{"operation":"document","citation":"CPF 12024026WL","title":"GRANITE STATE GAS TRANSMISSION INC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-05-07","effective_on":null,"summary":"CLOSED warning letter citing 192.947(d).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024026wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024026wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024026wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12024026WL","body":"Warning Letter involving GRANITE STATE GAS TRANSMISSION INC. PHMSA's enforcement data identifies the cited regulation as 192.947(d). The case was opened on 2024-05-07 and is reported as closed as of 2024-05-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12024026WL_Warning Letter_05072024_(23-264045).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024026WL/12024026WL_Warning%20Letter_05072024_(23-264045).pdf\n\n12024026WL_Warning Letter_05072024_(23-264045)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024026WL/12024026WL_Warning%20Letter_05072024_(23-264045)_text.pdf\n\n12024026WL_Warning Letter_05072024_(23-264045)_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nMay 7, 2024\nMr. Thomas Meissner\nPresident and Chief Executive Officer\nGranite State Gas Transmission Inc\n6 Liberty Lane W.\nHampton, New Hampshire 03842\nCPF 1-2024-026-WL\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, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and\nthe probable violation is:\n1. § 192.947 What records must an operator keep?\nAn operator must maintain, for the useful life of the pipeline,\nrecords that demonstrate compliance with the requirements of this\nsubpart. At minimum, an operator must maintain the following records\nfor review during an inspection.\n(a) …\n(d) Documents to support any decision, analysis and process\ndeveloped and used to implement and evaluate each element of the\nbaseline assessment plan and integrity management program.\nDocuments include those developed and used in support of any\nidentification, calculation, amendment, modification, justification,\ndeviation and determination made, and any action taken to implement\nand evaluate any of the program elements;\n\n\n\nGranite State failed to maintain records to support any decision, analysis and process used to\nimplement and evaluate an element of its integrity management program. Specifically, Granite\nState failed to maintain in-line inspection assessment validation records in accordance with §\n192.947(d).\nDuring the inspection, PHMSA requested records regarding validation of in-line inspection\nassessments. Granite State provided its ID Smith Pipeline Engineering – Final Report Validations,\ndated 06/29/23 (Validation Reports) and ILI Assessment Spreadsheet, dated 06/29/23 (Assessment\nSpreadsheet). The Assessment Spreadsheet listed (11) total pipeline segments which required an\nin-line inspection as the last performed reassessment. Furthermore, the Assessment Spreadsheet\nwas not linked or referenced to the integrity management manual, nor was it included as part of its\nreview processes. The Validation Reports were applicable to only (5) of the (11) total assessments\nwhich were issued final reports dated from calendar year 2020 through 2023. The Validation\nReports, however, failed to include validation from each of the most recent assessment tool runs.\nWhen PHMSA asked where the validation reports were for the (6) missing pipeline segments:\nMaine South, New Hampshire South Extended, Gosling Road West, New Hampshire Portsmouth,\nNew Hampshire Pease Lateral and Maine North which dated as far back as 2017 assessment runs,\nGranite State discussed how they do not require any actions to be taken or any validation report to\nbe completed within a set timeframe.\nSubsequent to the inspection, Granite State stated that it is enhancing its ILI procedure to provide\nmore detail on the timeframes for the validation reports and that it anticipated obtaining additional\ndata for the Pease Lateral, NH South Extension, NH 8” Gas and Maine South. segments by the 3rd\nquarter of 2024.\nTherefore, Granite State failed to maintain records to support a decision, analysis, and process of\nan element of its integrity management plan, in accordance with § 192.947(d).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$266,015 per violation per day the violation persists, up to a maximum of $2,660,135 for a related\nseries of violations. For violation occurring on or after January 6, 2023 and before December 28,\n2023, the maximum penalty may not exceed $257,664 per violation per day the violation persists,\nup to a maximum of $2,576,627 for a related series of violations. For violation occurring on or\nafter March 21, 2022 and before January 6, 2023, the maximum penalty may not exceed $239,142\nper violation per day the violation persists, up to a maximum of $2,391,142 for a related series of\nviolations. For violation occurring on or after May 3, 2021 and before March 21, 2022, the\nmaximum penalty may not exceed $225,134 per violation per day the violation persists, up to a\nmaximum of $2,251,334 for a related series of violations. For violation occurring on or after\nJanuary 11, 2021 and before May 3, 2021, the maximum penalty may not exceed $222,504 per\nviolation per day the violation persists, up to a maximum of $2,225,034 for a related series of\nviolations. For violation occurring on or after July 31, 2019 and before January 11, 2021, the\nmaximum penalty may not exceed $218,647 per violation per day the violation persists, up to a\nmaximum 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.\n\n\n\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\nGranite State Gas Transmission Inc 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 1-2024-026-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\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","truncated":false,"body_characters":7003}