{"operation":"document","citation":"CPF 12024025NOA","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":"2024-06-04","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(1), 192.907(a), 192.919(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024025noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024025noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024025noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12024025NOA","body":"Notice of Amendment involving GRANITE STATE GAS TRANSMISSION INC. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(1),  192.907(a),  192.919(e). The case was opened on 2024-06-04 and is reported as closed as of 2024-07-25. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12024025NOA_Closure Letter_07252024_(23-264045).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024025NOA/12024025NOA_Closure%20Letter_07252024_(23-264045).pdf\n\n12024025NOA_Closure Letter_07252024_(23-264045)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024025NOA/12024025NOA_Closure%20Letter_07252024_(23-264045)_text.pdf\n\n12024025NOA_Notice of Amendment_06112024_(23-264045).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024025NOA/12024025NOA_Notice%20of%20Amendment_06112024_(23-264045).pdf\n\n12024025NOA_Notice of Amendment_06112024_(23-264045)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024025NOA/12024025NOA_Notice%20of%20Amendment_06112024_(23-264045)_text.pdf\n\n12024025NOA_Operator Response to Notice (Supplemental)_07122024_(23-264045).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024025NOA/12024025NOA_Operator%20Response%20to%20Notice%20(Supplemental)_07122024_(23-264045).pdf\n\n12024025NOA_Operator Response to Notice_07082024_(23-264045).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024025NOA/12024025NOA_Operator%20Response%20to%20Notice_07082024_(23-264045).pdf\n\n12024025NOA_Closure Letter_07252024_(23-264045)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJuly 25, 2024\nMr. Thomas Meissner\nPresident and Chief Executive Officer\nGranite State Gas Transmission Inc.\n6 Liberty Lane W\nHampton, New Hampshire 03842\nCPF 1-2024-025-NOA\nDear Mr. Meissner:\nFrom April 4, 2023 through June 2, 2023, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.)\nconducted an integrity management inspection of Granite State Gas Transmission Inc.’s (Granite\nState) procedures and records. As a result of the inspection, Granite State was issued a Notice of\nAmendment on June 11, 2024 requiring Granite State to amend certain aspects of its procedures.\nGranite State submitted its amended procedures on July 8, 2024. On July 12, 2024, Granite State\nsubmitted further information related to its procedural updates, per PHMSA request. My staff\nreviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of\nAmendment have been corrected.\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\n12024025NOA_Notice of Amendment_06112024_(23-264045)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nJune 11, 2024\nMr. Thomas Meissner\nPresident and Chief Executive Officer\nGranite State Gas Transmission Inc.\n6 Liberty Lane W\nHampton, New Hampshire 03842\nCPF 1-2024-025-NOA\nDear Mr. Meissner:\nFrom April 4, 2023 through June 2, 2023, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.),\nconducted an integrity management inspection of Granite State Gas Transmission Inc.’s (Granite\nState) procedures and records.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nGranite State’s plans or procedures. The items inspected and the inadequacies are described\nbelow:\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) Operating, maintaining, and repairing the pipeline in\naccordance with each of the requirements of this subpart and Subpart\nM of this part.\nGranite State’s procedures for maintenance and normal operations were inadequate. Specifically,\nGranite State’s Unitil Integrity Management Program – Section 3 Identification of Threats and\nRisk Assessment, dated 05/01/23 (IMP-3) and Analysis of Predicted Failure Pressure – 220.02.12,\ndated 12/16/22 (Failure Pressure) failed to include a process related to cracks that survive pressure\ntesting, per the requirements of § 192.712(d)(3).\n\n\n\nSection 192.712(d)(3) states:\n§ 192.712 Analysis of predicted failure pressure\n(a) ….\n(d) Cracks and crack-like defects –\n(1) ….\n(3) Cracks that survive pressure testing. For cases in which the operator does not have in-line\ninspection crack anomaly data and is analyzing potential crack defects that could have\nsurvived a pressure test, the operator must calculate the largest potential crack defect sizes\nusing the methods in paragraph (d)(1) of this section. If pipe material toughness is not\ndocumented in traceable, verifiable, and complete records, the operator must use one of the\nfollowing for Charpy v-notch toughness values based upon minimum operational temperature\nand equivalent to a full-size specimen value:\n(i) Charpy v-notch toughness values from comparable pipe with known properties of the same\nvintage and from the same steel and pipe manufacturer;\n(ii) A conservative Charpy v-notch toughness value to determine the toughness based upon\nthe material properties verification process specified in §192.607;\n(iii) A full size equivalent Charpy v- notch upper-shelf toughness level of 120 ft.-lbs.; or\n(iv) Other appropriate values that an operator demonstrates can provide conservative Charpy\nv-notch toughness values of the crack-related conditions of the pipeline segment. Operators\nDuring the inspection, PHMSA requested Granite State’s procedures on cracks that survive\npressure testing and calculations. Granite State provided the IMP-3 and Failure Pressure\nprocedures. The Failure Pressure procedure Section 3.2.2 stated in part:\nFor cases in which Unitil does not have inline inspection crack anomaly data and is analyzing\npotential crack defects that could have survived a pressure test, the Gas Engineer calculates\nthe largest potential crack defect sizes in accordance with IMP 3-3, SCC Evaluation\nProcedure. If pipe material toughness is not documented in TVC records as defined in\n220.02.09, MAOP Reconfirmation, the Gas Engineer uses one of the following for Charpy v-\nnotch toughness values based upon minimum operational temperature and equivalent to a full-\nsize specimen value:\n• Charpy v-notch toughness values from comparable pipe with known properties of the same\nvintage and from the same steel and pipe manufacturer\n• A conservative Charpy v-notch toughness value to determine the toughness based upon the\nmaterial properties verification process specified in 220.02.08, Material Verification Plan\n• A full size equivalent Charpy v-notch upper-shelf toughness level of 120 ft.-lbs.\n• Other appropriate values that Asset Integrity Engineers demonstrate can provide\nconservative Charpy v-notch toughness values of the crack-related conditions of the pipeline\nsegment.\nIf the Charpy v-notch toughness value is an assumed other appropriate value, Unitil notifies\nPHMSA in accordance with 220.05.06, Agency Notifications Normal.\nHowever, the Failure Pressure procedure reiterated § 192.712(d)(3) in its entirety. Failure Pressure\nfailed to describe any process related to crack analysis models that would be used in determining\n\n\n\nand calculating cracks that survive pressure testing. PHMSA asked Granite State where this\ninformation was documented and Granite State did not provide any additional information. After\nthe inspection, Granite State stated that it is making enhancements to the existing procedures and\ndeveloping a stress corrosion cracking plan.\nTherefore, Granite State’s procedures failed to include a process related to cracks that survive\npressure testing, in accordance with § 192.712(d)(3). Granite State must revise its procedures to\naddress this requirement.\n2. § 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) Operating, maintaining, and repairing the pipeline in\naccordance with each of the requirements of this subpart and Subpart\nM of this part.\nGranite State’s procedures for maintenance and normal operations were inadequate to ensure\npipeline safety. Specifically, Granite State’s Unitil Integrity Management Program – Section 3\nIdentification of Threats and Risk Assessment, dated 05/01/23 (IMP-3) and Analysis of Predicted\nFailure Pressure – 220.02.12, dated 12/16/22 (Failure Pressure) failed to include a process for\nevaluating crack like defects to ensure that a determination of the predicted failure pressure and\nthe remaining life of the pipeline segment is established at the location of each anomaly or defect,\nper the requirements of § 192.712(d)(1).\nSection 192.712(d)(1) states:\n§ 192.712 Analysis of predicted failure pressure\n(a)….\n(d) Cracks and crack-like defects –\n(1) Crack analysis models. When analyzing cracks and crack-like defects under this section,\nan operator must determine predicted failure pressure, failure stress pressure, and crack\ngrowth using a technically proven fracture mechanics model appropriate to the failure mode\n(ductile, brittle or both), material properties (pipe and weld properties), and boundary\ncondition used (pressure test, ILI, or other)\nDuring the inspection, PHMSA requested Granite State’s procedures on evaluating crack defects\npursuant to § 192.712(d)(1). Granite State provided the IMP-3 and Failure Pressure procedures.\nFailure Pressure Section 3.2 stated in part:\nUnitil repairs cracks on site upon discovery in the field unless extenuating circumstances exist.\nWhen analyzing cracks and crack-like defects, the Gas Engineer or designee determines\npredicted failure pressure, failure stress pressure, and crack growth using a technically proven\nfracture mechanics model appropriate to the failure mode (ductile, brittle or both), material\nproperties (pipe and weld properties), and boundary condition used (pressure test, ILI, or other).\n\n\n\nHowever, the Failure Pressure procedure reiterated § 192.712(d)(1) in its entirety. Failure Pressure\nfailed to describe any process related to how cracks would be analyzed, or any details related to a\ncrack analysis model that would be used. When PHMSA asked Granite State where this\ninformation was documented and Granite State stated it is not aware of how it makes\ndeterminations for cracks or crack like defects. After the inspection, Granite State stated that it\nwill be enhancing the procedures and developing a plan focused on the evaluation of cracks and\ncrack like defects and establishing a baseline susceptibility plan.\nTherefore, Granite State’s procedures failed to include a process for evaluating crack like defects\nto ensure that a determination of the predicted failure pressure and the remaining life of the pipeline\nsegment is established at the location of each anomaly or defect, in accordance with §\n192.712(d)(1). Granite State must revise its procedures to address this requirement.\n3. § 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) Operating, maintaining, and repairing the pipeline in\naccordance with each of the requirements of this subpart and Subpart\nM of this part.\nGranite State’s procedures for maintenance and normal operations were inadequate to ensure\npipeline safety. Specifically, Granite State’s Analysis of Predicted Failure Pressure – 220.02.12,\ndated 12/16/22 (Failure Pressure) failed to include a process for collecting, creating and retaining\nrecords pursuant to § 192.712(g), including records related to all investigations and analyses of\npredicted or assumed anomalies or defects, per the requirements of § 192.605(a).\nSection 192.712(g) requires operators to maintain specific records for the life of the pipeline\nrelated to the investigations, analyses, and other actions taken in accordance with the requirements\nof § 192.712.\nDuring the inspection, PHMSA requested Granite State’s procedures on collecting and retaining\nrecords, including those related to analyses of anomalies or defects. Granite State provided the\nFailure Pressure procedures. The Failure Pressure procedure Section 5.0 stated in part:\nUnitil keeps records of the investigations, analyses, and other actions taken for the life of the\npipeline. Records document justifications, deviations, and determinations made for the\nfollowing, as applicable:\n• The technical approach used for the analysis\n• All data used and analyzed\n• Pipe and weld properties\n• Procedures used\n• Evaluation methodology used\n• Models used\n• Direct in situ examination data\n\n\n\n• In-line inspection tool run information evaluated, including any multiple in-line inspection\ntool runs\n• Pressure test data and results\n• In-the-ditch assessments\n• All measurement tool, assessment, and evaluation accuracy specifications and tolerances used\nin technical and operational results\n• All finite element analysis results\n• The number of pressure cycles to failure, the equivalent number of annual pressure cycles,\nand the pressure cycle counting method\n• The predicted fatigue life and predicted failure pressure from the required fatigue life models\nand fracture mechanics evaluation methods\n• Safety factors used for fatigue life and/or predicted failure pressure calculations\n• Reassessment time interval and safety factors\n• The date of the review\n• Confirmation of the results by qualified technical subject matter experts\n• Approval by responsible operator management personnel\nHowever, the Failure Pressure procedure reiterated § 192.712(g) in its entirety. Failure Pressure\nfailed to describe any process related to how and where records are retained, as well as details on\nthe collection, creation and retention of records related to investigations and analyses. PHMSA\nasked Granite State where this information was documented and Granite State stated that the\nprocess is done through training. However, nothing is noted in the procedure for how this process\nis conducted. After the inspection, Granite State stated that it will be enhancing the procedures to\naddress the process for managing and retaining all documents and records generated during any\nsusceptibility study, analysis, or engineering assessment.\nTherefore, Granite State’s procedures failed to include a process related to retaining records\npursuant to § 192.712(g), in accordance with § 192.605(a). Granite State must revise its\nprocedures to address this requirement.\n4. § 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) Operating, maintaining, and repairing the pipeline in\naccordance with each of the requirements of this subpart and Subpart\nM of this part.\nGranite State’s procedures for maintenance and normal operations were inadequate to ensure\npipeline safety. Specifically, Granite State’s Unitil Integrity Management Program – Section 3\nIdentification of Threats and Risk Assessment, dated 05/01/23 (IMP-3) and Analysis of Predicted\nFailure Pressure – 220.02.12, dated 12/16/22 (Failure Pressure) failed to include a process related\nto the performance of fatigue analysis and remaining life calculations for pipeline segments\nsusceptible to cyclic fatigue or other loading conditions that could lead to fatigue crack growth,\nper the requirements of § 192.712(d)(2).\n\n\n\nSection 192.712(d)(2) states:\n§ 192.712 Analysis of predicted failure pressure\n(a)….\n(d) Cracks and crack-like defects –\n(1) ….\n(2) Analysis for crack growth and remaining life. If the pipeline segment is susceptible to\ncyclic fatigue or other loading conditions that could lead to fatigue crack growth, fatigue\nanalysis must be performed using an applicable fatigue crack growth law (for example, Paris\nLaw) or other technically appropriate engineering methodology. For other degradation\nprocesses that can cause crack growth, appropriate engineering analysis must be used. The\nabove methodologies must be validated by a subject matter expert to determine conservative\npredictions of flaw growth and remaining life at the maximum allowable operating pressure.\nThe operator must calculate the remaining life of the pipeline by determining the amount of\ntime required for the crack to grow to a size that would fail at maximum allowable operating\npressure.\nDuring the inspection, PHMSA requested Granite State’s procedures on its analysis for crack\ngrowth and remaining life. Granite State provided the IMP-3 and Failure Pressure procedures.\nFailure Pressure Section 3.2 stated in part:\nIf the pipeline segment is susceptible to cyclic fatigue or other loading conditions that could\nlead to fatigue crack growth, fatigue analysis is performed using an applicable fatigue crack\ngrowth law (for example, Paris Law) or other technically appropriate engineering\nmethodology. Cyclic fatigue susceptibility is determined by employing the Cyclic Fatigue\nSusceptibility Determination Form. For other degradation processes that can cause crack\ngrowth, appropriate engineering analysis must be used. The above methodologies must be\nvalidated by a subject matter expert to determine conservative predictions of flaw growth and\nremaining life at the maximum allowable operating pressure. The operator must calculate the\nremaining life of the pipeline by determining the amount of time required for the crack to grow\nto a size that would fail at maximum allowable operating pressure.\nHowever, the Failure Pressure procedure reiterated § 192.712(d)(2) in its entirety. Failure Pressure\nfailed to describe any process related to how an analysis for crack growth and remaining life is\ncalculated, or any details related to an appropriate engineering methodology to be used. PHMSA\nasked Granite State where this information was documented and Granite State stated that, if\nneeded, it would send out to a contractor for review to conduct an analysis. After the inspection,\nGranite State stated that it is making enhancements to the existing procedures and developing a\nstress corrosion cracking plan.\nTherefore, Granite State’s procedures failed to include a process related to the performance of\nfatigue analysis and remaining life calculations for pipeline segments susceptible to cyclic fatigue,\nor other loading conditions that could lead to fatigue crack growth, in accordance with §\n192.712(d)(2). Granite State must revise its procedures to address this requirement.\n\n\n\n5. § 192.907 What must an operator do to implement this subpart?\n(a) General. No later than December 17, 2004, an operator of a\ncovered pipeline segment must develop and follow a written integrity\nmanagement program that contains all the elements described in §\n192.911 and that addresses the risks on each covered transmission\npipeline segment. The initial integrity management program must\nconsist, at a minimum, of a framework that describes the process for\nimplementing each program element, how relevant decisions will be\nmade and by whom, a time line for completing the work to implement\nthe program element, and how information gained from experience will\nbe continuously incorporated into the program. The framework will\nevolve into a more detailed and comprehensive program. An operator\nmust make continual improvements to the program.\nGranite State’s integrity management program procedures were inadequate to ensure pipeline\nsafety. Specifically, Granite State’s Unitil Integrity Management Program – Section 4 Integrity\nAssessment Plan, dated 05/01/23 (IMP-4) failed to include details on gathering and integrating\nexisting data and information on its pipelines, per the requirements of § 192.917(b).\nSection 192.917(b) states:\n(b) Data gathering and integration. To identify and evaluate the potential threats to a covered\npipeline segment, an operator must gather and integrate existing data and information on the\nentire pipeline that could be relevant to the covered segment. In performing this data gathering\nand integration, an operator must follow the requirements in ASME/ANSI B31.8S, section 4.\nAt a minimum, an operator must gather and evaluate the set of data specified in Appendix A\nto ASME/ANSI B31.8S, and consider both on the covered segment and similar non-covered\nsegments, past incident history, corrosion control records, continuing surveillance records,\npatrolling records, maintenance history, internal inspection records and all other conditions\nspecific to each pipeline.\nASME/ANSI B31.8S Section 4.4 states:\nA plan for collecting, reviewing and analyzing the data shall be created and in place from the\nconception of the data collection effort. These processes are needed to verify the quality and\nconsistency of the data.\nDuring the inspection, PHMSA requested Granite State’s procedures on collecting, gathering, and\nintegrating in-line inspection data. Granite State provided the IMP-4. The IMP-4 Section 8 stated\nin part, “the ILI Consultant integrates the ILI results with historical ILI and operations data in order\nto align the data.”\nHowever, the IMP-4 failed to describe any processes or details regarding how/when Granite State\nconducts this analysis, as well as how Granite State integrates in-line inspection data amongst its\nvarious programs. PHMSA asked Granite State where this information was documented and\nGranite State stated that its process does not explicitly state instructions or further guidance. After\nthe inspection, Granite State stated that the Company is in the process of enhancing the IMP 4-2\n\n\n\nILI procedures to include detailing the integration of the ILI run data with operations data, defining\nrequirements and vendor expectations, and expanding the detail associated with validating and\naccepting an ILI run.\nTherefore, Granite State’s integrity management procedures failed to include details on gathering\nand integrating existing data and information on its pipelines, in accordance with § 192.917(b).\nGranite State must revise its procedures to address this requirement.\n6. § 192.919 What must be in the baseline assessment plan?\nAn operator must include each of the following elements in its\nwritten baseline assessment plan:\n(a) ….\n(e) A procedure to ensure that the baseline assessment is being\nconducted in a manner that minimizes environmental and safety risks.\nGranite State’s written baseline assessment plan required by § 192.919 was inadequate to ensure\npipeline safety. Specifically, Granite State’s Environmental Impact and Safety Risk, dated\n05/01/23 (IMP-15), OEP-129 – Inline Inspection Procedures, dated 05/02/23 (OEP-129) and ECS\n– Environmental Construction Standards, dated 05/02/23 (ECS) failed to include a process to\nensure the baseline assessment is being conducted in a manner that minimizes environmental and\nsafety risks, per the requirements of § 192.919(e).\nDuring the inspection, PHMSA requested the procedures regarding conducting integrity\nassessments in a manner that minimizes environmental and safety risks. Granite State provided\nthe IMP-15 and ECS. The IMP-15 Section 15.3 - 15.4 stated in part:\n15.3 Environmental Impact\nAll baseline assessments, reassessments and remediation activities shall be performed in\naccordance with Environmental Construction Standards, which are designed to minimize\nenvironmental impact. These Environmental Construction Standards are located in the Granite\nO&M Manual and constitute the minimum requirements that must be followed and may be\nsupplemented with more stringent requirements based on specific assessment project locations\nand permits.\n15.4 Protection from Safety Hazards\nDuring baseline assessment, reassessment and remediation activities, precautions will be\nimplemented to protect workers and members of the public from safety hazards in accordance\nwith Granite’s existing plans and procedures. Such precautions include but are not limited to\nnotifying emergency response personnel of planned activities as appropriate, and notifying\nlandowners and/or occupants of activities along the pipeline that may require precautionary\nmeasures prior to commencing work on or along the pipeline.\nHowever, the IMP-15 failed to contain any specific processes or details on how Granite State\nensures the baseline assessment is being conducted in a manner that minimizes environmental and\nsafety risks. The IMP-15 failed to mention any processes related to pig launcher/receiver safety,\nor completion of any job safety and hazard analysis forms. Furthermore, the language used\n\n\n\nthroughout the OEP-129 and ECS contains numerous “should” statements, which do not mandate\nany specific action to be done regarding minimizing environmental and safety risks and therefore\nare not a requirement. The relevant sections of the OEP-129 and ECS must be modified to include\nthe applicable “shall” statements in lieu of should statements, in order to ensure these are\nrequirements.\nPHMSA asked Granite State where this information was documented and Granite State did not\nprovide any additional information. After the inspection, Granite State stated that “the Company’s\nIMP-15 Section 2.0 covers the requirements for conducting integrity assessments in a manner that\nminimizes environmental and safety risks.” However, the language used in IMP-15 Section 2.0\ndoes not require any specific processes or actions to be conducted.\nTherefore, Granite State’s procedures failed to include a process to ensure the baseline assessment\nis being conducted in a manner that minimizes environmental and safety risks, in accordance with\n§ 192.919(e). Granite State must revise its procedures to address this requirement.\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\nthe document 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 of\nthe 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. In correspondence\nconcerning this matter, please refer to CPF 1-2024-025-NOA and, for each document you submit,\n\n\n\nP.P.\nplease provide a copy in electronic format whenever possible.\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":28837}