COLUMBIA GAS TRANSMISSION, LLC — Notice of Amendment

party submissionOfficial PDF120111002M_Operator Response to NOA_04152011.pdf#

120111002M_Closure Letter_05312011_text.pdf, page 1Official PDFU.S. Department 820 Bear Tavern Road, Suite 103 Of Transportation West Trenton, NJ 08628 Pipeline and 609.989.2171 Hazardous Materials Safety Administration UPS OVERNIGHT DELIVERY May 31, 2011 Mr. Victor Gaglio Sr. Vice President of Operations & Engineering NiSource Gas Transmission & Storage 1700 MacCorkle Avenue SE Charleston, WV 25314 CPF 1-2011-1002M Dear Mr. Gaglio: From September 21 through 24, 2009, representatives of New York State Department of Public Service (NYSDPS), acting as agents for the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code, inspected Columbia Gas Transmission Corporation’s facility (CGT), which is a subsidiary of NiSource Gas Transmission & Storage, in Binghamton, New York. As a result of the inspection, CGT was issued a Notice of Amendment on March 22, 2011, which proposed amendment of your procedures. CGT submitted its amended procedures on April 15, 2011. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Byron Coy, PE Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Cc: NYSDPS- Mr. Gavin Nicoletta#

120111002M_Notice of Amendment_03222011_text.pdf, page 1Official PDFU.S. Department 820 Bear Tavern Road, Suite 103 Of Transportation West Trenton, NJ 08628 Pipeline and 609.989.2171 Hazardous Materials Safety Administration NOTICE OF AMENDMENT OVERNIGHT EXPRESS MAIL March 22, 2011 Mr. Victor Gaglio Sr. Vice President of Operations & Engineering NiSource Gas Transmission & Storage 1700 MacCorkle Avenue SE Charleston, WV 25314 CPF 1-2011-1002M Dear Mr. Gaglio: From September 21 through 24, 2009, representatives of New York Public Service Commission (NY PSC) acting as agents for the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code, inspected Columbia Gas Transmission Corp’s facility (CGT), which is a subsidiary of NiSource Gas Transmission & Storage, in Binghamton, New York. On the basis of the inspection, PHMSA has identified the apparent inadequacies found within CGT’s plans or procedures, as described below: 1. §192.605 Procedural manual for operations, maintenance, and emergencies. (b) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following, if applicable, to provide safety during maintenance and operations. (8) Periodically reviewing the work done by operator personnel to determine the effectiveness and adequacy of the procedures used in normal operation and maintenance and modifying the procedure when deficiencies are found.#

120111002M_Notice of Amendment_03222011_text.pdf, page 2CPF 1-2011-1002M At the time of the inspection, CGT did not have specific written procedures for periodically reviewing the work done by operator personnel. In reviewing CGT’s Operation and Maintenance manual, procedures for periodically reviewing the work done by operator personnel were not found. CGT explained it had an internal process by which, annually, each team leader is sent from corporate to evaluate a single procedure, then the results were sent back to be reviewed by a committee. At the time of the inspection, this internal process was not documented. CGT’s procedures need to specify the process for reviewing work performed by operator personnel. 2. §192.615 Emergency plans. (b) Each operator shall: (2) Train the appropriate operating personnel to assure that they are knowledgeable of the emergency procedures and verify that the training is effective. CGT’s Emergency Plan procedures were inadequate because the plans did not completely address training of appropriate personnel to assure that they were knowledgeable of the emergency procedures and verified that the training was effective. CGT’s procedures do not provide a method to review performance, make appropriate changes, and verify that training was effective. CGT’s electronic database that tracks the emergency training, Learning Management System (LMS), documents that training was completed. CGT’s Emergency Plan must clearly describe what actions must be taken to meet the requirement of section 192.615(b)(2). Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings. Please refer to this document and note the response options. 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). If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue a Final Order. 120111002M_Notice of Amendment_03222011 Page 2 of 3#

120111002M_Notice of Amendment_03222011_text.pdf, page 3CPF 1-2011-1002M If, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that Columbia maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Byron Coy, PE, Director, Eastern Region, Pipeline and Hazardous Materials Safety Administration, 820 Bear Tavern Rd, West Trenton, NJ 08628. In correspondence concerning this matter, please refer to CPF 1-2011-1002M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Byron E. Coy Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings 120111002M_Notice of Amendment_03222011 Page 3 of 3#