# COLUMBIA GAS TRANSMISSION, LLC — Notice of Probable Violation

**Citation:** CPF 320101005  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2010-11-05

CLOSED notice of probable violation citing 192.477, 192.479(a).

## Document text

Notice of Probable Violation involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.477,  192.479(a). The case was opened on 2010-11-05 and is reported as closed as of 2012-06-14. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320101005_Final Order_06142012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320101005/320101005_Final%20Order_06142012.pdf

320101005_Final Order_06142012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320101005/320101005_Final%20Order_06142012_text.pdf

320101005_NOPV PCO_11052010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320101005/320101005_NOPV%20PCO_11052010.pdf

320101005_NOPV PCO_11052010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320101005/320101005_NOPV%20PCO_11052010_text.pdf

320101005_Operator Response to NOPV_12032010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320101005/320101005_Operator%20Response%20to%20NOPV_12032010.pdf

320101005_Final Order_06142012_text.pdf

JUNE 14, 2012
Mr. Robert C. Skaggs, Jr.
President and Chief Executive Officer
Columbia Gas Transmission, LLC
1700 MacCorkle Avenue SE
Charleston, WV 25314
Re: CPF No. 3-2010-1005
Dear Mr. Skaggs:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation and finds that Columbia Gas Transmission, LLC, has completed the actions specified in
the Notice to comply with the pipeline safety regulations. Therefore, this case is now closed.
Service of the Final Order by certified mail is deemed effective upon the date of mailing, or as
otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. David Barrett, Director, Central Region, OPS
Mr. Perry M. Hoffman, Manager – System Integrity, NiSource Gas Transmission &
Storage
Mr. Alan Mayberry, Deputy Associate Administrator for Field Operations, OPS
CERTIFIED MAIL - RETURN RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
)
In the Matter of )
)
Columbia Gas Transmission, LLC, ) CPF No. 3-2010-1005
)
Respondent. )
____________________________________)
FINAL ORDER
On June 7-17, 2010, pursuant to 49 U.S.C. § 60117, representatives of the Ohio Public Utilities
Commission (PUCO), as agent for the Pipeline and Hazardous Materials Safety Administration
(PHMSA), Office of Pipeline Safety (OPS), conducted an on-site pipeline safety inspection of
the facilities and records of Columbia Gas Transmission, LLC (Columbia or Respondent) in
Crawford, Ohio. Columbia, a subsidiary of NiSource Inc., owns and operates approximately
11,453 miles of pipeline in Delaware, Kentucky, Maryland, New Jersey, New York, North
Carolina, Ohio, Pennsylvania, Virginia, and West Virginia.1 Approximately 400 miles of
Columbia’s pipelines are in High Consequence Areas.
2
As a result of the inspection, the Director, Central Region, OPS (Director), issued to Respondent,
by letter dated November 5, 2010, a Notice of Probable Violation and Proposed Compliance
Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that
Columbia had violated 49 C.F.R. §§ 192.477 and 192.479(a) and proposed ordering Respondent
to take certain measures to correct the alleged violations.
NiSource Gas Transmission & Storage, also a subsidiary of NiSource Inc., responded to the
Notice on behalf of Columbia, by letters dated December 3, 2010, and January 26, 2011
(Response). The company did not contest one of the allegations of violation, contested the
second, and offered additional information in response to the Notice.
1 NiSource Inc. Form 10-K for the fiscal year ended December 31, 2011, filed with the Securities and Exchange
Commission on February 24, 2012.
2 49 CFR § 192.903.



2
FINDINGS OF VIOLATION
The Notice alleged that Respondent violated 49 C.F.R. Part 192, as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.477, which states:
§ 192.477 Internal corrosion control: Monitoring.
If corrosive gas is being transported, coupons or other suitable means
must be used to determine the effectiveness of the steps taken to minimize
internal corrosion. Each coupon or other means of monitoring internal
corrosion must be checked two times each calendar year, but with
intervals not exceeding 7½ months.
The Notice alleged that Respondent violated 49 C.F.R. § 192.477 by failing to check each
coupon or other means of monitoring internal corrosion at least twice each calendar year, but
with intervals not exceeding 7½ months. Specifically, the Notice alleged that Columbia
inspected a corrosion coupon known as asset #911063 at the Benton compressor station yard on
September 17, 2008, but did not inspect it again until June 4, 2009, which exceeded the
maximum allowable interval of 7½ months.
In its Response, Columbia stated that asset #911063 is a gas sampling point and not a corrosion
coupon, and provided records demonstrating that gas sampling was completed within the
work management records may not have accurately reflected the nature of the work completed
required 7½ month interval.3 Columbia explained that at the time of the PUCO inspection, its
on asset #911063.
Accordingly, after considering all of the evidence, I find that Columbia checked the means of
monitoring internal corrosion at asset #911063 at the required interval. Based upon the
foregoing, I hereby order that Item 1 be withdrawn.
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 192.479(a), which states:
§ 192.479 Atmospheric corrosion control: General.
(a) Each operator must clean and coat each pipeline or portion of
pipeline that is exposed to the atmosphere, except pipelines under
paragraph (c) of this section.
The Notice alleged that Respondent violated 49 C.F.R. § 192.479(a) by failing to clean and coat
each portion of pipeline that is exposed to the atmosphere. Specifically, the Notice alleged that
Columbia did not clean or coat three portions of pipeline that were exposed to the atmosphere,
that these locations were not included in Columbia’s atmospheric corrosion control program, and
that at least one of these locations exhibited corrosion pits. Respondent did not contest this
allegation of violation, and stated that it had either repaired the identified locations or had
3 Response at 2.



3
scheduled remedial action.
Respondent violated 49 C.F.R. § 192.479(a) by failing to clean and coat each portion of pipeline
that is exposed to the atmosphere.
4 Accordingly, based upon a review of all of the evidence, I find that
This finding of violation will be considered a prior offense in any subsequent enforcement action
taken against Respondent.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Item 2 in the Notice for violation of
49 C.F.R. § 192.479(a). Under 49 U.S.C. § 60118(a), each person who engages in the
transportation of gas or who owns or operates a pipeline facility is required to comply with the
applicable safety standards established under chapter 601. The Director indicates that
Respondent has taken the following actions that were specified in the proposed compliance
order:
With respect to the violation of § 192.479(a) (Item 2), Respondent
submitted a plan to evaluate and immediately address any areas of pipeline
exposed to the atmosphere in the McArthur and Crawford operating areas,
and to document the exposures in Respondent’s existing atmospheric
corrosion program. Respondent submitted the results of its evaluation on
December 7, 2011, providing a summary of the exposure locations
identified, corrosion levels at each exposure, and the remedial actions
taken for each exposure. This evaluation included the three exposures that
had been identified during the PUCO inspection.
Accordingly, I find that compliance has been achieved with respect to this violation. Therefore,
the compliance terms proposed in the Notice are not included in this Order.
The terms and conditions of this Final Order are effective upon service in accordance with
49 C.F.R. § 190.5.
___________________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety
4 Response at 2-3.

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/320101005>
- Source ID: `phmsa-enforcement`
- SHA-256: `ce762ae731305659fbc474d95ffe6fd0e9af84457abb4cf135b0d58b99495574`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T13:56:07.569Z
- Document slug: `phmsa-enforcement-320101005`

### Source metadata

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  "pipelineType": "GAS INTERSTATE ONSHORE",
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  ],
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```
