{"operation":"document","citation":"CPF 120191006W","title":"COLUMBIA GAS TRANSMISSION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-04-01","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120191006w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120191006w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120191006w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120191006W","body":"Warning Letter involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2019-04-01 and is reported as closed as of 2019-04-01. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120191006W_Warning Letter_04012019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191006W/120191006W_Warning%20Letter_04012019.pdf\n\n120191006W_Warning Letter_04012019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191006W/120191006W_Warning%20Letter_04012019_text.pdf\n\n120191006W_Warning Letter_04012019_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nApril 1, 2019\nMr. Stanley Chapman III\nPresident, US Gas Pipelines\nColumbia Gas Transmission, LLC\n700 Louisiana Street, Suite 700\nHouston, TX 77002\nCPF 1-2019-1006W\nDear Mr. Chapman:\nOn July 12, 2018, a representative of the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected Columbia Gas\nTransmission, LLC’s (CGT) WB Express construction project in Strasburg, Virginia.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violation(s) are:\n1. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least once\neach calendar year. This manual must be prepared before operations of a pipeline\nsystem commence. Appropriate parts of the manual must be kept at locations\nwhere operations and maintenance activities are conducted.\nCGT failed to follow its manual of written procedures for conducting maintenance activities.\nSpecifically, CGT failed to follow its “Blow Down and Purge Procedure Gate Setting to Station\nFire Valves VB, VB-5, VB-Loop to Bypass Station” dated 03/27/2018 (BD Procedure) by failing\n\n\n\nCPF 1-2019-1006W\nto install locks and tags on valves 331 and 334 during maintenance activities at its Strasburg,\nVirginia compressor station.\nDuring the inspection, the PHMSA inspector observed that valves 331 and 334 were not locked\nand tagged in the post-blowdown period during maintenance and construction activities when the\nstation was in an outage. Specifically, CGT’s BD Procedure required valves 331 and 334 be locked\nand tagged after the station is blown down and during an outage. In the section entitled “Individual\nValve Operations Guide for Blow Down”, operation #17 states, “Open, lock, and tag VB-5\nreceiver valve 334...”. Also, operation # 26 of the same section states, “Open, lock, and tag VB-\nLoop receiver valve 331...”. Subsequent to the inspection and the inspector notifying CGT of the\nobservation, the valves were locked and tagged.\nTherefore, CGT failed to follow its manual of written procedures for conducting maintenance\nactivities by not locking and tagging valves 331 and 334 in accordance with its BD Procedure.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$213,268 per violation per day the violation persists, up to a maximum of $2,132,679 for a related\nseries of violations. For violation occurring on or after November 2, 2015 and before November\n27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum\npenalty not to exceed $2,090,022. For violations occurring prior to November 2, 2015, the\nmaximum penalty may not exceed $200,000 per violation per day, with a maximum penalty not to\nexceed $2,000,000 for a related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct the\nitem(s) identified in this letter. Failure to do so will result in Columbia Gas Transmission, LLC\nbeing subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, be advised that all material you submit in\nresponse to this enforcement action is subject to being made publicly available. If you believe that\nany portion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document with\nthe portions you believe qualify for confidential treatment redacted and an explanation of why you\nbelieve the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nNo reply to this letter is required. If you choose to reply, please submit all correspondence in this\nmatter to Robert Burrough, Director, PHMSA Eastern Region, 840 Bear Tavern Road, Suite 300,\nWest Trenton, NJ 08628. Please refer to CPF 1-2019-1006W on each document you submit, and\nwhenever possible provide a signed PDF copy in electronic format. Smaller files may be emailed\nto robert.burrough@dot.gov. Larger files should be sent on a CD accompanied by the original\npaper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120191006W_Warning Letter_04012019_text Page 2 of 2","truncated":false,"body_characters":5638}