{"operation":"document","citation":"CPF 12020015NOA","title":"COLUMBIA GAS TRANSMISSION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-12-29","effective_on":null,"summary":"CLOSED notice of amendment citing 192.303, 192.605(b)(1), 192.805(g), 192.907(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12020015noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12020015noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12020015noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12020015NOA","body":"Notice of Amendment involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.303,  192.605(b)(1),  192.805(g),  192.907(a). The case was opened on 2020-12-29 and is reported as closed as of 2021-04-09. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12020015NOA_Closure Letter_04092021_(20-171819).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12020015NOA/12020015NOA_Closure%20Letter_04092021_(20-171819).pdf\n\n12020015NOA_Closure Letter_04092021_(20-171819)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12020015NOA/12020015NOA_Closure%20Letter_04092021_(20-171819)_text.pdf\n\n12020015NOA_Notice of Amendment_12292020_(20-171819).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12020015NOA/12020015NOA_Notice%20of%20Amendment_12292020_(20-171819).pdf\n\n12020015NOA_Notice of Amendment_12292020_(20-171819)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12020015NOA/12020015NOA_Notice%20of%20Amendment_12292020_(20-171819)_text.pdf\n\n12020015NOA_Closure Letter_04092021_(20-171819)_text.pdf\n\nVIA ELECTRONIC MAIL TO: stanley chapman iii@tcenergy.com\nApril 9, 2021\nStanley Chapman\nSenior Vice President & General Manager\nColumbia Gas Transmission, LLC\n700 Louisiana Street\nHouston, Texas 77003\nCPF 1-2020-015-NOA\nDear Mr. Chapman:\nOn April 20-24, 2020, a representative from the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, conducted an on-\nsite pipeline safety inspection of Columbia Gas Transmission, LLC’s (Columbia Gas) procedures\nin Charleston, WV. As a result of the inspection, Columbia Gas was issued a Notice of Amendment\non December 29, 2020, which proposed amendment of your procedures.\nColumbia Gas submitted its amended procedures on January 28, 2021. My staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave 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\n12020015NOA_Notice of Amendment_12292020_(20-171819)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nDecember 29, 2020\nStanley Chapman\nSenior Vice President & General Manager\nColumbia Gas Transmission, LLC\n700 Louisiana Street\nHouston, Texas 77003\nCPF 1-2020-015-NOA\nDear Mr. Chapman:\nOn April 20-24, 2020, 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 (Columbia Gas) procedures1 in Charleston, WV.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within Columbia\nGas’ plans or procedures, as described below:\n1. § 192.303 Compliance with specifications or standards.\nEach transmission line or main must be constructed in accordance with\ncomprehensive written specifications or standards that are consistent with this\npart.\nColumbia Gas’ comprehensive written specifications or standards that are consistent with Part 192 were\ninadequate. Specifically, Columbia Gas’ Engineering Specification, TES-CT-GEN-G Pipeline\nConstruction Specification (US-Mex), dated 2020-Jan-02, (Specification) failed to include sufficient\ndetails regarding repairing steel pipe in accordance with § 192.309(a)2\n.\nDuring the inspection, the PHMSA inspector reviewed Columbia Gas’ Specification. The Specification,\nunder section 2.7 “Inspection and Repair of Company Assets (pipe, equipment, or appurtenances)”, sub-\nsection 2.7.7 was inadequate as it did not include procedures addressing the requirements of § 192.309(a).\n1 Columbia Gas was acquired by TC Energy and uses TC Energy procedures to comply with the pipeline safety regulations.\n2 § 192.309 Repair of steel pipe.\n(a) Each imperfection or damage that impairs the serviceability of a length of pipeline of steel pipe must be repaired or\nremoved. If a repair is made by grinding, the remaining wall thickness must a least be equal to either:\n(1) The minimum thickness required by the tolerances in the specification to which the pipe was manufactured; or\n(2) the design pressure of the pipeline.\n\n\n\nCPF 1-2020-015-NOA\nTherefore, Columbia Gas failed to include procedures in its construction specifications addressing the\nrequirements of § 192.309(a), as required by § 192.303. Columbia Gas must amend its specifications to\ninclude details of the criteria required by § 192.309(a).\n2. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a)…\n(b) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following, if\napplicable, to provide safety during maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in accordance with\neach of the requirements of this subpart and Subpart M of this part.\nColumbia Gas’ procedures for operating its pipelines in accordance with each of the requirements of 49\nCFR Part 192 Subpart L were inadequate. Specifically, Columbia Gas’ Operations and Maintenance\n(O&M) Manual, U.S. Natural Gas Pipelines and Underground Natural Gas Storage Facilities, dated\n12/20/2019 (Procedures) failed to include procedures addressing the requirements of § 192.620(c)(1)-(3)3\nunder Alternative Maximum Allowable Operating Pressure (AMAOP).\nColumbia Gas’ Procedure failed to include the requirements under § 192.620(c)(1)-(3) entitled: “What is\nan operator electing to use the alternative maximum allowable operating pressure required to do?”\nColumbia Gas indicated that the pipeline operating under § 192.620 had already satisfied that section of\nthe code and they believe that this portion of the code is not required to be included in their procedures.\nDuring the inspection, Columbia Gas informed PHMSA that this operator temporarily de-rated their line\noperating under the AMAOP. However, they do plan to convert back to their original § 192.620 AMAOP\nstatus. When converting back to the AMAOP, the operator must follow all the applicable code\nrequirements, including § 192.620(c)(1-3).\n3 § 192.620 Alternative maximum allowable operating pressure for certain steel pipelines.\n(a) …\n(c) What is an operator electing to use the alternative maximum allowable operating pressure required to do? If an operator\nelects to use the alternative maximum allowable operating pressure calculated under paragraph (a) of this section for a\npipeline segment, the operator must do each of the following:\n(1) For pipelines already in service, notify the PHMSA pipeline safety regional office where the pipeline is in service of the\nintention to use the alternative pressure at least 180 days before operating at the alternative MAOP. For new pipelines, notify\nthe PHMSA pipeline safety regional office of planned alternative MAOP design and operation at least 60 days prior to the\nearliest start date of either pipe manufacturing or construction activities. An operator must also notify the state pipeline safety\nauthority when the pipeline is located in a state where PHMSA has an interstate agent agreement or where an intrastate\npipeline is regulated by that state.\n(2) Certify, by signature of a senior executive officer of the company, as follows:\n(i) The pipeline segment meets the conditions described in paragraph (b) of this section; and\n(ii) The operating and maintenance procedures include the additional operating and maintenance requirements of paragraph\n(d) of this section; and\n(iii) The review and any needed program upgrade of the damage prevention program required by paragraph (d)(4)(v) of this\nsection has been completed.\n(3) Send a copy of the certification required by paragraph (c)(2) of this section to each PHMSA pipeline safety regional\noffice where the pipeline is in service 30 days prior to operating at the alternative MAOP. An operator must also send a copy\nto a State pipeline safety authority when the pipeline is located in a State where PHMSA has an interstate agent agreement, or\nan intrastate pipeline is regulated by that State.\n12020015NOA_Notice of Amendment_12292020_(20-171819)_text Page 2 of 5\n\n\n\nCPF 1-2020-015-NOA\nTherefore, Columbia Gas’ Procedure was inadequate as it does not include procedures addressing the\nrequirements of § 192.620(c)(1-3). Columbia Gas must revise its O&M to address this deficiency or state\nin the O&M AMAOP will not be utilized unless such revisions are made.\n3. § 192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The\nprogram shall include provisions to:\n…\n(g) Identify those covered tasks and the intervals at which evaluation of the\nindividual's qualifications is needed;\nColumbia Gas’ written qualification program was inadequate. Specifically, Columbia Gas’ Operator\nQualification Program, dated 12/20/2019, (OQ Program) failed to include procedures addressing the\nrequirements of requalification intervals in accordance with § 192.805(g).\nDuring the inspection, the PHMSA inspector reviewed Columbia Gas’ OQ Program. The OQ Program,\nunder section 6.1.2 “Subsequent Qualification”, did not provide adequate provisions to identify the\nintervals at which evaluation of the individual’s qualifications is needed.\nTherefore, Columbia Gas failed to include procedures addressing the requirements of§ 192.805(g).\nColumbia Gas must amend its procedures to include details of the criteria required by § 192.805(g).\n4. § 192.907 What must an operator do to implement this subpart?\n(a) General. No later than December 17, 2004, an operator of a covered\npipeline segment must develop and follow a written integrity management\nprogram that contains all the elements described in § 192.911 and that\naddresses the risks on each covered transmission pipeline segment. The initial\nintegrity management program must consist, at a minimum, of a framework\nthat describes the process for implementing each program element, how\nrelevant decisions will be made and by whom, a time line for completing the\nwork to implement the program element, and how information gained from\nexperience will be continuously incorporated into the program. The\nframework will evolve into a more detailed and comprehensive program. An\noperator must make continual improvements to the program.\nColumbia Gas’ integrity management program procedures were inadequate. Specifically, Columbia Gas’\nTEP-ASV-RCV-US Line Break Control Analysis Procedures -US, dated May 15, 2016 (IMP Procedure),\nfailed to include the minimal factors in performing a risk analysis for determining the need for Automatic\nShutoff Valves (ASV)/Remote Control Valves (RCV) to protect high consequence areas, as required by\n§ 192.935(c)4\n.\n4 § 192.935 What additional preventive and mitigative measures must an operator take?\n(a)…\n(c) Automatic shut-off valves (ASV) or Remote control valves (RCV). If an operator determines, based on a risk analysis, that\nan ASV or RCV would be an efficient means of adding protection to a high consequence area in the event of a gas release, an\noperator must install the ASV or RCV. In making that determination, an operator must, at least, consider the following\n12020015NOA_Notice of Amendment_12292020_(20-171819)_text Page 3 of 5\n\n\n\nCPF 1-2020-015-NOA\nColumbia Gas’ IMP Procedure under section 7.1 included an erroneous code section reference to\n192.953(c) instead of 192.935(c), and only stated that the threat/risk factors it contains will be evaluated.\nNo further details were included on what those threat/risk factors are and how they would be evaluated.\nTherefore, Columbia Gas’ integrity management procedures were inadequate. Columbia Gas must revise\nits IMP Procedure to include the correct code, § 192.935(c), as well as details on the specific threats/risk\nfactors and processes that Columbia Gas will utilize in accordance with § 192.935(c).\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 part of\nthis Notice is a document entitled Response Options for Pipeline Operators in Enforcement Proceedings.\nPlease refer to this document and note the response options. Be advised that all material you submit in\nresponse to this enforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with\nthe complete original document you must provide a second copy of the document with the portions you\nbelieve qualify for confidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised procedures,\nor a request for a hearing under §190.211. If you do not respond within 30 days of receipt of this Notice,\nthis constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate\nAdministrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and\nto issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R.\n§ 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures\nto my office within 30 days of receipt of this Notice. This period may be extended by written request for\ngood cause. Once the inadequacies identified herein have been addressed in your amended procedures,\nthis enforcement action will be closed.\nIt is requested (not mandated) that Columbia Gas Transmission, LLC maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) 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 1-2020-015-NOA on each\ndocument you submit, and whenever possible provide a signed PDF copy in electronic format. Smaller\nfiles may be emailed to robert.burrough@dot.gov. Larger files should be sent on USB flash drive\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 letter\nfactors—swiftness of leak detection and pipe shutdown capabilities, the type of gas being transported, operating pressure, the\nrate of potential release, pipeline profile, the potential for ignition, and location of nearest response personnel.\n12020015NOA_Notice of Amendment_12292020_(20-171819)_text Page 4 of 5\n\n\n\nCPF 1-2020-015-NOA\npertains solely to one CPF case number.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n12020015NOA_Notice of Amendment_12292020_(20-171819)_text Page 5 of 5","truncated":false,"body_characters":15244}