# COLUMBIA GAS TRANSMISSION, LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 120081003
- **title:** COLUMBIA GAS TRANSMISSION, LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2008-03-14
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 192.605(a).
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-120081003.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-120081003
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120081003
**body:**

Notice of Probable Violation involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2008-03-14 and is reported as closed as of 2010-08-20. Proposed civil penalty: $100,000. Assessed civil penalty: $100,000. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120081003_Final Order_08202010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120081003/120081003_Final%20Order_08202010.pdf

120081003_Final Order_08202010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120081003/120081003_Final%20Order_08202010_text.pdf

120081003_NOPV PCP_03142008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120081003/120081003_NOPV%20PCP_03142008.pdf

120081003_nopv pcp_03142008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120081003/120081003_nopv%20pcp_03142008_text.pdf

120081003_Operator Response_04232008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120081003/120081003_Operator%20Response_04232008.pdf

120081003_Final Order_08202010_text.pdf

AUG 20 2010
Mr. Christopher A. Helms
Executive Vice President
NiSource, Inc.
5151 San Felipe, Suite 2500
Houston, Texas 77056
Re: CPF No. 1-2008-1003
Dear Mr. Helms:
Enclosed please find the Final Order issued in the above-referenced case. It makes a finding of
violation and assesses a civil penalty of $100,000. I acknowledge receipt of payment of the full
penalty amount, by wire transfer, dated June 30, 2010. This enforcement action 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. Byron Coy, Director, Eastern Region, PHMSA (by email to byron.coy@dot.gov)
Mr. Kenneth W. Christman, Esq., Counsel for Columbia Gas Transmission, LLC (by
email to kchrist@nisource.com)
CERTIFIED MAIL – RETURN RECEIPT REQUESTED [7005 1160 0001 0039 0720]



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. 1-2008-1003
)
Respondent. )
_______________________________ )
FINAL ORDER
On August 23, 2006, pursuant to 49 U.S.C. § 60117, a representative of the West Virginia Public
Service Commission, as agent for the Pipeline and Hazardous Materials Safety Administration
(PHMSA), Office of Pipeline Safety (OPS), conducted an investigation of an August 21, 2006
incident involving the pipeline system operated by Columbia Gas Transmission, LLC (CGT or
Respondent),
transmission pipelines throughout the eastern and southern United States.
1 in Hardy County, West Virginia. CGT operates over 14,000 miles of natural gas
The OPS investigation arose from an incident in which an excavator performing work for CGT
struck an underground tap on the company’s WB Loop Line on the grounds of the Lost River
Compressor Station. The resulting damage caused a rupture and release of gas. No property
damage or injuries resulted from the incident.
As a result of the investigation, the Director, Eastern Region, OPS, issued to Respondent, by
letter dated March 14, 2008, a Notice of Probable Violation and Proposed Civil Penalty (Notice).
In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that CGT had committed a
violation of 49 C.F.R. § 192.605(a) and proposed assessing a civil penalty of $100,000 for the
alleged violation.
CGT responded to the Notice by letter dated April 23, 2008. The company initially contested the
allegation of violation and the proposed civil penalty, and requested a hearing. A hearing was
held on November 20, 2008, with Jim Curry, an attorney from the Office of Chief Counsel,
PHMSA, presiding. Respondent was represented by counsel during the hearing. Respondent
timely submitted a post-hearing closing statement on December 22, 2008. By letter dated
June 30, 2010, Respondent sought closure of the case and informed PHMSA that “after further
consideration of the [Notice] and related circumstances,” it would pay the full amount of the
proposed civil penalty.2
CGT also described the actions it had taken since the Notice to improve
the safety of its pipeline operations.
1 CGT is a wholly owned subsidiary of NiSource, Inc.
2 NiSource Gas Transmission & Storage sent this letter and paid the civil penalty on behalf of CGT.



2
Payment of the penalty serves to close the case with prejudice to Respondent.
FINDING OF VIOLATION
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.605(a), which states, in
relevant part:
§ 192.605 Procedural manual for operations, maintenance, and
emergencies.
(a) General. Each operator shall prepare and follow for each
pipeline, a manual for written procedures for conducting operations and
maintenance activities and for emergency response. For transmission
lines, the manual must include procedures for handling abnormal
operations. This manual must be reviewed and updated by the operator at
intervals not exceeding 15 months, but at least once each calendar year.
This manual must be prepared before operations of a pipeline system
commence. Appropriate parts of the manual must be kept at locations
where operations and maintenance activities are conducted.
The Notice alleged that CGT violated 49 C.F.R. § 192.605(a) by failing to follow its manual of
written procedures for conducting operations and maintenance activities (O&M Plan).
Specifically, it alleged that the operator failed to follow its procedures for Trenching and
Excavation, located in Section No. 110.01.13 of the O&M Plan, by failing to communicate to its
excavation contractor the exact location of an underground pipeline tap on the WB Loop Line.
The Notice alleged that this failure was a contributing factor to the August 21, 2006 incident.
CGT initially contested this allegation on numerous grounds, but later paid the full proposed
civil penalty and requested closure of the case. Accordingly, based upon a review of all of the
evidence, I find that CGT committed a violation of § 192.605(a) by failing to follow its manual
of written procedures for conducting operations and maintenance activities.
This finding of violation will be considered a prior offense in any subsequent enforcement action
taken against Respondent. Having reviewed the record and considered the assessment criteria, I
assess Respondent a total civil penalty of $100,000, which amount has already been paid in full
by Respondent.
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
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