COLUMBIA GAS TRANSMISSION, LLC — Corrective Action Order

120021004h_corrective action order_06202002_text.pdf, page 1Official PDF406 Sevettth Street, S W Weehw@toe 0 C 2@59/ Mr. Reed D. Robinson Vice-President, Field Services Colurnbla Gas Transrnlsslorl Company P. O, Box 1273 1700 MacCorkle Avenue, SE Charleston, O'V 25325-1273 Enclosed ls 8, Corrective Action Order Issued by thc Assoc18te Adrn1nlstfatol' fof Plpcllnc S8fcly in the above-referenced case. The Order places a pressure restriction on the line segment from Quakertovm M8r R station to HCHerto~vn Mkk station and the Easton Compressor station to the PA-NY state line. Scrvlcc ls bclng fAadc by ccrtif'lcd mail and facsimile. Your lccelpt of thc cncloscd document constitutes service of that document. The terms and conditions of this Corrective Action Order are effective upon rccctpt. Gvvendolyn M. I ill Pipeline Compliance Registry OAICC of Plpcl'inc Safety VIA CERTNlK9 MAlL RX RN RECEIPT RK UKSTKD AND TELKCOPV#

120021004h_corrective action order_06202002_text.pdf, page 2In the Matter of ) Coltlnthia Gas Transmission Company, Respondent. ) CPF No. 1-2002-1004-H This Corrective Action Order is being issued, under authority of 49 U. S. C. g 60112, to require Columbia Gas Transmission Company (Respondent) to take the necessary corrective action to protect the public and property from potential hazards associated with Respondent's 1 ine 1278, vvhich extends from Lancaster County at the Pennsylvania state line to the Delaware River at thc Pennsylvania(PA) New York (NY) state line On May 13 2002, Respondent reposed that duc to a safety-related condition, it. lowered the maximum allowable operating pressure (MAOP) in three sections of Line 1278 fi'om Easton to Stroudsburg from Stroudsburg to Milford and from Milford to Millrift at the PA-NY state linc. On April 29, 2002„Respondent received the preliminary results of an internal inspection that was conducted on March 26, 2002 from Laston to MIllrIA. The Internal mspectlon log IdentIlled a proximately 800 anomalies on the pipeline with wall loss greater than 65 percent. Seventy-six (76) of the anomalies have wall loss equal to or greater than 80 percent and were prcssure rated less thaA the MAOP of 1000 pslg. OA May13, 2002, RespoAdent flied Safety-Related COAdltlon Report (SRCR) No. 2002-0018 with the Office of Pipeline Safety(OPS). Pulsuaflt to 49 U. S. C. ) 60117, the Fastern Region, OPS, initiated an investigation of the safety- related condltlon, PrebrnIna ' Findin s 1. Respondent's Line 1278 which consists of 147 miles of 20-inch and14-inch pipehne, extends from Lancaster County at the Pennsylvania state line to the Delaware %vcr at the Pellnsylvanla(PA)"Ncw Yol'k (N Y)state lfnc. LInc 1278 transports natural gas. RcspoIldcnt Is hcadquartcred in Charleston, %', '»I'a. and operates 12, 750 miles of natural gas pipeline in the Northeast and Central rey'ons of thc country.#

120021004h_corrective action order_06202002_text.pdf, page 32. I he coated 20" Inch pIpe exteIMls aboUt 29 mlles from the PA state hne to the DowQIngiown Compressor Station (Downington) and continues for 13 miles from the Hellertown metering and regulatIng (Hellertown) statIon to the Easton Compressor Statton (Easton). The coated14-inch segment extends 51 miles from the Downingtown Compressor station to the Qu&ertown MAR Station (Quakertown). Eight miles in the 11-mile guakertown to thc HeHertown section is uncoated14-inch pipe. The remaining 60 miles of pipe consists of 52 AlIles of Uncoated14-Inch pIpc frorA Easton io the PA-NY state IIne. There BIe four compressor stations on Line 1278: Downington, Eagle, Easton, and Mil ford, 4. On March 26, 2002, an internal inspection was performed on Respondent's Line 1278„ in the 14-inch uncoated segment of pipeline ftom Easton to MiHriA. On Apr11 29, 2002„Respondent receIvcd the preltmlnary results of the internal IAspectlon conducted on March 26, 2002. The internal inspection log revealed approximately 800 anomalies on the pipeline with waH loss greater than 65 percent, Seventy-six (76) of the anomalies have wall loss equal to or greater than 80 percent; Easton to Stroudsburg twenty-six (26) anomahes; Stroudsburg to Milford forty-nine (49) anomalies. Three have been repaired. Milford to MillrN had one (1) anomaly, It has been repaired. Final internal inspection log results wiH be available in the erst week of August 2002. 6. ln. response to the 800 anomalies that were identified„Respondent reduced the MAOP in three secttons of the afl'ected 14-Inch plpellne Easton to Stroudsbur 950 psig to 900 psig on May 01, 2002 900 psig to 800 psig OQ May 14, 2002 800 psig to 600 psig on May 22, 2002 Stroudsbur to Milford 9501900 psig to 400 psig on May 15, 2002 400 psig to 56 psig„on June 7, 2002 (& 30 /0 SpecifIed MinilTkum Yield Strength) 950/900 to 800 psig on May 14, 2002. 7. On Junc 7, 2002, in. order to perform caHbration digs and verify anomaly depths, Respondent had a six mile segment on the Stroudsburg to Milford section blown down. This segment is Aow valved in at 50 psig idle pipehne pressure. 8 LIAe 1278 orlglnates at the Pennsylvania-Maryland border rnovtng IA a northeasterly direction Nto Pennsylvania through Lancaster County, Chester County, Bt the Downtngtown coAlplessol station BAd passes the Lagle corApressor statIon where It contnlUes ln a northerly dtfccfton ihtoUgh MontgoInery Bnd Bucks CAUnttes passing thc 1'HsioA conlpfessoI' statIon IA Norfhhanlpton„PA on into Monroe Bnd Pike Counties and ends at the Delaware River NY-PA State line. The affected segment hes between the Fagle compressor station and MI llrI ft at the#

120021004h_corrective action order_06202002_text.pdf, page 4Delaware River NY-PA State line. "1'he length of the affected segment of the pipeline is approximately 70, 5 miles. Quakcrtown to Milh ift is 1 1 mI les Bnd Easton to PA"N Y state 1Hlc is 59. 5 miles. Portions of the affected 14-inch segment are routed through small communities and cross numerous state Bnd interstate highways. 10. Line 1278 was instaHed in 1948 rvithout cathodic protection and was originally constructed of 14-inch bare, API 5LX seamless pipe manufactured by National fube, with a specIfied minimum yield strength of 45, 000 psig. 11. Cathodic protection on Line 1278 is provided by rectificrs and anodes. Portions of I. ine 1278 are located In rocky terram where rock blasttng was frequently used to mstall the pipe hi such areas lt is difficult to acquirc cffcctIVC cathodic protection and meaningful cathodic protection readings. ln 1996 and 1997, an on/off close Interval survey (CIS) was conducted Linc 1278„ from thc Insulator at Quakcrtown to thc N Y State linc. As 8 result ot this survey thc tollowing catnouic protection upgrades were implemented in 1997/1998. Quakcrtown to HcHcrtown - 14 dtstributtve ground beds consisting of 665 anodes were installed Easton to NY State hne - 41 distributive ground beds consistmg ot 1 896 anodes were installed 13. Respondent made 254 previous leak repairs between the Easton and the Millrift since the pipelmc first v ent into service in 1948. This equates to about 4. 30 leaks per pipeline mile. Most of the leaks wei'e repaired within the past 10 years. The leak repair breakdown is as follows: one hundred and seventy-three (173) previous leaks werc repaired in 1996 and 1997; seven leaks were repaired between 1993 and 1995; one leak was repaired in 1988; twenty-one (~1) leaks were repaired in 1973 and 1974 thirty-one (31) leaks were repaired in 1966; and, eleven (11) leaks werc repaired between 1954 and 1958. A majority of these leaks occuITcd in pipeline sections within 220 yards of paved roads and near buildings intended for human occupancy. Since 1996 numerous short segments of the 14-inch pipe have been replaced and repaired Respondent replaced the pipe with 14-inch diameter coated pipe, installed launchers and I'cccivcrs and replaced valves, The rcplaccIncnt Bnd repairs wcic IAade because of corrosioil leaks and in areas where previous internal inspection tools had revealed corroded areas ofpipe. Currently, sixty (60) miles of Luke 1278 does Aot have pl'otcctivc coating: Eight IA11cs witliln the 11-mile Quakcrtown to Hcllertown section and 52 miles from the Easton to thc PA-NY state 11Ac.#

120021004h_corrective action order_06202002_text.pdf, page 5On J811UBfy. . . Alc - fl . ' ' ' ' b'out 50 mlles noftheast 6 1996 Line 1278 ruptured in a sparsely populated area about 50 nliles northeast ofAHentowniAEastStroudsburg, PA. Thegasigniteds ort ya er ru PIPC. 17, Since e anuary, i, . ln all UACGA'trolled burn an 8 I'Us 1rc. c d b h f The force of the rupee excised 8 30-foot section 0 ' ' rn Res Indent that th J 6 1996 incident OPS has received six (6) SRCRS from Respondent that . d E ' 1278, The reports «vcre made on the foHov ing dates: pri July 19, 1996, November 15, 1996, December 05, 1996, Apri u y. . . , * ' « fil 16 1997 and May 13„2002. 18. '1'hc first five(5) SRCRS wcfc Icpoftcd 8'kcf leaks In the 1 l-lm Q "Imlc Au@k4, fto«vn to HcHcftown section. These leaks were caused by localized corrosion and pitting on the pipe wall. . Th 1' SRCR d ted May 13, 2002 was pronlpted by 8 prehminary internal inspection PH ultfasomc tool I'cport that Idcntlf lcd apploxlIAatcly 800 8nolnahcs GA thc plpc he i linc with wall loss greater tllan 65'/0 between Easton and MillriA, . 20. After the issuance of SRCRs for five reportable leaks, in c leaks ln Mafch 1997 kcspondcnt pcrtofnlcd an internal inspection. from the Quakerto«vn o c, «vn to Hcllerto«vn. This profnpted 85 be oe ins ctions and the replacenlent of approximately three miles of uncoated pipe wit coa e d plpc. Tile fcplacenlcnt of Uncoatc plpc wl ' th three miles of coated pipe removed t«venty-onc (21) previously instnHed leak clalnps. 21. 1A June 1997, an Internal inspection was pefforme y ip rmed b Pi etronix from Easton to the MiHrift valve. 1 his fcsUltc«l ln 139 bell hole lnspcctlons an«1 thc replacement of about 2. Inl cs 0 uncoated pipe with coated plpc. 22. hl 1998 8, «vifelinc was run ln Linc l278 ffonl lc I om the MHlfiA valve to the Delaware River at the s 8 c lnc. PA-N Y state Hne. One caHbration dig was performed to verify p ' v flf fc oftcd anonl811cs. 'Ic . Tl MAOP of this scctloA «v8s retained 8i 1000 pslg. 23. 1 1999 a foHow-up C1S was perfornled to determine whethe p ~ A, 8 0 0%- ther Res ondent was achieving the 100 mV olarization shiA cathodic protection criteria. ' scctlons of UAcoatc«l pipe on Line 1278 that do not Incc c sec ' ' ', meet the 0, 85 V or 100 mV shift criteria. * ' ' . '1 he C1S revealed that there are still e rcv 11 Addit'onal anodes must be installed to achieve the p 100 AIV 018I'lz8tlon shift. As of thc atc 0 this Of cr, cspon cn 0 «1, R ' d t has Aot fccclvcd pcfIIIits froln local authofltK cs to lnstaH 155 Bno cs IA ' thc Pike, Monroe, Le ig, an o a h' h dN fthalnptoncounties. Rcspondenthasnotpefforrn - a ff rrnedfoHow-u . p sufvcyslnthcplpcllAcscctlonsw crc ls fl U c h d t b tcd anode gfoun«1 beds and continuous anode flc c flex cable were installed. 24. 1 hc Quakelto«vn to HcHcfto«vn scctlon ls schcdulc(1 for 811 IAtcfna 'p nal ms ection m early 2003. 25. Respondent ls cuffcntly A181nt81Alng 11 pfcssufc reduction 0uctlon on thc af tcctcd scgrAcnts ot Linc l 278.#

120021004h_corrective action order_06202002_text.pdf, page 6Deierlnlnat?OI? of recess for Cori'ective AetioI? Order and Rl ht to Hear?N Section 60112 of 1"itle 49, United States Code, provides for ihe issuance of a Corrective Action Order, after reasonable notice and the opportunity for 8 hearing, requiring corrective action„which may include thc suspended oi rcstr? cted use of a plpel?ne facility physical inspection test? ng iepall replacement, or other action as appropriate. The basis for making the determination that a pipeline facility is hazardous, requiring corrective action, is set forth boih in the above referenced statute and 49 C. F. R. $190. 233, a copy of which is enclosed, Section 60112, and the rcgulat?ons promulgated thereunder, provides for the lssU8Ace of' 8 Corrective Act?on Order without prloI' opportunity fof notice and hearing upon 8 f? ndi ng that fai I Urc io issue the Order expeditiously will result in likely serious harm to life, property or the env?I'onIAent. In such cases, 8Il opportun?ty lof 8. heallg will bc provided as soon as practicable after the issuance of the Order, After evaluating the foregoing prel?m?nary findings of fact, 1 find that the continued operailoA of ih?s p?pellne w?thouI corrective measures wotlld be hazardous to 1?fe and property. Add?tlonally, after considering the circumstances surrounding the 800 anomalies found by internal inspection, the pfoxiinity of the plpel?Ae to popul ated 8rcas, ihe line s prox in?ity io public highways, the higMy combustible nature of the product the pipeline transports, the prcssure required for transporting the A&aterial, and the Unce?dainties as to the cause of the anomalies, I find that a failure to issue expeditiously this Order, requiring immediate corrective action, would result in likely serious harm io 1? fe and, propel'iv. Accord? Agly„ th? s Corrective Action Order mandating needed BH fnedlatc corrective action ls? ssued without prior notice and opportunity for a hearing. The terms and conditions of this Order are effective Upon I'ecclpt. . ?th?Q 10 days of receipt, of this Order, Columb?8?nay I'equest a heal?Ag, to bc held as soon as practicable, by notifying the Associate Adn?inistratof fof Pipehne Safety ln wfltlAg, delivered personally„by mail or by telecopy at (202) 366-4566. The hearing will be held in %'ashington, DC on 8 date that ls AlutuaHy coflvenlent io OPS and Respol?dent, After receiving and analyzing additional data in the course of this investigation, OPS may identify other longer term measures that need to be taken. Columbia will be notified of any additional measures required and anlendnlent of this Order will be considered. To the extent consistent with safety, Cohlmbla w?11 be afforded notice and an opportunity for a hearmg prior to the lmposltlon of 8ny add?t?onal corrective measures. Pursuant to 49 U. S. C. g 60112, 1 hereby order Columbia io immediately take the followi??g corrective actions with respect to Line 1278 from Quakertown to Hellertown and from Faston to the Delaware River on the PA-NY state line.#

120021004h_corrective action order_06202002_text.pdf, page 7A* VA'th respect to the 14-inch pipehnc from the Qllakertown Mkm Station to the Hellertwvn MAR Station: MalntaIA thc current plcssurc 1'cdUctlon on 'thc pipeline segment ll'onl thc Qual(crtown to thc HcllcrtowA. MAOP ffoIA Quakcrtown to Hcllcrfown ls Aot to exceed 600 psfg. This restriction is to remain in place until. thc results of the internal inspection required In Iten) 4 and thc calculations fcqUrrcd, ln Item 9 vcllfy thc lntcgllty of plpclinc Bnd written approval is obtained from the Director, Eastern Region. Within 15 days of receiving this Order, submit to the Director, Eastern Region 8 set of allgnnlcnt IAaps for the pipcllAC scgmcnt fr()A'i thc Quakcrtown to the Hellcrtown. Thc maps must Identify and scgrcgatc class location areas» ldcntlfy locations o'I all leak repall's ol plpc rcplacelncnt rcsultlng from leaks, and thc date last I'cvlscd. Within 90 days of receipt of this Order verify whether the cathodic protection criteria 4, "0. 85 V or 100 mV po4ization shift) is being met. In the interim„conduct v ee. ly foot patrols with leakage detection equipment until preliminary internal inspection results are made available. %'Ithln 90 days of' receipt of this Order, internally rnspect the plpehne scynent. Commission a third-party consultant to examine the internal inspection logs and tabulated results and analyze the remaining strength calculations reported by the vendor. Subn'lit to thc DII'cctor, i~astern Rcglon» thc prclilTll nary IAtcf Aal Inspection report within five days of receiving it fronl thc vendor. %ithin one week of receiving the final inteITial inspection report from the vendor» subIQIt thc tabUlatcd results to thc DIrector» Eas»tern Region. Ihc Dlfcctor, Lastefn Region» A)ay have 8 third-party coAsUltBnt review thc IAtcfnal inspection logs BAd tabulated results, which will require access to the electronic image fife. within 15 days of receiving the final internal inspection report from the vendor, submit to thc Director, I astern Rcglon, BA Updated sct of BIIgntncnt inaps for this pipeline seglncnt Idcntlfylng thc locations of 811 wall loss anoIABllcs color coded by scvcrlty, Develop 8 Alcchanlsni to vcl'1fy that Bll Bnonlallcs that cMi advcrscly IIApact thc Intcgnty of thc plpcllnc segAMnt Brc Jlscovcrcd BIld repaired. Es'tablish written crlterla and methodologies for the evaluation of anonlalies reported by the internal inspection vendor, removal or repair or anomalies, and testing to bc conducted to confirn) the soundness of the repairs.#

120021004h_corrective action order_06202002_text.pdf, page 89) within 5 days after receiving the preliminary report from the internal inspection vendor, dctcrfnlnc thc safe MAOP for 811 anonlahcs thctt, IA thc opmlon of RcspoAdcnt and other Independent rllctallul'glcal and plpchnc cnglnccrlng consultants, Hlcct thc cl ltcF18, hstcd below. The safe MAOP is thc calcu@ted MAOP based on remaining wall thickness or 600 psig, whichever is the lower pressure. Require repair or removal immediately. Require a temporary operating prcssure reduction or shut down the pipeline until thc operator coA'lplctcs tllc repair of thcsc conditions. Have metal loss greater than 80'/o of Hominal wall regardless of diameter. A c81culatlon of thc Felnalnlng strength of the plpc shows 8 predicted burst pressure less than the established nlaximum operating pressure at the location of the anomaly. A calculation of the remaining strength of the pipe shows an operating pressure that ls less than the current estabhshed maximum operatmg prcssure at thc location of thc anolnaly. Predicted metal loss greater than 500/o of nominal pipe wall that is located Gt 8 crossing with another plpcllnes or ls ln an afcR with wKlcspfcad clfcu1TiicrcntIRI corrosloA„or ls ln an area that could Rffcct, 8 girth weld. Anomalies that cannot support a restoration of pressul'e. 10) Calculate the safe MAOP of 811 the anomalies that do not fall within the criteria abov( 1 1) Identlly 8nd lcport those Bnon'IRllcs that will bc repaired of rcfnovcd from the pl pell AC, 12) Maintain the current MAOP. or the lower pressure required under Item 9, of the plpcllnc scglncnt until 811 anomalies nlcctlng thc crltcrla ln Itcnl 9 rare repaired OF rc61ovcd. 8 %1th respect to the I4-Inch plpehne froIII the Kaston Compressor Station to the PC@&vare River crossing at the PA-NY state lime: 1) Maintain the current pressure reduction on the pipeline segment from the Easton to the Delaware River crossing at the PA-NY state line, Maximum allowable operating pressure from Easton to thc Delaware River crossmg at the PA-NY state linc ls Aot to exceed 600 pslg m the k aston to Stroudsburg section 50 pslg m the Stroudsburg to Milford section, and 800 psig in the Milford to Millrift to PA-NY state linc. This restriction is to remain in place until all critical anomalies (dellned in A-9) rlre repaired or removed and written approval is obtained from the Director, 1":astern Region,#

120021004h_corrective action order_06202002_text.pdf, page 9Should fhc SiroudsbU1'g to Mll ford scgrncnf, , which ls currently un(lcr' ldlc plpcllnc prcssure of 50 psig need an increase to a higher MAOP to meet winter heating dcrnarld, then fhc Rcspondcnt must dcnlonstfatc to fhc Eastern Rcglon Dllcctor 1A writing that the remaining pipeline waH loss anomalies in this segment will be able to support thc prcssure lncrcasc. %lthIB 10 working days of recelvlng this Order, submit calculations to show thai existing MAOP of 600 psig and 800 psig can be safely supported by the Easfon to Stfoudsburg scgnlcnt 8nd fhc Mijfowl to PA-5 Y st8tc linc segment, rcspcctlvcly. Submit internal inspection log and tabulated values to the Director, Eastern Region. The Eastern Region Director may have a third-party consultant verify that all critical anomaHcs have been discovered, which will require access to the electronic image file. Con'lrnlsslon 8 tnlrd-party consllnaAI lo exaIBJBc 'thc lntcrnal Inspection logs and tabulated results and analyze the remaining strength calculations reported by the vendor. %'ithin 15 days of receiving the final internal inspection report from the vendor, sublmt to the Dilector, Eastern Region, an updated set of alignment maps for this pipeline segment identifying the locations of all vvall loss anomalies color coded by scvcl"lty. Develop 8 Incchanisfn to vcrlfy that 8H anomalies that can adversely lrnp8ct thc Integrity ol thc plpchnc scglncnt 8rc dlscovclcd and repaired. Estallhsh written criteria and Alcthodologies for the evaluation of anomaHes reported by the internal inspection vendor„removal or repair or anomalies„and testing to be conducted to confirm the soundness of the repairs. Within 5 days after receiving the preliminary report from the internal inspection vendor, deterlnine the safe MAOP for the most critical anomalies on the tv o pipelirle segments The safe MAOP for the Easton to Stroudsburg segment ls the calculated MAOP based on relnalnlng waH thlckncss or 600 pslg, whichever ls the lowcl' pressure. Thc safe MAOI for thc Milford to PA-N Y state line scgfncnt ls the calculated IVfAOP based on remaining wall thickness or 800 psig, whichever is the lovver pressure. %lthln 45 days of rccclvlng fhc fina] lcport froln thc mfcrA81 Qlspcctloll vcfldor, dcicrlnlnc fhe safe MAOP of thc rclHalnlng anomallcs. 1A lto case will thc sal'c MAOP bc grcaicf than 600 pslg for the E8stoA to Sffoudsbur'g segment or 800 pslg fol ihe lvlllfofd to PA-8 Y state linc segment,#

120021004h_corrective action order_06202002_text.pdf, page 109) Identify and report those anomalies that will be repaired or rcrnovcd froln the pipeline. C. All Uncoated Pipc4nc ScglncIIts 1 akc thc fOHowlng steps with respect to all Uncoated plpc11nc scgnlcnts fl'oln thc Quakcftown to the Hc}lcrtown and from the Easton to the PA-NY State Linc: 1) Dcvclop 8 written plan fof fclllcdlal action to ATItlgatc thc contlnlnng growth 8nd occuffcncc of anolnallcs ldcntlfled by thc lntcnlal inspection 1001 and by Gny other A%cans during execution 0'f thc fcpalf pfogfaln. Thc wnttcn plan should Include Pfovlslons fol". I) Dctcflnlnatlon of thc cause and contributing factors to thc occuffcAcc and continuing gfowth of anornallcs. Determination of thc cause and contributing tactors 101" anv additional anomalies detected by Ineans other than the internal inspection tool, i, e. vlsua1 Observation. iii) Performance of' appropriate survey Gnd/Or testing programs to be used in regard to Items (i) Gnd (ii) above. lv) Pcrfotmance of close"lntcl val, curI'cnt lntcrfuptcd, sldc drain, pipe-to-soll potcntl81 surveys, and Other appropriate tcstlng to dctcfIDlnc thc adcqUacy of the corrosion control GppHed to the pipeline after repairs have been made. v) Determine by cnglnccl"lng analyses thc location anil 11UATbcf of test wires 1'cqull'ed to GdcqUatcly rnofntol thc plpcllnc for cathodic protcctlon. 2) Using Geographic Information Systems (GIS) technology collect data at all points of pipeline inflection from Quakertown to Hcllertown and from Faston to the Delaware River at the PA-NY state Hne and sublmt data to the National Pipchne Mapping System using their standards. 3) Submit 8 written pipeline remediation (repair or removal) plan at those locations where the remaining strength of the pipe is less than the pre-1996 MAOP. Consider tool tolerances ln Identifying those mall loss anomalies that could adversely affect thc plpcl inc s lritcgrlty 4) For the pipcHnc segment from the Easton to the PA-NY state linc, submit 8 written plan to replace pipe sections with clusters ofrcpairs or reITlovals after superimposing Gnd integrating thc 2002 PII lntcfnal ulspcction wall loss Gnofnaly data. A clustcl ls defHlcd Gs 8 onc-mlle long plpcllnc scglTlcQt with five or Alorc rcpalis ot' pipe#

120021004h_corrective action order_06202002_text.pdf, page 11replacement resulting from RH previous leaks in the pipeline, The cluster includes pipe repair or replacement resulting from 2002 Pl 1 internal inspection, For the Quakertown to Hei lertown segment„submit a written plan to replace pipe scctlons with clusters of repairs or removals after superimposing RAd lntcgl Rtll'lg thc lntcfnal lnspcctlon lcsults fcqulrcd In A4. A cluster ls defined Rs 8 01M-fnllc long pipehne segment with tive or more repails or removals in the pipeline's history. Submit a written pipe replacement plan that has been prioritized after considering Rt least thc foHowlng factors: Class Locations'„safety scnsltlvc areas defined as RI'I arc8 th3t cxtcAds 220 valds fI'ofn 8 public paved road, , 8 pUbllc gRthcrlng area, or any building intended for human occupancy; leak history'„&Ial internal inspection report„' and„number of leak repairs or pipeline removals, Incorporate foreseeable class location chaAgcs based on rcglo»81 dcvcloprncnt history Into accoUnt. Replace the affected uncoated 14-inch diameter pipe using the following guidelines: In Class 3 areas replace within two years. ln Class 2 areas rcplacc within three years. In Class 1 areas I"cplace wlthln flvc years. Subnut the written plans for Itcfns A, 8 4 C, addressing repRlf, I'cmcdlai action, and cathodic protection to the Director„Eastern Region, for review. Each element of the plan must be approved by thc Director, Eastern Rey'on, who may provide approvals incrementally. implement the plan as approved. Provide dctalicd reports to tl'lc Director, Eastern Rcglon, Ot flndlngs and actions taken to repair thc pl pcillM Idcntlfylng the anolTlallcs detected and evaluated tlMlf location circumfcrentiRHy on thc pipe, the characterization of the anomalies (type and size of defect)„ the severity of the anomaly, and the repair action taken, including the size predicted by the internal inspection tool and the actual size. Additionally, provide a summary by type of defect of the number of ano»18iics identified by the tool, the number of actual anomahes found, and number repaired, Res ponde»t must request approval from thc Director, Eastern Region to remove or odify the self-imposed pressure restriction of the pipeline segments. The request »1Ust dcnloAstratc that thc hazard has been abated and that 8 higher prcssUfc ls justI fled based on an anaivsls showIng that thc prcssure lncl case ls safe coAsldcrlng RH known defects, anomalies and operating parameters o t the pipeline. Respondent will each month submit status repolts on the types of repairs or removals completed, cathodic protection readings, nexv leak discoveries, number Of' dlstrlbuted anode ground beds Installed, anomaly dIscoverlcs, RAG other pert»lent t'acts as applied to this Order.#

120021004h_corrective action order_06202002_text.pdf, page 1213) The Director, Eastern Region, may grant an extension of time for compliance with any of the terms of this order for good cause. A request for an extension must bc in wrltlng. R cspondcnt Irlay appeal 8rly decl sion of thc Director, Eastern Rcglon to thc Assoclatc Admlnlstrator for Plpcllnc Safety, Dcclslons of thc Assoclatc Adlnlrlistrator shaH bc final. The procedures for the issuance of this Order are described in Part 190, Title 49„Code of Federal Regulations, $ 190. 233, a copy of which is enclosed, is made part of this Order and describes thc Respondents' procedural rights re1ative to this Order. Failure to comply with this Order may result in the assessment of civil penalties of not more than $25, 000 per day and in referral to the Attorney General for appropriate relief in United States District Court ey Gerard Assoclatc Admlnlstrator for Plpcl Inc Safety#

120021004H_Closure Letter_02102011_text.pdf, page 1Official PDFU.S. Department 820 Bear Tavern Road, Suite 103 Of Transportation West Trenton, NJ 08628 Pipeline and 609.989.2171 Hazardous Materials Safety Administration OVERNIGHT EXPRESS MAIL February 10, 2011 Mr. Victor Gaglio Senior Vice President of Operations and Engineering NiSource Gas Transmission & Storage 1700 MacCorkle Avenue Charleston, WV 25314 CPF 1-2002-1004H Dear Mr. Gaglio: On June 20, 2002, Columbia Gas Transmission Company (CGT), which is a subsidiary of NiSource Gas Transmission & Storage, was issued a Corrective Action Order in the above referenced case. Subsequently, CGT was issued an Amendment to the Corrective Action Order on November 19, 2003. This Order included a requirement to take corrective actions on your pipeline. Based on our review of the documentation you provided, it has been determined that you have complied with the terms of this Order. Accordingly, this case is now closed and no further action is contemplated with respect to the matters involved in this case. Thank you for your cooperation in this matter. Sincerely, Byron Coy, PE Director, Easter Region Pipeline and Hazardous Materials Safety Administration#