{"operation":"document","citation":"CPF 120191005M","title":"COLUMBIA GAS TRANSMISSION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-01-17","effective_on":null,"summary":"CLOSED notice of amendment citing 192.631(a)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120191005m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120191005m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120191005m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120191005M","body":"Notice of Amendment involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.631(a)(1). The case was opened on 2019-01-17 and is reported as closed as of 2019-05-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120191005M_Closure Letter_05102019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191005M/120191005M_Closure%20Letter_05102019.pdf\n\n120191005M_Closure Letter_05102019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191005M/120191005M_Closure%20Letter_05102019_text.pdf\n\n120191005M_Notice of Amendment_01172019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191005M/120191005M_Notice%20of%20Amendment_01172019.pdf\n\n120191005M_Notice of Amendment_01172019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191005M/120191005M_Notice%20of%20Amendment_01172019_text.pdf\n\n120191005M_Closure Letter_05102019_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nMay 10, 2019\nStan Chapman\nSenior Vice President and General Manager\nColumbia Gas Transmission, LLC\n700 Louisiana Street\nHouston, TX 77002\nCPF 1-2019-1005M\nDear Mr. Chapman:\nFrom January 29, 2018 to September 14, 2018, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected Columbia Gas Transmission, LLC’s (Columbia) procedures for operation and\nmaintenance of its natural gas transmission pipeline system in West Virginia and Kentucky. As a\nresult of the inspection, Columbia was issued a Notice of Amendment on January 17, 2019\n(Notice).\nColumbia responded on March 8, 2019, and submitted amended procedures and supporting forms\nto ensure compliance with the terms of the Notice. Based on our review of the documentation, it\nappears that the inadequacy outlined in this Notice has been corrected.\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\n120191005M_Notice of Amendment_01172019_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nJanuary 17, 2019\nStan Chapman\nSenior Vice President and General Manager\nColumbia Gas Transmission, LLC\n700 Louisiana Street\nHouston, TX 77002\nCPF 1-2019-1005M\nDear Mr. Chapman:\nFrom January 29, 2018 to September 14, 2018, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected Columbia Gas Transmission’s (CGT) procedures for control room management in\nCharleston, West Virginia.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within\nColumbia’s plans or procedures, as described below:\n1. §192.631 Control room management.\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline\nfacility through a SCADA system. Each operator must have and follow written\ncontrol room management procedures that implement the requirements of this\nsection, except that for each control room where an operator's activities are\nlimited to either or both of:\n\n\n\nCPF 1-2019-1005M\nCGT’s written control room management procedures were inadequate. Specifically, CGT’s\nControl Room Management Plan, dated 5/21/2018 (CRM Plan) did not require review and\napproval of deviations from control room management procedures prior to, or during, the time\nwhen the deviations could impact safe operation of the pipeline system, in accordance with\n§ 192.631(d)(4).\nSection 192.631(d)(4) states:\n(d) Fatigue mitigation. Each operator must implement the following methods to reduce the\nrisk associated with controller fatigue that could inhibit a controller's ability to carry out\nthe roles and responsibilities the operator has defined:\n…\n(4) Establish a maximum limit on controller hours-of-service, which may provide for an\nemergency deviation from the maximum limit if necessary for the safe operation of a\npipeline facility.\nDuring the inspection, the inspection team reviewed CGT’s CRM Plan and records of deviations\nfrom hours of service requirements. The records indicated that CGT failed to contemporaneously\ncomplete documentation to demonstrate that deviations from the hours of service requirements\nnoted in the CRM Plan were necessary for the safe operation of the pipeline system. The CRM\nPlan, Section 1.9, specified that “Deviations from the requirement of this plan are permitted only\nif necessary for the safe operation of the pipeline facility(s). Any deviations from this CRM Plan\nmust be approved by the Director, Gas Control or his/her designee. Any deviations must be\nrecorded and must contain justification of why the deviation was necessary for the safe operation\nof a pipeline. Hours of Service (HOS) deviations will be prepared/submitted by the designated\nFatigue Risk Manager.”\nThe plan further specified in Section 2 that “Should work limitations need to be exceeded due to\nemergencies or unscheduled absences, the Director of Gas Control or designee must approve\nHours of Service (HOS) deviation forms submitted by the Fatigue Risk Manager.\"\nThe form that CGT was using to document Hours of Service deviations did not note a manager's\ncontemporaneous approval. The form had a space for the Director of Gas Control to sign for what\nlooks like approval in advance, but during the headquarters review the CGT control room\nmanagement team confirmed that the form typically documents a post-event review only. The\nreview or acknowledgement may take place long after the deviation has occurred, and the impacts\non the safe operation of the system have passed.\nThe inspection team noted the following historical occurrences of hours of service deviations\nwhere management approval was documented:\n 2018 - 3 occurrences\n 2017 - 7 occurrences\n 2016 - 3 occurrences\n 2015 - 18 occurrences\n 2014 - 3 occurrences\n120191005M_Notice of Amendment_01172019_Text Page 2 of 4\n\n\n\nCPF 1-2019-1005M\nOf these 34 instances noted above, 20 were reviewed and approved after the occurrence of the\nhours-of-service deviation.\nTherefore, CGT’s control room management procedures were inadequate regarding review and\napproval of deviations.\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 60 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 maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Robert Burrough, Director, PHMSA Eastern Region, 840 Bear\nTavern Road, Suite 300, West Trenton, NJ 08628. Please refer to CPF 1-2019-1005M on each\ndocument you submit, and whenever possible provide a signed PDF copy in electronic format.\nSmaller files may be emailed to robert.burrough@dot.gov. Larger files should be sent on a CD\naccompanied by the original paper copy to the Eastern Region Office.\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.\n120191005M_Notice of Amendment_01172019_Text Page 3 of 4\n\n\n\nCPF 1-2019-1005M\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120191005M_Notice of Amendment_01172019_Text Page 4 of 4","truncated":false,"body_characters":9277}