# COLUMBIA MIDSTREAM GROUP, LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 120186001
- **title:** COLUMBIA MIDSTREAM GROUP, LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2018-01-05
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.402(a), 195.403(c).
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-120186001
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120186001
**body:**

Notice of Probable Violation involving COLUMBIA MIDSTREAM GROUP, LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.403(c). The case was opened on 2018-01-05 and is reported as closed as of 2018-07-31. Proposed civil penalty: $20,700. Assessed civil penalty: $20,700. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120186001_Closure Letter_07312018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120186001/120186001_Closure%20Letter_07312018.pdf

120186001_Closure Letter_07312018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120186001/120186001_Closure%20Letter_07312018_text.pdf

120186001_Final Order_06152018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120186001/120186001_Final%20Order_06152018.pdf

120186001_Final Order_06152018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120186001/120186001_Final%20Order_06152018_text.pdf

120186001_NOPV PCP PCO_01052018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120186001/120186001_NOPV%20PCP%20PCO_01052018.pdf

120186001_NOPV PCP PCO_01052018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120186001/120186001_NOPV%20PCP%20PCO_01052018_text.pdf

120186001_NOPV PCP PCO_01052018_text.pdf

NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPLIANCE ORDER
OVERNIGHT EXPRESS DELIVERY
January 5, 2018
Mr. Stanley Chapman III
President, US Gas Pipelines
Columbia Midstream Group, LLC
700 Louisiana Street, Suite 700
Houston, TX 77002
CPF 1-2018-6001
Dear Mr. Chapman:
From April 24 – 28, 2017, a representative of 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 the procedures and records of Columbia Midstream Group, LLC,
a subsidiary of TransCanada (TransCanada), at its pipeline facility located in Leetonia, Ohio.
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. § 195.402(a) Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a
manual of written procedures for conducting normal operations and maintenance
activities and handling abnormal operations and emergencies. This manual shall be
reviewed at intervals not exceeding 15 months, but at least once each calendar year,
and appropriate changes made as necessary to insure that the manual is effective.
This manual shall be prepared before initial operations of a pipeline system
commence, and appropriate parts shall be kept at locations where operations and
maintenance activities are conducted.



CPF 1-2018-6001
TransCanada failed to follow its procedural manual for operations, maintenance and
emergencies. Specifically, TransCanada failed to follow its abnormal operating conditions
(AOC) procedure, pursuant to § 195.402(d)(5), by failing to document the required
effectiveness review.
Section 195.402(d)(5) states:
“(d) Abnormal operation. The manual required by paragraph (a) of this section must include
procedures for the following to provide safety when operating design limits have been
exceeded;
(5) Periodically reviewing the response of operator personnel to determine the effectiveness of
the procedures controlling abnormal operation and taking corrective action where deficiencies
are found.”
During the inspection, the PHMSA inspector reviewed TransCanada’s (Procedure) “Abnormal
Operations Plan for Liquid Pipelines”, dated 9/19/16, and prior versions dated 7/1/15 and
5/2014. The 2015 and 2016 Procedure versions, Section 5 stated, “Twice per calendar year,
the Manager of Engineering Services – System Integrity (or designee) will review an Abnormal
Operations report from the Company’s work management system to determine the Company’s
effectiveness in controlling Abnormal Operations. Document the review in the Company’s
work management system using Procedure 220.005.004 – Abnormal Operations Review.
When deficiencies are found, corrective actions will be initiated.” Similarly, Section 3.1.7 of
the 2014 version of the procedures stated, “Twice per calendar year, the Manager of
Engineering Services (or designee) will review an Abnormal Operations report from the
Company’s work management system to determine the Company’s effectiveness in controlling
Abnormal Operations. Document this review in the Company’s work management system
using Company Specification - Abnormal Operation Conditions Report. When deficiencies are
found, take corrective action.”
The PHMSA inspector requested AOC records and AOC effectiveness records for the 2014 –
2017 timeframe. TransCanada provided the following (4) records:
 Columbia Midstream 2014 AOC 1
 Columbia Midstream 2015 AOC 4
 Columbia Midstream 2016 AOC 3
 Columbia Midstream 2017 AOC 2
TransCanada failed to provide any record of AOC effectiveness review for 2014-2017.
Additionally, the records TransCanada provided failed to include the following, but not limited
to:
 Documentation of AOC effectiveness review
 Corrective actions taken
 Signature or approval by supervisor
 Date of AOC closure
120186001_NOPV PCP PCO_01052018_text Page 2 of 5



CPF 1-2018-6001
The PHMSA inspector re-requested the AOC effectiveness records for the 2014-2017
timeframe. TransCanada stated, “The effectiveness review is conducted through root cause and
discussion with the operations team, but this is not documented.”
Therefore, TransCanada failed to follow its AOC procedure for periodically reviewing the
response of operator personnel to determine the effectiveness of the procedure, per the
requirements of § 195.402(d)(5).
2. § 195.403 Emergency Response Training.
(c) Each operator shall require and verify that its supervisors maintain a thorough
knowledge of that portion of the emergency response procedures established
under § 195.402 for which they are responsible to ensure compliance.
TransCanada failed to require and verify that its supervisors maintained a thorough knowledge
of the portion of the emergency response procedures established under § 195.402 for which
they are responsible to ensure compliance.
During the inspection, the PHMSA inspector requested records of supervisor training for 2015
– 2016 regarding emergency response procedures. TransCanada was unable to provide any
documentation, training record or response demonstrating that it verified that supervisors
maintained a thorough knowledge of the portions of the emergency response procedures for
which they are responsible to ensure compliance.
The PHMSA inspector also reviewed TransCanada’s (Procedure), “Emergency Response
Plan Manual Administration Plan”, dated 12/07/16 and “Liquid Pipeline Emergency Plan”,
dated 02/16/17 (Procedures). The Procedures did not include details such as:
 Defining Emergency Response supervisor role
 Emergency response supervisor training requirements
 Process for verification of supervisor knowledge
The PHMSA inspector asked TransCanada where the applicable information is documented
and TransCanada was not able to provide a response.
Therefore, TransCanada failed to provide any data that showed it required and verified that
supervisors maintained a thorough knowledge of that portion of the emergency response
procedures established under § 195.402 for which they are responsible to ensure compliance.
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 $20,700 as follows:
120186001_NOPV PCP PCO_01052018_text Page 3 of 5



CPF 1-2018-6001
Item number PENALTY
1 $20,700
Proposed Compliance Order
With respect to item number 2 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous
Materials Safety Administration proposes to issue a Compliance Order to Columbia Midstream
Group, LLC. 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.
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, NJ 08628. Please refer to CPF 1-2018-
6001 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
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Compliance Proceedings
120186001_NOPV PCP PCO_01052018_text Page 4 of 5



CPF 1-2018-6001
PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Columbia Midstream Group, LLC (TransCanada)
a Compliance Order incorporating the following remedial requirements to ensure the compliance
of TransCanada with the pipeline safety regulations:
1. 2. In regard to Item Number 2 of the Notice pertaining to TransCanada’s failure to
require and verify that its supervisors maintained a thorough knowledge of the
portion of the emergency response procedures established under § 195.402 for
which they are responsible to ensure compliance, TransCanada shall, within
60 days of issuance of the Final Order, revise its procedures to include guidance for
requiring and verifying supervisor’s knowledge of emergency response procedures
for which they are responsible.
It is requested (not mandated) that TransCanada 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.
120186001_NOPV PCP PCO_01052018_text Page 5 of 5

120186001_Closure Letter_07312018_text.pdf

OVERNIGHT EXPRESS DELIVERY
July 31, 2018
Mr. Stanley Chapman III
President, US Gas Pipelines
Columbia Midstream Group, LLC
700 Louisiana Street, Suite 700
Houston, TX 77002
CPF 1-2018-6001
Dear Mr. Chapman:
On June 15, 2018, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued
to Columbia Midstream Group, LLC, a subsidiary of TransCanada (TransCanada) a Final Order
in the above-referenced case. This Order included a Compliance Order requirement to take
corrective actions on your pipeline. Based on our review of the documentation you provided, it
has been determined that you have complied with the terms of this Order.
Accordingly, this case is now closed and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration

120186001_Final Order_06152018_text.pdf

June 15, 2018
Mr. Stanley Chapman, III
President, US Gas Pipelines
Columbia Midstream Group, LLC
700 Louisiana Street, Suite 700
Houston, TX 77002
Re: CPF No. 1-2018-6001
Dear Mr. Chapman:
Enclosed please find the Final Order issued in the above-referenced case. It makes two findings
of violation and assesses a civil penalty of $20,700. This is to acknowledge receipt of payment
of the full penalty amount, by wire transfer, dated February 21, 2018. When the terms of the
compliance order have been 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. Russell K. Girling, President & CEO, TransCanada Corporation, 450 – 1 St. SW,
Calgary, Alberta, Canada T2P 5H1
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 Midstream Group, LLC, ) CPF No. 1-2018-6001
a subsidiary of TransCanada Corporation, )
)
)
)
Respondent. )
_________________________________________ )
FINAL ORDER
From April 24-28, 2017, pursuant to 49 U.S.C. § 60117, a representative of 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
Midstream Group, LLC (Columbia or Respondent), a subsidiary of TransCanada Corporation
(TransCanada) in Leetonia, Ohio. Columbia operates a hazardous liquid pipeline transporting
natural gas liquids products and running approximately 36 miles from the Hickory Bend
processing plant in Mahoning County, Ohio, to the UEO Buckeye Kensington Plant in
Columbiana County, Ohio.1
As a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Respondent,
by letter dated January 5, 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 Columbia had violated 49 C.F.R. §§ 195.402(a) and 195.403(c) and
proposed assessing a civil penalty of $20,700 for the alleged violations. The Notice also
proposed ordering Respondent to take certain measures to correct the alleged violations.
Respondent failed to respond within 30 days of receipt of service of the Notice. Under 49 C.F.R.
§ 190.208(d), such failure to respond constitutes a waiver of Columbia’s right to contest the
allegations in the Notice and authorizes the Associate Administrator, without further notice, to
find facts as alleged in the Notice and to issue this Final Order under § 190.213. Despite such
waiver, on February 23, 2018, the Eastern Region, OPS, reached out to Mr. Lee Romack,
Manager of U.S. Regulatory Compliance for Respondent, to confirm the company’s receipt of
the Notice. In a phone conversation, Mr. Romack confirmed that the Notice had been received,
and stated that TransCanada had not intended to contest any of the contents of the Notice.
Respondent paid the civil penalty of $20,700 by wire transfer dated February 21, 2018.
1 https://www.transcanada.com/en/operations/natural-gas/columbia-midstream/systems/ (last accessed Mar. 7,
2018).



CPF No. 1-2018-6001
Page 2
FINDINGS OF VIOLATION
Columbia did not contest the allegations in the Notice that it violated 49 C.F.R. Part 195, as
follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a), which states:
§ 195.402 Procedural manual for operations, maintenance, and
emergencies.
(a) General. Each operator shall prepare and follow for each pipeline
system a manual of written procedures for conducting normal operations and
maintenance activities and handling abnormal operations and emergencies.
This manual shall be reviewed at intervals not exceeding 15 months, but at
least once each calendar year, and appropriate changes made as necessary to
insure that the manual is effective. This manual shall be prepared before initial
operations of a pipeline system commence, and appropriate parts shall be kept
at locations where operations and maintenance activities are conducted.
The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a) by failing to follow its own
manual of written procedures for conducting normal operations, maintenance, and handling
abnormal operations and emergencies. Specifically, the Notice alleged that Columbia failed to
follow its abnormal operating conditions (AOC) procedure, pursuant to § 195.402(d)(5), by
failing to document the required effectiveness review. During the inspection, Columbia failed to
provide PHMSA with any record of an AOC effectiveness review for 2014-2017, despite the
company’s procedures requiring an effectiveness review twice per calendar year. Columbia
stated: “The effectiveness review is conducted through root cause and discussion with the
operations team, but this is not documented.”
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 195.402(a) failing to follow its own
manual of written procedures for conducting normal operations, maintenance and handling
abnormal operations and emergencies.
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.403(c), which states:
§ 195.403 Emergency response training.
(a) . . . .
(c) Each operator shall require and verify that its supervisors maintain
a thorough knowledge of that portion of the emergency response procedures
established under §195.402 for which they are responsible to ensure
compliance.
The Notice alleged that Respondent violated 49 C.F.R. § 195.403(c) by failing to require and
verify that its supervisors maintained a thorough knowledge of the portion of the emergency
response procedures established under § 195.402 for which they are responsible to ensure
compliance. Specifically, the Notice alleged that during the inspection, the PHMSA inspector



CPF No. 1-2018-6001
Page 3
requested records of supervisor training for 2015-2016 regarding emergency response
procedures. Columbia was allegedly unable to provide any documentation, training record, or
response demonstrating that it had verified that supervisors maintained a thorough knowledge of
the portions of the emergency response procedures for which they were responsible to ensure
compliance. The PHMSA inspector also reviewed Columbia’s Emergency Response Plan
Manual Administration Plan, dated December 7, 2016, and Liquid Pipeline Emergency Plan,
dated February 16, 2017. The Notice alleged that the procedures did not include details such as:
(1) defining the emergency response supervisor’s role; (2) the emergency response supervisor’s
training requirements; or (3) the process for verification of a supervisor’s knowledge. The
PHMSA inspector asked Columbia where the applicable information was documented and
Columbia was unable to provide a response.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 195.403(c) by failing to require and
verify that its supervisors maintained a thorough knowledge of the portion of the emergency
response procedures established under § 195.402 for which they are responsible to ensure
compliance.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
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.2 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,
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; the Respondent’s
ability to pay the penalty and 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 $20,700 for the violation cited above in Item 1.
Item 1: The Notice proposed a civil penalty of $20,700 for Respondent’s violation of 49 C.F.R.
§ 195.402(a), for failing to follow its manual of written procedures for operations, maintenance,
and emergencies. Columbia neither contested the allegation nor presented any evidence or
argument justifying elimination of the proposed penalty. Accordingly, having reviewed the
record and considered the assessment criteria for violation of 49 C.F.R. § 195.402(a), I assess
Respondent a total civil penalty of $20,700, which has already been paid in full by wire transfer
dated February 21, 2018.
2 These amounts are adjusted annually for inflation. See, e.g., Pipeline Safety: Inflation Adjustment of Maximum
Civil Penalties, 82 Fed. Reg. 19325 (April 27, 2017).



CPF No. 1-2018-6001
Page 4
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Item 2 in the Notice, for the violation of
49 C.F.R. § 195.403(c). Under 49 U.S.C. § 60118(a), each person who engages in the
transportation of hazardous liquids or who owns or operates a pipeline facility is required to
comply with the applicable safety standards established under chapter 601. 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 § 195.403(c) (Item 2), Respondent must, within
60 days of issuance of this Final Order, revise its procedures to include guidance for
requiring and verifying supervisors’ knowledge of emergency response procedures
for which they are responsible.
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.
The terms and conditions of this Final Order are effective upon service in accordance with
49 C.F.R. § 190.5.
June 15, 2018
___________________________________ __________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety
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