{"operation":"document","citation":"CPF 320191002M","title":"GREAT LAKES GAS TRANSMISSION CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-06-17","effective_on":null,"summary":"CLOSED notice of amendment citing 192.909(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320191002m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320191002m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320191002m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320191002M","body":"Notice of Amendment involving GREAT LAKES GAS TRANSMISSION CO. PHMSA's enforcement data identifies the cited regulation as 192.909(a). The case was opened on 2019-06-17 and is reported as closed as of 2020-02-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320191002M_Closure Letter_02102020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320191002M/320191002M_Closure%20Letter_02102020.pdf\n\n320191002M_Closure Letter_02102020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320191002M/320191002M_Closure%20Letter_02102020_text.pdf\n\n320191002M_Notice of Amendment_06172019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320191002M/320191002M_Notice%20of%20Amendment_06172019.pdf\n\n320191002M_Notice of Amendment_06172019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320191002M/320191002M_Notice%20of%20Amendment_06172019_text.pdf\n\n320191002M_Operator Response to Notice_07172019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320191002M/320191002M_Operator%20Response%20to%20Notice_07172019.pdf\n\n320191002M_Notice of Amendment_06172019_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 17, 2019\nStanley Chapman\nExecutive VP and President of US Natural Gas Pipelines\nTransCanada Great Lakes Gas Transmission\n700 Louisiana St., Suite 300\nHouston, TX 77002\nCPF 3-2019-1002M\nDear Mr. Chapman:\nFrom April 16-20, 2018, April 30-May 4, 2018, May 14 – 18, 2018, May 21 – 24, 2018, June 4\n-6, 2018, July 16 – 20, 2018, July 23 – 27, 2018, and August 20 – 24, 2018, a representative of\nthe Pipeline and Hazardous Materials Safety Administration (PHMSA), Michigan Public\nService Commission and Minnesota Department of Public Safety,pursuant to Chapter 601 of\n49 United States Code inspected Great Lakes Gas Transmission procedures for The TER as it\nrelates to Risk assessment in the IM Plan when reviewed in Houston, TX.\nBased on the inspection, PHMSA has identified the apparent inadequacy found within Great\nLakes Gas Transmission’s plans or procedures, as described below:\n1. 192.909 (a) How can an operator change its integrity management program?\nGeneral. An operator must document any change to its program and the reasons for\nthe change before implementing the change.\nGreat Lakes Gas Transmission’s (GLGT) Risk Model Procedure is inadequate because it fails\nto accurately describe how GLGT documents changes to its program and the reasons for the\nchange before implementing the change by computing risk based on different formulas and\nfactors for the new assessment year than those provided in the current procedure.\nAfter completion of the Risk Assessment, the procedure formulas and factors were updated to\nreflect and document the process. The procedure lagged behind the actual process\n\n\n\nimplemented for risk assessment. Language related to the retroactive procedure update process\nneeds to be included if TC/GLGT continues this practice.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 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 §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis 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\namend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are\nnot contesting this Notice, we propose that you submit your amended procedures to my office\nwithin [number of days] days of receipt of this Notice. This period may be extended by written\nrequest for good cause. Once the inadequacies identified herein have been addressed in your\namended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that Great Lakes Gas Transmission maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Allan Beshore, Director,\nCentral Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 3-2019-1002M and, for each document you\nsubmit, please provide a copy in electronic format whenever possible.\nSincerely,\nAllan C. Beshore, P.E.\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n2\n\n320191002M_Closure Letter_02102020_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 10, 2020\nStanley Chapman\nExecutive VP and President of US Natural Gas Pipelines\nTransCanada Great Lakes Gas Transmission\n700 Louisiana St., Suite 300\nHouston, TX 77002\nCPF 3-2019-1002M\nDear Mr. Chapman:\nFrom April 16-20, 2018, April 30-May 4, 2018, May 14 – 18, 2018, May 21 – 24, 2018, June\n4 -6, 2018, July 16 – 20, 2018, July 23 – 27, 2018, and August 20 – 24, 2018, a representative\nof the Pipeline and Hazardous Materials Safety Administration (PHMSA), Michigan Public\nService Commission and Minnesota Department of Public Safety, pursuant to Chapter 601 of\n49 United States Code inspected Great Lakes Gas Transmission procedures reviewed in\nHouston, TX. As a result of the inspection, Great Lakes Gas Transmission was issued a\nNotice of Amendment on June 13, 2019, which proposed amendment of your procedures.\nGreat Lakes Gas Transmission submitted its amended procedures on February 4, 2020. My\nstaff reviewed the amended procedures, and it appears that the inadequacies outlined in this\nNotice of Amendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nAllan C. Beshore\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":6882}