# COLUMBIA GAS TRANSMISSION, LLC — Notice of Amendment

- **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:** Not available
- **summary:** CLOSED notice of amendment citing 192.605(b)(2).
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- **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.

Official case documents:

120181015M_Closure Letter_09212018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181015M/120181015M_Closure%20Letter_09212018.pdf

120181015M_Closure Letter_09212018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181015M/120181015M_Closure%20Letter_09212018_text.pdf

120181015M_Notice of Amendment_05172018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181015M/120181015M_Notice%20of%20Amendment_05172018.pdf

120181015M_Notice of Amendment_05172018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181015M/120181015M_Notice%20of%20Amendment_05172018_text.pdf

120181015M_Closure Letter_09212018_text.pdf

OVERNIGHT EXPRESS DELIVERY
September 21, 2018
Randal Broussard
SVP, US Gas Operations East
Columbia Gas Transmission, LLC
201 Energy Parkway, Suite 100
Lafayette, LA 70508
CPF 1-2018-1015M
Dear Mr. Broussard:
On August 29, 2017, a representative from the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, inspected
TransCanada Corporation’s (TC) and Columbia Gas Transmission, LLC’s, a subsidiary of TC,
procedures for Special Permits in Charleston, WV. As a result of the inspection, TC was issued a
Notice of Amendment on May 17, 2018, which proposed amendment of your procedures.
TC submitted its amended procedures on July 19, 2018. My staff reviewed the amended
procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been
corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration

120181015M_Notice of Amendment_05172018_text.pdf

NOTICE OF AMENDMENT
OVERNIGHT EXPRESS DELIVERY
May 17, 2018
Randal Broussard
SVP, US Gas Operations East
Columbia Gas Transmission, LLC
201 Energy Parkway, Suite 100
Lafayette, LA 70508
CPF 1-2018-1015M
Dear Mr. Broussard:
On August 29, 2017, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected
TransCanada Corporation’s (TC) and Columbia Gas Transmission, LLC’s, a subsidiary of TC,
procedures for Special Permits in Charleston, WV.
On the basis of the inspection, PHMSA has identified the apparent inadequacy found within
Columbia Gas Transmission, LLC’s plans or procedures, as described below:
1. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) …
(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) …
(2) Controlling corrosion in accordance with the operations and maintenance
requirements of Subpart I of this part.
TC’s procedures for controlling corrosion in accordance with the operations and maintenance
requirements of Subpart I of CFR Part 192 were inadequate. Specifically, 70.01.01, External
Corrosion Control, Effective date 12/12/2013, specified record retention requirements for



CPF 1-2018-1015M
atmospheric corrosion inspections that conflict with the requirements of § 192.491(c).
TC’s procedure 70.01.01, External Corrosion Control, Effective date 12/12/2013, states in part:
“5.2 Records Retention
A. The two most recent Atmospheric Corrosion inspections for onshore facilities will be
retained. The five most recent Atmospheric Corrosion inspections for offshore will be
retained.”
Per Subpart I, § 192.491(c), records of each test required by that Subpart, which includes
atmospheric corrosion inspections, must be retained for at least 5 years. The two most recent
atmospheric corrosion inspection records may not provide the last 5 years.
Therefore, TC’s procedures for controlling corrosion in accordance with the operations and
maintenance requirements of Subpart I of CFR Part 192 was inadequate with regards to
atmospheric corrosion inspection records retention.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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. Be advised that all
material you submit in response to this enforcement action is subject to being made publicly
available. If you believe that any portion of your responsive material qualifies for confidential
treatment under 5 U.S.C. 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, revised
procedures, or a request for a hearing under §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 an Order Directing Amendment. If your plans or
procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans
or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this
Notice, we propose that you submit your amended procedures to my office within 30 days of
receipt of this Notice. This period may be extended by written request for good cause. Once the
inadequacies identified herein have been addressed in your amended procedures, this enforcement
action will be closed.
It is requested (not mandated) that Columbia Gas Transmission, LLC maintain documentation of
the safety improvement costs associated with fulfilling this Notice of Amendment
(preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director,
PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103, West Trenton, NJ 08628. Please refer
to CPF 1-2018-1015M 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.
120181015M_Notice of Amendment_05172018_text Page 2 of 3



CPF 1-2018-1015M
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
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
120181015M_Notice of Amendment_05172018_text Page 3 of 3
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