# COLUMBIA GAS TRANSMISSION, LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 12021005NOPV
- **title:** COLUMBIA GAS TRANSMISSION, LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2021-06-24
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 192.605(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-12021005nopv.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-12021005nopv.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-12021005nopv
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/12021005NOPV
**body:**

Notice of Probable Violation involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2021-06-24 and is reported as closed as of 2021-10-29. Proposed civil penalty: $418,004. Assessed civil penalty: $418,004. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

12021005NOPV_Closure Letter_10292021_(21-199574).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021005NOPV/12021005NOPV_Closure%20Letter_10292021_(21-199574).pdf

12021005NOPV_Closure Letter_10292021_(21-199574)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021005NOPV/12021005NOPV_Closure%20Letter_10292021_(21-199574)_text.pdf

12021005NOPV_Final Order_08232021_(21-199574).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021005NOPV/12021005NOPV_Final%20Order_08232021_(21-199574).pdf

12021005NOPV_Final Order_08232021_(21-199574)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021005NOPV/12021005NOPV_Final%20Order_08232021_(21-199574)_text.pdf

12021005NOPV_PCP PCO (Amended)_07012021_(21-199574).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021005NOPV/12021005NOPV_PCP%20PCO%20(Amended)_07012021_(21-199574).pdf

12021005NOPV_PCP PCO (Amended)_07012021_(21-199574)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021005NOPV/12021005NOPV_PCP%20PCO%20(Amended)_07012021_(21-199574)_text.pdf

12021005NOPV_PCP PCO_06242021_(21-199574).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021005NOPV/12021005NOPV_PCP%20PCO_06242021_(21-199574).pdf

12021005NOPV_PCP PCO_06242021_(21-199574)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021005NOPV/12021005NOPV_PCP%20PCO_06242021_(21-199574)_text.pdf

12021005NOPV_PCP PCO (Amended)_07012021_(21-199574)_text.pdf

NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPLIANCE ORDER
OVERNIGHT EXPRESS DELIVERY
July 01, 2021
Mr. Stanley G. Chapman, III
SVP & General Manager, US NG Pipelines
Columbia Gas Transmission, LLC
700 Louisiana Street
Houston, TX 77002
CPF 1-2021-005-NOPV
Dear Mr. Chapman:
From October 23, 2017 to May 27, 2020, representatives of the Pipeline and Hazardous materials
Safety Administration (PHMSA), Office of Pipeline Safety (OPS), and Public Utilities
Commission of Ohio (PUCO), acting as Agent for PHMSA, pursuant to Chapter 601 of 49 United
States Code (U.S.C) responded to and conducted an investigation into an incident at Timken
Metering Station in Stark County, Ohio. Timken Metering Station was operated by Columbia Gas
Transmission, LLC (Columbia).
On October 23, 2017, an incident occurred during a scheduled meter module replacement and
inspection (maintenance activity), at Timken Metering Station. Two Columbia technicians,
identified here as “Technician A” and “Technician B,” performed the maintenance activity. The
maintenance activity consisted of: isolating the meter run, blowing down the meter run, changing
the turbine meter module, conducting a spin test, and inspecting internal meter run piping and
components. The internal inspection required opening the Aitken Type T-A 8-inch Single Bolt
Tube Turns Hinged Closure (closure) to examine the straightening vanes within the piping. The
closure was of carbon steel, Size 8, 600S Class manufactured by Sypris® Technologies.
After the maintenance activity was completed, the closure was shut, and the line was re-
pressurized. A leak was identified at the head of the closure by Technician A. Technician A was



CPF 1-2021-005-NOPV
standing at the end of the meter run in front of the closure while preparing to tighten the swing
bolt in an effort to stop the leak. Loading imparted during tightening led to failure of the swing
bolt pin and ejection of the closure (Incident).
The failure resulted in the fatality of Technician A and the evacuation of three members of the
public. Unintended release of gas continued for approximately forty nine minutes (10:03AM to
10:52AM), until the facility was isolated with assistance from the fire department. The pipeline
was operating at 356 psig when the failure occurred, resulting in a release of approximately 12.97
million standard cubic feet of natural gas. Following the Incident, the closure components were
provided to a metallurgical laboratory, DNV GL, for analysis.
As a result of the investigation, it is alleged that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected
and the probable violations are:
1. § 192.605 Procedure manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each
pipeline, a manual of written procedures for conducting operations and
maintenance activities and for emergency response. For transmission
lines, the manual must also include procedures for handling abnormal
operations. This manual must be reviewed and updated by the operator
at intervals not exceeding 15 months, but at least once each calendar
year. This manual must be prepared before operations and
maintenance activities are conducted.
Columbia violated 49 C.F.R. § 192.605(a) by failing to prepare and follow a manual of written
procedures for conducting operations and maintenance activities and for emergency
response. Specifically, Columbia failed to prepare and follow its own written procedures for
maintenance activities involving closures that included manufacturer specifications for closure,
torque, and O-ring replacement.
As noted above, on October 23, 2017, the maintenance activity involving the operation of a closure
was performed by two Columbia technicians. After the maintenance activity was completed, the
closure was shut with a swing bolt and the line was re-pressurized. A leak was identified at the
head of the closure and the swing bolt was tightened in an effort to stop the leak. Loading imparted
during the tightening led to failure of the swing bolt pin, causing the Incident.
The Closure Specifications of the manufacturer, Sypris® Technologies’ Yoke Type Hinged
Closures Installation, Operation & Maintenance Bulletin No. TT720 revised December 2012
(Closure Specification), reviewed by the PUCO during the investigation, stated in part:
“For S closures: To close the unit, first inspect the O-ring, O-ring groove and seating
surfaces and remove all foreign material. Swing the head to the closed position, and
draw the yoke halves over the head flange. Place the bolt in its locking position and draw
the nut to approximately 20 ft-lbs. Tighten the pressure warnings device holding nut to
approximately 15 ft-lbs after the positioning plate has engaged the yoke lugs.
12021005NOPV_PCP PCO (Amended)_07012021_(21-199574)_text Page 2 of 7



CPF 1-2021-005-NOPV
Maintenance
Gasket: The O-ring should be inspected prior to every closing. Variations in service
conditions will determine its useful life.
….
During reassembly, care must be exercised to insure that all components are properly
aligned before operating the closure. Misalignment can cause excessive wear and
leakage.”
During the investigation, Columbia provided a copy of its written procedures, Measurement
Facilities Service Manual, LRD 4/96, Turbine Meter Proof Inspection and Certification, effective
2014/08/13, and Measurement and Regulation Field Handbook. The procedures, effective at the
time of the incident, did not address the closure operation being performed, or manufacturer
specifications for closure, torque, and O-ring replacement.
The leak identified during re-pressurization likely resulted from reusing the embrittled O-ring or
improper alignment of the O-ring. The cause of the closure swing bolt pin failure, confirmed by
laboratory analysis, was double shear force while tightening the swing bolt nut.1 Failure to prepare
and follow a manual of written procedures that addressed the closure operation being performed,
or manufacturer specifications for closure, torque, and O-ring replacement was a proximate cause
in the incident.
Therefore, Columbia failed to prepare and follow a manual of written procedures for conducting
operations and maintenance activities and for emergency response with regard to closure
operation, torque, and O-ring replacement.
2. § 192.605 Procedure manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each
pipeline, a manual of written procedures for conducting operations and
maintenance activities and for emergency response. For transmission
lines, the manual must also include procedures for handling abnormal
operations. This manual must be reviewed and updated by the operator
at intervals not exceeding 15 months, but at least once each calendar
year. This manual must be prepared before operations and
maintenance activities are conducted.
Columbia failed to follow a manual of written procedures for conducting operations and
maintenance activities and for emergency response. Specifically, Columbia failed to follow its
procedures for Lockout and Tagout (LOTO).
On October 23, 2017, the performed maintenance activity required isolating energy sources and
de-energizing stored energy. Columbia’s procedure, Plan Number:110.01.10 Lockout Tagout,
1 See, PHMSA Failure Investigation Report No. 20170115-32529 (May 27,2020), on file with PHMSA.
12021005NOPV_PCP PCO (Amended)_07012021_(21-199574)_text Page 3 of 7



CPF 1-2021-005-NOPV
effective 3/7/2016 (LOTO procedure) required all employees performing activities where injury
could occur during the release of stored energy during repair, maintenance, testing, and all other
activities associated with the use of stored energy sources. The failure to comply with the
procedure may result in disciplinary action, including potential dismissal.
The LOTO procedure directed employees to perform LOTO and to record on a “Lockout/Tagout
Procedures and Checklist” each time a LOTO occurred. Part of the steps of the LOTO procedure
included isolating equipment from energy sources, ensuring there is no residual energy, applying
personal locks to LOTO devices for all authorized employees, and for the Team Leader to ensure
employees follow the LOTO procedure.
Although the performed maintenance activity required isolating energy sources and de-energizing
stored energy, the LOTO procedure was not followed at various steps leading up to the Incident.
These included:
 Technician A arrived at the Timken Meter Station and placed the meter run on bypass
without utilizing the LOTO procedure.
 Technician B arrived at the location and helped Technician A purge gas from the meter
run without utilizing the LOTO procedure.
 After the maintenance activity was completed, the line was re-pressurized. Subsequently,
Technician A identified a leak at the head of the closure. However, neither Technician A
or B utilized the LOTO procedure prior to the attempt to stop the leak.
 LOTO was not recorded on the “Lockout/Tagout Procedures and Checklist”
 A Team Leader was not present on site, nor was a lead authorized person appointed,
therefore did not ensure employees followed LOTO procedures.
Therefore, Columbia failed in at least five instances to follow its manual of written procedures for
conducting operations and maintenance activities and for emergency response by failing to follow
its LOTO procedure.
3. § 192.605 Procedure manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each
pipeline, a manual of written procedures for conducting operations and
maintenance activities and for emergency response. For transmission
lines, the manual must also include procedures for handling abnormal
operations. This manual must be reviewed and updated by the operator
at intervals not exceeding 15 months, but at least once each calendar
year. This manual must be prepared before operations and
maintenance activities are conducted.
Columbia failed to follow its manual of written procedures for conducting operations and
maintenance activities and for emergency response. Specifically, Columbia failed to follow its
procedure, Plan Number:110.02.01 Personal Protective Equipment, effective 4/13/2016 (PPE
Procedure) that established minimum required use of personal protective equipment (PPE) for
Columbia personnel. The PPE Procedure directed that a hard hat must be worn when work is
12021005NOPV_PCP PCO (Amended)_07012021_(21-199574)_text Page 4 of 7



CPF 1-2021-005-NOPV
being performed, except for inside an office, and that flame-resistant clothing (FRC) be worn when
entering a metering station.
On October 23, 2017, Technician A and Technician B performed a maintenance activity at
Columbia's Timken Metering Station, a fenced outdoor metering station. Technician B failed to
wear full FRC during the work activity. Technician B was wearing FRC jeans, but no FRC shirt.
After the maintenance activity was completed, Technician A and Technician B removed their hard
hats. When they discovered the leak, they attempted to stop the leak but failed to put their hard
hats back on during this work.
Therefore, Columbia failed to follow its manual of written procedures for conducting operations
and maintenance activities and for emergency response by failing to follow its PPE procedure.
Proposed Civil Penalty
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related
series of violations. For violation occurring on or after January 11, 2021 and before May 3, 2021,
the maximum penalty may not exceed $222,504 per violation per day the violation persists, up to
a maximum of $2,225,034 for a related series of violations. For violation occurring on or after
July 31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per
violation per day the violation persists, up to a maximum of $2,186,465 for a related series of
violations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the
maximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to
exceed $2,132,679. For violation occurring on or after November 2, 2015 and before November
27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum
penalty not to exceed $2,090,022.
We have reviewed the circumstances and supporting documentation involved for the above
probable violations and recommend that you be preliminarily assessed a civil penalty of $418,004
as follows:
Item number
PENALTY
1
$209,002
2
$209,002
Warning Items)
With respect to Item Number 3, we have reviewed the circumstances and supporting documents
involved in this case and have decided not to conduct additional enforcement action or penalty
assessment proceedings at this time. We advise you to promptly correct this item. Failure to do
so may result in additional enforcement action.
1202100SNOPV_PCP PCO (Amended)_07012021_(21-199574)_text
Page 5 of 7



CPF 1-2021-005-NOPV
Proposed Compliance Order
With respect to Item Number 1, pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous
Materials Safety Administration proposes to issue a Compliance Order to Columbia Gas
Transmission, LLC. Please refer to the Proposed Compliance Order, which is enclosed and made
a part of this Notice.
Response to this Notice
Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in
Enforcement Proceedings. Please refer to this document and note the response options. All
material you submit in response to this enforcement action may be made publicly available. If you
believe that any portion of your responsive material qualifies for confidential treatment under 5
U.S.C. 552(b), along with the complete original document you must provide a second copy of the
document with the portions you believe qualify for confidential treatment redacted and an
explanation of why you believe the redacted information qualifies for confidential treatment under
5 U.S.C. 552(b).
Following the receipt of this Notice, you have 30 days to submit written comments, or request a
hearing under 49 CFR § 190.211. If you do not respond within 30 days of receipt of this Notice,
this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the
Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further
notice to you and to issue a Final Order. If you are responding to this Notice, we propose that you
submit your correspondence to my office within 30 days from receipt of this Notice. This period
may be extended by written request for good cause.
In your correspondence on this matter, please refer to CPF 1-2021-005-NOPV and, for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Enforcement Proceedings
12021005NOPV_PCP PCO (Amended)_07012021_(21-199574)_text Page 6 of 7



CPF 1-2021-005-NOPV
PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Columbia Gas Transmission, LLC (Columbia) a
Compliance Order incorporating the following remedial requirements to ensure the compliance
of Columbia with the pipeline safety regulations:
A. B. In regard to Item Number 1 of the Notice pertaining to § 192.605, Columbia shall
revise its procedures to reflect maintenance activities involving closures,
accounting for manufacturer specifications regarding closure, torque, and O-ring
replacement Columbia shall provide PHMSA the revised procedure for review
within 30 days of receipt of the Final Order.
It is requested (not mandated) that Columbia Gas Transmission, LLC maintain
documentation of the safety improvement costs associated with fulfilling this
Compliance Order and submit the total to Robert Burrough, Director, Eastern
Region, Pipeline and Hazardous Materials Safety Administration. It is requested
that these costs be reported in two categories: 1) total cost associated with
preparation/revision of plans, procedures, studies and analyses, and 2) total cost
associated with replacements, additions and other changes to pipeline
infrastructure.
12021005NOPV_PCP PCO (Amended)_07012021_(21-199574)_text Page 7 of 7

12021005NOPV_Final Order_08232021_(21-199574)_text.pdf

August 23, 2021
VIA ELECTRONIC MAIL TO: stanley chapman iii@tcenergy.com
Mr. Stanley G. Chapman, III
Executive Vice President and President
U.S. Natural Gas Pipelines
TC Energy Corporation
700 Louisiana Street
Houston, TX 77002
Re: CPF No. 1-2021-005-NOPV
Dear Mr. Chapman:
Enclosed please find the Final Order issued in the above-referenced case to your subsidiary,
Columbia Gas Transmission, LLC. It makes findings of violation, assesses a civil penalty of
$418,004, and specifies actions that need to be taken to comply with the pipeline safety
regulations. When the civil penalty has been paid and the terms of the compliance order are
completed, as determined by the Director, Eastern Region, this enforcement action will be
closed. Service of the Final Order by e-mail is effective upon the date of transmission as
provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosures (Final Order and NOPV)
cc: Mr. Robert Burrough, Director, Eastern Region, Office of Pipeline Safety, PHMSA
Mr. Lee Romack, Director, Regulatory Compliance, TC Energy Corp.,
lee_romack@tcenergy.com
Ms. Wendy West, Vice President, Safety, Quality and Compliance, TC Energy Corp.,
wendy_west@tcenergy.com



Mr. Chris Humes, Senior Vice President, Operations and Project Execution, TC Energy
Corp., chris_humes@tcenergy.com
CONFIRMATION OF RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Columbia Gas Transmission, LLC, ) CPF No. 1-2021-005-NOPV
a subsidiary of TC Energy Corp., )
)
)
)
Respondent. )
____________________________________)
FINAL ORDER
On July 1, 2021, pursuant to 49 C.F.R. § 190.207, the Director, Eastern Region, Office of
Pipeline Safety (OPS), issued a Notice of Probable Violation (Notice) to Columbia Gas
Transmission, LLC (Respondent), a subsidiary of TC Energy Corporation. The Notice proposed
finding that Respondent had violated the pipeline safety regulations in 49 C.F.R. Part 192 and
proposed a civil penalty of $418,004. The Notice also proposed certain measures to correct the
violations. Respondent did not contest the allegations of violation, the proposed civil penalty, or
corrective measures.
Based upon a review of all of the evidence, pursuant to § 190.213, I find Respondent violated the
pipeline safety regulations listed below, as more fully described in the enclosed Notice, which is
incorporated by reference:
49 C.F.R. § 192.605(a) (Item 1) ─ Respondent failed to prepare and follow a
manual of written procedures for conducting operations and maintenance
activities involving closures that included manufacturer specifications for closure,
torque, and O-ring replacement.
49 C.F.R. § 192.605(a) (Item 2) ─ Respondent failed to follow its manual of
written procedures for conducting operations and maintenance activities and for
emergency response, specifically its procedures for Lockout and Tagout.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent. In accordance with 49 C.F.R. § 190.223, I assess Respondent a
total civil penalty of $418,004.
Payment of the civil penalty must be made within 20 days of service. Federal regulations (49
C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer through the Federal



CPF No.1-2021-005-NOPV
Page 2
Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed
instructions are contained in the enclosure. Questions concerning wire transfers should be
directed to: Financial Operations Division (AMK-325), Federal Aviation Administration, Mike
Monroney Aeronautical Center, 6500 S MacArthur Blvd, Oklahoma City, Oklahoma 79169.
The Financial Operations Division telephone number is (405) 954-8845.
Failure to pay the $418,004 civil penalty will result in accrual of interest at the current annual
rate in accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to
those same authorities, a late penalty charge of six percent (6%) per annum will be charged if
payment is not made within 110 days of service. Furthermore, failure to pay the civil penalty
may result in referral of the matter to the Attorney General for appropriate action in a district
court of the United States.
COMPLIANCE ACTIONS
Pursuant to 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the
actions proposed in the enclosed Notice to correct the violations. The Director may grant an
extension of time to comply with any of the required items upon a written request timely
submitted by the Respondent and demonstrating good cause for an extension. Upon completion
of ordered actions, Respondent may request that the Director close the case. Failure to comply
with this Order may result in the assessment of civil penalties under 49 C.F.R. § 190.223 or in
referral to the Attorney General for appropriate relief in a district court of the United States.
WARNING ITEM
With respect to Item 3, the Notice alleged a probable violation of 49 C.F.R. § 192.605(a) for
failing to follow its procedure that established the minimum required used of personal protective
equipment for its personnel, but did not propose a civil penalty or compliance order for this
item. Therefore, this is considered to be a warning item. If OPS finds a violation of this
provision in a subsequent inspection, Respondent may be subject to future enforcement action.
The terms and conditions of this order are effective upon service in accordance with 49 C.F.R.
§ 190.5.
August 23, 2021
___________________________________ _________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety

12021005NOPV_Closure Letter_10292021_(21-199574)_text.pdf

OVERNIGHT EXPRESS DELIVERY
October 29, 2021
Mr. Stanley G. Chapman, III
Executive Vice President and President
U.S. Natural Gas Pipelines
TC Energy Corporation
700 Louisiana Street
Houston, TX 77002
CPF 1-2021-005-NOPV
Dear Mr. Chapman:
On August 23, 2021, the Pipeline and Hazardous Materials Safety Administration (PHMSA)
issued to Columbia Gas Transmission, LLC, a subsidiary of TC Energy Corporation, a Final Order
in the above-referenced case. This Order included a Compliance Order and Civil Penalty
assessment. Based on our review of the documentation you provided and confirmation of payment
of the civil penalty, it has been determined that you have complied with the terms of this Order.
Accordingly, this case is now closed, and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
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