{"operation":"document","citation":"CPF 120151006","title":"COLUMBIA GAS TRANSMISSION, LLC — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-04-07","effective_on":null,"summary":"CLOSED notice of probable violation citing 192.503(a)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120151006.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120151006.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120151006","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120151006","body":"Notice of Probable Violation involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.503(a)(1). The case was opened on 2015-04-07 and is reported as closed as of 2016-06-16. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120151006_Closure Letter_06162016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151006/120151006_Closure%20Letter_06162016.pdf\n\n120151006_Closure Letter_06162016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151006/120151006_Closure%20Letter_06162016_text.pdf\n\n120151006_Final Order_02052016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151006/120151006_Final%20Order_02052016.pdf\n\n120151006_Final Order_02052016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151006/120151006_Final%20Order_02052016_text.pdf\n\n120151006_NOPV PCO_04072015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151006/120151006_NOPV%20PCO_04072015_text.pdf\n\n120151006_NOPV_PCO_04072015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151006/120151006_NOPV_PCO_04072015.pdf\n\n120151006_Final Order_02052016_text.pdf\n\nFebruary 05, 2016\nMr. Robert C. Skaggs, Jr., CEO\nColumbia Gas Transmission, LLC\nColumbia Pipeline Group\n5151 San Felipe, Suite 2500\nHouston, Texas 77056\nRe: CPF No. 1-2015-1006\nDear Mr. Skaggs:\nEnclosed please find the Final Order issued in the above-referenced case to your subsidiary,\nColumbia Gas Transmission, LLC. It makes a finding of violation and specifies actions that\nneed to be taken by Columbia Gas Transmission, LLC to comply with the pipeline safety\nregulations. When the terms of the compliance order have been completed, as determined by the\nDirector, Eastern Region, this enforcement action will be closed. Service of the Final Order by\ncertified mail is deemed effective upon the date of mailing, or as otherwise provided under 49\nC.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. Byron Coy, P.E., Director, Eastern Region, PHMSA OPS\nMr. Perry M. Hoffman, Manager – System Integrity, Columbia Gas Transmission, LLC\n1700 MacCorkle Ave., SE, Charleston, West Virginia 25314\nMr. Ken Oostman, VP of Engineering, Columbia Gas Transmission, LLC\n5151 San Felipe, Suite 2500, Houston, Texas 77056\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\n\n\n\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, LLC ) CPF No. 1-2015-1006\na subsidiary of Columbia Pipeline Group, )\n)\n)\n)\nRespondent. )\n_________________________________________ )\nFINAL ORDER\nBetween December 12, 2012, and October 14, 2013, pursuant to 49 U.S.C. § 60117,\nrepresentatives of the New York Department of Public Service (NYDPS), acting as agent for the\nPipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS), conducted an on-site pipeline safety inspection of the facilities and records of Columbia\nGas Transmission, LLC’s (CGTC or Respondent) Minisink Compressor Station in Minisink,\nNew York. Millennium Pipeline Company (Millennium) constructed and currently owns the\nMinisink Compressor Station facilities and associated piping. The facilities were placed into\nservice and CGTC assumed operation of them on June 1, 2013. CGTC transports an average of\nthree billion cubic feet of natural gas per day through an approximately 12,000-mile pipeline\nnetwork and 92 compressor stations in 10 states.1\nAs a result of the inspection, on April 7, 2015, the Director, Eastern Region, OPS (Director),\nissued a Notice of Probable Violation and Proposed Compliance Order (Notice) to CGTC. In\naccordance with 49 C.F.R. § 190.207, the Notice proposed finding that Respondent had violated\n49 C.F.R. § 192.503 and ordering Respondent to take certain measures to correct the alleged\nviolation.\nCGTC replied to the Notice by letter dated May 26, 2015 (Response). Respondent did not\ncontest the allegation of violation or proposed compliance order, but did provide additional\ninformation regarding actions it had to take in response to the Notice. Respondent did not\nrequest a hearing and therefore has waived its right to one.\n1 See Our Companies – Columbia Gas Transmission, Columbia Pipeline Group, https://www.cpg.com/about-us/our-\ncompanies#columbiagastransmission (last visited November 30, 2015).\n\n\n\nCPF No. 1-2015-1006\nPage 2\nFINDING OF VIOLATION\nIn its Response, CGTC did not contest the allegation in the Notice that it violated 49 C.F.R. Part\n192, as follows:\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.503(a)(1), which states:\n§ 192.503 General requirements.\n(a) No persons may operate a new segment of pipeline, or\nreturn to service a segment of pipeline that has been relocated or\nreplaced, until—\n(1) It has been tested in accordance with this subpart and\n§ 192.619 to substantiate the maximum allowable operating pressure;\nand\n(2) Each potentially hazardous leak has been located and\neliminated.\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.503(a)(1) by failing to test a new\nsegment of pipeline prior to placing it into operation. Specifically, the Notice alleged that CGTC\nfailed to test a new segment of pipeline in accordance with Part 192, subpart J (Test\nRequirements) and 49 C.F.R. § 192.619 to substantiate the maximum allowable operating\npressure prior to placing the Minisink Compressor Station and associated pipeline facilities into\noperation on June 1, 2013.2\nFrom December 12, 2012, through October 13, 2013, NYDPS performed record and field\ninspections of the Minisink Compressor Station and associated pipeline facilities. A review of\nthe records revealed approximately 844 welds made in the shop and 59 welds made in the field.\nAccording to Millennium, the welds were hydrostatically tested in the shop at the manufacture\nsite; however, the welds were not hydrostatically tested after the completion of the field\nconstruction, as Millennium did not want to risk intrusion of residual water into its compressors.\nRespondent did not contest this allegation of violation. Accordingly, based upon a review of all\nthe evidence, I find that Respondent violated 49 C.F.R. § 192.503(a)(1) by failing to test a\nnew segment of pipeline in accordance with Part 192, subpart J (Test Requirements) and 49\nC.F.R. § 192.619. This finding of violation will be considered a prior offense in any subsequent\nenforcement action taken against Respondent.\nThe Notice proposed a compliance order with respect to Item 1 in the Notice for violations of\n49 C.F.R. § 192.503(a)(1). Under 49 U.S.C. § 60118(a), each person who engages in the\ntransportation of gas or who owns or operates a pipeline facility is required to comply with the\napplicable safety standards established under chapter 601. Pursuant to the authority of 49 U.S.C.\nCOMPLIANCE ORDER\n2 See 49 C.F.R. §§ 192.503(a)(1).\n\n\n\nCPF No. 1-2015-1006\nPage 3\n§ 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following actions to\nensure compliance with the pipeline safety regulations applicable to its operations:\n1. With respect to the violation of 49 C.F.R. § 192.503(a)(1) (Item 1), Respondent\nmust: (1) reevaluate the installed Minisink Compressor Station and related piping to\ndetermine what further piping will need to be tested in accordance with\n§ 192.503(a)(1); and (2) perform needed testing in accordance with § 192.503(a)(1).\n2. Respondent will have 60 days within receipt of this Final Order to provide a tally\nor detailed drawings that identify what piping in 1 of the Compliance Order (above)\nwill be tested, and CGTC will have 210 days within receipt of the Final Order to\ncomplete testing in 1 of the Compliance Order (above).\n3. It is requested (not mandated) that Respondent maintain documentation of the\nsafety improvement costs associated with fulfilling this Compliance Order and submit\nthe total to Mr. Byron Coy, Director, Eastern Region, Pipeline and Hazardous\nMaterials Safety Administration. It is requested that these costs be reported in two\ncategories: (1) total cost associated with preparation/revision of plans, procedures,\nstudies and analyses; and (2) total cost associated with replacements, additions and\nother changes to pipeline infrastructure.\nThe Director may grant an extension of time to comply with any of the required items set forth\nabout upon a written request timely submitted by the Respondent and demonstrating good cause\nfor an extension.\nFailure to comply with this Order may result in the administrative assessment of civil penalties\nnot to exceed $200,000 for each violation for each day the violation continues or in referral to the\nAttorney General for appropriate relief in a district court of the United States.\nUnder 49 C.F.R. § 190.243, Respondent has a right to submit a Petition for Reconsideration of\nthis Final Order. The petition must be sent to: Associate Administrator, Office of Pipeline\nSafety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC\n20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address. PHMSA\nwill accept petitions received no later than 20 days after receipt of service of this Final Order by\nthe Respondent, provided they contain a brief statement of the issue(s) and meet all other\nrequirements of 49 C.F.R. § 190.243. Unless the Associate Administrator, upon request, grants a\nstay, the terms and conditions of this Final Order are effective upon service in accordance with\n49 C.F.R. § 190.5.\n___________________________________ __________________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n120151006_Closure Letter_06162016_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJune 16, 2016\nKen Oostman, VP Engineering\nColumbia Gas Transmission, LLC\n5151 San Felipe, No. 2500\nHouston, TX, 77056\nCPF 1-2015-1006\nDear Mr. Oostman:\nOn February 5, 2016, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued to Columbia Gas Transmission, LLC (Columbia) a Final Order in the above-referenced\ncase. This Order included a Compliance Order. Based on our review of the documentation\nColumbia provided, and the witnessing of work and testing related to the Compliance Order by\nNew York State Department of Public Service (NYSDPS) staff representing PHMSA, it has been\ndetermined that Columbia has complied 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\nCc: Mr. Kevin Speicher, NYSDPS","truncated":false,"body_characters":10931}