COLUMBIA GAS TRANSMISSION, LLC — Warning Letter

12021029WL_Warning Letter_03252021_(20-173065)_text.pdf, page 1Official PDFWARNING 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#

12021029WL_Warning Letter_03252021_(20-173065)_text.pdf, page 2CPF 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 12021029WL_Warning Letter_03252021_(20-173065)_text Page 2 of 2#