{"operation":"document","citation":"CPF 120201013W","title":"COLUMBIA GAS TRANSMISSION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-04-30","effective_on":null,"summary":"CLOSED warning letter citing 192.161(c)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120201013w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120201013w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120201013w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120201013W","body":"Warning Letter involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.161(c)(2). The case was opened on 2020-04-30 and is reported as closed as of 2020-04-30. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120201013W_Warning Letter_04302020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201013W/120201013W_Warning%20Letter_04302020.pdf\n\n120201013W_Warning Letter_04302020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201013W/120201013W_Warning%20Letter_04302020_text.pdf\n\n120201013W_Warning Letter_04302020_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nApril 30, 2020\nStanley G. Chapman, III\nExecutive Vice-President and President, U.S. Natural Gas Pipelines\nTC Energy\n700 Louisiana Street\nHouston, TX 77002\nCPF 1-2020-1013W\nDear Mr. Chapman:\nOn April 4th and 6th, 2018, an inspector from the Public Utility Commission of Ohio (PUCO),\nacting as Agent for the Pipeline and Hazardous Materials Safety Administration (PHMSA),\npursuant to Chapter 601 of 49 United States Code (U.S.C.), investigated Columbia Gas\nTransmission, LLC (Columbia)’s pipeline failure incident in Straitsville, Ohio. On April 3, 3018,\na pipeline failure occurred on pipeline H109 as it crossed Monday Creek in Straitsville, Ohio. The\n6-inch diameter pipeline on the west bank of the stream failed during heavy rainfall and flooding,\nresulting in an unintended gas release.\nAs a result of the investigation, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and\nthe probable violation is:\n1. § 192.161 Supports and anchors.\n(a)…\n(c) Each support or anchor on an exposed pipeline must be made of\ndurable, noncombustible material and must be designed and installed\nas follows:\n(1) …\n(2) Provision must be made for the service conditions involved.\nColumbia failed to install support on an exposed pipeline with provision made for the service\nconditions involved. Specifically, Columbia failed to install supports along its pipeline H109 as it\ncrossed Monday Creek in Straitsville, Ohio. Provisions did not account for the creek crossing’s\nconditions.\n\n\n\nCPF 1-2020-1013W\nOn April 3, 3018, a pipeline failure occurred on pipeline H109 as it crossed Monday Creek in\nStraitsville, Ohio. The pipeline did not have any cables or other supports at the time of the rupture.\nHowever, the support columns, with no cables attached, were visible on each side of the creek\ncrossing.\nDuring the investigation, the PUCO inspector reviewed a construction drawing from 1981 when\nthis pipeline crossing was replaced. It showed that the pipeline was intended to be supported with\ncables. Columbia provided a few photos of the H109 creek crossing, from 2010 and the photos of\nthe pipeline did not show cable supports connected to the pipe. Columbia did not have any\ntimeframe for the installation or removal of the pipeline cable supports. Columbia also did not\nhave documentation of any load support calculations or studies to validate removal of the pipeline\ncable supports at the H109 span crossing.\nTherefore, Columbia failed to install supports on the exposed portion of its H109 pipeline’s\nMonday Creek crossing with provisions made for the service conditions involved, by not using the\ncable supports that the construction drawing called for, or any other method of support.\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,\n2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum\npenalty not to exceed $2,132,679. For violation occurring on or after November 2, 2015 and before\nNovember 27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a\nmaximum penalty not to exceed $2,090,022. For violations occurring prior to November 2, 2015,\nthe maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty\nnot to exceed $2,000,000 for a related series of violations. We have reviewed the circumstances\nand supporting 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.\nBe advised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you must\nprovide a second copy of the document with the portions you believe qualify for confidential\ntreatment redacted and an explanation of why you believe the redacted information qualifies for\nconfidential 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 1-2020-1013W 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 USB flash drive accompanied by the\noriginal paper copy to the Eastern Region Office.\n120201013W_Warning Letter_04302020_text Page 2 of 3\n\n\n\nCPF 1-2020-1013W\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nCC: George Hamaty, US Regulatory Compliance Manager Eastern Region, TC Energy\n(via email)\n120201013W_Warning Letter_04302020_text Page 3 of 3","truncated":false,"body_characters":6048}