{"operation":"document","citation":"CPF 120201003W","title":"COLUMBIA GAS TRANSMISSION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-01-02","effective_on":null,"summary":"CLOSED warning letter citing 192.12(d).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120201003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120201003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120201003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120201003W","body":"Warning Letter involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(d). The case was opened on 2020-01-02 and is reported as closed as of 2020-01-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120201003W_Warning Letter_01022020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201003W/120201003W_Warning%20Letter_01022020.pdf\n\n120201003W_Warning Letter_01022020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201003W/120201003W_Warning%20Letter_01022020_text.pdf\n\n120201003W_Warning Letter_01022020_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nJanuary 2, 2020\nMr. Stan Chapman\nSenior Vice President\nColumbia Gas Transmission, LLC\n700 Louisiana St.\nHouston, TX 77002\nCPF 1-2020-1003W\nDear Mr. Chapman:\nFrom March 25 – August 1, 2019 represenatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected\nColumbia Gas Transmission, LLC’s (Columbia) Underground Natural Gas facilities in Ohio. The\ninspections included the Wayne, Holmes, Medina, Brinker, Crawford, Pavonia, Weaver and Lucas\nfacilities.\nAs a result of the inspections, it is alleged that you have committed a probable violation of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and the probable\nviolation is:\n1. § 192.12 Underground natural gas storage facilities.\n(a) …\n(d) Each underground natural gas storage facility that uses a depleted\nhydrocarbon reservoir or an aquifer reservoir for gas storage, including\nthose constructed not later than July 18, 2017 must meet the operations,\nmaintenance, integrity demonstration and verification, monitoring, threat\nand hazard identification, assessment, remediation, site security,\nemergency response and preparedness, and recordkeeping requirements\nand recommendations of API RP 1171, sections 8, 9, 10, and 11\n(incorporated by reference, see §192.7) by January 18, 2018.\nColumbia failed to meet the monitoring requirements of API RP 1171, section 9. Specifically,\nColumbia failed to evaluate each annular gas occurrence that exceeded operator-defined threshold\n\n\n\nCPF 1-2020-1003W\nlevels determined from well integrity evaluation and from risk assessment, as directed by API RP 1171,\nSection 9.3.2.\nSection 9.3.2 of API RP 1171, Well Integrity Monitoring, states in part:\nThe operator shall evaluate each annular gas occurrence that exceeds operator- or regulatory-\ndefined threshold levels determined from well integrity evaluation and from risk assessment.\nColumbia’s procedure TEP-PR-REST-G, Well Annulus Pressure Analysis Section 2.1, states every\nwell shall have a calculated Maximum Allowable Annulus Surface Pressure (MAASP).\nDuring the inspection, the PHMSA inspector reviewed records for MAASP cacluations. The records\ndemonstrated that not all wells had MAASP cacluations completed, and therefore not all annular gas\noccurences were evaluated based on an operator-defined threshold.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related\nseries of violations. For violation occurring on or after November 27, 2018 and before July 31, 2019,\nthe maximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to\nexceed $2,132,679. For violation occurring on or after November 2, 2015 and before November 27,\n2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum penalty\nnot to exceed $2,090,022. For violations occurring prior to November 2, 2015, the maximum penalty\nmay not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000 for\na related series of violations. We have reviewed the circumstances and supporting documents involved\nin this case, and have decided not to conduct additional enforcement action or penalty assessment\nproceedings at this time. We advise you to correct the item(s) identified in this letter. Failure to do so\nwill result in Columbia Gas Transmission, LLC being subject to additional enforcement action.\nBe advised that all material you submit in response to this enforcement action is subject to being made\npublicly available. 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 second\ncopy of the document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under 5\nU.S.C. 552(b).\nNo reply to this letter is required. If you choose to reply, please submit all correspondence in this matter\nto Robert Burrough, Director, PHMSA Eastern Region, 840 Bear Tavern Road, Suite 300, West\nTrenton, NJ 08628. Please refer to CPF 1-2020-1003W on each document you submit, and whenever\npossible provide a signed PDF copy in electronic format. Smaller files may be emailed to\nrobert.burrough@dot.gov. Larger files should be sent on a USB flash drive accompanied by the\noriginal paper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120201003W_Warning Letter_01022020_text Page 2 of 2","truncated":false,"body_characters":5493}