{"operation":"document","citation":"CPF 120181014W","title":"COLUMBIA GAS TRANSMISSION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-05-17","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181014w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181014w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181014w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120181014W","body":"Warning Letter involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2018-05-17 and is reported as closed as of 2018-05-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120181014W_Warning Letter_05172018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181014W/120181014W_Warning%20Letter_05172018.pdf\n\n120181014W_Warning Letter_05172018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181014W/120181014W_Warning%20Letter_05172018_text.pdf\n\n120181014W_Warning Letter_05172018_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nMay 17, 2018\nRandal Broussard\nSVP, US Gas Operations East\nColumbia Gas Transmission, LLC\n201 Energy Parkway, Suite 100\nLafayette, LA 70508\nCPF 1-2018-1014W\nDear Mr. Broussard:\nOn August 29, 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\nColumbia Gas Transmission, LLC’s, a subsidiary of TransCanada Corporation’s (TC), Special\nPermit Docket Number RSPA-80-6W in Charleston, WV.\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. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least once\neach calendar year. This manual must be prepared before operations of a pipeline\nsystem commence. Appropriate parts of the manual must be kept at locations\nwhere operations and maintenance activities are conducted.\nTC failed to follow, for each pipeline, a manual of written procedures for conducting operations\nand maintenance activities. Specifically, TC failed to record data as specified in its procedure\n\n\n\nCPF 1-2018-1014W\n70.001.002, Pipe Inspection, Effective date 6/5/2013 (Pipe Inspection Procedure).\nDuring the inspection, the PHMSA Inspector reviewed a Pipe Inspection and Reporting record,\nWork Order B4284760 (Record), conducted on 10/27/2014, and TC’s related procedures.\nTC’s procedure 70.01.01, External Corrosion Control, Effective date 12/12/2013 (Corrosion\nControl Procedure), stated in part:\n“3.2.3 Examination of a Buried Facility When Exposed\nA. Whenever any buried facility is exposed, the exposed portion must be examined for\nevidence of external corrosion. This examination must be documented using Procedure\n70.001.002 – Pipe Inspection and Reporting”\nTC’s Pipe Inspection Procedure stated in part:\n“2.6 Record Information for Level 1 (Simple) Inspection\n…\n2.6.3 Record the length of exposed pipe (in feet – e.g., 20.5)\n2.6.4 Record the soil condition (1 =“Dry”, 2 =“Moist” or 3 =“Wet” Note: If Maximo is being\nused to record this inspection, enter the number code corresponding to the applicable\ncategory in the work order).\n2.6.5 Record the soil type (1 =“Solid Rock”, 2 =“Rocky Soil”, 3 = “Sandy Soil”, 4 =“Topsoil”,\n5 =“Gravel”, 6 = “Shale”, 7 = “Sand”, 8 = “Clay”, 9 = “Loam”, or 11 = “Unknown” Note: If\nMaximo is being used to record this inspection, enter the number code corresponding to the\napplicable category in the work order).\n…\n2.6.17 Record whether SCC testing is required based on the below criteria…”\nThe Record reviewed presented fields without entry for data required by its Procedure: exposed\nlength, soil type, soil condition, and SCC testing required.\nTherefore, TC failed to follow, for each pipeline, a manual of written procedures for conducting\noperations and maintenance activities.\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. For violations occurring prior to November 2, 2015, the maximum penalty\nmay not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000\nfor a related series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this letter.\nFailure to do so will result in Columbia Gas Transmission, LLC being subject to additional\nenforcement 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\n120181014W_Warning Letter_05172018_text\nPage 2 of 3\n\n\n\nCPF 1-2018-1014W\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 1-2018-1014W 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.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120181014W_Warning Letter_05172018_text\nPage 3 of 3","truncated":false,"body_characters":6095}