{"operation":"document","citation":"CPF 120181016S","title":"COLUMBIA GAS TRANSMISSION, LLC — Safety Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-07-09","effective_on":null,"summary":"CLOSED safety order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181016s.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181016s.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181016s","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120181016S","body":"Safety Order involving COLUMBIA GAS TRANSMISSION, LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2018-07-09 and is reported as closed as of 2020-03-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120181016S_Closure Letter_03022020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181016S/120181016S_Closure%20Letter_03022020.pdf\n\n120181016S_Closure Letter_03022020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181016S/120181016S_Closure%20Letter_03022020_text.pdf\n\n120181016S_Notice Of Proposed Safety Order_07092018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181016S/120181016S_Notice%20Of%20Proposed%20Safety%20Order_07092018.pdf\n\n120181016S_Notice Of Proposed Safety Order_07092018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181016S/120181016S_Notice%20Of%20Proposed%20Safety%20Order_07092018_text.pdf\n\n120181016S_Operator Response to Notice_08082018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181016S/120181016S_Operator%20Response%20to%20Notice_08082018.pdf\n\n120181016S_Safety Order_10102019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181016S/120181016S_Safety%20Order_10102019.pdf\n\n120181016S_Safety Order_10102019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181016S/120181016S_Safety%20Order_10102019_text.pdf\n\n120181016S_Safety Order_10102019_text.pdf\n\nOctober 10, 2019\nMr. Stanley Chapman, III\nExecutive Vice President and President\nU.S. Natural Gas Pipelines\nTC Energy\n700 Louisiana Street, Suite 700\nHouston, Texas 77002\nRe: CPF No. 1-2018-1016S\nDear Mr. Chapman:\nEnclosed please find the Safety Order issued in the above-referenced case. It makes a finding\nthat the pipeline system of your subsidiary, Columbia Gas Transmission, LLC, has a condition or\nconditions that pose a pipeline integrity risk and specifies actions that must be taken to ensure\nthat the public, property, and the environment are protected from the risk. When the terms of the\norder have been completed, as determined by the Director, Eastern Region, this enforcement\naction will be closed. Your receipt of the Safety Order constitutes service of the document, as\nprovided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. Robert Burrough, Director, Eastern Region, Office of Pipeline Safety, PHMSA\nMr. Lee Romack, Manager, U.S. Regulatory Compliance, TC Energy, 700 Louisiana\nStreet, Suite 700, Houston, Texas 77002\nMr. Randal Broussard, Senior Vice President, U.S. Gas Operations East, Columbia Gas\nTransmission, LLC, 201 Energy Parkway, Suite 100, Lafayette, Louisiana 70508\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nColumbia Gas Transmission, LLC, )\na subsidiary of TC Energy, ) CPF No. 1-2018-1016S\n)\n)\n)\nRespondent. )\n____________________________________)\nSAFETY ORDER\nPursuant to Chapter 601 of Title 49, United States Code, the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), U.S. Department of Transportation, initiated an investigation\nand information review of the safety of Columbia Gas Transmission, LLC’s (CGT) Leach\nXpress (LEX) gas pipeline system. CGT is a subsidiary of TC Energy (collectively,\nRespondent).1 The investigation was initiated after PHMSA was notified, on June 7, 2018, of a\nreportable incident that occurred on the LEX pipeline system, which resulted in the release of\napproximately 165 million cubic feet (MMCF) of natural gas, an ignition of natural gas, and a\nfire (Failure). The Failure resulted in the ejection of approximately 83 feet of 36-inch diameter\npipe from the ditch onto the right of way. The Failure occurred in a remote, Class 1 rural\nlocation, and there were no reported injuries, fatalities or evacuations. The cause of the Failure\nhas not yet been determined.\nAs a result of the investigation, and pursuant to 49 U.S.C. § 60117(1), the Director, Eastern\nRegion, OPS (Director), issued a Notice of Proposed Safety Order (Notice) to CGT on July 9,\n2018, proposing certain measures be taken to ensure that the public, property, and the\nenvironment are protected from identified integrity risks related to the Failure. The Notice\nnotified Respondent of the preliminary findings of the investigation and proposed that\nRespondent take certain measures to ensure that the public, property, and the environment are\nprotected from the integrity risk of LEX related to the Failure.\nOn August 8, 2018, TC Energy responded to the Notice on behalf of CGT (Response).2 In the\nResponse, Respondent did not contest the proposed findings or remedial requirements contained\nin the Notice, but provided an update on the work it had completed to date to ensure the safe\n1 See, TC Energy Website, available at https://www.tcenergy.com/operations/natural-gas/columbia-gas-transmission/\n(last accessed October 3, 2019).\n2 In May 2019, TransCanada Corporation changed its name to TC Energy. See, TC Energy Website, available at\nhttps://www.tcenergy.com/TC-Energy/ (last accessed October 3, 2019).\n\n\n\nCPF No. 1-2018-1016S\nPage 2\noperation of the LEX. Respondent did request that the Proposed Safety Order requirements be\nmodified based on the work completed and approved by PHMSA to date. In subsequent\nsubmissions, including emails dated January 11 and February 22, 2019, Respondent submitted\nadditional documentation of completed actions. Respondent did not request a hearing and\ntherefore has waived its right to one.\nFINDINGS OF PIPELINE INTEGRITY RISK\nRespondent did not contest the proposed findings in the Notice that its pipeline has a condition or\nconditions that pose a pipeline integrity risk. Accordingly, pursuant to 49 U.S.C. § 60117(1) and\n49 C.F.R. § 190.239, I find as follows:\n• Columbia Gas Transmission, LLC, a subsidiary of TC Energy, operates over 10,468\nmiles of interstate natural gas transmission pipelines, 37 storage fields across four states,\nand transports an average of three billion cubic feet of natural gas per day through New\nYork, New Jersey, Pennsylvania, Maryland, Virginia, West Virginia, Ohio, Kentucky,\nNorth Carolina, and Delaware. Columbia Gas was acquired by TransCanada Corporation\nin 2016. In My 2019, TransCanada changed its name to TC Energy.\n• The failed pipeline is a 36-inch diameter, 130 mile-long line that transports natural gas\nand runs from Majorsville, Pennsylvania, to Crawford, Ohio. The Failure occurred near\nmilepost (MP) 20.6, approximately seven miles south of Moundsville, West Virginia\n(Failure Site).\n• The Affected Segment runs along several hills and ridges with steep elevation changes.\nThe Failure Site is located on Nixon Ridge.3\n• The Affected Segment near the Failure Site was constructed in 2017. The pipeline at the\nFailure Site consists of grade X-70, 36-inch steel pipe with a wall thickness of 0.515” and\n0.618”. The pipeline has fusion bonded epoxy coating and double submerged arc welded\n(DSAW) seams. The impressed current cathodic protection system had not been\nenergized, but Respondent was in the process of having it commissioned. Galvanic\nanodes were installed at foreign lines crossings.\n• The maximum allowable operating pressure (MAOP) of the Affected Segment is 1440\npounds per square inch gauge (psig), as established by hydrostatic test in 2017. At the\ntime of the Failure, the actual operating pressure of the pipeline upstream from the\nFailure was 1280 psig; downstream of the Failure at the Eureka Metering Station, the\noperating pressure was 1243.7 psig.\n• At approximately 4:55 a.m. EDT on June 7, 2018, Respondent discovered a failure on the\n3 “Affected Segment” means the approximately 50 miles of Respondent’s 30-inch and 36-inch LEX Pipeline from\nthe upstream Lone Oak Compressor Station (MP 7.2) near Lone Oak, West Virginia within Marshall County\nthrough the downstream Summerfield Compressor Station (MP 57.2) near Summerfield, OH in Noble County. The\n“Affected Segment” generally runs westerly through portions of Noble and Monroe Counties in Ohio, and Marshall\nCounty in West Virginia.\n\n\n\nCPF No. 1-2018-1016S\nPage 3\nLEX pipeline system, as determined by its gas controller, from a pressure drop\nobservation. The incident was determined to be a natural gas release, an ignition of\nnatural gas, and fire in the area of Moundsville, West Virginia. The Failure resulted in\nthe ejection of approximately 83 feet of 36-inch pipe from the ditch onto the right of way,\nand the loss of 165 MMCF of natural gas. The Failure occurred in a remote, Class 1 rural\nlocation. There were no reported injuries, fatalities or evacuations. The Failure was\nreported to the National Response Center (NRC Report No. 1214458) on June 7, 2018, at\napproximately 6:12 a.m. EDT.\n• Respondent isolated the Affected Segment via manual closure of valves LEX-500, which\nis a main line valve (MLV) known as MLV 2, and LEX-600 (MLV 3) (Isolated\nSegment).4 MLV 2 is located approximately 1.6 miles upstream of the Failure Site and\nwas manually closed at approximately 5:20 a.m. EDT. MLV 3 is located approximately\n12.75 miles downstream of the Failure Site and automatically closed at approximately\n4:55 a.m. EDT. The upstream Lone Oak compressor station’s compressor units were\nshut down via a command issued from Respondent’s Gas Control at approximately 4:36\na.m. EDT. In addition, LEX-700, MLV 4, further downstream from MLV 3,\nautomatically closed at approximately 5:32 a.m. EDT.\n• PHMSA, Roberts Ridge Volunteer Fire Department, the West Virginia Department of\nEnvironmental Protection, the West Virginia Division of Forestry, and the Federal\nEnergy Regulatory Commission responded to the scene. PHMSA inspectors initiated an\ninvestigation of the Failure on June 7, 2018.\n• The Isolated Segment, which was shut-in via the closure of MLVs 2 and 3, currently\nremains out of service.\n• On December 12, 2017, Respondent completed a hydrostatic test on “test section LX1-\n3A” of the LEX pipeline, which includes the location of Failure. The section was\nsuccessfully tested for a duration of eight hours to a minimum test pressure of 1880 psig.\nIn addition, on December 14, 2017, Respondent ran an Enduro Digital Data Logger\nCaliper tool from the Taylor B (746+11) launch site near Glen Easton, West Virginia, to\nGames Ridge (1139+34.9) receive site near Moundsville, West Virginia. The report was\ngenerated on December 20, 2017. On May 17, 2018, a combo High-Resolution Magnetic\nFlux Leakage (HR MFL) + Geo Tool was run with an inertial measurement unit.\nRespondent did not immediately receive the report from the combo HR MFL + Geo Tool\nrun, but the vendor was asked to provide an expedited preliminary in-line inspection\nreport as soon as practicable due to the Failure.\n• Since the Failure, Respondent has identified six other points along the pipeline that,\nbased on their geotechnical flyover, are areas of concern due to the existence of large\nspoil piles, steep slopes, or indications of slips. Respondent has also performed minor\nrepair work and grading of the Failure Site.\n4 “Isolated Segment” means the approximately 14.35-mile segment of the LEX pipeline from the upstream valve\nLEX-500 (MLV 2) at MP 18.5 to the downstream valve LEX-600 (MLV 3) at MP 32. It is the portion of the\n“Affected Segment” that was shut-in after the failure on June 7, 2018, by closing MLV 2 (upstream of the failure)\nand MLV 3 (downstream of the failure).\n\n\n\nCPF No. 1-2018-1016S\nPage 4\n• The PHMSA investigation is ongoing and the cause of the Failure is unknown at this\ntime. The preliminary investigation suggests that the Failure was the result of land\nsubsidence causing stress on a girth weld.\nISSUANCE OF SAFETY ORDER\nSection 60117(1) of Title 49, United States Code, provides for the issuance of a safety order,\nafter reasonable notice and the opportunity for a hearing, requiring corrective measures, which\nmay include physical inspection, testing, repair, or other action, as appropriate. The basis for\nmaking the determination that a pipeline facility has a condition or conditions that pose a\npipeline integrity risk to public safety, property, or the environment is set forth both in the above-\nreferenced statute and 49 C.F.R. § 190.239.\nAfter evaluating the foregoing findings and considering the age of the pipe involved, the\nhazardous nature of the product transported, the circumstances surrounding the Failure, including\nthe uncertainties of the cause of the Failure and the potential for the conditions that caused the\nFailure to be present elsewhere on the pipeline system, PHMSA finds that Respondent’s LEX\ngas pipeline system has a condition or conditions that pose a pipeline integrity risk to public\nsafety, property, or the environment. Accordingly, PHMSA issues this Safety Order, which\nrequires that Respondent take measures specified below to address the risk.\nCORRECTIVE MEASURES\nThe Notice proposed certain actions with respect to the Affected Segment. As described below,\nRespondent has completed certain actions relating to Items 3 and 4.\nAs for the remaining compliance terms, pursuant to 49 U.S.C. § 60117(1) and 49 C.F.R.\n§ 190.239, Respondent must take the following remedial requirements with respect to the\nAffected Segment:\n1. Review of Isolated Segment. Respondent must review and inspect the Isolated Segment\nfor conditions similar to those of the Failure including a review of construction, operating\nand maintenance (O&M), and integrity management records such as in-line inspection\n(ILI) results, hydrostatic tests, root cause failure analysis of the Failure, aerial and ground\npatrols, cathodic protection, excavations and pipe replacements. Respondent must\naddress any findings that require remedial measures to be implemented within 30 days of\ndiscovery.\nRespondent has completed aerial and ground patrols of the Isolated Segment,5 however it\nmust still conclude its review of construction, O&M and integrity management records,\nsuch as ILI results, hydrostatic tests, root cause failure analysis of the Failure, cathodic\nprotection, excavations and pipe replacement records in order to satisfy this Corrective\n5 Response, at 1.\n\n\n\nCPF No. 1-2018-1016S\nPage 5\n2. 3. 4. 5. 6. 7. Action Item.\nEnhanced Surveillance and Monitoring. Respondent must provide for enhanced\npatrolling and surveillance of the Isolated Segment until completion of the Root Cause\nFailure Analysis required in Corrective Action 10.\nRespondent completed enhanced surveillance and patrolling of the Isolated Segment\nduring the purge, load and restart of the pipeline. Its Response acknowledged that\nadditional surveillance, patrolling and monitoring will be included during the completion\nof its actions in response to additional items.6 I have therefore modified this Corrective\nAction Item to require that enhanced patrolling and surveillance of the Isolated Segment\ncontinue until the completion of the Root Cause Failure Analysis required in Corrective\nAction 10.\nInstallation of Strain Gauges. Respondent installed a total of 11 sets of strain gauges.\nThese strain gauges included those required as a part of its Repair Plan, and additional\nsets determined to be needed after identification of an additional location with the\npotential for land movement. Accordingly, Respondent has completed the requirements\nof Corrective Action 3.\nHydrostatic Testing. Respondent completed a 49 C.F.R. Part 192 Subpart J pressure test\nof all replacement pipe utilized at the failure site within the Isolated Segment, in\naccordance with the Hydrostatic Testing Plan it provided to PHMSA on June 28, 2018.\nAccordingly, Respondent has completed the requirements of Corrective Action 4.\nWeather Contingency Plan. Within 30 days of receipt of this Safety Order, Respondent\nmust submit to the Director a contingency plan to operate and monitor the Isolated\nSegment during saturated soil or flooding conditions, including enhanced patrolling and\nsurveillance.\nInstrumented Leakage Survey. Within 30 days of receipt of this Safety Order,\nRespondent must perform an aerial or ground instrumented leakage survey of the\nAffected Segment. Respondent must investigate all leak indications and remedy all leaks\ndiscovered. Respondent must submit documentation of this survey to the Director within\n45 days of receipt of this Safety Order.\nRespondent completed instrumented leakage surveys of the Isolated Segment between\nJuly 13 and 15, 2018, following the purge and load steps during the restart of the\npipeline.7 However, Respondent has not submitted documentation of an aerial or ground\ninstrumented leakage survey for the entire Affected Segment as required.\nRecords Verification. Respondent must verify the records for the Affected Segment to\nconfirm the maximum operating pressure or MAOP (See PHMSA Advisory Bulletin\n6 Response, at 1.\n7 Response, at 2.\n\n\n\nCPF No. 1-2018-1016S\nPage 6\n8. ADB 12-06). Respondent must submit documentation of this record verification within\n45 days of receipt of this Safety Order.\nReview of Prior Inline Inspection (ILI) Results. Within 30 days of receipt of this Safety\nOrder, Respondent must conduct a review of any previous ILI results of the Affected\nSegment. Respondent must re-evaluate all ILI results, including a review of the ILI\nvendors’ raw data and analysis. Respondent must determine whether any features were\npresent in the failed pipe joint and any other pipe removed. Also, Respondent must\ndetermine if any features with similar characteristics are present elsewhere on the\nAffected Segment. Respondent must submit documentation of this ILI review to the\nDirector within 45 days of receipt of this Safety Order as follows:\nA. List all ILI tool runs, tool types, and the calendar years of the tool runs.\nB. List, describe (type, size, wall loss, etc.), and identify the specific location of all ILI\nfeatures present in the failed joint and/or other pipe removed.\nC. List, describe (type, size, wall loss, etc.), and identify the specific location of all ILI\nfeatures with similar characteristics present elsewhere on the Affected Segment.\nD. Explain the process used to review the ILI results and the results of the\nreevaluation.\n9. Mechanical and Metallurgical Testing. Respondent developed a Work Plan and testing\nprotocol, assessment schedule, and commenced mechanical and metallurgical testing of\nthe failed segments by a third-party (Blade Energy Partners), as outlined in the Notice,\nCorrective Action 9. Metallurgical testing of the failed segments commenced on July 30,\n2018. To clarify, the testing protocol defines the requirement for five-day advanced\nnotice and that all testing reports are distributed simultaneously to OPS and Respondent.\nIn addition, daily progress reports and schedules of events from Blade Energy Partners\nwere disseminated to OPS. The final Failure Analysis Report prepared by Blade Energy\nPartners, dated February 14, 2019, was submitted to OPS on February 22, 2019.\nAccordingly, Respondent has completed the requirements of Corrective Action 9.\n10. Root Cause Failure Analysis. Within 90 days following receipt of this Safety Order,\nRespondent must complete a root cause failure analysis (RCFA) and submit a final report\nof this RCFA to the Director. The RCFA must be supplemented and facilitated by an\nindependent third-party with prior written approval of the Director, and must document\nthe decision-making process used in the analysis and all factors contributing to the\nFailure. The final report must include findings, any lessons learned, and whether the\nfindings and any lessons learned are applicable to other locations within Respondent’s\npipeline system.\n11. Remedial Work Plan. On June 13, 2018, Respondent prepared an Integrity Verification\n& Remedial Work Plan detailing the actions that it will, or already has, take to ensure the\ncontinued integrity of the LEX pipeline. Geotechnical evaluations have been completed\nalong the entire LEX right-of-way and areas of concern identified. Measures to mitigate,\nmonitor and/or repair areas of identified land movement are underway. There are\ncurrently no known conditions that would significantly impact the integrity of the\npipeline. Accordingly, Respondent has completed the requirements of Corrective Action\n11.\n\n\n\nCPF No. 1-2018-1016S\nPage 7\n12. Monthly Reports. Respondent must submit monthly reports to the Director that: (1)\ninclude analysis of all available data and results of the testing and evaluations required by\nthis Safety Order; (2) describe the progress of repairs and other remedial actions being\nundertaken; and (3) document all mandated actions and management of change plans to\nensure that all procedural modifications are incorporated into Respondent’s operations\nand maintenance procedures manual. The first report will be due 30 days from issuance\nof this Safety Order.\n13. Safety Order Documentation Report (SODR). When Respondent has completed all the\ncorrective action items in this Safety Order, it must submit a final SODR in its entirety to\nthe Director. This will allow the Director to conduct a thorough review of all actions\ntaken by Respondent with regards to this Safety Order prior to approving the closure of\nthis Safety Order. The intent is for the SODR to summarize all activities and\ndocumentation associated with this Safety Order in one document.\nA. The Director may approve the SODR incrementally without approving the entire\nSODR.\nB. Once approved by the Director, the SODR will be incorporated by reference into\nthis Safety Order.\nC. The SODR must include, but is not limited to:\ni. Table of Contents;\nii. Summary of the Failure, and the response activities;\niii. Summary of pipe data/properties and all prior assessments of the Affected\nSegment;\niv. Summary of all tests, inspections, assessments, evaluations, and analysis\nrequired by this Safety Order;\nv. Summary of the Mechanical and Metallurgical Testing as required by this\nSafety Order;\nvi. vii. Summary of the RCFA with all root causes as required by this Safety Order;\nDocumentation of all actions taken by Respondent to implement the RWP, the\nresults of those actions, and the inspection and repair criteria used;\nviii. Documentation of any revisions to the RWP including those necessary to\nincorporate the results of actions undertaken pursuant to this Safety Order and\nwhenever necessary to incorporate new information obtained during the\nfailure investigation and remedial activities;\nLessons learned while completing this Safety Order;\nA path forward describing specific actions Respondent will take on its entire\npipeline system as a result of the lessons learned from work on this Safety\nOrder; and\nxi. Appendices (if required).\nWith respect to each submission under this Safety Order that requires the approval of the\nDirector, the Director may: (a) approve, in whole or part, the submission; (b) approve the\nsubmission on specified conditions; (c) modify the submission to cure any deficiencies; (d)\ndisapprove, in whole or in part, the submission, directing that Respondent modify the\nsubmission; or (e) any combination of the above. In the event of approval, approval upon\nconditions, or modification by the Director, Respondent shall take all required actions in the\nix. x.\n\n\n\nCPF No. 1-2018-1016S\nPage 8\nsubmission as approved or modified by the Director. If the Director disapproves all or any\nportion of the submission, Respondent shall correct all deficiencies within the time specified by\nthe Director, and resubmit it for approval. If a resubmitted item is disapproved in whole or in\npart, the Director may again require Respondent to correct the deficiencies in accordance with\nthe foregoing procedure, and the Director may otherwise proceed to enforce the terms of this\nSafety Order.\nIt is requested (not mandated) that Respondent maintain documentation of the safety\nimprovement costs associated with fulfilling this Safety Order and submit the total to the\nDirector. It is requested that these costs be reported in two categories: (1) total cost associated\nwith preparation/revision of plans, procedures, studies and analyses; and (2) total cost associated\nwith replacements, additions and other changes to pipeline infrastructure.\nThe Director may grant an extension of time for compliance with any of the terms of this Safety\nOrder upon a written request timely submitted demonstrating good cause for an extension.\nRespondent may appeal any decision of the Director to the Associate Administrator for Pipeline\nSafety. Decisions of the Associate Administrator shall be final.\nIn your correspondence on this matter, please refer to CPF No. 1-2018-1016S and for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nBe advised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential 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\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. § 552(b).\nThe actions taken pursuant to this Safety Order are in addition to and do not waive any\nrequirements that apply to Respondent’s pipeline system under 49 C.F.R. Parts 190 through 199,\nunder any other order issued to Respondent under authority of 49 U.S.C. Chapter 601, or under\nany other provision of Federal or state law.\nAfter receiving and analyzing additional data in the course of this proceeding and\nimplementation of the required tests and analysis, PHMSA may identify other safety measures\nthat need to be taken. In that event, Respondent will be notified of any proposed additional\nmeasures and, if necessary, amendments to the Safety Order.\nThe terms and conditions of this Safety Order are effective upon service in accordance with 49\nC.F.R. § 190.5.\nOctober 10, 2019\n___________________________________ __________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n120181016S_Notice Of Proposed Safety Order_07092018_text.pdf\n\nVIA FEDERAL EXPRESS MAIL AND FAX TO: (403) 920-2200\nJuly 9, 2018\nMr. Randal Broussard\nSVP, US Gas Operations East\nColumbia Gas Transmission, LLC\n201 Energy Parkway, Suite 100\nLafayette, LA 70508\nCPF 1-2018-1016S\nDear Mr. Broussard:\nEnclosed is a Notice of Proposed Safety Order (Notice) issued by the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) in the above-referenced case. The Notice proposes that\nTransCanada take certain measures with respect to Columbia Gas Transmission, LLC’s Leach\nXpress (LEX) pipeline system, near Moundsville, WV. Your options for responding are set forth\nin the Notice. Your receipt of the Notice constitutes service of that document under § 190.5.\nWe look forward to a successful resolution to ensure pipeline safety. Please direct any questions\non this matter to me at 609-771-7809.\nThank you for your cooperation in this matter.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Notice of Proposed Safety Order\nCopy of 49 C.F.R. § 190.239\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, PHMSA\nMr. Stanley Chapman III, President, US Gas Pipelines, Columbia Midstream Group, LLC;\n700 Louisiana Street, Suite 700, Houston, TX 77002\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n_________________________________________\n)\nIn the Matter of )\n)\nColumbia Gas Transmission, LLC, )\na subsidiary of TransCanada Corporation, ) )\n)\nCPF No. 1-2018-1016S\nRespondent. )\n_________________________________________ )\nNOTICE OF PROPOSED SAFETY ORDER\nBackground and Purpose:\nPursuant to Chapter 601 of Title 49, United States Code, the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), U.S. Department of Transportation, has initiated an\ninvestigation and information review of the safety of Columbia Gas Transmission, LLC’s, a\nsubsidiary of TransCanada Corporation (TransCanada or Respondent), Leach Xpress (LEX) gas\npipeline system.\nThe investigation was prompted after PHMSA was notified on June 7, 2018, by the National\nResponse Center of a reportable incident that occurred on the LEX pipeline system, which resulted\nin the release of approximately 165 million cubic feet (MMCF) of natural gas, an ignition of natural\ngas, and a fire (the Failure). The Failure resulted in the ejection of approximately 83 feet of 36-\ninch pipe from the ditch onto the right of way. The Failure occurred in a remote, Class 1 rural\nlocation and there were no reported injuries, fatalities or evacuations. The cause of the Failure has\nnot yet been determined.\nAs a result of the investigation, it appears conditions exist on your pipeline system that pose an\nintegrity risk to public safety, property, or the environment. Pursuant to 49 U.S.C. § 60117(1),\nPHMSA, Office of Pipeline Safety (OPS), issues this Notice of Proposed Safety Order (Notice),\nnotifying you of the preliminary findings of the investigation, and proposing that you take certain\nmeasures to ensure that the public, property, and the environment are protected from this integrity\nrisk.\nPage 2 of 12\n\n\n\nFor the purposes of this Notice:\n“Affected Segment” means the approximately 50 miles of TransCanada’s 30-inch and 36-inch\nLEX Pipeline from the upstream Lone Oak Compressor Station (Mile Post 7.2) near\nLone Oak, WV within Marshall County through the downstream Summerfield Compressor Station\n(MP 57.2) near Summerfield, OH in Noble County. The “Affected Segment” generally runs\nwesterly through portions of Noble and Monroe Counties in OH, and Marshall County in WV.\n\"Isolated Segment\" means the approximately 14.35-mile segment of the LEX pipeline from the\nupstream valve LEX-500 (MLV 2) at MP 18.5 to the downstream valve LEX-600 (MLV 3) at\nMP 32. It is the portion of the “Affected Segment” that was shut-in after the failure on June 7, 2018\nby closing MLV 2 (upstream of the failure) and MLV 3 (downstream of the failure) and that must\nremain shut-in until a restart plan is approved by the “Director”.\n\"Director\" means the Director, Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety, Eastern Region, 820 Bear Tavern Road Suite 103,\nWest Trenton, NJ 08628\nPreliminary Findings:\n Columbia Gas Transmission, LLC, a subsidiary of TransCanada Corporation, operates\nover 10,468 miles of interstate natural gas transmission pipelines, 37 storage fields across\nfour states, and transports an average of three billion cubic feet of natural gas per day\nthrough New York, New Jersey, Pennsylvania, Maryland, Virginia, West Virginia, Ohio,\nKentucky, North Carolina and Delaware. Columbia Gas was acquired by TransCanada in\n2016.1\n The failed pipeline is a 36-inch diameter line that transports natural gas and runs from\nMajorsville, PA, to Crawford, OH, approximately 130 miles. The Failure occurred near\nmilepost 20.6, approximately seven miles south of Moundsville, WV (Failure Site).\n The Affected Segment runs along several hills and ridges with steep elevation changes.\nThe Failure Site is located on Nixon Ridge.\n The section of the Affected Segment near the Failure Site was constructed in 2017. The\npipeline at the Failure Site section consists of grade X-70, 36” steel pipe with a wall\nthickness of 0.515” and 0.618”. The pipeline, which was manufactured by Durabond in\n2015, has fusion bonded epoxy coating and double submerged arc welded (DSAW) seams.\nThe impressed current cathodic protection system has not been energized, but\n1 See, TransCanada Website, available at https://www.transcanada.com/en/operations/natural-gas/columbia-gas-\ntransmission/(last accessed June 11, 2018)\nPage 3 of 12\n\n\n\nTransCanada is in the process of having it commissioned. Galvanic anodes were installed\nat foreign lines crossings.\n The maximum allowable operating pressure (MAOP) of the Affected Segment is\n1440 psig, as established by hydrostatic test in 2017. At the time of the Failure, the actual\noperating pressure of the pipeline upstream from the Failure was 1280 psig; downstream\nof the Failure at Eureka Metering Station, the operating pressure was 1243.7 psig.\n At approximately 4:55 a.m. EDT on June 7, 2018, TransCanada discovered a failure on\nthe LEX pipeline system, as determined by its gas controller, from a pressure drop\nobservation. The incident was determined to be a natural gas release, an ignition of natural\ngas, and fire in the area of Moundsville, West Virginia. The Failure resulted in the ejection\nof approximately 83 feet of 36-inch pipe from the ditch onto the right of way and the loss\nof 165 MMCF of natural gas. The Failure occurred in a remote, Class 1 rural location.\nThere were no reported injuries, fatalities or evacuations. The Failure was reported to the\nNational Response Center (NRC Report No. 1214458) on June 7, 2018 at approximately\n6:12 a.m. EDT.\n TransCanada isolated the Affected Segment via manual closure of LEX-500, a main line\nvalve (MLV) known as MLV 2, and LEX-600 (MLV 3) (Isolated Segment). MLV 2 is\nlocated approximately 1.6 miles upstream of the Failure Site and was manually closed at\napproximately 5:20 a.m. EDT. MLV 3 is located approximately 12.75 miles downstream\nof the Failure Site and automatically closed at approximately 4:55 a.m. EDT. The\nupstream Lone Oak compressor station’s compressor units were shut down via a\ncommand issued from TransCanada’s Gas Control at approximately 4:36 a.m. EDT. In\naddition, LEX-700, MLV 4, further downstream from MLV 3, automatically closed at\napproximately 5:32 a.m. EDT.\n PHMSA, Roberts Ridge Volunteer Fire Department, West Virginia Department of\nEnvironmental Protection, West Virginia Division of Forestry, and the Federal Energy\nRegulatory Commission responded to the scene. PHMSA inspectors initiated an\ninvestigation of the Failure on June 7, 2018.\n The Isolated Segment was shut-in via the closure of MLVs 2 and 3. The Isolated Segment\ncurrently remains out of service.\n On December 12, 2017, TransCanada completed a hydrostatic test on test section LX1-\n3A of the LEX pipeline, which includes the location of Failure. The section was\nsuccessfully tested for a duration of 8 hours to a minimum test pressure of 1880 psig. In\naddition, on December 14, 2017, TransCanada ran an Enduro Digital Data Logger Caliper\ntool from the Taylor B (746+11) launch site near Glen Easton, WV to Games Ridge\n(1139+34.9) receive site near Moundsville, WV. The report was generated on\nPage 4 of 12\n\n\n\nDecember 20, 2017. On May 17th, 2018, a combo High-Resolution Magnetic Flux\nLeakage (HR MFL) + Geo Tool was run with IMU. TransCanada has not yet received the\nreport from the combo HR MFL + Geo Tool run, but the vendor has been asked to provide\nan expedited preliminary inline inspection report as soon as practicable due to the Failure.\nPHMSA has not yet received the preliminary inline inspection report or any analysis from\nthe report.\n Since the Failure, TransCanada has identified six other points along the pipeline that,\nbased on their geotechnical flyover, are areas of concern due to the existence of large spoil\npiles, steep slopes, or indications of slips. TransCanada has also performed minor repair\nwork and grading of the Failure Site.\n The PHMSA investigation is ongoing and the cause of the failure is unknown at this time.\nThe preliminary investigation suggests that the Failure was the result of land subsidence\ncausing stress on a girth weld.\n PHMSA has issued several Advisory Bulletins of note, including Advisory Bulletin\nADB 97-03 on March 4, 1997 entitled “Potential Soil Subsidence on Pipeline Facilities,”\ncautioning owners and operators of possible hazards relating to soil subsidence on pipeline\nfacilities, and advising the need to monitor the potential impact of flooding and soil\nsubsidence on those facilities. PHMSA also issued Advisory Bulletin, ADB 12-06 on\nMay 7, 2012, entitled “Verification of Records Establishing MAOP and MOP,” advising\noperators of gas transmission pipelines and associated facilities to verify that their records\nconfirm their MAOP and MOP.\nProposed Issuance of Safety Order:\nSection 60117(1) of Title 49, United States Code, provides for the issuance of a safety order, after\nreasonable notice and the opportunity for a hearing, requiring corrective action, which may include\nphysical inspection, testing, repair, replacement, or other action, as appropriate. The basis for\nmaking the determination that a pipeline facility has a condition or conditions that pose a pipeline\nintegrity risk to public safety, property, or the environment is set forth both in the above referenced\nstatute and 49 C.F.R. § 190.239, a copy of which is enclosed.\nAfter evaluating the foregoing preliminary findings of fact and considering the location of the\nFailure Site on Nixon Ridge, the identification of six additional areas of concern based on the\nexistence of large spoil piles, steep slopes, or indications of slips, the fact that subsidence or\nslippage could lead to additional failures of the pipeline in areas with similar geological conditions,\nthe fact that the Affected Segment was operating between approximately 86-89% of its MAOP at\nthe time of the Failure, the hazardous nature of the natural gas transported, the age of the pipe, and\nthe ongoing investigation to determine the cause of the failure, it appears that the continued\noperation of the Affected Segment, without corrective measures, poses a pipeline integrity risk to\nPage 5 of 12\n\n\n\npublic safety, property, and the environment.\nAccordingly, PHMSA issues this Notice of Proposed Safety Order to notify Respondent of the\nproposed issuance of a safety order and to propose that Respondent take measures specified herein\nto address the potential risk\nProposed Corrective Actions:\nPursuant to 49 U.S.C. § 60117(1) and 49 C.F.R. § 190.239, PHMSA proposes to issue to\nTransCanada Corporation a safety order incorporating the following remedial requirements with\nrespect to the Affected Segment and Isolated Segment:\n1. Review of Isolated Segment. TransCanada must review and inspect the Isolated Segment\nfor conditions similar to those of the Failure including a review of construction, operating\nand maintenance (O&M) and integrity management records such as in-line inspection\n(ILI) results, hydrostatic tests, root cause failure analysis of the Failure, aerial and ground\npatrols, cathodic protection, excavations and pipe replacements. Respondent must address\nany findings that require remedial measures to be implemented within 30 days of\ndiscovery.\n2. Enhanced surveillance and monitoring. TransCanada must provide for enhanced\npatrolling and surveillance of the Isolated Segment until the cause of the Failure is\ndetermined.\n3. Installation of Strain Gauges. Within 45 days of receipt of the final Safety Order,\nTransCanada must install at least six (6) strain gauges on the pipeline in the immediate\narea of the Failure. TransCanada must also determine if additional locations exist along\nthe Affected Segment with conditions similar to the Failure site and install strain gauges.\nHydrostatic Testing. TransCanada must provide for hydrostatic pressure testing of any\npipe installed in the Isolated Segment.\n5. Weather Contingency Plan. Within 30 days of receipt of the final Safety Order,\nTransCanada must submit to the Director a contingency plan to operate and monitor the\nIsolated Segment during saturated soil or flooding conditions, including enhanced\npatrolling and surveillance.\n6. I","truncated":true,"body_characters":57594}