COLUMBIA GAS TRANSMISSION, LLC — Notice of Probable Violation

party submissionOfficial PDF120181003_Operator Request For an Informal Meeting and Alternative Request For Hearing and Preliminary Statement of Issues (Title Page)_02272018.pdf#

party submissionOfficial PDF120181003_Operator Request for Hearing_02272018.pdf#

120181003_NOPV PCP PCO_01182018_text.pdf, page 1Official PDFNOTICE OF PROBABLE VIOLATION PROPOSED CIVIL PENALTY and PROPOSED COMPLIANCE ORDER OVERNIGHT EXPRESS DELIVERY January 18, 2018 Mr. Stanley Chapman III President, US Gas Pipelines Columbia Gas Transmission, LLC 700 Louisiana Street Houston, TX 77002 CPF 1-2018-1003 Dear Mr. Chapman: From May 2 to 20, 2016, an inspector from the Public Utilities Commission of Ohio (PUCO), acting as an Agent for the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected portions of Columbia Gas Transmission, LLC’s (CGT) pipeline system in Ohio. CGT, a subsidiary of Columbia Pipeline Group Inc., was acquired by TransCanada Corporation since completion of the inspection. As a result of the inspection, it is alleged that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected and the probable violation(s) are: 1. § 192.603 General Provisions. (b) Each operator shall keep records necessary to administer the procedures established under § 192.605 CGT failed to keep records necessary to administer the procedures established under § 192.605. Specifically, CGT failed to keep records that substantiate the established MAOP of its pipelines pursuant to § 192.619.#

120181003_NOPV PCP PCO_01182018_text.pdf, page 2CPF 1-2018-1003 Section 192.605, found in subpart L of 49 CFR 192, states in part: “… (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) Operating, maintaining, and repairing the pipeline in accordance with each of the requirements of this subpart and Subpart M of this part” Section 192.619, also found in subpart L of 49 CFR 192, states in part: “No person may operate a segment of steel or plastic pipeline at a pressure that exceeds a maximum allowable operating pressure determined under paragraph (c) or (d) of this section, or the lowest of the following…” During the inspection, the PUCO inspector requested MAOP records for jurisdictional pipeline segments within PHMSA Inspection Unit 9353, Crawford/McArthur. CGT indicated that their Engineering group would have to find, verify and validate their MAOP documentation. In response to subsequent PUCO email requests, CGT provided the spreadsheet App B-Post Code piping missing MAOP data for Crawford, Benton and McArthur 2016_12082016 (Missing MAOP Spreadsheet). The Missing MAOP Spreadsheet listed 213 rows of pipeline segments, accounting for a total of 16.828 miles of pipeline, with incomplete MAOP documentation. The PUCO inspector spoke to CGT on November 2, 2016 regarding the missing MAOP data. CGT stated that the missing MAOP documentation had not been found. The information provided during the inspection and in the subsequent communications did not include sufficient records necessary to validate the MAOP of these pipeline segments. Therefore, CGT failed to keep records necessary to administer the procedures established under § 192.605. 2. § 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 did not have a cathodic protection (CP) system designed to protect the pipeline in accordance with Subpart I of Part 192, installed and placed in operation within 1 year after completion of construction. Specifically, CGT did not install a cathodic protection system on 77 feet of 4-inch diameter coated piping on pipeline R-486, constructed and placed into service on July 10, 2003. 120181003_NOPV PCP PCO_01182018_text Page 2 of 5#

120181003_NOPV PCP PCO_01182018_text.pdf, page 3CPF 1-2018-1003 During the inspection, the PUCO inspector reviewed CGT’s work management system database (Database). The PUCO inspector noted a 77-foot section of coated piping in the Database and requested a map, procedure, installation record, and monitoring information related to CP of the pipeline. On December 8, 2016, CGT replied in part, “My understanding is that Line R-486 was a bare unprotected section of pipeline. There was (were) a section(s) of this line replaced with coated pipe and not insulated. Today’s management was unaware of the missing isolation and this situation predates Columbia’s current corrosion services team. It has been treated as bare unprotected and including active corrosion zone testing as applicable in which is a three year interval for net protective current survey. It was observed by Corrosion Services Specialist within the last 2 years that someone… installed a bond at an insulating flange therefore protecting this pipeline as a single unit with impressed current. Perhaps this was the intent, perhaps not, we don’t know. Unfortunately, the line continued to be electrically surveyed as bare unprotected with net protective current methodology. The Corrosion Specialist removed the bond at the time of discovery because it was our understanding that this line was bare and unprotected and we did not have situational awareness of replaced coated sections.” Therefore, CGT did not have a CP system installed and placed in operation within 1 year after the completion of construction of the 77 feet of its 4-inch diameter pipeline R-486. This violation is a repeat of violation found in CPF # 1-2015-1008, Item # 1. Proposed Civil Penalty Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $209,002 per violation per day the violation persists up to a maximum of $2,090,022 for a related series of violations. For violations occurring prior to November 2, 2015, the maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000 for a related series of violations. The Compliance Officer has reviewed the circumstances and supporting documentation involved in the above probable violation(s) and has recommended that you be preliminarily assessed a civil penalty of $115,100 as follows: Item number PENALTY 1 2 $ 47,500 $ 67,600 Proposed Compliance Order With respect to item(s) 1 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials Safety Administration proposes to issue a Compliance Order to Columbia Gas Transmission. 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. 120181003_NOPV PCP PCO_01182018_text Page 3 of 5#

120181003_NOPV PCP PCO_01182018_text.pdf, page 4CPF 1-2018-1003 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). Following the receipt of this Notice, you have 30 days to submit written comments, or request a hearing under 49 CFR § 190.211. 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. If you are responding to this Notice, we propose that you submit your correspondence to my office within 30 days from receipt of this Notice. This period may be extended by written request for good cause. Please submit all correspondence in this matter to Robert Burrough, Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103, West Trenton, New Jersey 08628. Please refer to CPF 1-2018-1003 on each document you submit, and whenever possible provide a signed PDF copy in electronic format. Smaller files may be emailed to robert.burrough@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, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Cc: Mr. Pete Chace PUCO Enclosures: Proposed Compliance Order Response Options for Pipeline Operators in Compliance Proceedings 120181003_NOPV PCP PCO_01182018_text Page 4 of 5#

120181003_NOPV PCP PCO_01182018_text.pdf, page 5CPF 1-2018-1003 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. 5. In regard to Item Number 1 of the Notice pertaining to § 192.603 and CGT’s failure to keep records necessary to substantiate the established MAOP of its pipelines pursuant to § 192.619, CGT shall determine MAOP records availability for all jurisdictional pipeline segments operated in Ohio. Within 60 days of issuance of the Final Order, CGT shall provide PHMSA a spreadsheet of the results of this review, which shall include the following information: a. b. c. d. A list of all jurisdictional pipeline segments operated by CGT in Ohio MAOP of the pipeline segment Identification of segments that do not have adequate records Identification of what required record(s) are missing for the segment For each pipeline segment determined to not have adequate records necessary to substantiate the established MAOP, CGT must develop a plan to re-establish its MAOP in accordance with 49 CFR Part 192.619. The plan must include the following: a. b. c. A list of segments identified to not have adequate records Method to obtain adequate records or re-establish the MAOP Safety measures to be taken pre- MAOP re-establishment or record obtainment. CGT shall provide the plan to PHMSA for review within 120 day of issuance of the Final Order. CGT shall provide records indicating the completion of the plan elements within 365 days of issuance of the Final Order. Upon request, CGT shall provide records necessary to substantiate the established MAOP to PHMSA within 14 days of the request. 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 Robert Burrough, 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. 120181003_NOPV PCP PCO_01182018_text Page 5 of 5#

120181003_Final Order_10102019_text.pdf, page 1Official PDFOctober 10, 2019 Mr. Stanley Chapman, III Executive Vice President and President U.S. Natural Gas Pipelines TC Energy 700 Louisiana Street, Suite 700 Houston, Texas 77002 Re: CPF No. 1-2018-1003 Dear Mr. Chapman: Enclosed please find the Final Order issued in the above-referenced case to your subsidiary, Columbia Gas Transmission, LLC. It withdraws one of the allegations of violation and its associated civil penalty, makes one finding of violation, assesses a civil penalty of $47,500, and specifies actions that need to be taken by Columbia Gas Transmission to comply with the pipeline safety regulations. The penalty payment terms are set forth in the Final Order. When the civil penalty has been paid and the terms of the compliance order completed, as determined by the Director, Eastern Region, this enforcement action will be closed. Service of the Final Order by certified mail is effective upon the date of mailing, as provided under 49 C.F.R. § 190.5. Thank you for your cooperation in this matter. Sincerely, Alan K. Mayberry Associate Administrator for Pipeline Safety Enclosure cc: Mr. Robert Burrough, Director, Eastern Region, Office of Pipeline Safety, PHMSA Mr. Lee Romack, Manager, U.S. Regulatory Compliance, TC Energy, 700 Louisiana Street, Suite 700, Houston Texas 77002 Mr. Randal Broussard, Senior Vice President, U.S. Gas Operations East, Columbia Gas Transmission, LLC, 201 Energy Parkway, Suite 100, Lafayette, Louisiana 70508 CERTIFIED MAIL - RETURN RECEIPT REQUESTED#

120181003_Final Order_10102019_text.pdf, page 2U.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. 1-2018-1003 a subsidiary of TC Energy, ) ) ) ) Respondent. ) ______________________________________) FINAL ORDER From May 2 through May 20, 2016, pursuant to 49 U.S.C. § 60117, a representative of the Public Utilities Commission of Ohio (PUCO), 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 (CGT or Respondent) in Ohio. CGT, a subsidiary of TC Energy, operates approximately 12,000 miles of pipelines and 37 gas storage fields in four states.1 As a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Respondent, by letter dated January 18, 2018, 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 CGT had committed two violations of 49 C.F.R. Part 192 and proposed assessing a civil penalty of $115,100 for the alleged violations. The Notice also proposed that Respondent be required to take certain measures to correct the alleged violations. TC Energy, on behalf of CGT, responded to the Notice by letter dated February 27, 2018 (Response).2 The company contested both allegations of violation and requested an informal meeting, or, alternatively, a hearing. Subsequently, in March 2018, Respondent met with the Director to discuss the Notice and, by letter dated September 27, 2018, withdrew its request for a hearing and thereby authorized the entry of this Final Order without further notice. FINDING OF VIOLATION The Notice alleged that Respondent violated 49 C.F.R. Part 192, as follows: 1 See, TC Energy website, available at https://www.tcenergy.com/operations/natural-gas/columbia-gas- transmission/ (last accessed October 3, 2019). 2 In May 2019, TransCanada Corporation changed its name to TC Energy. See, TC Energy website, available at https://www.tcenergy.com/TC-Energy/ (last accessed October 3, 2019).#

120181003_Final Order_10102019_text.pdf, page 3CPF No. 1-2018-1003 Page 2 Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.603(b), which states: § 192.603 General provisions. (a) . . . (b) Each operator shall keep records necessary to administer the procedures established under § 192.605. The Notice alleged that Respondent violated 49 C.F.R. § 192.603(b) by failing to keep records necessary to administer its manual of written procedures for operations, maintenance and emergencies established under § 192.605.3 Specifically, the Notice alleged that CGT had failed to keep records that substantiated the established maximum allowable operating pressure (MAOP) of its pipelines pursuant to § 192.619. Subparagraph § 192.605(b)(1) requires that an operator’s procedural manual include procedures for “[o]perating, maintaining, and repairing the pipeline in accordance with each of the requirements of this [Subpart L] and Subpart M of this Part.” Under Subpart L, § 192.619 sets requirements for establishing the MAOP of steel pipelines: § 192.619 Maximum allowable operating pressure: Steel or plastic pipelines. (a) No person may operate a segment of steel or plastic pipeline at a pressure that exceeds a maximum allowable operating pressure determined under paragraph (c) or (d) of this section, or the lowest of the following…” The section lists a number of options that an operator has to establish a safe MAOP, including the design pressure of the weakest segment, certain test-pressure calculations, or a combination of historical actual operating conditions. In addition, the operator must keep records necessary to document how it determined the calculated MAOP. According to the Notice, the PUCO inspector requested the company’s MAOP records for PHMSA-regulated pipeline segments within PHMSA Inspection Unit 9353, Crawford/McArthur (Ohio). Subsequently, CGT provided an MAOP spreadsheet accounting for 16.828 miles of pipeline that allegedly contained incomplete MAOP documentation. The PUCO inspector spoke with CGT on November 2, 2016, regarding the missing MAOP data and was told that the missing MAOP documentation had not been found. The information provided during the inspection and in subsequent communications did not include sufficient records necessary to validate the MAOP of these pipeline segments. In its September 27, 2018 letter, CGT withdrew its objection to this allegation of violation and request for an informal hearing. Accordingly, after considering all of the evidence, I find that Respondent violated 49 C.F.R. § 192.603(b) by failing to keep records necessary to administer its written procedures established under § 192.605. This finding of violation will be considered a prior offense in any subsequent enforcement action taken against Respondent. 3 Section 192.605 requires all operators of gas pipelines to prepare and follow for each pipeline a manual of written procedures for conducting normal operations and maintenance activities, and for emergency response.#

120181003_Final Order_10102019_text.pdf, page 4CPF No. 1-2018-1003 Page 3 WITHDRAWAL OF ALLEGATION OF VIOLATION Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 192.455(a)(2), which states: § 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)(2) by failing to have a cathodic protection (CP) system designed to protect its pipeline in accordance with Part 192, Subpart I, installed and placed in operation within one year after completion of construction. Specifically, the Notice alleged that CGT had not installed a CP system on 77 feet of its 4-inch- diameter coated piping on Pipeline R-486, which was constructed and placed into service on July 10, 2003. During the inspection, the PUCO inspector reviewed CGT’s work-management system database (Database). The PUCO inspector noted a 77-foot section of coated piping in the Database and requested a map, procedure, installation record, and monitoring information related to the CP on this pipeline.4 Following the March 2018 informal meeting with OPS Eastern Region, CGT provided records from 2002 to 2016 that had not been previously presented during the PHMSA inspection. These records demonstrated that CGT did indeed have a CP system installed and placed in operation within one year of completing the construction of the subject 77-foot pipeline segment on Pipeline R-486. PHMSA’s Regional Director accepted this new evidence as demonstrating compliance with 49 C.F.R. § 192.455(a)(2). Accordingly, based upon the foregoing, I hereby order that Item 2 be withdrawn. 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.5 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, 4 The monitoring of pipelines under cathodic protection is required under 49 C.F.R. § 192.465 in order to determine whether corrosion-protection levels are adequate. 5 These amounts are adjusted annually for inflation. See 49 C.F.R. § 190.223; Revisions to Civil Penalty Amounts, 83 Fed. Reg. 60732, 60744 (Nov. 27, 2018).#

120181003_Final Order_10102019_text.pdf, page 5CPF No. 1-2018-1003 Page 4 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; 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 $115,100 for the violations cited above. Item 1: The Notice proposed a civil penalty of $47,500 for Respondent’s violation of 49 C.F.R. § 192.603(b), for failing to keep records necessary to administer the procedures established under § 192.605. In Respondent’s September 27, 2018 letter, Respondent agreed to pay the proposed penalty.6 Accordingly, having reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of $47,500 for violation of 49 C.F.R. § 192.603(b). Item 2: The Notice proposed a civil penalty of $67,600 for Respondent’s violation of 49 C.F.R. § 192.455(a)(2), for failing to have a CP system designed to protect its pipeline in accordance with Part 192, Subpart I, installed and placed in operation within one year after completion of construction. Having withdrawn Item 2, I hereby withdraw the proposed civil penalty associated with this Item. In summary, having reviewed the record and considered the assessment criteria for each of the Items cited above, I assess Respondent a total reduced civil penalty of $47,500. 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, 6500 S MacArthur Blvd, Oklahoma City, Oklahoma 79169. The Financial Operations Division telephone number is (405) 954-8845. Failure to pay the $47,500 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 Item 1 in the Notice, for violation of 49 C.F.R. §§ 192.603(b). 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. 6 Hearing request withdrawal letter (on file with PHMSA), at 1.#

120181003_Final Order_10102019_text.pdf, page 6CPF No. 1-2018-1003 Page 5 With regard to the violation of § 192.603(b) (Item 1), Respondent requested that the proposed compliance terms be modified in order to allow CGT more time to re-establish the MAOP for segments lacking adequate records. The Director has recommended that the compliance order be modified accordingly. For the above reasons, the Compliance Order is modified as set forth below. Pursuant to the authority of 49 U.S.C. § 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 § 192.603(b) (Item 1), Respondent must determine MAOP records availability for jurisdictional pipeline segments operated in Ohio that are located in Class 3 locations, High Consequence Areas (HCAs), and post-1970 segments in Class 1 and 2 locations. CGT must provide PHMSA with a spreadsheet showing the results of this review by December 31, 2019. The following information must be included in the spreadsheet: a. A list of jurisdictional pipeline segments operated by CGT in Ohio, as per the above requirements; b. The MAOP of each pipeline segment; c. Identification of segments that do not have adequate records; and d. Identification of which required record(s) are missing for the segment. 2. With respect to the violation of § 192.603(b) (Item 1), Respondent must, for each pipeline segment determined to have inadequate records necessary to substantiate the established MAOP, develop a plan to re-establish its MAOP in accordance with 49 CFR § 192.619. CGT must provide the plan to PHMSA for review by December 31, 2019. The plan must include the following: a. A list of segments identified as having inadequate records; b. A method to obtain adequate records or re-establish the MAOP; and c. The safety measures to be taken before the MAOP is re-established or records obtained. 3. With respect to the violation of § 192.603(b) (Item 1), Respondent must provide records indicating the completion of the plan elements in Item 2 above and updates on the progress biannually (submissions due by June 30 and December 31 each year), including the following: a. By December 31, 2021, CGT must remediate a minimum of 50% of the MAOP gaps in HCA and Class 3 locations; b. By December 31, 2023, CGT must remediate all MAOP gaps on the identified segments in HCA and Class 3 locations in Ohio; and c. By December 31, 2027, CGT must remediate MAOP gaps on the identified post-1970 segments in Class 1 and Class 2 locations in Ohio. 4. Upon request, CGT must provide records necessary to substantiate the established MAOP to PHMSA within 14 days of the request.#

120181003_Final Order_10102019_text.pdf, page 7CPF No. 1-2018-1003 Page 6 The Director may grant an extension of time to comply with any of the required items upon a written request timely submitted by the Respondent and demonstrating good cause for an extension. 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 the Director. 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. Failure to comply with this Order may result in the administrative assessment of civil penalties not to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), 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 may submit a Petition for Reconsideration of this Final Order to the 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, no later than 20 days after receipt of service of this Final Order by Respondent. Any petition submitted must contain a 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. The other terms of the order, including corrective action, remain in effect 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. October 10, 2019 ___________________________________ __________________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety#