{"operation":"document","citation":"CPF 32025015NOA","title":"DTE GAS COMPANY — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-05-20","effective_on":null,"summary":"CLOSED notice of amendment citing 192.463(a), 192.921(a)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025015noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025015noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025015noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32025015NOA","body":"Notice of Amendment involving DTE GAS COMPANY. PHMSA's enforcement data identifies the cited regulations as 192.463(a),  192.921(a)(1). The case was opened on 2025-05-20 and is reported as closed as of 2025-07-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32025015NOA_Closure Letter_07072025_(24-299898).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025015NOA/32025015NOA_Closure%20Letter_07072025_(24-299898).pdf\n\n32025015NOA_Closure Letter_07072025_(24-299898)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025015NOA/32025015NOA_Closure%20Letter_07072025_(24-299898)_text.pdf\n\n32025015NOA_Notice of Amendment_05202025_(24-299898).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025015NOA/32025015NOA_Notice%20of%20Amendment_05202025_(24-299898).pdf\n\n32025015NOA_Notice of Amendment_05202025_(24-299898)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025015NOA/32025015NOA_Notice%20of%20Amendment_05202025_(24-299898)_text.pdf\n\n32025015NOA_Operator Response to Notice_06132025_(24-299898).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025015NOA/32025015NOA_Operator%20Response%20to%20Notice_06132025_(24-299898).pdf\n\n32025015NOA_Closure Letter_07072025_(24-299898)_text.pdf\n\nVIA ELECTRONIC MAIL TO: Joi.Harris@dteenergy.com;\nCedric.Flowers@dteenergy.com; Michael.Romein@dteenergy.com\nJuly 7, 2025\nMr. Joi Harris\nPresident and Chief Operating Officer\nDTE Gas Company\nOne Energy Plaza\nWCB 2377\nDetroit, MI 48226\nRE: CPF 3-2025-015-NOA\nDear Mr. Harris:\nFrom October 20 to November 10, 2024, representatives of the Michigan Public Service\nCommission, acting as an Interstate Agent for the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), conducted\nan integrated inspection of DTE Gas Company’s (DTE) procedures and natural gas facilities on\nthe Vector Pipeline System in Detroit, Michigan. On May 20, 2025, pursuant to 49 CFR § 190.206,\nPHMSA issued a Notice of Amendment which proposed amendment of DTE’s procedures.\nDTE submitted its amended procedures on June 13, 2025. PHMSA has reviewed the amended\nprocedures, and it appears that the inadequacies outlined in the Notice of Amendment have been\ncorrected.\nThis letter is to inform you that no further action is necessary, and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nDavid Barrett\nActing Director, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Mr. Cedric Flower, VP of Gas Operations, Cedric.Flowers@dteenergy.com\nMr. Mike Romein; Manager of Gas Codes & Standards and Laboratory Services,\nMichael.Romein@dteenergy.com\n\n32025015NOA_Notice of Amendment_05202025_(24-299898)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: Joi.Harris@dteenergy.com;\nCedric.Flowers@dteenergy.com; Michael.Romein@dteenergy.com\nMay 20, 2025\nMr. Joi Harris\nPresident and Chief Operating Officer\nDTE Gas Company\nOne Energy Plaza\nWCB 2377\nDetroit, MI 48226\nCPF 3-2025-015-NOA\nDear Mr. Harris:\nFrom October 20 to November 10, 2024, representatives of the Michigan Public Service\nCommission, acting as an Interstate Agent for the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),\nconducted an integrated inspection of DTE Gas Company’s (DTE) procedures and natural gas\nfacilities on the Vector Pipeline System in Detroit, Michigan.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nDTE’s plans or procedures. The items inspected and the inadequacies are described below:\n1. § 192.463 External corrosion control: Cathodic protection.\n(a) Each cathodic protection system required by this subpart must provide a level of\ncathodic protection that complies with one or more of the applicable criteria\ncontained in Appendix D of this part. If none of these criteria is applicable, the\ncathodic protection system must provide a level of cathodic protection at least\nequal to that provided by compliance with one or more of these criteria.\nAppendix D states:\nI. Criteria for cathodic protection –\nA. Steel, cast iron, and ductile iron structures.\n(1) A negative (cathodic) voltage of at least 0.85 volt, with reference to a\nsaturated copper-copper sulfate half cell. Determination of this voltage\nmust be made with the protective current applied, and in accordance with\nsections II and IV of this appendix.\n\n\n\nII. Interpretation of voltage measurement. Voltage (IR) drops other than those\nacross the structure electrolyte boundary must be considered for valid\ninterpretation of the voltage measurement in paragraphs A(1) and (2) and\nparagraph B(1) of section I of this appendix.\nDTE’s corrosion control standard 451, “Corrosion Control for Metallic Pipelines” (Standard\n451), did not address how often DTE personnel are to conduct voltage (IR) drop surveys on\nDTE’s anode protected lines. Appendix D, section II, requires that IR drops other than those\nacross the structure electrolyte boundary must be considered for valid interpretation of the\nvoltage measurement in (A)(1) and (A)(2) of Appendix D. Section 4.10 of Standard 451\nspecified obtaining IR free readings (a method of considering IR drops) on DTE’s rectified\nsystems every five years, but Standard 451 did not state how often DTE must do an IR free\nreading on its anode protected lines, such as the Vector line segment. Therefore, PHMSA\nproposes that DTE must revise its procedures to meet the requirements of § 192.463(a), in\naccordance with § 192.605(b)(2).\n2. § 192.921 How is the baseline assessment to be conducted?\n(a) Assessment methods. An operator must assess the integrity of the line pipe in\neach covered segment by applying one or more of the following methods for each\nthreat to which the covered segment is susceptible. An operator must select the\nmethod or methods best suited to address the threats identified to the covered\nsegment (See § 192.917).\n(1) Internal inspection tool or tools capable of detecting those threats to which\nthe pipeline is susceptible. The use of internal inspection tools is appropriate\nfor threats such as corrosion, deformation and mechanical damage\n(including dents, gouges and grooves), material cracking and crack- like\ndefects (e.g., stress corrosion cracking, selective seam weld corrosion,\nenvironmentally assisted cracking, and girth weld cracks), hard spots with\ncracking, and any other threats to which the covered segment is susceptible.\nWhen performing an assessment using an in-line inspection tool, an operator\nmust comply with § 192.493. In addition, an operator must analyze and\naccount for uncertainties in reported results (e.g., tool tolerance, detection\nthreshold, probability of detection, probability of identification, sizing\naccuracy, conservative anomaly interaction criteria, location accuracy,\nanomaly findings, and unity chart plots or equivalent for determining\nuncertainties and verifying actual tool performance) in identifying and\ncharacterizing anomalies;\nDTE’s integrity management procedure, “ILI of Transmission Pipelines (13-SWI-011-0053),”\nfor using in-line inspection (ILI) tools for assessments was not in accordance with\n§§ 192.921(a)(1) and 192.493. Section 192.493 incorporates by reference API RP 1163, “In-line\nInspection Systems Qualification.” API RP 1163, section 8, “System Results Validation,”\nprescribes methods that shall be applied to validate if the reported inspection results meet or are\nwithin the performance specification for the pipeline being inspected. DTE’s procedure did not\ncontain any guidance or specificity on how and when they would do this validation process.\nTherefore, PHMSA proposes that DTE must revise its integrity management procedures to meet\nthe requirements of §§ 192.921(a)(1) and 192.493.\n\n\n\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 CFR § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nEnforcement Proceedings.\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\nunder 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 amend\nyour plans or procedures to correct the inadequacies (49 CFR § 190.206). If you are not\ncontesting this Notice, we propose that you submit your amended procedures to my office within\n90 days of receipt of this Notice. This period may be extended by written request for good\ncause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested (not mandated) that DTE Gas Company maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Gregory A. Ochs, Director, Central Region, Pipeline\nand Hazardous Materials Safety Administration. In correspondence concerning this matter,\nplease refer to CPF 3-2025-015-NOA and, for each document you submit, please provide a copy\nin electronic format whenever possible.\nSincerely,\nDavid Barrett\nActing Director, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Mr. Cedric Flower, VP of Gas Operations, Cedric.Flowers@dteenergy.com\nMr. Mike Romein; Manager of Gas Codes & Standards and Laboratory Services,\nMichael.Romein@dteenergy.com\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings","truncated":false,"body_characters":10605}