{"operation":"document","citation":"CPF 120121025H","title":"COLUMBIA GAS TRANSMISSION, LLC — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-12-20","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120121025h.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120121025h.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120121025h","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120121025H","body":"Corrective Action Order involving COLUMBIA GAS TRANSMISSION, LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2012-12-20 and is reported as closed as of 2014-04-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120121025H_Closure Letter_04022014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120121025H/120121025H_Closure%20Letter_04022014.pdf\n\n120121025H_Closure Letter_04022014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120121025H/120121025H_Closure%20Letter_04022014_text.pdf\n\n120121025H_Corrective Action Order_12202012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120121025H/120121025H_Corrective%20Action%20Order_12202012.pdf\n\n120121025H_Corrective Action Order_12202012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120121025H/120121025H_Corrective%20Action%20Order_12202012_text.pdf\n\n120121025H_Corrective Action Order_12202012_text.pdf\n\nDECEMBER 20 2012\nVIA CERTIFIED MAIL AND FAX TO: (304) 357-2644\nMr. Robert C. Skaggs, Jr.\nPresident and Chief Executive Officer\nColumbia Gas Transmission, L.L.C\n1700 MacCorkle Avenue SE\nCharleston, WV 25314\nMr. Shawn Patterson\nPresident, Operations and Project Delivery\nColumbia Gas Transmission, L.L.C.\n1700 MacCorkle Avenue\nP.O. Box 1273\nCharleston, WV 25314\nRe: CPF No. 1-2012-1025H\nDear Mr. Skaggs and Mr. Patterson:\nEnclosed is a Corrective Action Order issued in the above-referenced case. It finds that\noperation of the 20-inch diameter Columbia Gas Transmission, L.L.C., natural gas transmission\npipeline, SM-80, is hazardous to life, property, and the environment without immediate\ncorrective action. The Corrective Action Order requires you to take immediate action to protect\nthe public, property, and the environment in connection with the December 11, 2012 failure of\nthe SM-80 Pipeline in Kanawha County, West Virginia. This segment is 26.2 miles long, from\nLanham Station to the Broad Run Meter facility. Service is being made by certified mail and\nfacsimile. Your receipt of this Corrective Action Order constitutes service of that document\nunder 49 C.F.R. § 190.5. The terms and conditions of this Order are effective upon receipt.\nWe look forward to a successful resolution of the concerns arising out of this failure to ensure\nthe safe operation of the pipeline. Please direct any questions on this matter to Byron Coy,\nDirector, Eastern Region, OPS, at (609) 989-2171.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator for Pipeline Safety\n\n\n\nEnclosure: Corrective Action Order and Copy of 49 C.F.R. §190.233\ncc: Mr. Byron Coy, Director, Eastern Region, PHMSA\nMr. David Hippchem, Manager Pipeline Safety, West Virginia Public Service\nCommission\n\n\n\n2\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nColumbia Gas Transmission L.L.C., ) CPF No. 1-2012-1025H\na subsidiary of NiSource Gas )\nTransmission & Storage )\n)\n)\n)\nRespondent )\n____________________________________)\nCORRECTIVE ACTION ORDER\nPurpose and Background\nThis Corrective Action Order (Order) is being issued, under authority of 49 U.S.C. § 60112, to\nColumbia Gas Transmission L.L.C.1 (Columbia Gas or Respondent), the operator of the 20-inch\nnatural gas transmission line, SM-80 (Affected Pipeline). On December 11, 2012, a pipeline\nrupture and fire occurred on the SM-80 pipeline, approximately 4.7 miles downstream of the\nLanham Compressor Station near Sissonville, WV. This Order finds that operation of the\npipeline without corrective action is hazardous to life, property, or the environment and requires\nRespondent to take immediate action to ensure the safe operation of the pipeline.\nOn December 11, 2012, Respondent experienced a failure on the Affected Pipeline requiring\nshutdown, and reported a natural gas pipeline failure to the National Response Center (NRC\n#1032935). Columbia Gas operates two additional pipelines, SM-86 Loop2 and SM-863, which\nrun parallel to the SM-80 pipeline in the incident area.\nPursuant to 49 U.S.C. § 60117, the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety (OPS), joined the National Transportation Safety Board\n(NTSB) and the Public Service Commission of West Virginia (PSCWV), acting as Agent for the\n1 Columbia Gas Transmission L.L.C., a subsidiary of NiSource Inc., owns and operates approximately 11,453 miles\nof pipeline in Delaware, Kentucky, Maryland, New Jersey, New York, North Carolina, Ohio, Pennsylvania,\nVirginia, and West Virginia.\n2 SM-86 Loop (Lanham Compressor Station to Broad Run) consists of approximately 26.0 miles of 30” diameter\npipeline.\n3 Line SM-86 (Lanham Compressor Station to Broad Run) consists of approximately 25.8 miles of 26” diameter\npipeline.\n\n\n\n3\nPHMSA, in the investigation of the Failure. OPS determined that the explosion and fire\noriginated in the Affected Pipeline, but the cause of the Failure is still under investigation. The\npreliminary findings of the investigation are as follows:\nPreliminary Findings\n• At approximately 12:43 p.m. EST, on December 11, 2012, Respondent experienced a\nfailure, in which a 15-foot section of pipe separated entirely from the Affected Pipeline\nand was ejected from the ground.\n• The NTSB noted at a December 14, 2012 press conference that evidence at the failure\nsite is consistent with external corrosion.4\n• The Failure site is located at Mile Post (M.P.) 4.7, in Sissonville, West Virginia,\napproximately two miles from the town center and 10 miles north of Charleston, West\nVirginia.5\n• The Failure resulted in the release and ignition of an undetermined amount of gas and\ncreated two flame plumes. As a result of the explosion and ensuing fire, Interstate 77 was\ndamaged and closed. In addition, the fire destroyed three neighbouring homes, severely\ndamaged another, and inflicted some damage to other residences.\n• Following the Failure, Respondent isolated the failed pipe by closing the Rocky Hollow\nvalve (13:20 p.m.) and the Lanham valve (13:40 p.m.). Currently, the failed segment is\nblocked off at upstream and downstream block valves, has not been repaired, or returned\nto service.\n• Respondent notified the National Response Center (Report # 1032935) at approximately\n1:45 p.m.\n• Due to its proximity to the Failure Site, Interstate 77 was closed by the West Virginia\nHighway Department. The highway surfaces sustained thermal damage, causing the\nhighway to be closed for approximately 18 hours while repairs were made.\n• Line SM-80 was originally installed in 1951, from Lanham to Broad Run (26.2 miles). In\n1955, it was extended from Lanham to Leach. Since that time, various segments of the\npipeline have been replaced, resulting in a line with various vintages of pipe, the newest\nof which stems from a 1992 project.\n• Columbia Gas operates two additional pipelines, SM-86 Loop and SM-86, which run\nparallel to the Affected Pipeline in the incident area. Following the explosion, service\nfrom Lanham Compressor Station to Patterson Fork was curtailed as a precautionary\nmeasure. After shut-in, Lines SM-86 Loop and SM-86 maintained a static pressure of\napproximately 520 psig.\n4 http://www.youtube.com/watch?v=DDK80Orr2hE&feature=youtu.be.\n5 See Map of Failure Site.\n\n\n\n4\n• At the incident location, SM-86 and the Affected Pipeline are separated by approximately\n183 feet. Through consultation with an independent engineering firm, Det Norske\nVeritas (DNV), the Respondent concluded that the incident did not affect Line SM-86\nand restored pressure slowly over a 2.5 hour period. Line SM-86 was returned to full\nservice in the early morning hours of December 12, 2012. No leaks were detected on the\npipeline during foot or aerial leakage surveys that were performed on start-up.\n• At the incident location, Line SM-86 Loop and the Affected Pipeline are separated by\napproximately 53 feet. DNV6 also concluded that SM-86 Loop was not adversely\nimpacted by the SM-80 accident. However, since SM-86 Loop is closer to SM-80,\nColumbia Gas developed a Return to Service Plan, dated December 15, 2012, for SM-86\nLoop, which OPS reviewed and approved. The Return to Service Plan for SM-86 Loop\npipeline was successfully implemented on December 19, 2012.\n• OPS observed general wall thinning on the underside of the Affected Pipeline at the\nFailure location, OPS has preliminarily concluded that general wall thinning is a major\nfactor in the cause of the Failure.\n• The Affected Pipeline pipe at the failure location was constructed in 1967. Preliminary\ndata from the pipe at the Failure location shows a general wall thickness of 0.281 inches,\n20 inches in diameter and has an electric resistance weld (ERW) long seam.\nDetermination of Necessity for Corrective Action Order and Right to Hearing\nUnder 49 U.S.C. § 60112 and 49 C.F.R. § 190.233, the Associate Administrator for Pipeline\nSafety (Associate Administrator) may issue a corrective action order (CAO) after providing\nreasonable notice and the opportunity for a hearing if he finds that a particular pipeline facility is\nor would be hazardous to life, property, or the environment. The terms of such an order may\ninclude the suspended or restricted use of a pipeline facility, physical inspection, testing, repair,\nreplacement, or any other action as appropriate. The Associate Administrator may also issue a\ncorrective action order without providing any notice or the opportunity for a hearing if he finds\nthat a failure to do so expeditiously will result in likely serious harm to life, property or the\nenvironment. The opportunity for a hearing will be provided as soon as practicable after the\nissuance of the CAO in such cases.\nAfter evaluating the foregoing preliminary findings of fact, I find that the continued operation of\nthe pipeline without corrective measures would be hazardous to life, property and the\nenvironment. Additionally, after considering the age of the pipe, circumstances surrounding this\nFailure, the proximity of the pipeline to populated areas, and public roadways the hazardous\nnature of the product the pipeline transports, the uncertainties as to the cause of the failure, and\nthe ongoing investigation to determine the cause of the failure, I find that a failure to issue this\nOrder expeditiously to require immediate corrective action would result in likely serious harm to\nlife, property, and the environment. Accordingly, this Order mandating immediate corrective\n6 Exhibit A. DNV Study.\n\n\n\n5\naction is issued without prior notice and opportunity for a hearing. The terms and conditions of\nthis Order are effective upon receipt.\nWithin 10 days of receipt of this Order, Respondent may request a hearing, to be held as soon as\npracticable, by notifying the Associate Administrator for Pipeline Safety in writing, delivered\npersonally, by mail or by telecopy at (202) 366-4566. The hearing will be held in the Eastern\nRegion on a date that is mutually convenient to PHMSA and Respondent.\nAfter receiving and analyzing additional data in the course of this investigation, OPS may\nidentify other corrective measures that need to be taken. Respondent will be notified of any\nadditional measures required and amendment of this Order will be considered. To the extent\nconsistent with safety, Respondent will be afforded notice and an opportunity for a hearing prior\nto the imposition of any additional corrective measures.\nRequired Corrective Action\nPursuant to 49 U.S.C. § 60112, Columbia Gas is ordered to immediately take the following\ncorrective actions to ensure the safe operation of the Affected Pipeline, from Lanham Station to\nthe Broad Run Meter facility:\nI. PHASE I: RETURN LINE TO RESTRICTED OPERATION\na. Create Plan. Respondent must establish a written Phase I plan, and then seek written\napproval from the Director, Eastern Region, prior to the initiation of the plan.\nb. Repairs. Conduct repairs based on Respondent’s established written procedures. These\nprocedures are to be identified in the plan.\nc. d. e. f. Cathodic Protection (CP). Verify that all CP equipment and test stations are operating\nproperly, on all three pipelines, three miles up and down stream of the incident location.\nCritical Valves. Inspect and partially operate all critical valves that might be required\nduring any emergency to ensure they can be completely closed. Take prompt remedial\naction to correct any deficiencies.\nDischarge Pressure. Analyze and validate the actual discharge pressure at Lanham\ncompressor station for the Affected Pipeline at the time of the failure.\nTemporary Maximum Allowable Operating Pressure.\n1. 2. 3. Use the lower of 741 or 80% of the validated Lanham compressor station pressure\nin Item I.e. above.\nSet the temporary maximum allowable operating pressure, to the pressure\ndetermined in Item I.f.1.\nStep increase the pressure in SM-80, in quarter increments up to the pressure\ndetermined in Item I.f.1.\n\n\n\n6\nII. a. b. c. d. e. f. g. h. 4. 5. 6. 7. 8. 9. Set any and all pressure control and relief devices to insure the temporary\nmaximum allowable operating pressure will not be exceeded.\nEach quarter step is to be followed by a 30-minute idle period.\nConduct a leak survey over the entire segment with either foot or aerial patrol, but\nensure that an on-ground foot leak patrol with hydrogen flame ionization devices\nare conducted for 300 feet up and down stream of the incident location.\nInvestigate and resolve any discovered leaks before continuing the quarter step\nprocess.\nConduct another set of leak surveys, as set forth in Item I.f.6 above, 24 hours after\nthe fourth quarter pressure increment is completed.\nInvestigate and resolve any discovered leaks within 24 hours.\nPHASE II: LONG TERM ASSESSMENT AND REMEDIATION\nCreate Plan. Respondent must establish a written Phase II plan, and then seek written\napproval from the Director, Eastern Region, prior to the initiation of the plan.\nData. Review pipe data to ascertain records reflect actual pipe specifications, including\nrepresentative sampling with bell hole validation.\nRecords. Review MAOP records to ascertain MAOP does not exceed related records. If\nrecords do not support the current normal MAOP, arrange to reset normal MAOP to\nmatch records.\nIn-Line Inspection (ILI). Conduct an ILI inspection for High Resolution Deformation and\nMetal Loss within 30 days of completing Phase I. Submit to the Director, Eastern\nRegion, copies of the preliminary ILI reports, which would delineate any and all\nimmediate conditions that could jeopardize the temporary maximum allowable operating\npressure, from successful tool runs within 40 days of running the tools, directly from the\ntool vendors.\nAnalysis. Analyze all data, including field digs for tool results validation.\nExcavation. Excavate to investigate anomalies and make repairs as though the entire\nAffected Pipeline was in an HCA, using the criteria established in 49 C.F.R. Subpart O.\nCathodic Potential Survey. Perform close interval survey, investigate, and correct\ndeficiencies.\nCoating Integrity. Assess the integrity of the coating using direct current voltage gradient\n(DCVG) or alternating current voltage gradient (ACVG). Within 30 days of completing\nthe CIS. Perform a DCVG or ACVG survey in accordance with NACE RP 0502-2002,\nAppendix A, of all pipe locations where CIS results reveal CP levels below the\nrequirements of 49 CFR Part 192, Subpart I. Correct any deficiencies identified.\n\n\n\n7\nIII. PHASE III: CRITERIA\na. Criteria. Complete assessment and all necessary repairs in Phase II within 365 days of\nissuance of this Order.\nb. Summarize Work. Operator is to maintain records of work performed and prepare a\ncomplete package of information for presentation to OPS when they believe the work in\ncomplete. Operator is to use this information to seek OPS approval to return the line to\nfull and normal pressure.\nc. Restore Pressure. Pressure can only be returned to normal MAOP after all work is\nsuccessfully completed and approved by the Director.\nIV. PHASE IV: CONCLUSION CRITERIA\na. Monthly Reports for Phase I. Submit monthly reports to the Director, Eastern Region,\nthat: (1) include all available data and results of the testing and evaluations required by\nthis Order; and (2) describe the progress of the repairs or other corrective and/or remedial\nactions being undertaken. The first monthly report is due by the third week of each\nmonth until Phase I has been completed. The Director may adjust the reporting period\nupon written request of the Respondent.\nb. Quarterly Reports for Phase II. Submit quarterly reports to the Director, Eastern Region,\nthat: (1) include all available data and results of the testing and evaluations required by\nthis CAO; and (2) describe the progress of the repairs or other corrective and/or remedial\nactions being undertaken. The first calendar quarterly report are due once Phase I has\nbeen determined by the Director to be completed. There should be four quarterly report\nsubmissions while this Order is still in effect.\nc. Summary Report for Phase II. When the Operator believes Phase II has been completed,\na composite summary of all work performed is to be assembled, regardless of what may\nhave been provided earlier, and presented to the Director. The Director will review the\nsummary as part of the consideration for approval to return to normal MAOP.\nd. Documentation. It is requested but not required that Respondent maintain documentation\nof the costs associated with implementation of this Corrective Action Order. Include in\neach monthly report submitted, the to-date total costs associated with: (1) preparation and\nrevision of procedures, studies and analyses; (2) physical changes to pipeline\ninfrastructure, including repairs, replacements and other modifications; and (3)\nenvironmental remediation, if applicable.\nThe Director may grant an extension of time for compliance with any of the terms of this Order\nupon a written request timely submitted demonstrating good cause for an extension.\nWith respect to each submission that under this Order requires the approval of the Director, the\nDirector may: (a) approve, in whole or part, the submission; (b) approve the submission on\n\n\n\n8\nspecified conditions; (c) modify the submission to cure any deficiencies; (d) disapprove in whole\nor in part, the submission, directing that Respondent modify the submission, or (e) any\ncombination of the above. In the event of approval, approval upon conditions, or modification\nby the Director, Respondent must take all actions required by the submission, as approved or\nmodified by the Director. If the Director disapproves all or any portion of the submission,\nRespondent must correct all deficiencies within the time specified by the Director, and resubmit\nit for approval. If a resubmitted item is disapproved in whole or in part, the Director may again\nrequire Respondent to correct the deficiencies in accordance with the foregoing procedure, and\nthe Director may otherwise proceed to enforce the terms of this Order.\nBe advised 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), you must provide, along with the complete original\ndocument, a second copy of the document with those portions you believe qualify for\nconfidential treatment redacted, along with an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b).\nIn your correspondence on this matter, please refer to “CPF No. 1-2012-1025H” and for each\ndocument you submit, please provide a copy in electronic format whenever possible. The\nactions required by this Corrective Action Order are in addition to and do not waive any\nrequirements that apply to Respondent’s pipeline system under 49 C.F.R. Part 195, under any\nother order issued to Respondent under authority of 49 U.S.C. § 60101 et seq., or under any other\nprovision of Federal or State law.\nRespondent may appeal any decision of the Director to the Associate Administrator for Pipeline\nSafety. Decisions of the Associate Administrator shall be final.\nFailure to comply with this Order may result in the assessment of civil penalties and in referral to\nthe Attorney General for appropriate relief in United States District Court pursuant to\n49 U.S.C. § 60120.\nThe terms and conditions of this Corrective Action Order are effective upon receipt.\n__________________________________ __________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n120121025H_Closure Letter_04022014_text.pdf\n\nU.S. Department Of Transportation Pipeline and 609.989.2171\nHazardous Materials\nSafety Administration\n820 Bear Tavern Road, Suite 103\nWest Trenton, NJ 08628\nOVERNIGHT EXPRESS DELIVERY\nApril 2, 2014\nShawn Patterson\nPresident, Engineering and Project Delivery\nColumbia Gas Transmission, L.L.C.\n1700 MacCorkle Avenue, SE\nCharleston, WV 25314\nCPF 1-2012-1025H\nDear Mr. Patterson:\nOn December 20, 2012, the Pipeline and Hazardous Materials Safety Administration, Office of\nPipeline Safety, issued to Columbia Gas Transmission, L.L.C. (Columbia) a Corrective Action\nOrder following a pipeline rupture and fire that occurred on its SM-80 pipeline in Sissonville,\nWest Virginia. This Order included requirements to take corrective actions on the SM-80\npipeline from Lanham Station to the Broad Run Meter facility.\nBased on our review of the documentation you provided, it has been determined that you have\ncomplied with the terms of this Order.\nAccordingly, this case is now closed and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":22001}