# GREAT LAKES GAS TRANSMISSION CO — Warning Letter

- **operation:** document
- **citation:** CPF 320071001W
- **title:** GREAT LAKES GAS TRANSMISSION CO — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2007-01-09
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.905(c).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-320071001w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-320071001w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-320071001w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/320071001W
**body:**

Warning Letter involving GREAT LAKES GAS TRANSMISSION CO. PHMSA's enforcement data identifies the cited regulation as 192.905(c). The case was opened on 2007-01-09 and is reported as closed as of 2007-01-09. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320071001W_Warning Letter_01092007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320071001W/320071001W_Warning%20Letter_01092007.pdf

320071001W_Warning Letter_01092007.pdf

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Admlnlstrotion
901 Locusl Streel, Suite 462
Kansas City, MO 64106-2641
WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REOUESTEI)
January 9,2007
Mr. Mark R. Domke
Director of Engineering Services-Pipeline
Great Lakes Gas Transmission Company
5250 Corporate Drive
Troy, Michigan 48098
cPF 3-2007-1001W
Dear Mr. Domke:
On September 6-21,2006, a representative of the Minnesota Office of Pipeline Safety acting as
an Interstate Agent for the Pipeline and Hazardous Materials Safety Administration (PHMSA),
pursuant to Chapter 601 of 49 United States Code, inspected your records in Deer River, MN
and Troy, Michigan.
As a result of the inspection, it appears that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the
probable violation is:
1. $192.905(c) How does an operator identify a high consequence area?
(c) Newly identified areas. When an opeiator has information that the area around a
pipeline segment not previously identified as a high consequence area could satisff
any of the defrnitions in $ 192.903, the operator must complete the evaluation using
method (1) or (2). If the segment is determined to meet the definition as a high
consequence area, it must be incorporated into the operatorts baseline assessment
plan as a high consequenc€ area within one year from the date the area is identified.
Great Lakes Gas Transmission Company (GLGT) did not incorporate a high consequence area
(HCA) into its baseline assessment plan within one year from the date the HCA was



determined to exist. GLGT's personnel formally identified and documented the existence of
Tara's Family Day Cme Center at 758 1" Street West, in Deer River, MN, on July 26,2005.
GLGT's "Establishment in Vicinity of Right-of-way" form was completed by local personnel
and submitted to GLGT's offices in Troy, MI for evaluation. This site is a FICR that had not
been added to GLGT's list of HCAs for its baseline assessment plan, at the time of the
Minnesota Offrce of Pipeline Safety's September 6-21, 2006 inspection.
The process for evaluation of these forms and incorporation into the list of HCAs, if
appropriate, was found to be inadequate during the Integrity Management Inspection in July
and August of 2005 and cited as an item requiring revision in the Notice of Amendment dated
March 6, 2006. The procedure/process has been revised as ap'propriate; however, GLGT had
not yet determined that the subject HCA had not been included in its integrity management
plan. The baseline assessment segment that contains this new HCA will be assessed with an
ILI in 2007 along with the other HCAs previously identified in this segment. There appears to
be minimal safety concern in this specific case for the delay in identifying this HCA. Future
new HCAs should be incorporated as required with the implementation of the new procedure.
Under 49 United States Code, $ 60122, you are subject to a civil penalty not to exceed
$100,000 for each violation for each day the violation persists up to a maximum of $1,000,000
for any related series of violations. We have reviewed the circumstances and supporting
documents involved in this case, and have decided not to conduct additional enforcement
action or penalty assessment proceedings at this time. We advise you to correct the item(s)
identified in this letter. Be advised that failure to do so will result in Great Lakes Gas
Transmission Company being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer
to CPF 3-2007-t00lW.
Sincerelv.
fl n -t .L-
V,",-- U, /T/*"'.%-.,-
Ivan A. Huntoon
Director, Central Region
Pipeline and Hazardous Materials Safety Administration
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- **body characters:** 4354
