# LAKES GAS COMPANY — Notice of Amendment

- **operation:** document
- **citation:** CPF 32024078NOA
- **title:** LAKES GAS COMPANY — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2024-11-22
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 192.805(i).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-32024078noa.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-32024078noa.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-32024078noa
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/32024078NOA
**body:**

Notice of Amendment involving LAKES GAS COMPANY. PHMSA's enforcement data identifies the cited regulation as 192.805(i). The case was opened on 2024-11-22 and is reported as closed as of 2025-11-13. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

32024078NOA_Closure Letter_11132025_(23-264480).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024078NOA/32024078NOA_Closure%20Letter_11132025_(23-264480).pdf

32024078NOA_Closure Letter_11132025_(23-264480)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024078NOA/32024078NOA_Closure%20Letter_11132025_(23-264480)_text.pdf

32024078NOA_Notice of Amendment_11222024_(23-264480).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024078NOA/32024078NOA_Notice%20of%20Amendment_11222024_(23-264480).pdf

32024078NOA_Notice of Amendment_11222024_(23-264480)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024078NOA/32024078NOA_Notice%20of%20Amendment_11222024_(23-264480)_text.pdf

32024078NOA_Notice of Amendment_11222024_(23-264480)_text.pdf

NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: thampton@lakesgas.com; ssargeant@lakesgasco.com;
danderson@lakesgasco.com
November 22, 2022
Mr. Trent Hampton
Chief Executive Officer
Lakes Gas Company
26777 Fallbrook Ave,
Wyoming, Minnesota 55092
CPF 3-2024-078-NOA
Dear Mr. Hampton:
From September 11 to September 15, 2023, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code
(U.S.C.), inspected Lakes Gas Company (Lakes) procedures for its operator qualification
program in Sturgeon Bay, Wisconsin.
As a result of the inspection, PHMSA has identified the apparent inadequacy found within Lakes
procedures. The item inspected and the inadequacy is described below:
1. § 192.805 Qualification program.
Each operator shall have and follow a written qualification program. The program
shall include provisions to:
(a) . . . .
(i) After December 16, 2004, notify the Administrator or a state agency participating
under 49 U.S.C. Chapter 601 if an operator significantly modifies the program after
the administrator or state agency has verified that it complies with this section.
Notifications to PHMSA must be submitted in accordance with § 192.18.
Lakes’ Operator Qualification Program, last revised August 9, 2023, was inadequate because it
did not contain a provision requiring Lake to notify the Administrator or state agency if
significant modifications are made to the program, in accordance with § 192.18(i).



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
Enforcement 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
45 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 Lakes maintain documentation of the safety improvement
costs associated with fulfilling this Notice of Amendment (preparation/revision of plans,
procedures) and submit the total to Gregory A. Ochs, Director, Central Region, Pipeline and
Hazardous Materials Safety Administration. In correspondence concerning this matter, please
refer to CPF 3-2024-078-NOA and, for each document you submit, please provide a copy in
electronic format whenever possible.
Sincerely,
Gregory A. Ochs
Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: David Anderson, District Manager, danderson@lakesgasco.com
Steven Sargeant, EVP of Operations, ssargeant@lakesgasco.com
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings

32024078NOA_Closure Letter_11132025_(23-264480)_text.pdf

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
901 Locust Street, Suite 480
Kansas City, MO 64106
VIA ELECTRONIC MAIL TO: thampton@lakesgasco.com; jhellendrung@lakesgas.com
November 13, 2025
Mr. Trent Hampton
Chief Executive Officer
Lakes Gas Company
26777 Fallbrook Ave,
Wyoming, Minnesota 55092
RE: CPF 3-2024-078-NOA
Dear Mr. Hampton:
From September 11 to September 15, 2023, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code
(U.S.C.), conducted an inspection of Lakes Gas Company’s (Lakes) procedures for its operator
qualification program in Sturgeon Bay, Wisconsin. On November 22, 2024, pursuant to 49 CFR §
190.206, PHMSA issued a Notice of Amendment which proposed amendment of Lakes’
procedures.
Lakes submitted its amended procedures on December 17, 2024 and November 4, 2025. PHMSA
has reviewed the amended procedures, and it appears that the inadequacies outlined in the Notice
of Amendment have been corrected.
This letter is to inform you that no further action is necessary, and this case is now closed. Thank
you for your cooperation.
Sincerely,
David Barrett
Acting Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Jason Hellendrung Manager of Physical Operations / Fleet Manager / Pipeline Manager,
jhellendrung@lakesgas.com
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