{"operation":"document","citation":"CPF 120176009W","title":"COLUMBIA MIDSTREAM GROUP, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-12-14","effective_on":null,"summary":"CLOSED warning letter citing 195.402(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120176009w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120176009w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120176009w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120176009W","body":"Warning Letter involving COLUMBIA MIDSTREAM GROUP, LLC. PHMSA's enforcement data identifies the cited regulation as 195.402(a). The case was opened on 2017-12-14 and is reported as closed as of 2017-12-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120176009W_Warning Letter_12142017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176009W/120176009W_Warning%20Letter_12142017.pdf\n\n120176009W_Warning Letter_12142017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176009W/120176009W_Warning%20Letter_12142017_text.pdf\n\n120176009W_Warning Letter_12142017_text.pdf\n\nWARNING LETTER\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 1-2017-6009W\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 (U.S.C.) inspected\nthe procedures 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, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violation(s) are:\n1. § 195.402(a) Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall be\nreviewed at intervals not exceeding 15 months, but at least once each calendar year,\nand appropriate changes made as necessary to insure that the manual is effective.\nThis manual shall be prepared before initial operations of a pipeline system\ncommence, and appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\nTransCanada failed to follow its procedural manual for operations, maintenance and emergencies.\nSpecifically, TransCanada failed to follow its “Emergency Response Plan Manual Administration\n\n\n\nCPF 1-2017-6009W\nPlan”, dated 12/07/16 (Procedure), by failing to document the Emergency Response Plan Manual\nreview as required.\nDuring the inspection, the PHMSA inspector reviewed TransCanada’s Procedure. The Procedure,\nSection 3 stated, “When an Emergency Response Plan Manual is reviewed or updated, it should\nbe documented in the Company work management system using Procedure Review and Update\nEmergency Pre-plans.”\nThe PHMSA inspector requested records for the 2015 – 2016 emergency response plan manual.\nTransCanada provided the “Liquid Pipeline Emergency Response Plan – Appendix D – Change\nLog” for Emergency Plan No. 400.017.422LP, Liquid Pipeline Emergency Plan: Hickory Bend\nLiquid Pipeline System, Revised 2/16/2017. This document lists the brief description of changes\nto the emergency response manual.\nThe document did not indicate the following data:\n Date of annual review\n Personnel who conducted annual review\n Proper form\nDuring the inspection, the PHMSA inspector asked TransCanada how the records demonstrated\ncompliance to performing an annual review, per the Procedure. TransCanada responded, “There\nis no record of annual review other than the change log information.”\nTherefore, TransCanada failed to follow its Procedure for the 2015 and 2016 calendar years\nregarding documenting the review of its Emergency Response Plan Manual.\n2. § 195.402(a) Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall be\nreviewed at intervals not exceeding 15 months, but at least once each calendar year,\nand appropriate changes made as necessary to insure that the manual is effective.\nThis manual shall be prepared before initial operations of a pipeline system\ncommence, and appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\nTransCanada failed to review its operations and maintenance (O&M) manual at intervals not\nexceeding 15 months, but at least once each calendar year. Specifically, TransCanada failed to\nconduct an annual review of its O&M manual during the 2016 calendar year.\nDuring the inspection, the PHMSA inspector requested records for the 2014 – 2016 O&M annual\nreviews. TransCanada provided the records, “2014 O&M Manual Review Completion Letter Line\n800” and “2015 O&M Manual Review Completion Letter Line 800.” The PHMSA inspector re-\nrequested the 2016 O&M manual annual review and TransCanada stated, “It was not conducted.”\n120176009W_Warning Letter_12142017_text\nPage 2 of 4\n\n\n\nCPF 1-2017-6009W\nIn subsequent follow-ups to the inspection, TransCanada provided, “2016 OM Manual Letter”,\ndated 5/12/17. TransCanada stated, “I have attached the 2016 review letter which was not available\nat the time of the inspection.” The TransCanada 2016 OM Manual Letter was dated May 12, 2017,\nafter the PHMSA inspection on April 24-28, 2017. TransCanada was also unable to provide\nadditional records supporting the O&M Manual review out of their work management system upon\nrequest.\nTherefore, TransCanada failed to conduct an annual review of its O&M manual for the 2016\ncalendar year, per the requirements of §195.402(a).\n3. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall be\nreviewed at intervals not exceeding 15 months, but at least once each calendar year,\nand appropriate changes made as necessary to insure that the manual is effective.\nThis manual shall be prepared before initial operations of a pipeline system\ncommence, and appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\nTransCanada failed to follow its manual of written procedures for conducting normal operations\nand maintenance activities. Specifically, TransCanada failed to document and maintain its monthly\nfirefighting equipment inspections for calendar years 2015 and 2016, in accordance with its Plan\n110.01.08 “Portable Fire Extinguishers Plan” (Procedure).\nDuring the inspection, the PHMSA inspector reviewed TransCanada’s Procedure, versions dated\n10/13/16, 12/23/15 and 10/1/15. Section 4.1 of all versions of the Procedure stated, “Each\nextinguisher must be visually inspected on a monthly basis and receive proper maintenance\nannually, in accordance with NFPA standards.” The Procedure – Documentation Requirements\nSection stated, “…Complete WO for fire extinguisher monthly inspection…” Additionally, the\nProcedure listed the following under Documentation Requirements, “Record/Form Name – Form\n790-ST3-CSD and Work Management System – Complete WO for fire extinguisher monthly\ninspection.”\nThe PHMSA inspector requested records for firefighting equipment for 2015 and 2016.\nTransCanada provided “MLBV Fire Extinguisher Inspection – Document No. CFL-410-048” for\nthe following months during these timeframes:\n August, 2015\n September, 2015\n October, 2015\n November, 2015\n December, 2015\nThese records documented the fire extinguisher monthly inspections on Columbia Midstream\nCompany Form 410-CFL-048. This form is not referenced in TransCanada’s Procedure. During\n120176009W_Warning Letter_12142017_text\nPage 3 of 4\n\n\n\nCPF 1-2017-6009W\nthe inspection, TransCanada stated, “The remaining fire extinguisher records are documented on\nthe fire tags.”\nThe PHMSA inspector requested the work order and fire tag records required by the Procedure.\nTransCanada provided, “MLBV Fire Tags 2015 Line 800.” These records were a compilation of\nvarious fire extinguisher tags with unlabeled serial numbers which do not correspond, or include\nadequate data to the applicable mainline valve location firefighting equipment.\nTherefore, TransCanada failed to follow its manual of written procedures for conducting normal\noperations and maintenance activities regarding fire extinguisher inspection documentation.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$209,002 per violation per day the violation persists up to a maximum of $2,090,022 for a related\nseries of violations. We have reviewed the circumstances and supporting documents involved in\nthis case, and have decided not to conduct additional enforcement action or penalty assessment\nproceedings at this time. We advise you to correct the item(s) identified in this letter. Failure to do\nso will result in Transcanada being subject to additional enforcement action.\nPlease be advised that all material you submit in response to this enforcement action is subject to\nbeing made publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for confidential\ntreatment redacted and an explanation of why you believe the redacted information qualifies for\nconfidential treatment under 5 U.S.C. 552(b).\nNo reply to this letter is required. If you choose to reply, please submit all correspondence in this\nmatter to Robert Burrough, Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103,\nWest Trenton, NJ 08628. Please refer to CPF 1-2017-6009W on each document you submit, and\nwhenever possible provide a signed PDF copy in electronic format. Smaller files may be emailed\nto robert.burrough@dot.gov. Larger files should be sent on a CD accompanied by the original\npaper 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\n120176009W_Warning Letter_12142017_text\nPage 4 of 4","truncated":false,"body_characters":10462}