{"operation":"document","citation":"CPF 12026018NOA","title":"GREAT LAKES GAS TRANSMISSION LIMITED PARTNERSHIP — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2026-05-04","effective_on":null,"summary":"OPEN notice of amendment citing 192.605(a), 192.605(b)(2), 192.631(c)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026018noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026018noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026018noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12026018NOA","body":"Notice of Amendment involving GREAT LAKES GAS TRANSMISSION LIMITED PARTNERSHIP. PHMSA's enforcement data identifies the cited regulations as 192.605(a),  192.605(b)(2),  192.631(c)(3). The case was opened on 2026-05-04 and is reported as open. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12026018NOA_Notice of Amendment_05042026_(25-329585).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026018NOA/12026018NOA_Notice%20of%20Amendment_05042026_(25-329585).pdf\n\n12026018NOA_Notice of Amendment_05042026_(25-329585)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026018NOA/12026018NOA_Notice%20of%20Amendment_05042026_(25-329585)_text.pdf\n\n12026018NOA_Operator Response to Notice_06032026_(25-329585).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026018NOA/12026018NOA_Operator%20Response%20to%20Notice_06032026_(25-329585).pdf\n\n12026018NOA_Notice of Amendment_05042026_(25-329585)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials\nSafety Administration\n840 Bear Tavern Road, Suite 300\nWest Trenton, New Jersey 08628\n609.771.7800\nNOTICE OF AMENDMENT\nVIA EMAIL TO: david_brast@tcenergy.com\nMay 4, 2026\nMr. David Brast,\nPresident, US Natural Gas Pipelines\nGreat Lakes Gas Transmission\n700 Louisiana Street\nHouston, Texas 77002\nCPF 1-2026-018-NOA\nDear Mr. Brast:\nFrom March 18 through December 3, 2025, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), Eastern Region,\npursuant to Chapter 601 of Title 49 United States Code (U.S.C.), inspected Great Lakes Gas\nTransmission LP’s (GLGT) procedures, records, and facilities in Minnesota, Michigan, and\nWisconsin.\nAs a result of the inspection, Eastern Region has identified apparent inadequacies found within\nGLGT’s plans or procedures. The alleged inadequacies are described below:\n1. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each\npipeline, a manual of written procedures for conducting operations and\nmaintenance activities and for emergency response. For transmission\nlines, the manual must also include procedures for handling abnormal\noperations. This manual must be reviewed and updated by the operator\nat intervals not exceeding 15 months, but at least once each calendar\nyear. This manual must be prepared before operations of a pipeline\n\n\n\nCPF 1-2026-018-NOA\nsystem commence. Appropriate parts of the manual must be kept at\nlocations where operations and maintenance activities are conducted.\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(2) Controlling corrosion in accordance with the operations and\nmaintenance requirements of subpart I of this part.\nGLGT’s manual of written procedures were inadequate to ensure safe operation of a pipeline\nfacility. Specifically, GLGT's procedure, TES-CO-EPU-GL Field Applied External Coating\n(CAN-US-MEX) Rev 18 (05/01/2023) (Coatings Procedure), failed to include procedures for\ncontrolling corrosion in accordance with the operations and maintenance requirements of subpart\nI of Part 192, as required by section 192.605(b)(2).\nDuring the inspection, the Eastern Region inspector reviewed the Coatings Procedure. The\nCoatings Procedure outlined approved coating materials in section 2.4, which referred to Table 2-\n1 for company-approved external liquid coatings. Table 2-1 specified that abrasive service required\na higher dry film thickness than non-abrasive service. The Coatings Procedure defined abrasive\nservice, but the definition lacked specificity as it did not utilize quantitative criteria to define\nabrasive service conditions.\nFurther, the procedure failed to clearly define the party responsible for determining when an\nabrasive service coating is required. Section 2.1.10 of the Coatings Procedure required that the\nCoating Applicator submit an Inspection and Test Plan (ITP) for review of the supply and\napplication of coating materials before starting work. The ITP was to be reviewed by either the\nCompany Coating Inspector or the Company Coating SME. It is unclear in the Coatings Procedure\nwhether either of these parties are responsible for determining whether abrasive service coatings\nare required.\nTherefore, GLGT's manual of written procedures were inadequate to ensure safe operation of a\npipeline facility. Eastern Region proposes that GLGT revise its procedures to address the above\ndeficiency.\n2. § 192.631 Control room management.\n(a) …\n(c) Provide adequate information. Each operator must provide its\ncontrollers with the information, tools, processes and procedures\nnecessary for the controllers to carry out the roles and responsibilities\nthe operator has defined by performing each of the following:\n(1) …\n(3) Test and verify an internal communication plan to provide\nadequate means for manual operation of the pipeline safely, at least\nonce each calendar year, but at intervals not to exceed 15 months;\nPage 2 of 4\n\n\n\nCPF 1-2026-018-NOA\nGLGT’s written procedures were inadequate to ensure safe operation of a pipeline facility.\nSpecifically, GLGT's procedure, TC Energy West – Manual Pipeline Operations Procedure (US)\nRev 13 (11/1/2024) (Manual Operations Procedure), failed to include the information necessary to\ntest and verify its internal communication plan to provide adequate means for manual operation of\nthe pipeline safely in accordance with section 192.631(c)(3).\nDuring the inspection, the Eastern Region inspector reviewed the Manual Operations Procedure.\nSection 1.10 of the Manual Operations Procedure required controllers to record operational\ninformation on Manual Operations Logs (Form). The Manual Operations Procedure specified the\nlocation of the Form, but failed to specify the required format of the Form and failed to specify\nwhat information the Form must include. The Manual Operations Procedure also does not require\nthe Form to be classified as a controlled document that would be subjected to the required annual\nreview cycle.\nTherefore, GLGT's written procedures were inadequate to ensure safe operation of a pipeline\nfacility in accordance with section 192.631(c)(3). Eastern Region proposes that GLGT revise its\nprocedures to address the above deficiency.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 CFR § 190.206. Enclosed as part\nof 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 submit\nin response to this enforcement action is subject to being made publicly available. If you believe\nthat any portion of your responsive material qualifies for confidential treatment under 5 U.S.C.\n§ 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 49 CFR § 190.211. If you do not respond within 30\ndays of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in\nthis Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged\nin this Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 CFR § 190.206). If you are not contesting\nthis Notice, 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.\nPage 3 of 4\n\n\n\nCPF 1-2026-018-NOA\nIt is requested (not mandated) that Respondent maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to the Director, Eastern Region, Pipeline and Hazardous Materials\nSafety Administration, Office of Pipeline Safety. In correspondence concerning this matter, please\nrefer to CPF 1-2026-018-NOA and, for each document you submit, please provide a copy in\nelectronic format whenever possible.\nSincerely,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: Amy Willis, Director, US Regulatory Compliance, GLGT, amy_willis@tcenergy.com\nMike Murphy, Senior Manager, Pipeline Safety Compliance Governance and\nEngineering, mikej_murphy@tcenergy.com\nPage 4 of 4","truncated":false,"body_characters":9241}