{"operation":"document","citation":"CPF 120176008M","title":"COLUMBIA MIDSTREAM GROUP, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-12-14","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(c)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120176008m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120176008m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120176008m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120176008M","body":"Notice of Amendment involving COLUMBIA MIDSTREAM GROUP, LLC. PHMSA's enforcement data identifies the cited regulation as 195.402(c)(3). The case was opened on 2017-12-14 and is reported as closed as of 2018-03-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120176008M_Closure Letter_0302018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176008M/120176008M_Closure%20Letter_0302018.pdf\n\n120176008M_Closure Letter_0302018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176008M/120176008M_Closure%20Letter_0302018_text.pdf\n\n120176008M_Notice Of Amendment_12142017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176008M/120176008M_Notice%20Of%20Amendment_12142017.pdf\n\n120176008M_Notice Of Amendment_12142017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176008M/120176008M_Notice%20Of%20Amendment_12142017_text.pdf\n\n120176008M_Closure Letter_0302018_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nMarch 2, 2018\nMr. Stanley Chapman III\nPresident, US Gas Pipelines\nColumbia Midstream Group, LLC\n700 Louisiana Street, Suite 700\nHouston, TX 77002\nCPF 1-2017-6008M\nDear Mr. Chapman:\nFrom April 24-28, 2017, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the\nprocedures and records of Columbia Midstream Group, LLC, a subsidiary of TransCanada\n(TransCanada), at its pipeline facility located in Leetonia, Ohio.\nAs a result of the inspection, TransCanada was issued a Notice of Amendment (NOA) dated\nDecember 14, 2017. In response to the NOA, TransCanada discussed updates and changes to\nmultiple procedures; however, these procedures were not incorporated for review in the response\nletter on February 12, 2018. Subsequently, PHMSA granted an additional 30 days for TransCanada\nto respond to the NOA and provide the updated procedures. TransCanada submitted its revised\nprocedures on March 1, 2018. PHMSA has reviewed the amended procedures, and it appears that\nthe inadequacies outlined in this NOA have been corrected.\nThis letter is to inform you that no further action is necessary, and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n120176008M_Notice Of Amendment_12142017_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nDecember 14, 2017\nMr. Stanley Chapman III\nPresident, US Gas Pipelines\nColumbia Midstream Group, LLC\n700 Louisiana Street, Suite 700\nHouston, TX 77002\nCPF 1-2017-6008M\nDear Mr. Chapman:\nFrom April 24-28, 2017, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the\nprocedures and records of Columbia Midstream Group, LLC, a subsidiary of TransCanada\n(TransCanada), at its pipeline facility located in Leetonia, Ohio.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within\nTransCanada’s plans or procedures, as described below:\n1. § 195.402(c)(3)\n(C) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\nTransCanada’s procedures for operating, maintaining and repairing the pipeline system in\naccordance with each of the requirements of this subpart and subpart H of Part 195 were inadequate\nfor overpressure safety devices. Specifically, TransCanada’s procedures failed to provide\nsufficient guidance on how to conduct and document relief valve inspections, per § 195.428(a).\nSection 195.428(a) states:\n“(a) Except as provided in paragraph (b) of this section, each operator shall, at intervals not\n\n\n\nCPF 1-2017-6008M\nexceeding 15 months, but at least once each calendar year, or in the case of pipelines used to carry\nhighly volatile liquids, at intervals not to exceed 7½ months, but at least twice each calendar year,\ninspect and test each pressure limiting device, relief valve, pressure regulator, or other item of\npressure control equipment to determine that it is functioning properly, is in good mechanical\ncondition, and is adequate from the standpoint of capacity and reliability of operation for the\nservice in which it is used.”\nDuring the inspection, the PHMSA inspector reviewed TransCanada’s “Liquid Overpressure\nSafety Devices and Overfill Protection Plan”, dated 8/30/16 (Plan), “Liquid Pipeline Relief Valve\nSetpoint Test/Capacity Review Procedure”, dated 6/10/16 (Procedure), and relief valve inspection\nrecords (Record). TransCanada’s Plan and Procedure did not provide sufficient guidance on\nconducting and documenting a relief valve inspection.\nTo ensure that a relief valve will relieve at the specified set pressure when needed, data is needed\non the condition of the valve prior to the inspection (“as found”), as well as on the condition of the\nvalve after the inspection is completed (“as left”). Information typically documented includes:\n The relief pressure of the valve in the “as found” condition\n The relief pressure of the valve in the “as left” condition\n The “set point”\nTransCanada’s Plan and Procedure did not include sufficient guidance and criteria for capturing\neither the “as found” or “as left” pressure of a relief device, as the terms are not defined. The Plan\nstates in Section 3:\n“Documentation:\n…\nEquipment maintenance records for mechanical pressure relief valves (thermal relief and pressure\nrelief valves) records should include:\n…\ne) As found and as left set point pressure of the device.”\nThe Procedure provides guidance for documenting various pressure reading values during the\nperformance of a relief valve inspection. None of the values required by the Procedure are stated\nto be the “as found” or “as left” relief pressure required to be documented per the Plan.\nThe Records reviewed demonstrated inconsistency with the Plan, as no fields were defined for “As\nFound” or “As Left” relief pressure.\nIn addition, the Plan/Procedure lacked details such as, but not limited to:\n The criteria for determining acceptable “as-found” / “as left” relief pressures\n The actions that must be taken if the relief valve “as-found” pressure does not meet the\ncriteria\n The definition and criteria for determining “popping pressure”, “popping point”, “reseat\npressure”, “set pressure”.\n120176008M_Notice Of Amendment_12142017_text Page 2 of 3\n\n\n\nCPF 1-2017-6008M\nTherefore, TransCanada failed to provide sufficient guidance on how to conduct and document\nrelief valve inspections, per the requirements of § 195.428(a).\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 60 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that TransCanada maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Robert Burrough, Director, PHMSA Eastern Region,\n820 Bear Tavern Road, Suite 103, West Trenton, NJ 08628. Please refer to CPF 1- 2017-6008M\non each document you submit, and whenever possible provide a signed PDF copy in electronic\nformat. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should be sent on\na CD accompanied by the original paper copy to the Eastern Region Office.\nAdditionally, if you choose to respond to this (or any other case), please ensure that any response\nletter pertains solely to one CPF case number.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120176008M_Notice Of Amendment_12142017_text Page 3 of 3","truncated":false,"body_characters":9660}