# COLUMBIA GAS TRANSMISSION, LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 120153004
- **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:** 2015-09-08
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 193.2637.
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-120153004.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-120153004
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120153004
**body:**

Notice of Probable Violation involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 193.2637. The case was opened on 2015-09-08 and is reported as closed as of 2016-05-11. Proposed civil penalty: $58,100. Assessed civil penalty: $57,800. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120153004_Final Order_04292016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120153004/120153004_Final%20Order_04292016.pdf

120153004_Final Order_04292016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120153004/120153004_Final%20Order_04292016_text.pdf

120153004_NOPV_PCP_09082015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120153004/120153004_NOPV_PCP_09082015.pdf

120153004_NOPV_PCP_09082015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120153004/120153004_NOPV_PCP_09082015_text.pdf

120153004_Operator Response To Notice_10122015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120153004/120153004_Operator%20Response%20To%20Notice_10122015.pdf

120153004_Final Order_04292016_text.pdf

April 29, 2016
Mr. Robert C. Skaggs, Jr.
Chairman of the Board and CEO
Columbia Pipeline Group, Inc.
5151 San Felipe, No. 2500
Houston, TX 77056
Re: CPF No. 1-2015-3004
Dear Mr. Skaggs:
Enclosed please find the Final Order issued in the above-referenced case to your subsidiary,
Columbia Gas Transmission, LLC. It makes one finding of violation and assesses a reduced
civil penalty of $57,800. The penalty payment terms are set forth in the Final Order. This
enforcement action closes automatically upon receipt of payment. 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, PE, Director, Eastern Region, OPS
Mr. Perry M. Hoffman, Manager-System Integrity, Columbia Pipeline Group, Inc.,
1700 MacCorkle Avenue SE, Charleston, WV 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, ) CPF No. 1-2015-3004
a subsidiary of Columbia Pipeline Group, Inc., )
Respondent. )
)
)
)
)
FINAL ORDER
From December 8 through December 12, 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 (CGT or Respondent), in Chesapeake, Virginia. CGT owns
and operates a liquefied natural gas (LNG) facility located in Chesapeake.
As a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Respondent,
by letter dated September 8, 2015, a Notice of Probable Violation and Proposed Civil Penalty
(Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that CGT had
violated 49 C.F.R. § 193.2637 and proposed assessing a civil penalty of $58,100 for the alleged
violation.
CGT responded to the Notice by letter dated October 12, 2015 (Response). The Respondent did
not contest the allegation of violation, but did contest the number of instances of violation. CGT
provided an explanation of its actions and requested that the proposed civil penalty be reduced or
eliminated. Respondent did not request a hearing and, therefore, has waived its right to one.



CPF No. 1-2015-3004
2
FINDING OF VIOLATION
In its Response, CGT responded to the allegation in the Notice that it violated 49 C.F.R. Part
193, as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 193.2637, which states:
§ 193.2637 Remedial measures.
(a) Prompt corrective or remedial action must be taken whenever an
operator learns by inspection or otherwise that atmospheric, external, or
internal corrosion is not controlled as required by this subpart.
The Notice alleged that Respondent violated 49 C.F.R. § 193.2637 by failing to take prompt
corrective or remedial action when it learned by inspection that atmospheric corrosion was not
controlled at its LNG facility, as required by Part 193. Specifically, the Notice alleged that CGT
failed to follow its own procedures by not promptly remediating seven instances of deficiencies
found during atmospheric-corrosion inspections within the timeframes specified in its own
procedures.1
Respondent did not contest six of the seven allegations of violation and requested the elimination
or reduction of the penalty based upon six, as opposed to seven, instances of violation. In its
Response, CGT explained that one of the seven instances was for a conduit, a non-gas bearing
component, and, therefore, not subject to the same requirements for re-inspection or remediation
as required for gas-bearing components.2
I agree that the seventh instance does not constitute a violation and therefore I withdraw that one
allegation of violation. Accordingly, based upon a review of all of the evidence, I find that
Respondent violated 49 C.F.R. § 193.2637 by failing to take prompt corrective or remedial
action when it learned by inspection that atmospheric corrosion was not controlled as required by
this subpart.
This finding of violation will be considered a prior offense 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.
1 See CGT Plan 310.42.01 – Chesapeake LNG Facility Corrosion Control (requiring that Level 2 atmospheric
corrosion mitigation or re-inspection be performed within 12 months of discovery per Section 3.3.2.F). Here, the
atmospheric conditions were remediated or the components removed from service within 24 months of the initial
inspection.
2 Response, at 2.



CPF No. 1-2015-3004
3
§ 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 total
civil penalty of $58,100 for the violations cited above.
Item 1: The Notice proposed a civil penalty of $58,100 for Respondent’s violation of 49 C.F.R.
§ 193.2637, for failing to take prompt corrective or remedial action when it learned by inspection
that atmospheric corrosion was not controlled at its LNG facility, as required by this subpart.
CGT failed to follow its procedures by not remediating deficiencies found during its atmospheric
corrosion inspections within the timeframes specified in its own procedures. Since there were
only six occurrences of violation, rather than seven as cited in the Notice, I am reducing the
portion of the proposed penalty attributable to the gravity assessment criteria. This criterion
includes the number of instances of violation, which I am reducing from seven to six.
Accordingly, having reviewed the record and considered the assessment criteria for the Item
cited above, I assess Respondent a total civil penalty of $57,800 for violation of 49 C.F.R.
§ 193.2637.
Failure to pay the $57,800 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.
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,
6500 S MacArthur Blvd., Oklahoma City, Oklahoma 79169. The Financial Operations Division
telephone number is (405) 954-8845.
Under 49 C.F.R. § 190.243, Respondent has the 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 the 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. The filing of a petition automatically stays the payment of
any civil penalty assessed but does not stay any other provisions of the Final Order, including
any required corrective actions. If Respondent submits payment of the civil penalty, the Final



CPF No. 1-2015-3004
4
Order becomes the final administrative decision and the right to petition for reconsideration is
waived.
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



Payment Instructions
Civil Penalty Payments of Less Than $10,000
Payment of a civil penalty of less than $10,000 proposed or assessed, under Subpart B of
Part 190 of the Pipeline Safety Regulations can be made by certified check, money order
or wire transfer. Payment by certified check or money order (containing the CPF Number
for this case) should be made payable to the "Department of Transportation" and should
be sent to:
Federal Aviation Administration
Financial Operations Division (AMK-325)
ATTN: Shelby Jones
6500 S MacArthur Blvd.,
Oklahoma City, OK 79169
Wire transfer payments of less than $10,000 may be made through the Federal Reserve
Communications System (Fedwire) to the account of the U.S. Treasury. Detailed
instructions are provided below. Questions concerning wire transfer should be directed to
the Financial Operations Division at (405) 954-8845, or at the above address.
Civil Penalty Payments of $10,000 or more
Payment of a civil penalty of $10,000 or more proposed or assessed under Subpart B of
Part 190 of the Pipeline Safety Regulations must be made wire transfer (49 C.F.R. §
89.21 (b)(3)), through the Federal Reserve Communications System (Fedwire) to the
account of the U.S. Treasury. Detailed instructions are provided below. Questions
concerning wire transfers should be directed to the Financial Operations Division at
(405) 954-8845, or at the above address.



INSTRUCTIONS FOR ELECTRONIC FUND TRANSFERS
(1) RECEIVER ABA
NO. 021030004
(2) TYPE/SUB-TYPE
(Provided by sending bank)
(3) SENDING BANK ABA NO.
(Provided by sending bank)
(4) SENDING BANK REF NO.
(Provided by sending bank)
(5) AMOUNT (6) SENDING BANK NAME
(Provided by sending bank)
(7) RECEIVER NAME
TREAS NYC
(8) PRODUCT CODE
(Normally CTR, or as provided by sending bank)
(9) BENEFICIAL (BNF) = AGENCY
LOCATION CODE
BNF = /ALC-69-14-0001
(10) REASONS FOR PAYMENT
Example: PHMSA - CPF # / Ticket Number/Pipeline
Assessment number
INSTRUCTIONS: You, as sender of the wire transfer, must provide the sending bank with the
information for blocks (1), (5), (7), (9), and (10). The information provided in Blocks (1), (7),
and (9) are constant and remain the same for all wire transfers to the Pipeline and Hazardous
Materials Safety Administration, Department of Transportation.
Block #1 - RECEIVER ABA NO. - "021030004". Ensure the sending bank enters this 9-digit
identification number; it represents the routing symbol for the U.S. Treasury at the Federal
Reserve Bank in New York.
Block #5 - AMOUNT - You as the sender provide the amount of the transfer. Please be sure the
transfer amount is punctuated with commas and a decimal point. EXAMPLE: $10,000.00
Block #7 - RECEIVER NAME - "TREAS NYC". Ensure the sending bank enters this
abbreviation. It must be used for all wire transfers to the Treasury Department.
Block #9 - BENEFICIAL - AGENCY LOCATION CODE - "BNF=/ALC-69-14-0001". Ensure
the sending bank enters this information. This is the Agency Location Code for the Pipeline and
Hazardous Materials Safety Administration, Department of Transportation.
Block #10 - REASON FOR PAYMENT - “AC-payment for PHMSA Case # / To ensure your
wire transfer is credited properly, enter the case number/ticket number or Pipeline Assessment number,
and country.”
NOTE: A wire transfer must comply with the format and instructions or the Department cannot
accept the wire transfer. You as the sender can assist this process by notifying the Financial
Operations Division (405) 954-8845 at the time you send the wire transfer.
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