{"operation":"document","citation":"CPF 120021004H","title":"COLUMBIA GAS TRANSMISSION, LLC — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2002-06-20","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120021004h.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120021004h.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120021004h","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120021004H","body":"Corrective Action Order involving COLUMBIA GAS TRANSMISSION, LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2002-06-20 and is reported as closed as of 2011-02-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120021004H_Closure Letter_02102011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120021004H/120021004H_Closure%20Letter_02102011.pdf\n\n120021004H_Closure Letter_02102011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120021004H/120021004H_Closure%20Letter_02102011_text.pdf\n\n120021004H_Corrective Action Order_06202002.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120021004H/120021004H_Corrective%20Action%20Order_06202002.pdf\n\n120021004h_corrective action order_06202002_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120021004H/120021004h_corrective%20action%20order_06202002_text.pdf\n\n120021004h_corrective action order_06202002_text.pdf\n\n406 Sevettth Street, S W\nWeehw@toe 0 C 2@59/\nMr. Reed D. Robinson\nVice-President, Field Services\nColurnbla Gas Transrnlsslorl Company\nP. O, Box 1273\n1700 MacCorkle Avenue, SE\nCharleston, O'V 25325-1273\nEnclosed ls 8, Corrective Action Order Issued by thc Assoc18te Adrn1nlstfatol' fof Plpcllnc S8fcly\nin the above-referenced case. The Order places a pressure restriction on the line segment from\nQuakertovm M8r R station to HCHerto~vn Mkk station and the Easton Compressor station to the\nPA-NY state line.\nScrvlcc ls bclng fAadc by ccrtif'lcd mail and facsimile. Your lccelpt of thc cncloscd document\nconstitutes service of that document. The terms and conditions of this Corrective Action Order are\neffective upon rccctpt.\nGvvendolyn M. I ill\nPipeline Compliance Registry\nOAICC of Plpcl'inc Safety\nVIA CERTNlK9 MAlL RX RN RECEIPT RK UKSTKD AND TELKCOPV\n\n\n\nIn the Matter of\n)\nColtlnthia Gas Transmission Company,\nRespondent. )\nCPF No. 1-2002-1004-H\nThis Corrective Action Order is being issued, under authority of 49 U. S. C. g 60112, to require\nColumbia Gas Transmission Company (Respondent) to take the necessary corrective action to\nprotect the public and property from potential hazards associated with Respondent's 1 ine 1278,\nvvhich extends from Lancaster County at the Pennsylvania state line to the Delaware River at thc\nPennsylvania(PA) New York (NY) state line On May 13 2002, Respondent reposed that duc to\na safety-related condition, it. lowered the maximum allowable operating pressure (MAOP) in three\nsections of Line 1278 fi'om Easton to Stroudsburg from Stroudsburg to Milford and from Milford\nto Millrift at the PA-NY state linc.\nOn April 29, 2002„Respondent received the preliminary results of an internal inspection that was\nconducted on March 26, 2002 from Laston to MIllrIA. The Internal mspectlon log IdentIlled\na proximately 800 anomalies on the pipeline with wall loss greater than 65 percent. Seventy-six\n(76) of the anomalies have wall loss equal to or greater than 80 percent and were prcssure rated less\nthaA the MAOP of 1000 pslg. OA May13, 2002, RespoAdent flied Safety-Related COAdltlon Report\n(SRCR) No. 2002-0018 with the Office of Pipeline Safety(OPS).\nPulsuaflt to 49 U. S. C. ) 60117, the Fastern Region, OPS, initiated an investigation of the safety-\nrelated condltlon,\nPrebrnIna ' Findin s\n1. Respondent's Line 1278 which consists of 147 miles of 20-inch and14-inch pipehne, extends\nfrom Lancaster County at the Pennsylvania state line to the Delaware %vcr at the\nPellnsylvanla(PA)\"Ncw Yol'k (N Y)state lfnc. LInc 1278 transports natural gas. RcspoIldcnt Is\nhcadquartcred in Charleston, %', '»I'a. and operates 12, 750 miles of natural gas pipeline in the\nNortheast and Central rey'ons of thc country.\n\n\n\n2. I he coated 20\" Inch pIpe exteIMls aboUt 29 mlles from the PA state hne to the DowQIngiown\nCompressor Station (Downington) and continues for 13 miles from the Hellertown metering\nand regulatIng (Hellertown) statIon to the Easton Compressor Statton (Easton).\nThe coated14-inch segment extends 51 miles from the Downingtown Compressor station to\nthe Qu&ertown MAR Station (Quakertown). Eight miles in the 11-mile guakertown to thc\nHeHertown section is uncoated14-inch pipe. The remaining 60 miles of pipe consists of 52\nAlIles of Uncoated14-Inch pIpc frorA Easton io the PA-NY state IIne. There BIe four\ncompressor stations on Line 1278: Downington, Eagle, Easton, and Mil ford,\n4. On March 26, 2002, an internal inspection was performed on Respondent's Line 1278„ in the\n14-inch uncoated segment of pipeline ftom Easton to MiHriA.\nOn Apr11 29, 2002„Respondent receIvcd the preltmlnary results of the internal IAspectlon\nconducted on March 26, 2002. The internal inspection log revealed approximately 800\nanomalies on the pipeline with waH loss greater than 65 percent, Seventy-six (76) of the\nanomalies have wall loss equal to or greater than 80 percent; Easton to Stroudsburg twenty-six\n(26) anomahes; Stroudsburg to Milford forty-nine (49) anomalies. Three have been repaired.\nMilford to MillrN had one (1) anomaly, It has been repaired. Final internal inspection log\nresults wiH be available in the erst week of August 2002.\n6. ln. response to the 800 anomalies that were identified„Respondent reduced the MAOP in three\nsecttons of the afl'ected 14-Inch plpellne\nEaston to Stroudsbur\n950 psig to 900 psig on May 01, 2002\n900 psig to 800 psig OQ May 14, 2002\n800 psig to 600 psig on May 22, 2002\nStroudsbur to Milford\n9501900 psig to 400 psig on May 15, 2002\n400 psig to 56 psig„on June 7, 2002\n(& 30 /0 SpecifIed MinilTkum Yield Strength)\n950/900 to 800 psig on May 14, 2002.\n7. On Junc 7, 2002, in. order to perform caHbration digs and verify anomaly depths, Respondent\nhad a six mile segment on the Stroudsburg to Milford section blown down. This segment is\nAow valved in at 50 psig idle pipehne pressure.\n8 LIAe 1278 orlglnates at the Pennsylvania-Maryland border rnovtng IA a northeasterly direction\nNto Pennsylvania through Lancaster County, Chester County, Bt the Downtngtown coAlplessol\nstation BAd passes the Lagle corApressor statIon where It contnlUes ln a northerly dtfccfton\nihtoUgh MontgoInery Bnd Bucks CAUnttes passing thc 1'HsioA conlpfessoI' statIon IA\nNorfhhanlpton„PA on into Monroe Bnd Pike Counties and ends at the Delaware River NY-PA\nState line. The affected segment hes between the Fagle compressor station and MI llrI ft at the\n\n\n\nDelaware River NY-PA State line. \"1'he length of the affected segment of the pipeline is\napproximately 70, 5 miles. Quakcrtown to Milh ift is 1 1 mI les Bnd Easton to PA\"N Y state 1Hlc\nis 59. 5 miles.\nPortions of the affected 14-inch segment are routed through small communities and cross\nnumerous state Bnd interstate highways.\n10. Line 1278 was instaHed in 1948 rvithout cathodic protection and was originally constructed of\n14-inch bare, API 5LX seamless pipe manufactured by National fube, with a specIfied\nminimum yield strength of 45, 000 psig.\n11. Cathodic protection on Line 1278 is provided by rectificrs and anodes. Portions of I. ine 1278\nare located In rocky terram where rock blasttng was frequently used to mstall the pipe hi such\nareas lt is difficult to acquirc cffcctIVC cathodic protection and meaningful cathodic protection\nreadings.\nln 1996 and 1997, an on/off close Interval survey (CIS) was conducted Linc 1278„ from thc\nInsulator at Quakcrtown to thc N Y State linc. As 8 result ot this survey thc tollowing catnouic\nprotection upgrades were implemented in 1997/1998.\nQuakcrtown to HcHcrtown - 14 dtstributtve ground beds consisting of 665\nanodes were installed\nEaston to NY State hne - 41 distributive ground beds consistmg ot 1 896\nanodes were installed\n13. Respondent made 254 previous leak repairs between the Easton and the Millrift since the\npipelmc first v ent into service in 1948. This equates to about 4. 30 leaks per pipeline mile.\nMost of the leaks wei'e repaired within the past 10 years. The leak repair breakdown is as\nfollows: one hundred and seventy-three (173) previous leaks werc repaired in 1996 and 1997;\nseven leaks were repaired between 1993 and 1995; one leak was repaired in 1988; twenty-one\n(~1) leaks were repaired in 1973 and 1974 thirty-one (31) leaks were repaired in 1966; and,\neleven (11) leaks werc repaired between 1954 and 1958. A majority of these leaks occuITcd in\npipeline sections within 220 yards of paved roads and near buildings intended for human\noccupancy.\nSince 1996 numerous short segments of the 14-inch pipe have been replaced and repaired\nRespondent replaced the pipe with 14-inch diameter coated pipe, installed launchers and\nI'cccivcrs and replaced valves, The rcplaccIncnt Bnd repairs wcic IAade because of corrosioil\nleaks and in areas where previous internal inspection tools had revealed corroded areas ofpipe.\nCurrently, sixty (60) miles of Luke 1278 does Aot have pl'otcctivc coating: Eight IA11cs witliln\nthe 11-mile Quakcrtown to Hcllertown section and 52 miles from the Easton to thc PA-NY\nstate 11Ac.\n\n\n\nOn J811UBfy. . . Alc - fl .\n' ' ' ' b'out 50 mlles noftheast\n6 1996 Line 1278 ruptured in a sparsely populated area about 50 nliles northeast\nofAHentowniAEastStroudsburg, PA. Thegasigniteds ort ya er ru\nPIPC.\n17, Since e anuary, i, .\nln all UACGA'trolled burn an 8 I'Us 1rc. c\nd b h f The force of the rupee excised 8 30-foot section 0\n'\n' rn Res Indent that\nth J 6 1996 incident OPS has received six (6) SRCRS from Respondent that\n.\nd E\n' 1278, The reports «vcre made on the foHov ing dates: pri\nJuly 19, 1996, November 15, 1996, December 05, 1996, Apri\nu y. . . ,\n* ' « fil 16 1997 and May 13„2002.\n18. '1'hc first five(5) SRCRS wcfc Icpoftcd 8'kcf leaks In the 1 l-lm Q\n\"Imlc Au@k4, fto«vn to HcHcftown\nsection. These leaks were caused by localized corrosion and pitting on the pipe wall.\n. Th 1' SRCR d ted May 13, 2002 was pronlpted by 8 prehminary internal inspection PH\nultfasomc tool I'cport that Idcntlf lcd apploxlIAatcly 800 8nolnahcs GA thc plpc\nhe i linc with wall\nloss greater tllan 65'/0 between Easton and MillriA, .\n20. After the issuance of SRCRs for five reportable leaks, in\nc leaks ln Mafch 1997 kcspondcnt pcrtofnlcd\nan internal inspection. from the Quakerto«vn o c,\n«vn to Hcllerto«vn. This profnpted 85 be oe\nins ctions and the replacenlent of approximately three miles of uncoated pipe wit coa e\nd\nplpc. Tile fcplacenlcnt of Uncoatc plpc wl\n' th three miles of coated pipe removed t«venty-onc\n(21) previously instnHed leak clalnps.\n21. 1A June 1997, an Internal inspection was pefforme y ip\nrmed b Pi etronix from Easton to the MiHrift\nvalve. 1 his fcsUltc«l ln 139 bell hole lnspcctlons an«1 thc replacement of about 2. Inl cs 0\nuncoated pipe with coated plpc.\n22. hl 1998 8, «vifelinc was run ln Linc l278 ffonl lc I\nom the MHlfiA valve to the Delaware River at the\ns 8 c lnc. PA-N Y state Hne. One caHbration dig was performed to verify p\n' v flf fc oftcd anonl811cs. 'Ic\n. Tl MAOP\nof this scctloA «v8s retained 8i 1000 pslg.\n23. 1 1999 a foHow-up C1S was perfornled to determine whethe p\n~ A, 8 0 0%-\nther Res ondent was achieving the\n100 mV olarization shiA cathodic protection criteria. '\nscctlons of UAcoatc«l pipe on Line 1278 that do not Incc c\nsec\n' ' ', meet the 0, 85 V or 100 mV shift criteria.\n* ' '\n.\n'1 he C1S revealed that there are still\ne rcv\n11\nAddit'onal anodes must be installed to achieve the p\n100 AIV 018I'lz8tlon shift. As of thc atc 0\nthis Of cr, cspon cn\n0 «1, R ' d t has Aot fccclvcd pcfIIIits froln local authofltK\ncs to lnstaH 155 Bno cs IA\n'\nthc Pike, Monroe, Le ig, an o a\nh' h dN fthalnptoncounties. Rcspondenthasnotpefforrn -\na\nff rrnedfoHow-u\n.\np\nsufvcyslnthcplpcllAcscctlonsw crc ls fl U c\nh d t b tcd anode gfoun«1 beds and continuous anode flc\nc flex\ncable were installed.\n24. 1 hc Quakelto«vn to HcHcfto«vn scctlon ls schcdulc(1 for 811 IAtcfna 'p\nnal ms ection m early 2003.\n25. Respondent ls cuffcntly A181nt81Alng 11 pfcssufc reduction 0uctlon on thc af tcctcd scgrAcnts ot Linc l 278.\n\n\n\nDeierlnlnat?OI? of recess for Cori'ective AetioI? Order and Rl ht to Hear?N\nSection 60112 of 1\"itle 49, United States Code, provides for ihe issuance of a Corrective Action\nOrder, after reasonable notice and the opportunity for 8 hearing, requiring corrective action„which\nmay include thc suspended oi rcstr? cted use of a plpel?ne facility physical inspection test? ng iepall\nreplacement, or other action as appropriate. The basis for making the determination that a pipeline\nfacility is hazardous, requiring corrective action, is set forth boih in the above referenced statute and\n49 C. F. R. $190. 233, a copy of which is enclosed,\nSection 60112, and the rcgulat?ons promulgated thereunder, provides for the lssU8Ace of' 8\nCorrective Act?on Order without prloI' opportunity fof notice and hearing upon 8 f? ndi ng that fai I Urc\nio issue the Order expeditiously will result in likely serious harm to life, property or the\nenv?I'onIAent. In such cases, 8Il opportun?ty lof 8. heallg will bc provided as soon as practicable\nafter the issuance of the Order,\nAfter evaluating the foregoing prel?m?nary findings of fact, 1 find that the continued operailoA of\nih?s p?pellne w?thouI corrective measures wotlld be hazardous to 1?fe and property. Add?tlonally,\nafter considering the circumstances surrounding the 800 anomalies found by internal inspection,\nthe pfoxiinity of the plpel?Ae to popul ated 8rcas, ihe line s prox in?ity io public highways, the higMy\ncombustible nature of the product the pipeline transports, the prcssure required for transporting the\nA&aterial, and the Unce?dainties as to the cause of the anomalies, I find that a failure to issue\nexpeditiously this Order, requiring immediate corrective action, would result in likely serious harm\nio 1? fe and, propel'iv.\nAccord? Agly„ th? s Corrective Action Order mandating needed BH fnedlatc corrective action ls? ssued\nwithout prior notice and opportunity for a hearing. The terms and conditions of this Order are\neffective Upon I'ecclpt. .\n?th?Q 10 days of receipt, of this Order, Columb?8?nay I'equest a heal?Ag, to bc held as soon as\npracticable, by notifying the Associate Adn?inistratof fof Pipehne Safety ln wfltlAg, delivered\npersonally„by mail or by telecopy at (202) 366-4566. The hearing will be held in %'ashington, DC\non 8 date that ls AlutuaHy coflvenlent io OPS and Respol?dent,\nAfter receiving and analyzing additional data in the course of this investigation, OPS may identify\nother longer term measures that need to be taken. Columbia will be notified of any additional\nmeasures required and anlendnlent of this Order will be considered. To the extent consistent with\nsafety, Cohlmbla w?11 be afforded notice and an opportunity for a hearmg prior to the lmposltlon\nof 8ny add?t?onal corrective measures.\nPursuant to 49 U. S. C. g 60112, 1 hereby order Columbia io immediately take the followi??g\ncorrective actions with respect to Line 1278 from Quakertown to Hellertown and from Faston to\nthe Delaware River on the PA-NY state line.\n\n\n\nA* VA'th respect to the 14-inch pipehnc from the Qllakertown Mkm Station to the Hellertwvn\nMAR Station:\nMalntaIA thc current plcssurc 1'cdUctlon on 'thc pipeline segment ll'onl thc Qual(crtown\nto thc HcllcrtowA. MAOP ffoIA Quakcrtown to Hcllcrfown ls Aot to exceed 600 psfg.\nThis restriction is to remain in place until. thc results of the internal inspection required\nIn Iten) 4 and thc calculations fcqUrrcd, ln Item 9 vcllfy thc lntcgllty of plpclinc Bnd\nwritten approval is obtained from the Director, Eastern Region.\nWithin 15 days of receiving this Order, submit to the Director, Eastern Region 8 set of\nallgnnlcnt IAaps for the pipcllAC scgmcnt fr()A'i thc Quakcrtown to the Hellcrtown. Thc\nmaps must Identify and scgrcgatc class location areas» ldcntlfy locations o'I all leak\nrepall's ol plpc rcplacelncnt rcsultlng from leaks, and thc date last I'cvlscd.\nWithin 90 days of receipt of this Order verify whether the cathodic protection criteria\n4,\n\"0. 85 V or 100 mV po4ization shift) is being met. In the interim„conduct v ee. ly foot\npatrols with leakage detection equipment until preliminary internal inspection results\nare made available.\n%'Ithln 90 days of' receipt of this Order, internally rnspect the plpehne scynent.\nCommission a third-party consultant to examine the internal inspection logs and\ntabulated results and analyze the remaining strength calculations reported by the vendor.\nSubn'lit to thc DII'cctor, i~astern Rcglon» thc prclilTll nary IAtcf Aal Inspection report within\nfive days of receiving it fronl thc vendor.\n%ithin one week of receiving the final inteITial inspection report from the vendor»\nsubIQIt thc tabUlatcd results to thc DIrector» Eas»tern Region. Ihc Dlfcctor, Lastefn\nRegion» A)ay have 8 third-party coAsUltBnt review thc IAtcfnal inspection logs BAd\ntabulated results, which will require access to the electronic image fife.\nwithin 15 days of receiving the final internal inspection report from the vendor, submit\nto thc Director, I astern Rcglon, BA Updated sct of BIIgntncnt inaps for this pipeline\nseglncnt Idcntlfylng thc locations of 811 wall loss anoIABllcs color coded by scvcrlty,\nDevelop 8 Alcchanlsni to vcl'1fy that Bll Bnonlallcs that cMi advcrscly IIApact thc Intcgnty\nof thc plpcllnc segAMnt Brc Jlscovcrcd BIld repaired. Es'tablish written crlterla and\nmethodologies for the evaluation of anonlalies reported by the internal inspection\nvendor, removal or repair or anomalies, and testing to bc conducted to confirn) the\nsoundness of the repairs.\n\n\n\n9) within 5 days after receiving the preliminary report from the internal inspection vendor,\ndctcrfnlnc thc safe MAOP for 811 anonlahcs thctt, IA thc opmlon of RcspoAdcnt and other\nIndependent rllctallul'glcal and plpchnc cnglnccrlng consultants, Hlcct thc cl ltcF18, hstcd\nbelow. The safe MAOP is thc calcu@ted MAOP based on remaining wall thickness\nor 600 psig, whichever is the lower pressure.\nRequire repair or removal immediately.\nRequire a temporary operating prcssure reduction or shut down the pipeline\nuntil thc operator coA'lplctcs tllc repair of thcsc conditions.\nHave metal loss greater than 80'/o of Hominal wall regardless of diameter.\nA c81culatlon of thc Felnalnlng strength of the plpc shows 8 predicted burst\npressure less than the established nlaximum operating pressure at the\nlocation of the anomaly.\nA calculation of the remaining strength of the pipe shows an operating\npressure that ls less than the current estabhshed maximum operatmg\nprcssure at thc location of thc anolnaly.\nPredicted metal loss greater than 500/o of nominal pipe wall that is located\nGt 8 crossing with another plpcllnes or ls ln an afcR with wKlcspfcad\nclfcu1TiicrcntIRI corrosloA„or ls ln an area that could Rffcct, 8 girth weld.\nAnomalies that cannot support a restoration of pressul'e.\n10) Calculate the safe MAOP of 811 the anomalies that do not fall within the criteria\nabov(\n1 1) Identlly 8nd lcport those Bnon'IRllcs that will bc repaired of rcfnovcd from the\npl pell AC,\n12) Maintain the current MAOP. or the lower pressure required under Item 9, of the\nplpcllnc scglncnt until 811 anomalies nlcctlng thc crltcrla ln Itcnl 9 rare repaired OF\nrc61ovcd.\n8 %1th respect to the I4-Inch plpehne froIII the Kaston Compressor Station to the\nPC@&vare River crossing at the PA-NY state lime:\n1) Maintain the current pressure reduction on the pipeline segment from the Easton to\nthe Delaware River crossing at the PA-NY state line, Maximum allowable operating\npressure from Easton to thc Delaware River crossmg at the PA-NY state linc ls Aot\nto exceed 600 pslg m the k aston to Stroudsburg section 50 pslg m the Stroudsburg\nto Milford section, and 800 psig in the Milford to Millrift to PA-NY state linc. This\nrestriction is to remain in place until all critical anomalies (dellned in A-9) rlre\nrepaired or removed and written approval is obtained from the Director, 1\":astern\nRegion,\n\n\n\nShould fhc SiroudsbU1'g to Mll ford scgrncnf, ,\nwhich ls currently un(lcr' ldlc plpcllnc\nprcssure of 50 psig need an increase to a higher MAOP to meet winter heating\ndcrnarld, then fhc Rcspondcnt must dcnlonstfatc to fhc Eastern Rcglon Dllcctor 1A\nwriting that the remaining pipeline waH loss anomalies in this segment will be able\nto support thc prcssure lncrcasc.\n%lthIB 10 working days of recelvlng this Order, submit calculations to show thai\nexisting MAOP of 600 psig and 800 psig can be safely supported by the Easfon to\nStfoudsburg scgnlcnt 8nd fhc Mijfowl to PA-5 Y st8tc linc segment, rcspcctlvcly.\nSubmit internal inspection log and tabulated values to the Director, Eastern Region.\nThe Eastern Region Director may have a third-party consultant verify that all critical\nanomaHcs have been discovered, which will require access to the electronic image\nfile.\nCon'lrnlsslon 8 tnlrd-party consllnaAI lo exaIBJBc 'thc lntcrnal Inspection logs and\ntabulated results and analyze the remaining strength calculations reported by the\nvendor.\n%'ithin 15 days of receiving the final internal inspection report from the vendor,\nsublmt to the Dilector, Eastern Region, an updated set of alignment maps for this\npipeline segment identifying the locations of all vvall loss anomalies color coded by\nscvcl\"lty.\nDevelop 8 Incchanisfn to vcrlfy that 8H anomalies that can adversely lrnp8ct thc\nIntegrity ol thc plpchnc scglncnt 8rc dlscovclcd and repaired. Estallhsh written\ncriteria and Alcthodologies for the evaluation of anomaHes reported by the internal\ninspection vendor„removal or repair or anomalies„and testing to be conducted to\nconfirm the soundness of the repairs.\nWithin 5 days after receiving the preliminary report from the internal inspection\nvendor, deterlnine the safe MAOP for the most critical anomalies on the tv o\npipelirle segments The safe MAOP for the Easton to Stroudsburg segment ls the\ncalculated MAOP based on relnalnlng waH thlckncss or 600 pslg, whichever ls the\nlowcl' pressure. Thc safe MAOI for thc Milford to PA-N Y state line scgfncnt ls the\ncalculated IVfAOP based on remaining wall thickness or 800 psig, whichever is the\nlovver pressure.\n%lthln 45 days of rccclvlng fhc fina] lcport froln thc mfcrA81 Qlspcctloll vcfldor,\ndcicrlnlnc fhe safe MAOP of thc rclHalnlng anomallcs. 1A lto case will thc sal'c\nMAOP bc grcaicf than 600 pslg for the E8stoA to Sffoudsbur'g segment or 800 pslg\nfol ihe lvlllfofd to PA-8 Y state linc segment,\n\n\n\n9) Identify and report those anomalies that will be repaired or rcrnovcd froln the\npipeline.\nC. All Uncoated Pipc4nc ScglncIIts\n1 akc thc fOHowlng steps with respect to all Uncoated plpc11nc scgnlcnts fl'oln thc Quakcftown to\nthe Hc}lcrtown and from the Easton to the PA-NY State Linc:\n1) Dcvclop 8 written plan fof fclllcdlal action to ATItlgatc thc contlnlnng growth 8nd\noccuffcncc of anolnallcs ldcntlfled by thc lntcnlal inspection 1001 and by Gny other\nA%cans during execution 0'f thc fcpalf pfogfaln. Thc wnttcn plan should Include\nPfovlslons fol\".\nI) Dctcflnlnatlon of thc cause and contributing factors to thc occuffcAcc and\ncontinuing gfowth of anornallcs.\nDetermination of thc cause and contributing tactors 101\" anv additional\nanomalies detected by Ineans other than the internal inspection tool, i, e.\nvlsua1 Observation.\niii) Performance of' appropriate survey Gnd/Or testing programs to be used in\nregard to Items (i) Gnd (ii) above.\nlv) Pcrfotmance of close\"lntcl val, curI'cnt lntcrfuptcd, sldc drain, pipe-to-soll\npotcntl81 surveys, and Other appropriate tcstlng to dctcfIDlnc thc adcqUacy\nof the corrosion control GppHed to the pipeline after repairs have been made.\nv) Determine by cnglnccl\"lng analyses thc location anil 11UATbcf of test wires\n1'cqull'ed to GdcqUatcly rnofntol thc plpcllnc for cathodic protcctlon.\n2) Using Geographic Information Systems (GIS) technology collect data at all points\nof pipeline inflection from Quakertown to Hcllertown and from Faston to the\nDelaware River at the PA-NY state Hne and sublmt data to the National Pipchne\nMapping System using their standards.\n3) Submit 8 written pipeline remediation (repair or removal) plan at those locations\nwhere the remaining strength of the pipe is less than the pre-1996 MAOP. Consider\ntool tolerances ln Identifying those mall loss anomalies that could adversely affect\nthc plpcl inc s lritcgrlty\n4) For the pipcHnc segment from the Easton to the PA-NY state linc, submit 8 written\nplan to replace pipe sections with clusters ofrcpairs or reITlovals after superimposing\nGnd integrating thc 2002 PII lntcfnal ulspcction wall loss Gnofnaly data. A clustcl\nls defHlcd Gs 8 onc-mlle long plpcllnc scglTlcQt with five or Alorc rcpalis ot' pipe\n\n\n\nreplacement resulting from RH previous leaks in the pipeline, The cluster includes\npipe repair or replacement resulting from 2002 Pl 1 internal inspection,\nFor the Quakertown to Hei lertown segment„submit a written plan to replace pipe\nscctlons with clusters of repairs or removals after superimposing RAd lntcgl Rtll'lg thc\nlntcfnal lnspcctlon lcsults fcqulrcd In A4. A cluster ls defined Rs 8 01M-fnllc long\npipehne segment with tive or more repails or removals in the pipeline's history.\nSubmit a written pipe replacement plan that has been prioritized after considering\nRt least thc foHowlng factors: Class Locations'„safety scnsltlvc areas defined as RI'I\narc8 th3t cxtcAds 220 valds fI'ofn 8 public paved road, ,\n8 pUbllc gRthcrlng area, or any\nbuilding intended for human occupancy; leak history'„&Ial internal inspection\nreport„' and„number of leak repairs or pipeline removals, Incorporate foreseeable\nclass location chaAgcs based on rcglo»81 dcvcloprncnt history Into accoUnt.\nReplace the affected uncoated 14-inch diameter pipe using the following guidelines:\nIn Class 3 areas replace within two years.\nln Class 2 areas rcplacc within three years.\nIn Class 1 areas I\"cplace wlthln flvc years.\nSubnut the written plans for Itcfns A, 8 4 C, addressing repRlf, I'cmcdlai action, and\ncathodic protection to the Director„Eastern Region, for review.\nEach element of the plan must be approved by thc Director, Eastern Rey'on, who\nmay provide approvals incrementally. implement the plan as approved.\nProvide dctalicd reports to tl'lc Director, Eastern Rcglon, Ot flndlngs and actions\ntaken to repair thc pl pcillM Idcntlfylng the anolTlallcs detected and evaluated tlMlf\nlocation circumfcrentiRHy on thc pipe, the characterization of the anomalies (type\nand size of defect)„ the severity of the anomaly, and the repair action taken,\nincluding the size predicted by the internal inspection tool and the actual size.\nAdditionally, provide a summary by type of defect of the number of ano»18iics\nidentified by the tool, the number of actual anomahes found, and number repaired,\nRes ponde»t must request approval from thc Director, Eastern Region to remove or\nodify the self-imposed pressure restriction of the pipeline segments. The request\n»1Ust dcnloAstratc that thc hazard has been abated and that 8 higher prcssUfc ls\njustI fled based on an anaivsls showIng that thc prcssure lncl case ls safe coAsldcrlng\nRH known defects, anomalies and operating parameters o t the pipeline.\nRespondent will each month submit status repolts on the types of repairs or\nremovals completed, cathodic protection readings, nexv leak discoveries, number Of'\ndlstrlbuted anode ground beds Installed, anomaly dIscoverlcs, RAG other pert»lent\nt'acts as applied to this Order.\n\n\n\n13) The Director, Eastern Region, may grant an extension of time for compliance with\nany of the terms of this order for good cause. A request for an extension must bc in\nwrltlng.\nR cspondcnt Irlay appeal 8rly decl sion of thc Director, Eastern Rcglon to thc Assoclatc Admlnlstrator\nfor Plpcllnc Safety, Dcclslons of thc Assoclatc Adlnlrlistrator shaH bc final.\nThe procedures for the issuance of this Order are described in Part 190, Title 49„Code of Federal\nRegulations, $ 190. 233, a copy of which is enclosed, is made part of this Order and describes thc\nRespondents' procedural rights re1ative to this Order.\nFailure to comply with this Order may result in the assessment of civil penalties of not more than\n$25, 000 per day and in referral to the Attorney General for appropriate relief in United States\nDistrict Court\ney Gerard\nAssoclatc Admlnlstrator\nfor Plpcl Inc Safety\n\n120021004H_Closure Letter_02102011_text.pdf\n\nU.S. Department 820 Bear Tavern Road, Suite 103\nOf Transportation West Trenton, NJ 08628\nPipeline and 609.989.2171\nHazardous Materials\nSafety Administration\nOVERNIGHT EXPRESS MAIL\nFebruary 10, 2011\nMr. Victor Gaglio\nSenior Vice President of Operations and Engineering\nNiSource Gas Transmission & Storage\n1700 MacCorkle Avenue\nCharleston, WV 25314\nCPF 1-2002-1004H\nDear Mr. Gaglio:\nOn June 20, 2002, Columbia Gas Transmission Company (CGT), which is a subsidiary of\nNiSource Gas Transmission & Storage, was issued a Corrective Action Order in the above\nreferenced case. Subsequently, CGT was issued an Amendment to the Corrective Action Order\non November 19, 2003. This Order included a requirement to take corrective actions on your\npipeline. Based on our review of the documentation you provided, it has been determined that\nyou have complied with the terms of this Order.\nAccordingly, this case is now closed and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nByron Coy, PE\nDirector, Easter Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":29409}