{"operation":"document","citation":"CPF 120181015M","title":"COLUMBIA GAS TRANSMISSION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-05-17","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181015m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181015m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181015m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120181015M","body":"Notice of Amendment involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.605(b)(2). The case was opened on 2018-05-17 and is reported as closed as of 2018-09-21. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120181015M_Closure Letter_09212018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181015M/120181015M_Closure%20Letter_09212018.pdf\n\n120181015M_Closure Letter_09212018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181015M/120181015M_Closure%20Letter_09212018_text.pdf\n\n120181015M_Notice of Amendment_05172018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181015M/120181015M_Notice%20of%20Amendment_05172018.pdf\n\n120181015M_Notice of Amendment_05172018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181015M/120181015M_Notice%20of%20Amendment_05172018_text.pdf\n\n120181015M_Closure Letter_09212018_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nSeptember 21, 2018\nRandal Broussard\nSVP, US Gas Operations East\nColumbia Gas Transmission, LLC\n201 Energy Parkway, Suite 100\nLafayette, LA 70508\nCPF 1-2018-1015M\nDear Mr. Broussard:\nOn August 29, 2017, a representative from the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to chapter 601 of 49 United States Code, inspected\nTransCanada Corporation’s (TC) and Columbia Gas Transmission, LLC’s, a subsidiary of TC,\nprocedures for Special Permits in Charleston, WV. As a result of the inspection, TC was issued a\nNotice of Amendment on May 17, 2018, which proposed amendment of your procedures.\nTC submitted its amended procedures on July 19, 2018. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n120181015M_Notice of Amendment_05172018_text.pdf\n\nNOTICE OF AMENDMENT\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 1-2018-1015M\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 inspected\nTransCanada Corporation’s (TC) and Columbia Gas Transmission, LLC’s, a subsidiary of TC,\nprocedures for Special Permits in Charleston, WV.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within\nColumbia Gas Transmission, LLC’s plans or procedures, as described below:\n1. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(1) …\n(2) Controlling corrosion in accordance with the operations and maintenance\nrequirements of Subpart I of this part.\nTC’s procedures for controlling corrosion in accordance with the operations and maintenance\nrequirements of Subpart I of CFR Part 192 were inadequate. Specifically, 70.01.01, External\nCorrosion Control, Effective date 12/12/2013, specified record retention requirements for\n\n\n\nCPF 1-2018-1015M\natmospheric corrosion inspections that conflict with the requirements of § 192.491(c).\nTC’s procedure 70.01.01, External Corrosion Control, Effective date 12/12/2013, states in part:\n“5.2 Records Retention\nA. The two most recent Atmospheric Corrosion inspections for onshore facilities will be\nretained. The five most recent Atmospheric Corrosion inspections for offshore will be\nretained.”\nPer Subpart I, § 192.491(c), records of each test required by that Subpart, which includes\natmospheric corrosion inspections, must be retained for at least 5 years. The two most recent\natmospheric corrosion inspection records may not provide the last 5 years.\nTherefore, TC’s procedures for controlling corrosion in accordance with the operations and\nmaintenance requirements of Subpart I of CFR Part 192 was inadequate with regards to\natmospheric corrosion inspection records retention.\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 30 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 Columbia Gas Transmission, LLC maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director,\nPHMSA Eastern Region, 820 Bear Tavern Road, Suite 103, West Trenton, NJ 08628. Please refer\nto CPF 1-2018-1015M on each document you submit, and whenever possible provide a signed\nPDF copy in electronic format. Smaller files may be emailed to robert.burrough@dot.gov. Larger\nfiles should be sent on a CD accompanied by the original paper copy to the Eastern Region Office.\n120181015M_Notice of Amendment_05172018_text Page 2 of 3\n\n\n\nCPF 1-2018-1015M\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\n120181015M_Notice of Amendment_05172018_text Page 3 of 3","truncated":false,"body_characters":7291}