CPF 120101003W
CPF 120101003W
120101003W_Warning Letter_03292010_text.pdf, page 1Official PDFU.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 March 29, 2010 Mr. Victor Gaglio Senior Vice President Columbia Gas Transmission 1700 MacCorkle Avenue, SE Charleston, West Virginia 25314 CPF 120101003W Dear Mr. Gaglio: On September 9, 2008, an inspector from the New York Public Service Commission, acting as an agent for the Pipeline and Hazardous Materials Safety Administration, pursuant to Chapter 601 of 49 United States Code, inspected your Dundee Gas Storage Field in Rock Stream, New York. As a result of the inspection, it appears that you have committed a probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the probable violation is: 1. 192.475 Internal corrosion control: General. (b) Whenever any pipe is removed from a pipeline for any reason, the internal surface must be inspected for evidence of corrosion. During May and June of 2007, Columbia Gas Transmission (Columbia) removed the hydrogen sulfide plant from Line 9305 and replaced it with a pig launcher/receiver. Columbia was unable to provide associated records, requested by the inspector, to demonstrate that the internal surface of the removed facility was inspected for evidence of corrosion. The evidence for the violation is lack of a record to confirm the required action was performed.#
120101003W_Warning Letter_03292010_text.pdf, page 2CPF 120101003W 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 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 120101003W. 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 cc: Gavin Nicoletta, NYPSC 120101003W_Warning Letter_03292010 2 of 2#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.