# COLUMBIA GAS TRANSMISSION, LLC — Warning Letter

- **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:** Not available
- **summary:** CLOSED warning letter citing 192.481(c), 192.605(b)(3), 192.707(a)(2).
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- **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.

Official case documents:

120091008W_Warning Letter_10022009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120091008W/120091008W_Warning%20Letter_10022009.pdf

120091008W_Warning Letter_10022009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120091008W/120091008W_Warning%20Letter_10022009_text.pdf

120091008W_Warning Letter_10022009_text.pdf

U.S. Department 820 Bear Tavern Road, Suite 306
Of Transportation West Trenton, NJ 08628
Pipeline and 609.989.2171
Hazardous Materials
Safety Administration
WARNING LETTER
EXPRESS OVERNIGHT DELIVERY
October 02, 2009
Mr. Victor Gaglio
Sr. Vice President of Operations & Engineering
Columbia Gas Transmission Company
1700 MacCorkle Avenue, S.E.
P.O. Box 1273
Charleston, WV 25314
CPF 1-2009-1008W
Dear Mr. Gaglio:
On June 9 to13, 2008, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code conducted an
inspection on your Port Jervis, NJ/PA facilities portion of the transmission pipelines for
jurisdictional compliance under Title 49, Code of Federal Regulations, Section §192.
As a result of the inspection, it appears that you have committed probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the
probable violations are:
1. §192.481 (c) Atmospheric corrosion control: Monitoring.
(c) If atmospheric corrosion is found during an inspection, the operator must
provide protection against the corrosion as required by Sec. 192.479.
Section §192.481(c) requires that if atmospheric corrosion is found, protection against corrosion
must be provided.
At the time of inspection, a field review of the operator’s Easton compressor station revealed
atmospheric corrosion on station pipes and coating failure on a compressor station heater.



CPF 1-2009-1008W
2. §192.605 (b) (3) Procedural manual for operations, maintenance, and emergencies
(3) Making construction records, maps, and operating history available to
appropriate operating personnel.
Section §192.605 (b) (3) requires that operators maintain their pipeline maps.
No updated pipeline maps were available. The legend on an available map – CGT Asset Group
13 at the time of inspection, was dated December 1999. The operator stated that at the time,
updated maps showing piping changes were being worked on.
3. §192.707 Line markers for mains and transmission lines.
(a) Buried pipelines. Except as provided in paragraph (b) of this section, a line
marker must be placed and maintained as close as practical over each buried main
and transmission line:
(1) At each crossing of a public road and railroad; and
(2) Wherever necessary to identify the location of the transmission line or main to
reduce the possibility of damage or interference.
Section §192.707(a) (2) requires that operators provide and maintain line markers necessary to
reduce the possibility of damage or interference.
In the vicinity of Weber Rd, Mount Pleasant Rd, and Cummings Road, there were long expanses
of right-of-way with an inadequate number of line markers.
Under 49 United States Code, § 60122, you are subject 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 series of violations. We have reviewed the circumstances and supporting documents
involved in this case, and have decided not to conduct additional enforcement action or penalty
assessment proceedings at this time. We advise you to correct the item(s) identified in this letter.
Failure to do so will result in Columbia Gas Transmission Company being subject to additional
enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 1-2009-1008W. Be advised that all material you submit in response to this enforcement
action is subject to being made publicly available. If you believe that any portion of your
responsive material qualifies 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 believe qualify for confidential treatment redacted and an explanation of why you believe
the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).
Sincerely,
Byron Coy, PE
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
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