COLUMBIA GAS TRANSMISSION, LLC — Warning Letter

120071015w_warning letter_11272007_text.pdf, page 1Official PDFo U S Department of Transportation Pipeline and Hazardous Materials Safety ttdministratlon 409 3rd Street, SW, Suite 300 Washington, DC 20024 WARNING LETTER CERTIFIED MAIL - RETURN RECEIPT RE UESTED November 27, 2007 Mr Reed Robinson Vice President, Field Services Columbia Gas Transmission P 0 Box 1273 1700 MacCorckle Avenue, SE Charleston, WV 25325-1273 CPF 1-2007-1015W Dear Mr Robinsion On November 8, 2007, a representative of the Pipelme and Hazardous Matenals Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your underground damage prevention notification related to your nght-of-way cleanng work for the consnuctton of the Columbia Gas Transmission (CGT) WB-2 VA Loop prolect along portions of Thoroughfare Rd in Roctungham County, Vtrgtma This inspection was related to a damage investigation imtiated by PHMSA as a result of a reported lut on a Columbia Gas of Virginia dhstrtbunon pipehne dunng the CGT nght-of-way stump removal cleanng for the CGT loop pro) ect As a result of the review of this matter and the site inspection, it appears that you have committed a probable violation of the Pipelme Safety Regulations, Title 49, Code of Federal Regulations The items inspected and the probable violation is#

120071015w_warning letter_11272007_text.pdf, page 21. 1'1192. 614 (c)(5) Provide for temporary marking of buried pipelines in the area of excavation activity before, as far as practical, the activity begins. Columbia Gas Transmission Corporation (CGT) did not provide for adequate temporary marking of buned pipehnes in the area of the nght of way cleanng work for the CGT WB-2 VA Loop prolect, resulting m CGT third party damage to a Columbia Gas of Virginia gas distribution hne Dunng the course of the November 8, 2007 PHMSA field site visit of the WB-2 VA Loop proJect construction work, the Columbia Gas of Virgmia mcident site was visited A CGT contractor hit the Columbia Gas of Virgmia distnbution hne on September 5, 2007 while performing stump removal work for CGT An October 16, 2007 wntten response to PHMSA from CGT confirmed that the incident did take place Documents requested from CGT and received by PHMSA were one-call tickets from September 5-7, 2007 related to the stump removal work done near the incident site PHMSA was given the one-call tickets up to and beyond the area of the incident location According to CGT contractor's representative contacted by PHMSA, the one-call ticket for their cleanng work was not called in untd September 4, 2007, the day after Labor Day and the day the stump removal work began The damage was due to the CGT contractor's lack of not coordinating its work properly because of the Labor Day hohday, and mistakenly behevmg that a nearby Meter and Regulator (M 8c R) stanon owned and operated by the Columbia Gas of Vtrgima did not have a distnbution pipehne that crossed the intended area of the nght-of-way cleanng work Under 49 Uiuted States Code, I'l 60122, you are sublect to a civil penalty not to exceed $100, 000 for each violation for each day the violation persists up to a maximum of $1, 000, 000 for any related senes of violations. We have reviewed the circumstances and supporting documents involved in tlus case, and have decided not to conduct additional enforcement action or penalty assessment proceedings at this time We advise you to correct the item identified in this letter Failure to do so will result in Columbia Gas Transmission being sublect to additional enforcement action No reply to this letter is required If you choose to reply, in your correspondence please refer to CPF 1-2007-1015W. Be advised that all matenal you submit m response to this enforcement action is sub)ect to being made pubhcly available If you believe that any portion of your responsive matenal quahfies 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 beheve quahfy for confidential treatment redacted and an explanation of why you beheve the redacted mformanon qualifies for confidential treatment under 5 U S C 552(b)#

120071015w_warning letter_11272007_text.pdf, page 3Sincerely, Byron E Coy, Jr Director, Eastern Region Ptpehne and Hazardous Materials Safety Admuustranon#