{"operation":"document","citation":"CPF 320131014W","title":"GREAT LAKES GAS TRANSMISSION CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-08-19","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a), 192.707(d)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320131014w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320131014w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320131014w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320131014W","body":"Warning Letter involving GREAT LAKES GAS TRANSMISSION CO. PHMSA's enforcement data identifies the cited regulations as 192.605(a),  192.707(d)(1). The case was opened on 2013-08-19 and is reported as closed as of 2013-08-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320131014W_Warning Letter_08192013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320131014W/320131014W_Warning%20Letter_08192013.pdf\n\n320131014W_Warning Letter_08192013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320131014W/320131014W_Warning%20Letter_08192013_text.pdf\n\n320131014W_Warning Letter_08192013_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 19, 2013\nMr. Vern Meier\nVice President, Field Operations\nTransCanada, Great Lakes Gas Transmission\n717 Texas Avenue, Suite 2400\nHouston, Texas 77002-2761\nCPF 3-2013-1014W\nDear Mr. Meier:\nOn May 14 – May 18, July 30 – August 2, September 17 - 25, October 4 and November 2,\n2012, representatives of the Michigan Public Service Commission (MI-PSC) and the\nMinnesota Office of Pipeline Safety (MNOPS) acting as interstate agents the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49\nUnited States Code inspected your pipeline facilities in Minnesota and Michigan.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected\nand the probable violation(s) are:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies\nEach operator shall maintain the following records for transmission line for the\nperiods specified:\n(a) General. Each operator shall prepare and follow for each pipeline, a manual\nof written procedures for conducting operations and maintenance activities and\nfor emergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed\nand updated by the operator at intervals not exceeding 15 months, but at least\none each calendar year. This manual must be prepared before operations of a\npipeline system commence. Appropriate parts of the manual must be kept at\nlocations where operations and maintenance activities are conducted.\n\n\n\nGreat Lakes personnel did not follow their procedures for the inspection of the over-\npressure protection devices. TransCanada ANR’s procedures “DOT Regulator\nInspection and Maintenance, Section 5.0” and “Pressure Safety Valve Inspection\nSection 5.0” both require that the “As Found” and “As Left” data be recorded. This\nwas not being documented on the overpressure protection inspection forms for Thief\nRiver Falls and the Shevline Compressor Stations in Minnesota and Crystal Falls\nStation in Michigan.\nGreat Lakes personnel indicated that the relief devices at the stations were inspected,\nbut could not provide documentation for the “As Left” and “As Found” data on the\noverpressure protection forms.\n2. §192.707 Line markers for mains and transmission lines.\n(d) Marker warning. The following must be written legibly on a background of\nsharply contrasting color on each line marker:\n(1) The word \"Warning,\" \"Caution,\" or \"Danger\" followed by the words\n\"Gas (or name of gas transported) Pipeline\" all of which, except for\nmarkers in heavily developed urban areas, must be in letters at least 1\ninch (25 millimeters) high with ¼ inch (6.4 millimeters) stroke.\nGreat Lake’s line markers did not contain marker warnings legibly on a background of\nsharply contrasting color on numerous line markers throughout their system in\nMinnesota and Michigan.\nDuring the Minnesota field inspection, the marker warning on line markers were noted\nas being faded/unreadable. There were a significant amount of line markers with faded\nlettering that could not be read. The areas of pipeline right-of-way seen during the\ninspection with faded line markers included Bemidji to Grand Rapids, Minnesota.\nPictures of a the line markers at Mile Post 149.5, Mile Post 250, and Grand rapids\nStation were taken as a representative sample of the condition of the line markers.\nAdditionally, in Michigan, it was noted that line markers were faded throughout the\nsystem. During the Blue Lake Area field inspection, the marker warning on the line\nmarkers were observed as faded and unreadable at Mile Post 734.7 and 726.0. It was\nalso noted in the Northern Lakes Area field inspection where the marker warning on\nnumerous line markers were observed as faded and unreadable.\nAfter the inspections, Great Lakes personnel surveyed and replaced all the faded line\nmarkers along their right-of-way.\n2\n\n\n\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the maximum\npenalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a related series of violations. We have reviewed the circumstances\nand supporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to\ncorrect the item(s) identified in this letter. Failure to do so will result in TransCanada,\nGreat Lakes Gas Transmission being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please\nrefer to CPF 3-2013-1014W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C.\n552(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\ntreatment under 5 U.S.C. 552(b).\nSincerely,\nLinda Daugherty\nDirector, Central Region\nPipeline and Hazardous Materials Safety Administration\n3","truncated":false,"body_characters":6265}