defined in the O&M Manual will be performed, and this QA/QC will\nbe performed periodically. However, the O&M Manual failed to provide sufficient detail\nregarding who performs the review, how often the review is done, and how the review will be\ndocumented.\nTherefore, Granite’s written procedures were inadequate. Granite must revise its procedures to\nprovide sufficient detail regarding § 192.605(b)(8).\n2. § 192.605 Procedural manual for operations, maintenance, and emergencies\n(a) …\n(c) Abnormal operation. For transmission lines, the manual\nrequired by paragraph (a) of this section must include procedures for\nthe following to provide safety when operating design limits have been\nexceeded:\n(1) …\n(4) Periodically reviewing the response of operator personnel to\ndetermine the effectiveness of the procedures controlling abnormal\noperation and taking corrective action where deficiencies are found.\nGranite’s manual of written procedures was inadequate to ensure safe operation of a pipeline\nfacility. Specifically, Granite failed to include procedures for periodically reviewing work done\nby operator personnel to determine the effectiveness, and adequacy of the procedures used in\nabnormal operation and taking corrective action where deficiencies are found.\nDuring the inspection, PHMSA reviewed Granite’s O&M Manual, Section 220.05.03 - Abnormal\nOperations, subsection 3.1.4 - Reviewing Responses to an Abnormal Operation. The O&M\nManual failed to provide sufficient detail regarding who performs the review, how often the review\nis done, and how the review will be documented.\nTherefore, Granite’s written procedures were inadequate. Granite must revise its procedures to\nprovide sufficient detail regarding § 192.605(c)(4).\n3. § 192.605 Procedural manual for operations, maintenance, and emergencies\n(a) …\n(d) Safety-related condition reports. The manual required by\nparagraph (a) of this section must include instructions enabling\npersonnel who perform operation and maintenance activities to\nrecognize conditions that potentially may be safety-related conditions\nthat are subject to the reporting requirements of § 191.23 of this\nsubchapter.\n\n\n\nGranite’s manual of written procedures was inadequate to ensure safe operation of a pipeline\nfacility. Specifically, Granite’s O&M Manual did not provide any instructions enabling personnel\nwho perform operation and maintenance activities to recognize conditions that potentially may be\nsafety-related conditions (SRCs) pursuant to § 192.605(d).\nDuring the inspection, PHMSA requested Granite’s procedure(s) regarding recognizing SRCs.\nGranite provided its O&M Manual and referenced Section 220.005.002 - Safety Related Condition\nIdentification. This procedure identified a list of potential SRCs as defined in § 191.23. However,\nthis procedure failed to reference, provide any specific guidance, or instruct operations and\nmaintenance personnel on how to recognize potential SRCs.\nTherefore, Granite’s written procedures were inadequate. Granite must revise its procedures to\nenable personnel to recognize conditions that may be SRCs in accordance with § 192.605(d).\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. 552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 30 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Granite State Gas Transmission Inc. maintain documentation\nof the safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director,\nEastern Region, Pipeline and Hazardous Materials Safety Administration, 840 Bear Tavern Road,\nSuite 300, West Trenton, NJ 08628. In correspondence concerning this matter, please refer to CPF\n1-2022-074-NOA and, for each document you submit, please provide a copy in electronic format\nwhenever possible. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should\n\n\n\nbe sent on USB flash drive accompanied by the original paper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings","truncated":false,"body_characters":10238}