{"operation":"document","citation":"CPF 120131004W","title":"COLUMBIA GAS TRANSMISSION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-04-05","effective_on":null,"summary":"CLOSED warning letter citing 192.703(b), 192.751(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120131004w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120131004w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120131004w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120131004W","body":"Warning Letter involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.703(b),  192.751(a). The case was opened on 2013-04-05 and is reported as closed as of 2013-04-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120131004W_Warning Letter_04052013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120131004W/120131004W_Warning%20Letter_04052013.pdf\n\n120131004W_Warning Letter_04052013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120131004W/120131004W_Warning%20Letter_04052013_text.pdf\n\n120131004W_Warning Letter_04052013_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\nWARNING LETTER\nOVERNIGHT EXPRESS MAIL\nApril 5, 2013\nShawn L. Patterson\nPresident Operations & Project Delivery\nColumbia Gas Transmission Corporation\n1700 MacCorkle Avenue, SE\nCharleston, WV 25314\nCPF 1-2013-1004W\nDear Mr. Patterson:\nFrom September 21-24, 2010, representatives of West Virginia Public Service Commission (WV\nPSC), acting as agents for the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code,\ninspected Columbia Gas Transmission Corporation’s (CGT) compressor station facilities in\nClendenin, Glenville and Smithfield, West Virginia. In addition, representatives from WV PSC\nreviewed records related to CGT’s pipeline called T System (1570 pipelines), in Charleston,\nWest Virginia.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n1. § 192.751 Prevention of accidental ignition.\nEach operator shall take steps to minimize the danger of accidental ignition of\ngas in any structure or area where the presence of gas constitutes a hazard of fire or\nexplosion, including the following:\n(a) When a hazardous amount of gas is being vented into open air, each potential\nsource of ignition must be removed from the area and a fire extinguisher must be\nprovided.\n\n\n\nCPF 1-2013-1004W\nCGT failed to take steps to minimize the danger of accidental ignition in any structure or area\nwhere the presence of gas constitutes a hazard of fire or explosion.\nDuring the field inspection at CGT’s Clendenin Compressor Station, a representative from WV\nPSC observed and took photographs of a broken conduit between the explosive proof outlet and\nthe seal allowing the wires to be open to the atmosphere (see below). The seal in question was\noutside the compressor building. Therefore, it is possible for gas to enter the broken conduit\nwhich is a potential source of ignition. The conduit is located in a class 1 division 2 area.\n2. § 192.703 General.\n(a) . . .\n(b) Each segment of pipeline that becomes unsafe must be replaced, repaired, or\nremoved from service.\nCGT failed to take appropriate remedial and protective measures to address an unsafe segment of\nexposed plastic pipeline.\nCGT pipeline, designated 3665, is a 10-inch plastic pipeline. During the field inspection in\nSmithfield, a representative from WV PSC observed and took photographs of the segment of\npipeline 3665 that was exposed (see below). This exposed segment of pipeline was located near\na secondary highway.\nCGT indicated to the representative from WV PSC that this line was scheduled for replacement\nin 2012.\n120131004W_WL_04052013 Page 2 of 3\n\n\n\nCPF 1-2013-1004W\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the items identified in this letter.\nFailure to do so will result in CGT being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2013-1004W and, for each document you submit, please provide a copy in electronic\nformat whenever possible, and please whenever possible provide a signed PDF (Portable\nDocument Format). Smaller files may be emailed to Byron.Coy@dot.gov. Larger files should be\nsent on a CD (Compact Disc) accompanied by the original paper copy to the Eastern Region\nOffice. Be advised that all material you submit in response to this enforcement action is subject\nto being made publicly available. If you believe that any portion of your responsive material\nqualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original\ndocument you must provide a second copy of the document with the portions you believe qualify\nfor confidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nCc: Mr. David Hippchen, WV PSC\n120131004W_WL_04052013 Page 3 of 3","truncated":false,"body_characters":5536}