# TUSCARORA GAS TRANSMISSION COMPANY — Notice of Amendment

- **operation:** document
- **citation:** CPF 12026024NOA
- **title:** TUSCARORA GAS TRANSMISSION COMPANY — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2026-03-16
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 192.605(b)(1).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-12026024noa.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-12026024noa.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-12026024noa
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/12026024NOA
**body:**

Notice of Amendment involving TUSCARORA GAS TRANSMISSION COMPANY. PHMSA's enforcement data identifies the cited regulation as 192.605(b)(1). The case was opened on 2026-03-16 and is reported as closed as of 2026-07-07. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

12026024NOA_Closure Letter_07072026_(24-296052).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026024NOA/12026024NOA_Closure%20Letter_07072026_(24-296052).pdf

12026024NOA_Closure Letter_07072026_(24-296052)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026024NOA/12026024NOA_Closure%20Letter_07072026_(24-296052)_text.pdf

12026024NOA_Notice of Amendment_03162026_(24-296052).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026024NOA/12026024NOA_Notice%20of%20Amendment_03162026_(24-296052).pdf

12026024NOA_Notice of Amendment_03162026_(24-296052)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026024NOA/12026024NOA_Notice%20of%20Amendment_03162026_(24-296052)_text.pdf

12026024NOA_Operator Response to Notice_04142026_(24-296052).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026024NOA/12026024NOA_Operator%20Response%20to%20Notice_04142026_(24-296052).pdf

12026024NOA_Notice of Amendment_03162026_(24-296052)_text.pdf

U.S. Department
of Transportation
Pipeline and
Hazardous Materials
Safety Administration
840 Bear Tavern Road, Suite 300
West Trenton, NJ 08628
609.771.7800
NOTICE OF AMENDMENT
VIA EMAIL TO: david_brast@tcenergy.com
March 16, 2026
David Brast
President/Chief Executive Officer
Tuscarora Gas Transmission Company
700 Louisiana St.
Houston, TX 77002
CPF 1-2026-024-NOA
Dear Mr. Brast:
From April 1 through December 2, 2024, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA), Office of Pipeline Safety (OPS), Eastern Region, pursuant to
Chapter 601 of 49 United States Code (U.S.C.) inspected Tuscarora Gas Transmission Company’s
(Tuscarora or Respondent) procedures.1
As a result of the inspection, Eastern Region has identified an apparent inadequacy in Tuscarora’s
plans or procedures. The alleged inadequacy and proposed revision are described below:
1. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) …
(b) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following,
if applicable, to provide safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in
accordance with each of the requirements of this subpart and subpart
M of this part.
1 Tuscarora is a subsidiary of TC Energy.



CPF 1-2026-024-NOA
Tuscarora’s procedures for maintenance and normal operations were inadequate to assure safe
operation of a pipeline facility in accordance with section 192.605(b)(1). Specifically, Tuscarora’s
procedure, Valve and Valve Actuator Inspection and Servicing, Rev. 03 (04/01/2024) (Valve
Servicing Procedure), failed to include sufficient details regarding valve maintenance.
During the inspection, the Eastern Region inspector determined that Tuscarora’s Valve Servicing
Procedure (designated for US use) improperly referenced a “Canada-only” document—the
Canada Gas Valve Sealant and Sealant Guns Procedure (CAN), Rev.-01, (Approved Lubricant
Procedure)—for its approved list of valve lubricants. Furthermore, Tuscarora admitted that field
technicians in practice rely on an unreferenced, laminated “Approved Lubricant Card” to perform
this work. Tuscarora confirmed this card is an uncontrolled document containing no official title,
revision history, or date, demonstrating a failure to adhere to established document control and
procedural guidelines.
Finally, the Valve Servicing Procedure in section 1.2.6 directs Tuscarora to “re-energize a stem
seal with a small amount of grease” and refers the reader to use “OEM specifications” to select the
correct grease. However, the procedure failed to provide guidance on where to obtain OEM
specifications.
Therefore, Tuscarora’s procedures for maintenance and normal operations were inadequate to
assure safe operation of a pipeline facility in accordance with section 192.605(b)(1). Eastern
Region proposes that Tuscarora revise its procedures to address the above inadequacies.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 CFR § 190.206. Respondent must
respond as set forth below.
Please review the enclosed Response Options for Pipeline Operators in Enforcement Proceedings.
Respondent must respond to this Notice within 30 days of receipt. The Region Director may extend
this period upon receipt of a timely written request demonstrating good cause. Failure to respond
within 30 days (or by the extended deadline) constitutes a waiver of the right to contest the
allegations in the Notice and authorizes the Associate Administrator for Pipeline Safety, without
further notice to the Respondent, to find the facts as alleged in the Notice and to issue an Order
Directing Amendment. If Respondent’s plans or procedures are found inadequate as alleged in this
Notice, Respondent will be ordered to amend its plans or procedures to correct the inadequacies.
Once the inadequacies identified herein have been addressed in amended procedures, this
enforcement action will be closed.
All material submitted in response to this enforcement action may be made publicly available. If
Respondent believes that any portion of the responsive material qualifies for confidential treatment
under 5 U.S.C. § 552(b), along with the complete original document, it must provide a second
copy of the document with the portions that may qualify for confidential treatment redacted and
an explanation of why the redacted information may qualify for confidential treatment under 5
U.S.C. § 552(b).
Page 2 of 3



CPF 1-2026-024-NOA
PHMSA requests that Respondent maintain documentation of the safety improvement costs
associated with fulfilling this Notice (preparation/revision of plans and procedures) and submit the
total to the Region Director.
In correspondence on this matter, please refer to CPF 1-2026-024-NOA.
Sincerely,
Robert Burrough
Director, Eastern Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Dan Cerkoney, Sr. Manager, Regulatory Compliance, dan_cerkoney@tcenergy.com
Amy Willis, Director, Regulatory Compliance, amy_willis@tcenergy.com
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
Page 3 of 3

12026024NOA_Closure Letter_07072026_(24-296052)_text.pdf

U.S. Department
of Transportation
Pipeline and
Hazardous Materials
Safety Administration
840 Bear Tavern Road, Suite 300
West Trenton, New Jersey 08628
609.771.7800
VIA ELECTRONIC MAIL TO: david_brast@tcenergy.com
July 7, 2026
David Brast
President/Chief Executive Officer
Tuscarora Gas Transmission Company
700 Louisiana St.
Houston, TX 77002
CPF 1-2026-024-NOA
Dear Mr. Brast:
From April 1 through December 2, 2024, a representative from the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,
conducted an on-site pipeline safety inspection of Tuscarora Gas Transmission Company’s
(Tuscarora) procedures in Houston, Texas. As a result of the inspection, PHMSA issued Tuscarora
was issued a Notice of Amendment (NOA) on March 16, 2026, proposing modifications to your
procedures.
Tuscarora responded with proposed amendments on April 14, 2026 and submitted its amended
procedures on July 1, 2026. My staff has reviewed the amended procedures and determined that
the inadequacies outlined in this NOA have been corrected.
This letter is to inform you that no further action is necessary and this case is now closed. Thank
you for your cooperation.
Sincerely,
Robert Burrough
Director, Eastern Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration



cc: Dan Cerkoney, Sr. Manager, Regulatory Compliance, dan_cerkoney@tcenergy.com
Amy Willis, Director, Regulatory Compliance, amy)willis@tcenergy.com
5.9 Sample NOA Closure Letter (7/5/95)
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