# COLUMBIA GAS TRANSMISSION, LLC — Warning Letter

- **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:** Not available
- **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.

Official case documents:

12021029WL_Warning Letter_03252021_(20-173065).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021029WL/12021029WL_Warning%20Letter_03252021_(20-173065).pdf

12021029WL_Warning Letter_03252021_(20-173065)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021029WL/12021029WL_Warning%20Letter_03252021_(20-173065)_text.pdf

12021029WL_Warning Letter_03252021_(20-173065)_text.pdf

WARNING LETTER
OVERNIGHT EXPRESS DELIVERY
March 25, 2021
Mr. Stan Chapman
Senior Vice President & General Manager
Columbia Gas Transmission, LLC
7000 Louisiana Street
Houston, TX 77002
CPF 1-2021-029-WL
Dear Mr. Chapman:
From August 18 – 21, 2020, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected
Columbia Gas Transmission, LLC’s (Columbia) Ripley and Rockport underground natural gas
storage facilities in Jackson and Wood Counties, West Virginia.
As a result of the inspection, it is alleged that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and
the probable violation is:
1. § 192.12 Underground natural gas storage facilities.
(a) …
(b) Depleted hydrocarbon and aquifer reservoir UNGSFs.
(1) …
(2) Each UNGSF that uses a depleted hydrocarbon reservoir or an
aquifer reservoir for natural gas storage and was constructed on or
before July 18, 2017, must meet the provisions of API RP 1171
(incorporated by reference, see §192.7), sections 8, 9, 10, and 11, and
paragraph (c) of this section, by January 18, 2018, and must meet all
provisions of paragraph (d) of this section by March 13, 2021.
Columbia failed to meet the provisions of API RP1171, Section 9. Specifically, Columbia failed



CPF 1-2021-029-WL
to monitor for the presence of annular gas by measuring the annular pressure or annular gas flow,
in accordance with API RP 1171, Section 9.3.2 (Section 9.3.2).
Section 9.3.2 states in part that “The operator shall monitor for presence of annular gas by
measuring and recording annular pressure and/or annular gas flow.”
During the inspection, the inspection team reviewed Columbia’s records for annular gas
monitoring. It was noted that 4 wells were not monitored: Rockport 7247-OB, 7258-OB, and
Ripley 7320-OB, and 7321-OB. Columbia indicated that these wells did not have monitoring ports
on the wellhead assembly.
Therefore, Columbia failed to meet the provisions of Section 9.3.2.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to 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 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 correct the item identified in this letter. Failure to do so will result in
Columbia Gas Transmission, LLC being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 1-2021-029-WL. Be advised that all material you submit in response to this enforcement
action is subject to being 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).
Sincerely,
Robert Burrough
Director, Eastern Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
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