# COLUMBIA GAS TRANSMISSION, LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 120181003
- **title:** COLUMBIA GAS TRANSMISSION, LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** current
- **official:** true
- **published on:** 2018-01-18
- **effective on:** Not available
- **summary:** OPEN notice of probable violation citing 192.455(a)(2), 192.603(b).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-120181003.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-120181003.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-120181003
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120181003
**body:**

Notice of Probable Violation involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.455(a)(2),  192.603(b). The case was opened on 2018-01-18 and is reported as open. Proposed civil penalty: $115,100. Assessed civil penalty: $47,500. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120181003_Final Order_10102019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181003/120181003_Final%20Order_10102019.pdf

120181003_Final Order_10102019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181003/120181003_Final%20Order_10102019_text.pdf

120181003_NOPV PCP PCO_01182018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181003/120181003_NOPV%20PCP%20PCO_01182018.pdf

120181003_NOPV PCP PCO_01182018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181003/120181003_NOPV%20PCP%20PCO_01182018_text.pdf

120181003_Operator Request For an Informal Meeting and Alternative Request For Hearing and Preliminary Statement of Issues (Title Page)_02272018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181003/120181003_Operator%20Request%20For%20an%20Informal%20Meeting%20and%20Alternative%20Request%20For%20Hearing%20and%20Preliminary%20Statement%20of%20Issues%20(Title%20Page)_02272018.pdf

120181003_Operator Request for Hearing_02272018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181003/120181003_Operator%20Request%20for%20Hearing_02272018.pdf

120181003_NOPV PCP PCO_01182018_text.pdf

NOTICE 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.



CPF 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



CPF 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



CPF 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



CPF 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

October 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



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. 1-2018-1003
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).



CPF 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.



CPF 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).



CPF 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.



CPF 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.



CPF 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
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