{"operation":"document","citation":"CPF 120091008W","title":"COLUMBIA GAS TRANSMISSION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2009-10-02","effective_on":null,"summary":"CLOSED warning letter citing 192.481(c), 192.605(b)(3), 192.707(a)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120091008w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120091008w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120091008w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120091008W","body":"Warning Letter involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.481(c),  192.605(b)(3),  192.707(a)(2). The case was opened on 2009-10-02 and is reported as closed as of 2009-10-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120091008W_Warning Letter_10022009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120091008W/120091008W_Warning%20Letter_10022009.pdf\n\n120091008W_Warning Letter_10022009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120091008W/120091008W_Warning%20Letter_10022009_text.pdf\n\n120091008W_Warning Letter_10022009_text.pdf\n\nU.S. Department 820 Bear Tavern Road, Suite 306\nOf Transportation West Trenton, NJ 08628\nPipeline and 609.989.2171\nHazardous Materials\nSafety Administration\nWARNING LETTER\nEXPRESS OVERNIGHT DELIVERY\nOctober 02, 2009\nMr. Victor Gaglio\nSr. Vice President of Operations & Engineering\nColumbia Gas Transmission Company\n1700 MacCorkle Avenue, S.E.\nP.O. Box 1273\nCharleston, WV 25314\nCPF 1-2009-1008W\nDear Mr. Gaglio:\nOn June 9 to13, 2008, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code conducted an\ninspection on your Port Jervis, NJ/PA facilities portion of the transmission pipelines for\njurisdictional compliance under Title 49, Code of Federal Regulations, Section §192.\nAs a result of the inspection, it appears that you have committed probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n1. §192.481 (c) Atmospheric corrosion control: Monitoring.\n(c) If atmospheric corrosion is found during an inspection, the operator must\nprovide protection against the corrosion as required by Sec. 192.479.\nSection §192.481(c) requires that if atmospheric corrosion is found, protection against corrosion\nmust be provided.\nAt the time of inspection, a field review of the operator’s Easton compressor station revealed\natmospheric corrosion on station pipes and coating failure on a compressor station heater.\n\n\n\nCPF 1-2009-1008W\n2. §192.605 (b) (3) Procedural manual for operations, maintenance, and emergencies\n(3) Making construction records, maps, and operating history available to\nappropriate operating personnel.\nSection §192.605 (b) (3) requires that operators maintain their pipeline maps.\nNo updated pipeline maps were available. The legend on an available map – CGT Asset Group\n13 at the time of inspection, was dated December 1999. The operator stated that at the time,\nupdated maps showing piping changes were being worked on.\n3. §192.707 Line markers for mains and transmission lines.\n(a) Buried pipelines. Except as provided in paragraph (b) of this section, a line\nmarker must be placed and maintained as close as practical over each buried main\nand transmission line:\n(1) At each crossing of a public road and railroad; and\n(2) Wherever necessary to identify the location of the transmission line or main to\nreduce the possibility of damage or interference.\nSection §192.707(a) (2) requires that operators provide and maintain line markers necessary to\nreduce the possibility of damage or interference.\nIn the vicinity of Weber Rd, Mount Pleasant Rd, and Cummings Road, there were long expanses\nof right-of-way with an inadequate number of line markers.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violation persists up to a maximum of $1,000,000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this letter.\nFailure to do so will result in Columbia Gas Transmission Company being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2009-1008W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":4779}