{"operation":"document","citation":"CPF 120111002M","title":"COLUMBIA GAS TRANSMISSION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2011-03-22","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(8), 192.615(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120111002m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120111002m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120111002m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120111002M","body":"Notice of Amendment involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(8),  192.615(b)(2). The case was opened on 2011-03-22 and is reported as closed as of 2011-05-31. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120111002M_Closure Letter_05312011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120111002M/120111002M_Closure%20Letter_05312011.pdf\n\n120111002M_Closure Letter_05312011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120111002M/120111002M_Closure%20Letter_05312011_text.pdf\n\n120111002M_Notice of Amendment_03222011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120111002M/120111002M_Notice%20of%20Amendment_03222011.pdf\n\n120111002M_Notice of Amendment_03222011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120111002M/120111002M_Notice%20of%20Amendment_03222011_text.pdf\n\n120111002M_Operator Response to NOA_04152011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120111002M/120111002M_Operator%20Response%20to%20NOA_04152011.pdf\n\n120111002M_Closure Letter_05312011_text.pdf\n\nU.S. Department 820 Bear Tavern Road, Suite 103\nOf Transportation West Trenton, NJ 08628\nPipeline and 609.989.2171\nHazardous Materials\nSafety Administration\nUPS OVERNIGHT DELIVERY\nMay 31, 2011\nMr. Victor Gaglio\nSr. Vice President of Operations & Engineering\nNiSource Gas Transmission & Storage\n1700 MacCorkle Avenue SE\nCharleston, WV 25314\nCPF 1-2011-1002M\nDear Mr. Gaglio:\nFrom September 21 through 24, 2009, representatives of New York State Department of Public\nService (NYSDPS), acting as agents for the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code, inspected Columbia\nGas Transmission Corporation’s facility (CGT), which is a subsidiary of NiSource Gas\nTransmission & Storage, in Binghamton, New York. As a result of the inspection, CGT was issued\na Notice of Amendment on March 22, 2011, which proposed amendment of your procedures.\nCGT submitted its amended procedures on April 15, 2011. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nCc: NYSDPS- Mr. Gavin Nicoletta\n\n120111002M_Notice of Amendment_03222011_text.pdf\n\nU.S. Department 820 Bear Tavern Road, Suite 103\nOf Transportation West Trenton, NJ 08628\nPipeline and 609.989.2171\nHazardous Materials\nSafety Administration\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS MAIL\nMarch 22, 2011\nMr. Victor Gaglio\nSr. Vice President of Operations & Engineering\nNiSource Gas Transmission & Storage\n1700 MacCorkle Avenue SE\nCharleston, WV 25314\nCPF 1-2011-1002M\nDear Mr. Gaglio:\nFrom September 21 through 24, 2009, representatives of New York Public Service Commission\n(NY PSC) acting as agents for the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) pursuant to Chapter 601 of 49 United States Code, inspected Columbia Gas\nTransmission Corp’s facility (CGT), which is a subsidiary of NiSource Gas Transmission &\nStorage, in Binghamton, New York.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nCGT’s plans or procedures, as described below:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(8) Periodically reviewing the work done by operator personnel to determine the\neffectiveness and adequacy of the procedures used in normal operation and\nmaintenance and modifying the procedure when deficiencies are found.\n\n\n\nCPF 1-2011-1002M\nAt the time of the inspection, CGT did not have specific written procedures for periodically\nreviewing the work done by operator personnel.\nIn reviewing CGT’s Operation and Maintenance manual, procedures for periodically reviewing\nthe work done by operator personnel were not found. CGT explained it had an internal process\nby which, annually, each team leader is sent from corporate to evaluate a single procedure, then\nthe results were sent back to be reviewed by a committee. At the time of the inspection, this\ninternal process was not documented.\nCGT’s procedures need to specify the process for reviewing work performed by operator\npersonnel.\n2. §192.615 Emergency plans.\n(b) Each operator shall:\n(2) Train the appropriate operating personnel to assure that they are\nknowledgeable of the emergency procedures and verify that the training is effective.\nCGT’s Emergency Plan procedures were inadequate because the plans did not completely\naddress training of appropriate personnel to assure that they were knowledgeable of the\nemergency procedures and verified that the training was effective.\nCGT’s procedures do not provide a method to review performance, make appropriate changes,\nand verify that training was effective. CGT’s electronic database that tracks the emergency\ntraining, Learning Management System (LMS), documents that training was completed.\nCGT’s Emergency Plan must clearly describe what actions must be taken to meet the\nrequirement of section 192.615(b)(2).\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue a Final Order.\n120111002M_Notice of Amendment_03222011 Page 2 of 3\n\n\n\nCPF 1-2011-1002M\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the inadequacies\n(49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that you submit your\namended procedures to my office within 30 days of receipt of this Notice. This period may be\nextended by written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that Columbia maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Byron Coy, PE, Director, Eastern Region, Pipeline and\nHazardous Materials Safety Administration, 820 Bear Tavern Rd, West Trenton, NJ 08628. In\ncorrespondence concerning this matter, please refer to CPF 1-2011-1002M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nByron E. Coy\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120111002M_Notice of Amendment_03222011 Page 3 of 3","truncated":false,"body_characters":8021}