# COLUMBIA GAS TRANSMISSION, LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 120151008
- **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:** 2015-04-27
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 192.455(a), 192.605(b)(2).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-120151008.json
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-120151008
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120151008
**body:**

Notice of Probable Violation involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.455(a),  192.605(b)(2). The case was opened on 2015-04-27 and is reported as closed as of 2016-02-25. Proposed civil penalty: $61,900. Assessed civil penalty: $61,900. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120151008_Final Order_02052016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151008/120151008_Final%20Order_02052016.pdf

120151008_Final Order_02052016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151008/120151008_Final%20Order_02052016_text.pdf

120151008_NOPV PCP PCO_04272015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151008/120151008_NOPV%20PCP%20PCO_04272015.pdf

120151008_NOPV PCP PCO_04272015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151008/120151008_NOPV%20PCP%20PCO_04272015_text.pdf

120151008_Operator Response to Notice_05262015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151008/120151008_Operator%20Response%20to%20Notice_05262015.pdf

120151008_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. 1-2015-1008
Dear Mr. Skaggs:
Enclosed please find the Final Order issued in the above-referenced case to your subsidiary,
Columbia Gas Transmission, LLC. It makes findings of violation and assesses a civil penalty of
$61,900. It further finds that Columbia Gas Transmission, LLC has completed the actions
specified in the Notice to comply with the pipeline safety regulations. When the civil penalty
has been paid, 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 Hoffman, Manager - System Integrity, Columbia Gas Transmission, LLC
1700 MacCorkle Ave., SE, Charleston, West Virginia 25314
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, )
a subsidiary of Columbia Pipeline Group, ) CPF No. 1-2015-1008
)
)
)
Respondent. )
__________________________________________)
FINAL ORDER
On multiple occasions between June 24, 2014, and August 8, 2014, pursuant to 49 U.S.C.
§ 60117, a representative of 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 (Columbia or Respondent), at its
Millennium Pipeline facilities in Sparrow Bush, New York. Columbia transports natural gas
through nearly 12,000 miles of pipelines in the northeastern United States.1
As a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Respondent,
by letter dated April 27, 2015, a Notice of Probable Violation, Proposed Civil Penalty, and
Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice
proposed finding that Columbia had violated 49 C.F.R. §§ 192.455 and 192.605 and proposed
assessing a civil penalty of $61,900 for one of the alleged violations. The Notice also proposed
ordering Respondent to take certain measures to correct the alleged violations.
Columbia responded to the Notice by letter dated May 26, 2015 (Response).2 The company did
not contest the allegations of violation but provided information concerning the corrective
actions it had taken. Columbia also provided a second response by letter dated August 24, 2015
(Response 2) where it updated the Region on the actions it had taken in response to the Notice.
Respondent did not request a hearing and therefore has waived its right to one.
1 See https://www.cpg.com/about-us. At the time this case arose, Columbia Gas Transmission, LLC, was part of
Columbia Pipeline Group, a subsidiary of NiSource, Inc. In July 2015, NiSource separated Columbia Pipeline
Group into a stand-alone publicly traded company. See https://www.nisource.com/about-us/creating-two-energy-
infrastructure-companies (last accessed October 16, 2015).
2 By letter dated August 24, 2015, Columbia provided PHMSA with additional information on actions it had taken
in response to the Notice.



CPF No. 1-2015-1008
Page 2
FINDINGS OF VIOLATION
In its Response, Columbia did not contest the allegations 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. § 192.455(a), which states, in
relevant part:
§ 192.455 External corrosion control: Buried or submerged pipelines
installed after July 31, 1971.
(a) Except as provided in paragraphs (b), (c), and (f) of this section,
each buried or submerged pipeline installed after July 31, 1971, must be
protected against external corrosion, including the following:
(1) . . .
(2) It must have a cathodic protection system designed to protect the
pipeline in accordance with this subpart, installed and placed in operation
within 1 year after completion of construction.
The Notice alleged that Respondent violated 49 C.F.R. § 192.455(a) by failing to establish a
cathodic protection system designed to protect a new buried pipeline within one year after the
pipeline is placed into operation. Specifically, the Notice alleged that approximately 1,500 feet
of large-diameter piping was newly installed for the Minisink compressor station on
Respondent’s Millennium Pipeline in Orange County, New York. The station was placed into
operation on June 1, 2013, and during inspections on June 24-25, 2014, inspectors found
inadequate cathodic protection for the new pipeline. When asked how they provided cathodic
protection for the new pipeline, Columbia’s operations manager indicated that the company had
bonded the new piping to existing cathodic protection systems but planned to eventually provide
separate cathodic protection at the station.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 192.455(a) by failing to establish a
cathodic protection system designed to protect a new buried pipeline system within one year of
the pipeline being placed into operation.
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 192.605(b)(2), which states:
§ 192.605 Procedural manual for operations, maintenance, and emergencies.
(b) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following, if
applicable, to provide safety during maintenance and operations.
(1) …
(2) Controlling corrosion in accordance with the operations and
maintenance requirements of subpart I of this part.
The Notice alleged that Respondent violated 49 C.F.R. § 192.605(b)(2) by failing to prepare and



CPF No. 1-2015-1008
Page 3
follow for each pipeline a manual of written procedures for conducting operations and
maintenance activities and for emergency response. This includes procedures for controlling
corrosion in accordance with the requirements of subpart I of 49 C.F.R. Part 192. Specifically,
the Notice alleged that Columbia’s Procedure 70.01.0, External Corrosion Control, Section
3.2.1, failed to require adequate external corrosion control for all buried or submerged pipe
installed after July 31, 1971, in accordance with 49 C.F.R. § 192.455(a)(2), which is part of
subpart I of 49 C.F.R. Part 192. Instead, Columbia’s procedure only required external corrosion
control for pipe “installed as a replacement section for a pipeline,” not for newly-installed pipe.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 192.605(b)(2) by failing to prepare
and follow for each pipeline a manual of written procedures for external corrosion control that
met the requirements of subpart I of 49 C.F.R. Part 192.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed
$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any
related series of violations. In determining the amount of a civil penalty under 49 U.S.C. § 60122
and 49 C.F.R. § 190.225, I must consider the following criteria: the nature, circumstances, and
gravity of the violation, including adverse impact on the environment; the degree of
Respondent’s culpability; the history of Respondent’s prior offenses; and any effect that the
penalty may have on its ability to continue doing business; and the good faith of Respondent in
attempting to comply with the pipeline safety regulations. In addition, I may consider the
economic benefit gained from the violation without any reduction because of subsequent
damages, and such other matters as justice may require. The Notice proposed a civil penalty of
$61,900 for one of the violations cited above.
Item 1: The Notice proposed a civil penalty of $61,900 for Respondent’s violation of 49 C.F.R.
§ 192.455(a), for failing to establish a cathodic protection system designed to protect a new
buried pipeline within one year after the pipeline is placed into operation. Columbia neither
contested the allegation nor presented any evidence or argument justifying a reduction in the
proposed penalty. Considering the importance of adequate cathodic protection and the fact that
this is a repeat offense,3 I find that the penalty amount is justified. Accordingly, having
reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of
$61,900 for violation of 49 C.F.R. § 192.455(a).
In summary, having reviewed the record and considered the assessment criteria for each of Item
cited above, I assess Respondent a total civil penalty of $61,900.
3 In the Matter of NiSource Gas Transmissions and Storage Company, CPF 1-2012-1014 (Dec. 21, 2012), Item 2.



CPF No. 1-2015-1008
Page 4
Payment of the civil penalty must be made within 20 days of service. Federal regulations
(49 C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer through the Federal
Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed
instructions are contained in the enclosure. Questions concerning wire transfers should be
directed to: Financial Operations Division (AMK-325), Federal Aviation Administration, Mike
Monroney Aeronautical Center, P.O. Box 269039, Oklahoma City, Oklahoma 73125. The
Financial Operations Division telephone number is (405) 954-8845.
Failure to pay the $61,900 civil penalty will result in accrual of interest at the current annual rate
in accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to
those same authorities, a late penalty charge of six percent (6%) per annum will be charged if
payment is not made within 110 days of service. Furthermore, failure to pay the civil penalty
may result in referral of the matter to the Attorney General for appropriate action in a district
court of the United States.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Items 1 and 2 in the Notice for
violations of 49 C.F.R. §§ 192.455, 192.605, respectively. 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. The
Director has indicated that Respondent has taken the following actions to address some of the
cited violations:
Columbia included cathodic protection test station readings and a map of test station
locations in Attachments A and B of its response, related to Notice Item 1 and Proposed
Compliance Order Item 1. PHMSA Eastern Region has reviewed the August 24, 2015
response and the additional cathodic protection actions Columbia has taken, and it
appears the additional cathodic protection actions taken satisfied the requirements of
Proposed Compliance Order Item 1.
Columbia included revised operations and maintenance (O&M) procedures in
Attachment A of its Response related to Notice Item 2 and Proposed Compliance
Order Item 2. PHMSA Eastern Region has reviewed those revised procedures, and it
appears the revised procedures satisfy the requirements of Proposed Compliance Order
Item 2.
Accordingly, I find that compliance has been achieved with respect to these violations.
Therefore, the compliance terms proposed in the Notice for Item 1 and Item 2 are not included in
this Order.
It is requested (not mandated) that Columbia maintain documentation of the safety
improvement costs associated with fulfilling this Compliance Order and submit the total
to Mr. Byron Coy, PE, Director, Eastern Region, Pipeline and Hazardous Materials
Safety Administration.



CPF No. 1-2015-1008
Page 5
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 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

120151008_NOPV PCP PCO_04272015_text.pdf

U.S. Department Of Transportation Pipeline and 609.989.2171
Hazardous Materials
Safety Administration
820 Bear Tavern Road, Suite 103
West Trenton, NJ 08628
NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPLIANCE ORDER
OVERNIGHT EXPRESS DELIVERY
April 27, 2015
Ken Oostman, VP Engineering
Columbia Gas Transmission, LLC.
5151 San Felipe, No. 2500
Houston, TX, 77056
CPF 1-2015-1008
Dear Mr. Oostman:
Between June 24 and August 8, 2014, representatives of the New York State Department of Public
Service (NYDPS), acting as agents for the Pipeline and Hazardous Materials Safety Administration
(PHMSA) pursuant to Chapter 601 of 49 United States Code, inspected Columbia Gas Transmission,
LLC (CGT), Millennium pipeline facilities, in Sparrow Bush, New York.
As a result of the inspection, it appears that you have committed probable violations of the Pipeline Safety
Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable violations are:
1. §192.455 External corrosion control: Buried or submerged pipelines installed after July
31, 1971.
(a) Except as provided in paragraphs (b), (c), and (f) of this section, each buried or
submerged pipeline installed after July 31, 1971, must be protected against external
corrosion, including the following:
(2) It must have a cathodic protection system designed to protect the pipeline in accordance
with this subpart, installed and placed in operation within 1 year after completion of
construction.
CGT failed to establish a cathodic protection system designed to protect a new buried pipeline within one
year after the pipeline had been placed into operation.
1. During the first half of 2013, approximately 1,500 feet of large diameter (combination of 36-inch,
30-inch, and 24-inch) piping was newly installed for the Millennium Pipeline Company
(Millennium) Minisink compressor station in Westtown, Orange County, NY.



1-2015-1008
2. 3. 4. The compressor station was placed into operation by CGT on June 1, 2013.
During the inspection on 6/24/2014, NYSDPS requested that CGT take cathodic protection (CP)
pipe-to-soil potential readings at the Minisink compressor station piping. CGT took the CP
readings after the NYSDPS inspection, with no NYSDPS inspector present. Of the three readings
taken at the compressor station, NYSDPS noted one less than adequate pipe-to-soil potential
reading of -0.750 volts. On 6/25/2014, CGT found four additional pipe-to-soil potential readings
below the -0.85 Volt cathodic protection criteria. CGT did not provide any evidence that
cathodic protection was being deemed adequate by any other criteria.
NYSDPS asked CGT how they provided cathodic protection to the new piping. CGT indicated
that they bonded the new station piping to the existing cathodic protection system on the
Millennium mainline, and installed bonds across insulating joints on the inlet and outlet piping to
the compressor station. The Operations Manager for CGT, stated that CGT intends to install a
separate cathodic protection system at the station, but it has not yet been installed.
Thus, CGT failed to establish a cathodic protection system designed to protect a new buried pipeline
within one year after the pipeline had been placed into operation.
This probable violation is a repeat violation of CPF 1-2012-2014 Item 2.
2. §192.605 Procedural manual for operations, maintenance, and emergencies.
(b) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following, if applicable, to provide safety during
maintenance and operations.
(2) Controlling corrosion in accordance with the operations and maintenance requirements
of subpart I of this part.
CGT Procedure 70.01.01 “External Corrosion Control” is inadequate in that it does not address all of the
requirements of §192.455(a)(2) which states in part that “…each buried or submerged pipeline installed
after July 31, 1971, must be protected against external corrosion…”
CGT’s procedure (Section 3.2.1) refers only to pipe “installed as a replacement section for a pipeline” and
does not refer to newly installed pipe.
In an e-mail from CGT to the NYSDPS dated August 8, 2014, CGT indicated that they are in the process
of revising the language of their O&M Plan 70.01.01 “to ensure it is clear that all buried or submerged
metallic piping installed (or replaced) after July 31, 1971 must have a cathodic protection system
designed to protect the pipeline installed (or replaced) which is placed in operation within 1 year after the
completion of construction.”
Proposed Civil Penalty
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per
violation per day the violation persists up to a maximum of $2,000,000 for a related series of violations.
For violations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per
violation per day, with a maximum penalty not to exceed $1,000,000 for a related series of violations.
The Compliance Officer has reviewed the circumstances and supporting documentation involved in the
above probable violations and has recommended that you be preliminarily assessed a civil penalty of
$61,900 as follows:
Item number PENALTY
1 $61,900
120151008_NOPV_PCP_PCO_04272015 2 of 4



1-2015-1008
Proposed Compliance Order
With respect to items 1 and 2 pursuant to 49 United States Code § 60118, the Pipeline and Hazardous
Materials Safety Administration proposes to issue a Compliance Order to CGT. Please refer to the
Proposed Compliance Order, which is enclosed and made a part of this Notice.
Response to this Notice
Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in
Compliance Proceedings. Please refer to this document and note the response options. All material you
submit in response to this enforcement action may be made publicly available. If you believe that any
portion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with
the complete original document you must provide a second copy of the document with the portions you
believe qualify for confidential treatment redacted and an explanation of why you believe the redacted
information qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond within 30
days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this
Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this
Notice without further notice to you and to issue a Final Order.
Please submit all correspondence in this matter to Byron Coy, PE, Director, PHMSA Eastern Region, 820
Bear Tavern Road, Suite 103, W. Trenton, NJ 08628. Please refer to CPF 1-2015-1008 on each
document you submit and please, whenever possible, provide a signed PDF copy in electronic format.
Smaller files may be emailed to Byron.Coy@dot.gov. Larger files should be sent on a CD accompanied
by the original paper copy to the Eastern Region Office.
Additionally, if you choose to respond to this (or any other case), please ensure that any response letter
pertains solely to one CPF case number.
Sincerely,
Byron Coy, PE
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
Cc: Mr. Kevin Speicher, NYSDPS
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Compliance Proceedings
120151008_NOPV_PCP_PCO_04272015 3 of 4



1-2015-1008
PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration
(PHMSA) proposes to issue to Columbia Gas Transmission, LLC (CGT) a Compliance Order
incorporating the following remedial requirements to ensure the compliance of CGT with the pipeline
safety regulations:
1. 2. 3. 4. In regard to Item Number 1 of the Notice pertaining to CGT’s failure to establish a
cathodic protection system for the Minisink Compressor Station and associated piping
designed to protect a new buried pipeline within one year after the pipeline was placed
into operation on June 1, 2013, CGT must evaluate, and then ensure that adequate
cathodic protection is provided for the entirety of the Minisink Compressor Station, and
all of its inlet and outlet piping for a distance of 5 miles from the station fence lines.
In regard to Item Number 2 of the Notice pertaining to CGT’s Procedure 70.01.01 that
does not address all the requirements of §192.455(a)(2), CGT must revise the language of
their operations and maintenance (O&M) procedures to address that all buried or
submerged metallic piping installed, or replaced, after July 31, 1971 must have a cathodic
protection system designed to protect the pipeline installed, or replaced, and in operation,
within 1 year after the completion of construction.
CGT will have 90 days after receipt of the Final Order to perform a cathodic protection
evaluation on the subject station and inlet/outlet piping; then another 150 days to install
or modify cathodic protection as needed, to achieve adequate cathodic protection.
It is requested (not mandated) that CGT maintain documentation of the safety
improvement costs associated with fulfilling this Compliance Order and submit the total
to Byron Coy, PE, 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.
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