{"operation":"document","citation":"CPF 32024025NOA","title":"DTM GAS STORAGE COMPANY — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-03-15","effective_on":null,"summary":"CLOSED notice of amendment citing 192.505(d), 192.905(c), 192.911(l), 192.915(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024025noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024025noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024025noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32024025NOA","body":"Notice of Amendment involving DTM GAS STORAGE COMPANY. PHMSA's enforcement data identifies the cited regulations as 192.505(d),  192.905(c),  192.911(l),  192.915(b)(2). The case was opened on 2024-03-15 and is reported as closed as of 2024-06-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32024025NOA_Closure Letter_06142024_(23-265890).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024025NOA/32024025NOA_Closure%20Letter_06142024_(23-265890).pdf\n\n32024025NOA_Closure Letter_06142024_(23-265890)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024025NOA/32024025NOA_Closure%20Letter_06142024_(23-265890)_text.pdf\n\n32024025NOA_Notice of Amendment_03152024_(23-265890).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024025NOA/32024025NOA_Notice%20of%20Amendment_03152024_(23-265890).pdf\n\n32024025NOA_Notice of Amendment_03152024_(23-265890)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024025NOA/32024025NOA_Notice%20of%20Amendment_03152024_(23-265890)_text.pdf\n\n32024025NOA_Operator Response to Notice (REVISED)_05172024_(23-265890).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024025NOA/32024025NOA_Operator%20Response%20to%20Notice%20(REVISED)_05172024_(23-265890).pdf\n\n32024025NOA_Operator Response to Notice (REVISED)_06122024_(23-265890).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024025NOA/32024025NOA_Operator%20Response%20to%20Notice%20(REVISED)_06122024_(23-265890).pdf\n\n32024025NOA_Operator Response to Notice_04122024_(23-265890).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024025NOA/32024025NOA_Operator%20Response%20to%20Notice_04122024_(23-265890).pdf\n\n32024025NOA_Closure Letter_06142024_(23-265890)_text.pdf\n\nVIA ELECTRONIC MAIL TO: chris.zona@dtmidstream.com;\npatrick.raichel@dtmidstream.com\nJune 14, 2024\nMr. Christopher Zona,\nChief Operating Officer\nDTM Gas Storage Company\n500 Woodward Ave., 29th Floor\nDetroit, MI 48226\nRE: CPF 3-2024-025-NOA\nDear Mr. Zona:\nFrom July 10 through July 14, 2023, representatives of the Michigan Public Service Commission,\nacting as an interstate agent for the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected DTM Gas\nStorage Company’s (DTM) procedures for operation and maintenance. As a result of the\ninspection, DTM was issued a Notice of Amendment on March 15, 2024, which proposed\namendment of your procedures\nDTM submitted its amended procedures on June 12 and 13, 2024 My staff has reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave been corrected.\nThis letter is to inform you that no further action is necessary, and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nGregory A Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Patrick Raichel (patrick.raichel@dtmidstream.com)\n\n32024025NOA_Notice of Amendment_03152024_(23-265890)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: chris.zona@dtmidstream.com; patrick.raichel@dtmidstream.com\nMarch 15, 2024\nMr. Christopher Zona,\nChief Operating Officer\nDTM Gas Storage Company\n500 Woodward Ave., 29th Floor\nDetroit, MI 48226\nCPF 3-2024-025-NOA\nDear Mr. Zona:\nFrom July 10 through July 14, 2023, representatives of the Michigan Public Service Commission,\nacting as an interstate agent for the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected DTM Gas\nStorage Company’s (DTM) procedures for operation and maintenance.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nDTM’s plans or procedures. The items inspected and the inadequacies are described below:\n1. § 192.505 Strength test requirements for steel pipeline to operate at a hoop stress of 30\npercent or more of SMYS.\n(a) . . . .\n(d) For fabricated units and short sections of pipe, for which a post installation test is\nimpractical, a preinstallation strength test must be conducted by maintaining the\npressure at or above the test pressure for at least 4 hours.\nDTM’s specification “MS-ENG-040, Section 17 – Pressure Testing” was inadequate because it did\nnot appropriately define “short sections of pipe” or when “a post installation test is impractical.”\nPer DTM’s specification, piping assemblies were to be tested in place as much as practical, but the\nprocedure allowed up to seven tie-in welds per system (as defined by DTM) or more, if approved\nby Company Engineering. The procedure also defined “short sections of pipe” to be sections of\npipe up to 500 feet long. DTM’s specification “MS-ENG-040, Section 17 – Pressure Testing”\nrequired modification to properly describe the maximum number of welds and maximum\n\n\n\nallowable length of pipe for preinstallation pressure testing, so that it is clear when a post-\ninstallation hydrostatic test becomes necessary.\nDTM must amend its written procedures to comply with the requirements of § 192.505(d), in\naccordance with § 192.13(c).\n2. § 192.905 How does an operator identify a high consequence area?\n(a) . . . .\n(c) Newly identified areas. When an operator has information that the area around a\npipeline segment not previously identified as a high consequence area could satisfy\nany of the definitions in § 192.903, the operator must complete the evaluation using\nmethod (1) or (2). If the segment is determined to meet the definition as a high\nconsequence area, it must be incorporated into the operator's baseline assessment\nplan as a high consequence area within one year from the date the area is identified.\nDTM’s procedures for newly identified segments or new high consequence areas (HCA) did not\nindicate that those locations would be incorporated into the baseline assessment plan (BAP) within\na year of the date of identification. The process for newly found HCAs to be incorporated into the\nBAP must be addressed as required by § 192.911(a).\n3. § 192.911 What are the elements of an integrity management program?\n(a) . . . .\n(l) A quality assurance process as outlined in ASME/ANSI B31.8S, section 12.\nDTM’s quality assurance plan did not meet the requirements of ASME/ANSI B31.8S section 12.\nSpecifically, the plan did not have any documentation requirements for its internal audits for\nquality assurance. Section 12 of ASME/ANSI B.31.8S requires that “corrective actions to improve\nthe integrity management program or quality plan shall be documented and the effectiveness of\ntheir implementation monitored.” Section 192.911(I) requires that procedures for this requirement\nbe addressed within the quality assurance plan.\n4. § 192.915 What knowledge and training must personnel have to carry out an integrity\nmanagement program?\n(a) . . . .\n(b) Persons who carry out assessments and evaluate assessment results. The integrity\nmanagement program must provide criteria for the qualification of any person -\n(1) . . . .\n(2) Who reviews and analyzes the results from an integrity assessment and\nevaluation;\nDTM’s procedures for assessments, via a pressure test, did not define the criteria for the\nqualification of the person who reviews and analyzes the results from an integrity assessment\nevaluation. DTM’s Procedure 903.2 addressed the pressure test assessment methods, but did not\nspecify who evaluates the results of the pressure tests and what qualification they require.\nAlthough the procedure did reference DTM’s O&M Procedure 501, which required that an\nintegrity engineer must be involved, the procedure still failed to include any requirements defining\n\n\n\nwhat those criteria for that engineer must be or that engineer’s responsibility. A process for\ndefining the responsibility and the qualifications of individuals reviewing those tests must be\naddressed in the procedures as required by § 192.907(a).\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. § 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 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 Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this\nNotice without further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 30 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested that DTM maintain documentation of the safety improvement costs associated with\nfulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the\ntotal to Gregory A Ochs, Director, Central Region, Pipeline and Hazardous Materials Safety\nAdministration. In correspondence concerning this matter, please refer to CPF 3-2024-025-NOA\nand, for each document you submit, please provide a copy in electronic format, whenever possible.\nSincerely,\nGregory A Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: Patrick Raichel (patrick.raichel@dtmidstream.com)","truncated":false,"body_characters":10517}