{"operation":"document","citation":"CPF 12021029WL","title":"COLUMBIA GAS TRANSMISSION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-03-25","effective_on":null,"summary":"CLOSED warning letter citing 192.12(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021029wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021029wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021029wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12021029WL","body":"Warning Letter involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(b)(2). The case was opened on 2021-03-25 and is reported as closed as of 2021-03-25. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12021029WL_Warning Letter_03252021_(20-173065).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021029WL/12021029WL_Warning%20Letter_03252021_(20-173065).pdf\n\n12021029WL_Warning Letter_03252021_(20-173065)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021029WL/12021029WL_Warning%20Letter_03252021_(20-173065)_text.pdf\n\n12021029WL_Warning Letter_03252021_(20-173065)_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nMarch 25, 2021\nMr. Stan Chapman\nSenior Vice President & General Manager\nColumbia Gas Transmission, LLC\n7000 Louisiana Street\nHouston, TX 77002\nCPF 1-2021-029-WL\nDear Mr. Chapman:\nFrom August 18 – 21, 2020, 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) Ripley and Rockport underground natural gas\nstorage facilities in Jackson and Wood Counties, West Virginia.\nAs a result of the inspection, 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. § 192.12 Underground natural gas storage facilities.\n(a) …\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs.\n(1) …\n(2) Each UNGSF that uses a depleted hydrocarbon reservoir or an\naquifer reservoir for natural gas storage and was constructed on or\nbefore July 18, 2017, must meet the provisions of API RP 1171\n(incorporated by reference, see §192.7), sections 8, 9, 10, and 11, and\nparagraph (c) of this section, by January 18, 2018, and must meet all\nprovisions of paragraph (d) of this section by March 13, 2021.\nColumbia failed to meet the provisions of API RP1171, Section 9. Specifically, Columbia failed\n\n\n\nCPF 1-2021-029-WL\nto monitor for the presence of annular gas by measuring the annular pressure or annular gas flow,\nin accordance with API RP 1171, Section 9.3.2 (Section 9.3.2).\nSection 9.3.2 states in part that “The operator shall monitor for presence of annular gas by\nmeasuring and recording annular pressure and/or annular gas flow.”\nDuring the inspection, the inspection team reviewed Columbia’s records for annular gas\nmonitoring. It was noted that 4 wells were not monitored: Rockport 7247-OB, 7258-OB, and\nRipley 7320-OB, and 7321-OB. Columbia indicated that these wells did not have monitoring ports\non the wellhead assembly.\nTherefore, Columbia failed to meet the provisions of Section 9.3.2.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for a related\nseries of violations. For violation occurring on or after July 31, 2019 and before January 11, 2021,\nthe maximum penalty may not exceed $218,647 per violation per day the violation persists, up to\na maximum of $2,186,465 for a related series of violations. For violation occurring on or after\nNovember 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per\nviolation per day, with a maximum penalty not to exceed $2,132,679. For violation occurring on\nor after November 2, 2015 and before November 27, 2018, the maximum penalty may not exceed\n$209,002 per violation per day, with a maximum penalty not to exceed $2,090,022.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the item identified in this letter. Failure to do so will result in\nColumbia Gas Transmission, LLC being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2021-029-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n12021029WL_Warning Letter_03252021_(20-173065)_text Page 2 of 2","truncated":false,"body_characters":4881}