# COLUMBIA GAS TRANSMISSION, LLC — Notice of Probable Violation

- **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:** Not available
- **summary:** CLOSED notice of probable violation citing 192.503(a)(1).
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- **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.

Official case documents:

120151006_Closure Letter_06162016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151006/120151006_Closure%20Letter_06162016.pdf

120151006_Closure Letter_06162016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151006/120151006_Closure%20Letter_06162016_text.pdf

120151006_Final Order_02052016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151006/120151006_Final%20Order_02052016.pdf

120151006_Final Order_02052016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151006/120151006_Final%20Order_02052016_text.pdf

120151006_NOPV PCO_04072015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151006/120151006_NOPV%20PCO_04072015_text.pdf

120151006_NOPV_PCO_04072015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151006/120151006_NOPV_PCO_04072015.pdf

120151006_Final Order_02052016_text.pdf

February 05, 2016
Mr. Robert C. Skaggs, Jr., CEO
Columbia Gas Transmission, LLC
Columbia Pipeline Group
5151 San Felipe, Suite 2500
Houston, Texas 77056
Re: CPF No. 1-2015-1006
Dear Mr. Skaggs:
Enclosed please find the Final Order issued in the above-referenced case to your subsidiary,
Columbia Gas Transmission, LLC. It makes a finding of violation and specifies actions that
need to be taken by Columbia Gas Transmission, LLC to comply with the pipeline safety
regulations. When the terms of the compliance order have been completed, as determined by the
Director, Eastern Region, this enforcement action will be closed. Service of the Final Order by
certified mail is deemed effective upon the date of mailing, or as otherwise provided under 49
C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Byron Coy, P.E., Director, Eastern Region, PHMSA OPS
Mr. Perry M. Hoffman, Manager – System Integrity, Columbia Gas Transmission, LLC
1700 MacCorkle Ave., SE, Charleston, West Virginia 25314
Mr. Ken Oostman, VP of Engineering, Columbia Gas Transmission, LLC
5151 San Felipe, Suite 2500, Houston, Texas 77056
CERTIFIED MAIL - RETURN RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
_________________________________________
In the Matter of )
Columbia Gas Transmission, LLC ) CPF No. 1-2015-1006
a subsidiary of Columbia Pipeline Group, )
)
)
)
Respondent. )
_________________________________________ )
FINAL ORDER
Between December 12, 2012, and October 14, 2013, pursuant to 49 U.S.C. § 60117,
representatives of the New York Department of Public Service (NYDPS), acting as agent for the
Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
(OPS), conducted an on-site pipeline safety inspection of the facilities and records of Columbia
Gas Transmission, LLC’s (CGTC or Respondent) Minisink Compressor Station in Minisink,
New York. Millennium Pipeline Company (Millennium) constructed and currently owns the
Minisink Compressor Station facilities and associated piping. The facilities were placed into
service and CGTC assumed operation of them on June 1, 2013. CGTC transports an average of
three billion cubic feet of natural gas per day through an approximately 12,000-mile pipeline
network and 92 compressor stations in 10 states.1
As a result of the inspection, on April 7, 2015, the Director, Eastern Region, OPS (Director),
issued a Notice of Probable Violation and Proposed Compliance Order (Notice) to CGTC. In
accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Respondent had violated
49 C.F.R. § 192.503 and ordering Respondent to take certain measures to correct the alleged
violation.
CGTC replied to the Notice by letter dated May 26, 2015 (Response). Respondent did not
contest the allegation of violation or proposed compliance order, but did provide additional
information regarding actions it had to take in response to the Notice. Respondent did not
request a hearing and therefore has waived its right to one.
1 See Our Companies – Columbia Gas Transmission, Columbia Pipeline Group, https://www.cpg.com/about-us/our-
companies#columbiagastransmission (last visited November 30, 2015).



CPF No. 1-2015-1006
Page 2
FINDING OF VIOLATION
In its Response, CGTC did not contest the allegation in the Notice that it violated 49 C.F.R. Part
192, as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.503(a)(1), which states:
§ 192.503 General requirements.
(a) No persons may operate a new segment of pipeline, or
return to service a segment of pipeline that has been relocated or
replaced, until—
(1) It has been tested in accordance with this subpart and
§ 192.619 to substantiate the maximum allowable operating pressure;
and
(2) Each potentially hazardous leak has been located and
eliminated.
The Notice alleged that Respondent violated 49 C.F.R. § 192.503(a)(1) by failing to test a new
segment of pipeline prior to placing it into operation. Specifically, the Notice alleged that CGTC
failed to test a new segment of pipeline in accordance with Part 192, subpart J (Test
Requirements) and 49 C.F.R. § 192.619 to substantiate the maximum allowable operating
pressure prior to placing the Minisink Compressor Station and associated pipeline facilities into
operation on June 1, 2013.2
From December 12, 2012, through October 13, 2013, NYDPS performed record and field
inspections of the Minisink Compressor Station and associated pipeline facilities. A review of
the records revealed approximately 844 welds made in the shop and 59 welds made in the field.
According to Millennium, the welds were hydrostatically tested in the shop at the manufacture
site; however, the welds were not hydrostatically tested after the completion of the field
construction, as Millennium did not want to risk intrusion of residual water into its compressors.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
the evidence, I find that Respondent violated 49 C.F.R. § 192.503(a)(1) by failing to test a
new segment of pipeline in accordance with Part 192, subpart J (Test Requirements) and 49
C.F.R. § 192.619. This finding of violation will be considered a prior offense in any subsequent
enforcement action taken against Respondent.
The Notice proposed a compliance order with respect to Item 1 in the Notice for violations of
49 C.F.R. § 192.503(a)(1). Under 49 U.S.C. § 60118(a), each person who engages in the
transportation of gas or who owns or operates a pipeline facility is required to comply with the
applicable safety standards established under chapter 601. Pursuant to the authority of 49 U.S.C.
COMPLIANCE ORDER
2 See 49 C.F.R. §§ 192.503(a)(1).



CPF No. 1-2015-1006
Page 3
§ 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following actions to
ensure compliance with the pipeline safety regulations applicable to its operations:
1. With respect to the violation of 49 C.F.R. § 192.503(a)(1) (Item 1), Respondent
must: (1) reevaluate the installed Minisink Compressor Station and related piping to
determine what further piping will need to be tested in accordance with
§ 192.503(a)(1); and (2) perform needed testing in accordance with § 192.503(a)(1).
2. Respondent will have 60 days within receipt of this Final Order to provide a tally
or detailed drawings that identify what piping in 1 of the Compliance Order (above)
will be tested, and CGTC will have 210 days within receipt of the Final Order to
complete testing in 1 of the Compliance Order (above).
3. It is requested (not mandated) that Respondent maintain documentation of the
safety improvement costs associated with fulfilling this Compliance Order and submit
the total to Mr. Byron Coy, Director, Eastern Region, Pipeline and Hazardous
Materials Safety Administration. It is requested that these costs be reported in two
categories: (1) total cost associated with preparation/revision of plans, procedures,
studies and analyses; and (2) total cost associated with replacements, additions and
other changes to pipeline infrastructure.
The Director may grant an extension of time to comply with any of the required items set forth
about upon a written request timely submitted by the Respondent and demonstrating good cause
for an extension.
Failure to comply with this Order may result in the administrative assessment of civil penalties
not to exceed $200,000 for each violation for each day the violation continues or in referral to the
Attorney General for appropriate relief in a district court of the United States.
Under 49 C.F.R. § 190.243, Respondent has a right to submit a Petition for Reconsideration of
this Final Order. The petition must be sent to: Associate Administrator, Office of Pipeline
Safety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC
20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address. PHMSA
will accept petitions received no later than 20 days after receipt of service of this Final Order by
the Respondent, provided they contain a brief statement of the issue(s) and meet all other
requirements of 49 C.F.R. § 190.243. Unless the Associate Administrator, upon request, grants a
stay, the terms and conditions of this Final Order are effective upon service in accordance with
49 C.F.R. § 190.5.
___________________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

120151006_Closure Letter_06162016_text.pdf

OVERNIGHT EXPRESS DELIVERY
June 16, 2016
Ken Oostman, VP Engineering
Columbia Gas Transmission, LLC
5151 San Felipe, No. 2500
Houston, TX, 77056
CPF 1-2015-1006
Dear Mr. Oostman:
On February 5, 2016, the Pipeline and Hazardous Materials Safety Administration (PHMSA)
issued to Columbia Gas Transmission, LLC (Columbia) a Final Order in the above-referenced
case. This Order included a Compliance Order. Based on our review of the documentation
Columbia provided, and the witnessing of work and testing related to the Compliance Order by
New York State Department of Public Service (NYSDPS) staff representing PHMSA, it has been
determined that Columbia has complied with the terms of this Order.
Accordingly, this case is now closed and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
Byron Coy, PE
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
Cc: Mr. Kevin Speicher, NYSDPS
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