# DTE GAS COMPANY — Notice of Amendment

- **operation:** document
- **citation:** CPF 320201002M
- **title:** DTE GAS COMPANY — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2020-01-27
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 192.605(b)(8), 192.911(a), 192.911(a)(i), 192.911(c).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-320201002m.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-320201002m.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-320201002m
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/320201002M
**body:**

Notice of Amendment involving DTE GAS COMPANY. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(8),  192.911(a),  192.911(a)(i),  192.911(c). The case was opened on 2020-01-27 and is reported as closed as of 2020-08-04. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320201002M_Closure Letter_08042020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320201002M/320201002M_Closure%20Letter_08042020.pdf

320201002M_Closure Letter_08062020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320201002M/320201002M_Closure%20Letter_08062020_text.pdf

320201002M_Notice of Amendment (Correction)_02272020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320201002M/320201002M_Notice%20of%20Amendment%20(Correction)_02272020.pdf

320201002M_Notice of Amendment (Correction)_02272020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320201002M/320201002M_Notice%20of%20Amendment%20(Correction)_02272020_text.pdf

320201002M_Notice of Amendment_01272020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320201002M/320201002M_Notice%20of%20Amendment_01272020.pdf

320201002M_Notice of Amendment_01272020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320201002M/320201002M_Notice%20of%20Amendment_01272020_text.pdf

320201002M_Operator Response to Notice_02262020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320201002M/320201002M_Operator%20Response%20to%20Notice_02262020.pdf

320201002M_Closure Letter_08042020.pdf

U.S. Department 901 Locust Street, Suite 480
of Transportation Kansas City, MO 64106
Pipeline and Hazardous
Materials Safety
Administration
VIA ELECTRONIC MAIL TO: matthew.paul@dteenergy.com,
renee.tomina@dteenergy.com, and alida.sandbergy@dteenergy.com
August 4, 2020
Mr. Matthew Paul
President and Chief Operating Officer, DTE Gas
DTE Gas Company
One Energy Plaza
WCB 2377
Detroit, MI 48226
CPF 3-2020-1002M
Dear Mr. Paul:
On May 13-16, 2019, representatives of the Michigan Public Service Commission (MIPSC)
acting as an interstate agent for the Pipeline and Hazardous Materials Safety Administration
(PHMSA) pursuant to Chapter 601 of 49 United States Code inspected DTE Gas Company's
(DTE) procedures for operation and maintenance and integrity management at the Milford
Compressor Station near Milford, MI.
As a result of the inspection, DTE Gas Company was issued a Notice of Amendment on January
27, 2020, which proposed amendment of your procedures. On February 26, 2020 and April 30,
2020, DTE Gas Company submitted the amended procedures. My staff reviewed the amended
procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been
corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely,
Allan C. Beshore
Director, Central Region, OPS
Pipeline and Hazardous Materials Safety Administration

320201002M_Closure Letter_08062020_text.pdf

VIA ELECTRONIC MAIL TO: matthew.paul@dteenergy.com,
renee.tomina@dteenergy.com, and alida.sandberg@dteenergy.com
August 6, 2020
Mr. Matthew Paul
President and Chief Operating Officer, DTE Gas
DTE Gas Company
One Energy Plaza
WCB 2377
Detroit, MI 48226
CPF 3-2020-1002M
Dear Mr. Paul:
On May 13-16, 2019, representatives of the Michigan Public Service Commission (MIPSC)
acting as an interstate agent for the Pipeline and Hazardous Materials Safety Administration
(PHMSA) pursuant to Chapter 601 of 49 United States Code inspected DTE Gas Company's
(DTE) procedures for operation and maintenance and integrity management at the Milford
Compressor Station near Milford, MI.
As a result of the inspection, DTE Gas Company was issued a Notice of Amendment on January
27, 2020, which proposed amendment of your procedures. On February 26, 2020 and April 30,
2020, DTE Gas Company submitted the amended procedures. My staff reviewed the amended
procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been
corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely,
Allan C. Beshore
Director, Central Region, OPS
Pipeline and Hazardous Materials Safety Administration

320201002M_Notice of Amendment_01272020_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
January 27, 2020
Mr. Matthew Paul
President and Chief Operating Officer, DTE Gas
DTE Gas Company
One Energy Plaza
WCB 2377
Detroit, MI 48226
CPF 3-2020-1002M
Dear Mr. Paul:
On May 13-16, 2019, representatives of the Michigan Public Service Commission (MIPSC)
acting as an interstate agent for the Pipeline and Hazardous Materials Safety Administration
(PHMSA) pursuant to Chapter 601 of 49 United States Code inspected DTE Gas Company’s
(DTE) procedures for operation and maintenance and integrity management at the Milford
Compressor Station near Milford, MI.
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
DTE plans or procedures, as 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) . . .
(8) Periodically reviewing the work done by operator personnel to determine the
effectiveness and adequacy of the procedures used in normal operation and
maintenance and modifying the procedure when deficiencies are found.
DTE’s operation and maintenance manual did not have adequate procedures for periodically



2. 3. reviewing the work done by operator personnel to determine the effectiveness and adequacy
of the procedure. The procedure (Procedure 192.605(b)(8) on page 6 of the Operations
Standards) did not define what DTE would do to meet this requirement and how that review
would be documented. DTE’s procedures must set forth a process for how DTE would
conduct the periodic reviews to determine the effectiveness and adequacy of the procedures,
as well as how these reviews will be documented.
§192.911 What are the elements of an integrity management program?
An operator's initial integrity management program begins with a framework (see §
192.907) and evolves into a more detailed and comprehensive integrity management
program, as information is gained and incorporated into the program. An operator
must make continual improvements to its program. The initial program framework and
subsequent program must, at minimum, contain the following elements. (When
indicated, refer to ASME/ANSI B31.8S (incorporated by reference, see § 192.7) for
more detailed information on the listed element.)
(a) An identification of all high consequence areas in accordance with § 192.905.
§192.905 How does an operator identify a high consequence area?
(a) General. To determine which segments of an operator's transmission pipeline system
are covered by this subpart, an operator must identify the high consequence areas. An
operator must use method (1) or (2) from the definition in § 192.903 to identify a high
consequence area. An operator may apply one method to its entire pipeline system,
or an operator may apply one method to individual portions of the pipeline system.
An operator must describe in its integrity management program which method it is
applying to each portion of the operator's pipeline system. The description must
include the potential impact radius when utilized to establish a high consequence
area. (See appendix E.I. for guidance on identifying high consequence areas.)
DTE’s procedures (Section 2.0 – Identification of High Consequence Areas (HCA)) did not
consider long term construction activity within a potential impact radius (PIR) as potentially
creating a high consequence area.
Long term construction activities such as the Belle River Compressor Station Project often
have enough personnel to meet the definition of an identified site. DTE’s procedure must be
clarified to include those type of activities to ensure that all high consequence areas are
addressed in DTE’s written integrity management program.
§192.911 What are the elements of an integrity management program?
An operator's initial integrity management program begins with a framework (see §
192.907) and evolves into a more detailed and comprehensive integrity management
program, as information is gained and incorporated into the program. An operator
must make continual improvements to its program. The initial program framework and
subsequent program must, at minimum, contain the following elements. (When
2



4. indicated, refer to ASME/ANSI B31.8S (incorporated by reference, see § 192.7) for
more detailed information on the listed element.)
(a) . . .
(b) An identification of threats to each covered pipeline segment, which must include
data integration and a risk assessment. An operator must use the threat identification
and risk assessment to prioritize covered segments for assessment (§ 192.917) and to
evaluate the merits of additional preventive and mitigative measures (§ 192.935) for
each covered segment.
DTE’s procedures (Section 4.0 Identification of Threats and Risk Assessment) did not
include data integration and a risk assessment for station piping within meter, regulator, and
compressor stations as well as transmission pipeline segments that extend within a station
boundary. The integrity management regulation applies to these facilities and should be
addressed within DTE’s written integrity management program.
§192.911 What are the elements of an integrity management program?
An operator's initial integrity management program begins with a framework(see §
192.907) and evolves into a more detailed and comprehensive integrity management
program, as information is gained and incorporated into the program. An operator
must make continual improvements to its program. The initial program framework and
subsequent program must, at minimum, contain the following elements. (When
indicated, refer to ASME/ANSI B31.8S (incorporated by reference, see § 192.7) for
more detailed information on the listed element.)
(a) . . .
(i) A performance plan as outlined in ASME/ANSIB31.8S, section 9 that includes
performance measures meeting the requirements of § 192.945.
§192.945 What methods must an operator use to measure program effectiveness?
(a) General. An operator must include in its integrity management program methods to
measure whether the program is effective in assessing and evaluating the integrity of
each covered pipeline segment and in protecting the high consequence areas. These
measures must include the four overall performance measures specified in
ASME/ANSI B31.8S (incorporated by reference, see § 192.7 of this part), section 9.4,
and the specific measures for each identified threat specified in ASME/ANSI B31.8S,
Appendix A. An operator must submit the four overall performance measures as part
of the annual report required by § 191.17 of this subchapter.
DTE’s procedures (Section 13.0 Quality Assurance) did not include specific language on
how to determine whether DTE’s integrity management program is effective in assessing and
evaluating the integrity of each covered pipeline segment. The procedure lacked guidance on
what this evaluation includes and how this evaluation is documented. DTE’s procedures
must define how they are going to measure program effectiveness in accordance with
§192.945 and what records will be used to document this process.
3



Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as
part of this Notice is a document entitled Response Options for Pipeline Operators in
Compliance Proceedings. Please refer to this document and note the response options. Be
advised that all material you submit in response to this enforcement action is subject to being
made publicly available. If you believe that any portion of your responsive material qualifies for
confidential treatment under 5 U.S.C. 552(b), along with the complete original document you
must provide a second copy of the document with the portions you believe qualify for
confidential treatment redacted and an explanation of why you believe the redacted information
qualifies for confidential treatment under 5 U.S.C. 552(b).
Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of
receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this
Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in
this Notice without further notice to you and to issue an Order Directing Amendment. If your
plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend
your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not
contesting this Notice, we propose that you submit your amended procedures to my office within
[number of days] days of receipt of this Notice. This period may be extended by written request
for good cause. Once the inadequacies identified herein have been addressed in your amended
procedures, this enforcement action will be closed.
It is requested (not mandated) that DTE Gas Company maintain documentation of the safety
improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of
plans, procedures) and submit the total to Allan C. Beshore, Director, Central Region OPS,
Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this
matter, please refer to CPF 3-2020-1002M and, for each document you submit, please provide a
copy in electronic format whenever possible.
Sincerely,
Allan C. Beshore
Director, Central Region, OPS
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
Cc: Ms. Renee Tomina, Vice President of Gas Operations, DTE Gas Company, One Energy
Plaza, WCB 1718, Detroit, MI 48226
4

320201002M_Notice of Amendment (Correction)_02272020_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
February 27, 2020
Ms. Renee Tomina
Vice President of Gas Operations
DTE Gas Company
One Energy Plaza, WCB 1718
Detroit, MI 48226
Dear Ms. Tomina:
On January 27, 2020, a Notice of Amendment, CPF 3-2020-1002M (Notice) was sent to you
after an inspection of your operation and maintenance and integrity management procedures
was conducted by representatives of the Michigan Public Service Commission (MIPSC)
acting as an interstate agent for the Pipeline and Hazardous Materials Safety Administration
(PHMSA).
In the Notice, the number of days to submit the amended procedures was inadvertently left
blank. Therefore, if you are not contesting this Notice, we propose you submit your amended
procedures within 90 days of the date you received the Notice.
Sincerely,
Allan C. Beshore
Director, Central Region, OPS
Pipeline and Hazardous Materials Safety Administration
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