{"operation":"document","citation":"CPF 120201005M","title":"COLUMBIA GAS TRANSMISSION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-01-02","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120201005m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120201005m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120201005m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120201005M","body":"Notice of Amendment involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(e). The case was opened on 2020-01-02 and is reported as closed as of 2020-07-16. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120201005M_Closure Letter_07162020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201005M/120201005M_Closure%20Letter_07162020.pdf\n\n120201005M_Closure Letter_07162020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201005M/120201005M_Closure%20Letter_07162020_text.pdf\n\n120201005M_Notice of Amendment_01022020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201005M/120201005M_Notice%20of%20Amendment_01022020.pdf\n\n120201005M_Notice of Amendment_01022020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201005M/120201005M_Notice%20of%20Amendment_01022020_text.pdf\n\n120201005M_Closure Letter_07162020_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJuly 16, 2020\nMr. Stanley Chapman\nExecutive Vice President\nColumbia Gas Transmission, LLC\n700 Louisiana St.\nHouston, TX 77002\nCPF 1-2020-1005M\nDear Mr. Chapman:\nFrom September 16-19, 2019, a representative 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) procedures for Underground Natural Gas Storage\nin Charleston, West Virginia. As a result of the inspection, Columbia was issued a Notice of\nAmendment on January 2, 2020, which proposed amendment of your procedures.\nColumbia submitted its amended procedures in parts, on or around January 31st\n, May 5th and June\n3rd of 2020. My staff reviewed the amended procedures, and it appears that the inadequacies\noutlined in this Notice of Amendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n120201005M_Notice of Amendment_01022020_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nJanuary 2, 2020\nMr. Stan Chapman\nExecutive Vice President\nColumbia Gas Transmission, LLC\n700 Louisiana St.\nHouston, TX 77002\nCPF 1-2020-1005M\nDear Mr. Chapman:\nFrom September 16-19, 2019, a representative 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) procedures for Underground Natural Gas Storage\nin Charleston, West Virginia.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nColumbia’s plans or procedures, as described below:\n1. § 192.12 Underground natural gas storage facilities.\n(a) ….\n(e) Operators of underground gas storage facilities must establish\nand follow written procedures for operations, maintenance, and\nemergencies implementing the requirements of API RP 1170 and API\nRP 1171, as required under this section, including the effective dates as\napplicable, and incorporate such procedures into their written\nprocedures for operations, maintenance, and emergencies established\npursuant to § 192.605.\nColumbia’s written procedures for implementing the requirements of API RP 1171 were\ninadequate. Specifically, Columbia’s Gas Storage Well Integrity Assessment Section 2.1.11 -\nPerformance Measures and Continual Improvement procedures did not require a continual review\nand improvement cycle in accordance with API RP 1171, Section 8.7.1 General (Section 8.7.1).\n\n\n\nCPF 1-2020-1005M\nSection 8.7.1 states in part:\nThe operator shall assess the effectiveness of risk monitoring and risk management\nprograms and maintain a continual review and improvement cycle in risk management\nactivities to provide functional integrity of the storage operation.\nAt the time of the inspection, Columbia’s procedures stated that a review for continual\nimprovement “should” be done every three years. Columbia did not address that a continual\nreview and improvement cycle is required in accordance with Section 8.7.1.\n2. § 192.12 Underground natural gas storage facilities.\n(a) ….\n(e) Operators of underground gas storage facilities must establish\nand follow written procedures for operations, maintenance, and\nemergencies implementing the requirements of API RP 1170 and API\nRP 1171, as required under this section, including the effective dates as\napplicable, and incorporate such procedures into their written\nprocedures for operations, maintenance, and emergencies established\npursuant to § 192.605.\nColumbia’s written procedures for implementing the requirements of API RP 1171 were\ninadequate. Specifically, Columbia’s Gas Storage Well Integrity Assessment Section 2.1.11 -\nPerformance Measures and Continual Improvement procedures did not require an assessment of\nthe effectiveness of risk monitoring and risk management programs in accordance with API RP\n1171, Section 8.7.1 General (Section 8.7.1).\nSection 8.7.1 states in part:\nThe operator shall assess the effectiveness of risk monitoring and risk management\nprograms and maintain a continual review and improvement cycle in risk management\nactivities to provide functional integrity of the storage operation.\nAt the time of the inspection, Columbia’s procedures stated that a review for effectiveness\n“should” be done every three years. Columbia did not address that an effectiveness review is\nrequired in accordance with Section 8.7.1.\n3. § 192.12 Underground natural gas storage facilities.\n(a) ….\n(e) Operators of underground gas storage facilities must establish\nand follow written procedures for operations, maintenance, and\nemergencies implementing the requirements of API RP 1170 and API\nRP 1171, as required under this section, including the effective dates as\napplicable, and incorporate such procedures into their written\nprocedures for operations, maintenance, and emergencies established\npursuant to § 192.605.\n120201005M_Notice of Amendment_01022020_text Page 2 of 6\n\n\n\nCPF 1-2020-1005M\nColumbia’s written procedures for implementing the requirements of API RP 1171 were\ninadequate. Specifically, Columbia’s Gas Storage Well Integrity Assessment Section 2.1.11 -\nPerformance Measures and Continual Improvement procedures did not define a review frequency\nfor the risk assessment in accordance with API RP 1171, Section 8.7.2 Frequency (Section 8.7.2).\nSection 8.7.2 states in part:\nThe operator shall define a review frequency for the risk assessment and perform a review\nand update of the risk assessment in accordance with the defined frequency.\nAt the time of the inspection, Columbia’s procedures stated that a review “should” be done every\nthree years. Therefore, Columbia did not establish a defined frequency in accordance with Section\n8.7.2.\n4. § 192.12 Underground natural gas storage facilities.\n(a) ….\n(e) Operators of underground gas storage facilities must establish\nand follow written procedures for operations, maintenance, and\nemergencies implementing the requirements of API RP 1170 and API\nRP 1171, as required under this section, including the effective dates as\napplicable, and incorporate such procedures into their written\nprocedures for operations, maintenance, and emergencies established\npursuant to § 192.605.\nColumbia’s written procedures for implementing the requirements of API RP 1171 were\ninadequate. Specifically, Columbia did not have a process to request well integrity evaluation data\nfrom third-party well owner and operators as required by API RP 1171, Section 9.3.1 Well\nIntegrity Evaluation (Section 9.3.1).\nSection 9.3.1 states in part:\nThe operator shall request well integrity evaluation data from third-party well\nowner/operators following the frequency established using conclusions from the risk\nassessment.\nAt the time of the inspection, Columbia did not have a process in place to request third-party data\nin accordance with Section 9.3.1.\n5. § 192.12 Underground natural gas storage facilities.\n(a) ….\n(e) Operators of underground gas storage facilities must establish\nand follow written procedures for operations, maintenance, and\nemergencies implementing the requirements of API RP 1170 and API\nRP 1171, as required under this section, including the effective dates as\napplicable, and incorporate such procedures into their written\nprocedures for operations, maintenance, and emergencies established\npursuant to § 192.605.\n120201005M_Notice of Amendment_01022020_text Page 3 of 6\n\n\n\nCPF 1-2020-1005M\nColumbia’s written procedures for implementing the requirements of API RP 1171 were\ninadequate. Specifically, Columbia did not have a process to monitor for the presence of annular\ngas by measuring and recording annular gas flow as required by API RP 1171, Section 9.3.2 Well\nIntegrity Monitoring (Section 9.3.2).\nSection 9.3.2 states in part:\nThe operator shall monitor for presence of annular gas by measuring and recording annular\npressure and/or annular gas flow.\nAt the time of the inspection, Columbia did not have a process to monitor for the presence of\nannular gas by measuring and recording annular gas flow in accordance with Section 9.3.2.\n6. § 192.12 Underground natural gas storage facilities.\n(a) ….\n(e) Operators of underground gas storage facilities must establish\nand follow written procedures for operations, maintenance, and\nemergencies implementing the requirements of API RP 1170 and API\nRP 1171, as required under this section, including the effective dates as\napplicable, and incorporate such procedures into their written\nprocedures for operations, maintenance, and emergencies established\npursuant to § 192.605.\nColumbia’s written procedures for implementing the requirements of API RP 1171 were\ninadequate. Specifically, Columbia did not have a process to define a threshold or limit for the\nannular gas flow as required by API RP 1171, Section 9.3.2 Well Integrity Monitoring (Section\n9.3.2).\nSection 9.3.2 states in part:\nThe operator shall evaluate each annular gas occurrence that exceeds operator- or\nregulatory-defined threshold levels determined from well integrity evaluation and from risk\nassessment.\nAt the time of the inspection, Columbia did not have a process to define a threshold or limit for\nthe annular gas flow in accordance with Section 9.3.2.\n7. § 192.12 Underground natural gas storage facilities.\n(a) ….\n(e) Operators of underground gas storage facilities must establish\nand follow written procedures for operations, maintenance, and\nemergencies implementing the requirements of API RP 1170 and API\nRP 1171, as required under this section, including the effective dates as\napplicable, and incorporate such procedures into their written\nprocedures for operations, maintenance, and emergencies established\npursuant to § 192.605.\n120201005M_Notice of Amendment_01022020_text Page 4 of 6\n\n\n\nCPF 1-2020-1005M\n8. Columbia’s written procedures for implementing the requirements of API RP 1171 were\ninadequate. Specifically, Columbia did not have a process to evaluate each annular gas occurrence\nthat exceeds operator defined thresholds as required by API RP 1171, Section 9.3.2 Well Integrity\nMonitoring (Section 9.3.2).\nSection 9.3.2 states in part:\nThe operator shall evaluate each annular gas occurrence that exceeds operator- or\nregulatory-defined threshold levels determined from well integrity evaluation and from risk\nassessment.\nAt the time of the inspection, Columbia did not have a process to evaluate each annular gas\noccurrence that exceeds operator defined thresholds in accordance with Section 9.3.2.\n§ 192.12 Underground natural gas storage facilities.\n(a) ….\n(e) Operators of underground gas storage facilities must establish\nand follow written procedures for operations, maintenance, and\nemergencies implementing the requirements of API RP 1170 and API\nRP 1171, as required under this section, including the effective dates as\napplicable, and incorporate such procedures into their written\nprocedures for operations, maintenance, and emergencies established\npursuant to § 192.605.\nColumbia’s written procedures for implementing the requirements of API RP 1171 were\ninadequate. Specifically, Columbia did not have a process to annually test the operation of the\nmaster valve and wellhead pipeline isolation valve for the ability to isolate the well as required by\nAPI RP 1171, Section 9.3.2 Well Integrity Monitoring (Section 9.3.2).\nSection 9.3.2 states in part:\nThe operator shall test the operation of the master valve and wellhead pipeline isolation\nvalve at least annually for proper function and ability to isolate the well.\nAt the time of the inspection, Columbia did not have a process to annually test the operation of the\nmaster valve and wellhead pipeline isolation valve for the ability to isolate the well in accordance\nwith Section 9.3.2.\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 Enforcement\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\n120201005M_Notice of Amendment_01022020_text Page 5 of 6\n\n\n\nCPF 1-2020-1005M\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 30 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 Gas Transmission, LLC maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director,\nPHMSA Eastern Region, 840 Bear Tavern Road, Suite 300, West Trenton, NJ 08628. Please refer\nto CPF 1-2020-1005M on each document you submit, and whenever possible provide a signed\nPDF copy in electronic format. Smaller files may be emailed to robert.burrough@dot.gov. Larger\nfiles should be sent on USB flash drive accompanied by the original paper copy to the Eastern\nRegion 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.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n120201005M_Notice of Amendment_01022020_text Page 6 of 6","truncated":false,"body_characters":15818}