{"operation":"document","citation":"CPF 12021050NOA","title":"COLUMBIA GAS TRANSMISSION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-10-07","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021050noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021050noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021050noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12021050NOA","body":"Notice of Amendment involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2021-10-07 and is reported as closed as of 2021-12-29. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12021050NOA_Closure Letter_12292021_(20-174592).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021050NOA/12021050NOA_Closure%20Letter_12292021_(20-174592).pdf\n\n12021050NOA_Closure Letter_12292021_(20-174592)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021050NOA/12021050NOA_Closure%20Letter_12292021_(20-174592)_text.pdf\n\n12021050NOA_Notice of Amendment_10072021_(20-174592).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021050NOA/12021050NOA_Notice%20of%20Amendment_10072021_(20-174592).pdf\n\n12021050NOA_Notice of Amendment_10072021_(20-174592)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021050NOA/12021050NOA_Notice%20of%20Amendment_10072021_(20-174592)_text.pdf\n\n12021050NOA_Closure Letter_12292021_(20-174592)_text.pdf\n\nVIA ELECTRONIC MAIL TO: stanley chapman iii@tcenergy.com\nDecember 29, 2021\nMr. Stanley Chapman\nSenior Vice President & General Manager, US NG Pipelines\nColumbia Gas Transmission, LLC\n700 Louisiana Street\nHouston, Texas 77002\nCPF 1-2021-050-NOA\nDear Mr. Chapman:\nOn August 31, 2020, September 1, 2020 and September 4, 2020, a representative from the Pipeline\nand Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code, conducted an on-site pipeline safety inspection of Columbia Gas Transmission,\nLLC’s (Columbia) procedures for conducting operations, maintenance, and emergency\npreparedness and responses activities. As a result of the inspection, Columbia was issued a Notice\nof Amendment on October 7, 2021, which proposed amendment of your procedures.\nColumbia submitted its amended procedures on November 4, 2021. My staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n12021050NOA_Notice of Amendment_10072021_(20-174592)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nOctober 7, 2021\nMr. Stan Chapman\nSenior Vice President & General Manager, US NG Pipelines\nColumbia Gas Transmission, LLC\n700 Louisiana Street\nHouston, Texas 77002\nCPF 1-2021-050-NOA\nDear Mr. Chapman:\nOn August 31, 2020, September 1, 2020, and September 4, 2020, a representative of the Pipeline\nand Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United\nStates Code inspected Columbia Gas Transmission, LLC’s (Columbia) procedures for Storage\nIntegrity Management Framework and Gas Storage Well Casing Design Specification.\nOn the basis of the inspection, PHMSA has identified apparent inadequacies found within\nColumbia’s plans or procedures, as described below:\n1. § 192.12 Underground natural gas storage facilities.\nUnderground natural gas storage facilities (UNGSFs), as\ndefined in § 192.3, are not subject to any requirements of this part aside\nfrom this section.\n(a) …\n(c) Procedural manuals. Each operator of a UNGSF must prepare\nand follow for each facility one or more manuals of written procedures\nfor conducting operations, maintenance, and emergency preparedness\nand response activities under paragraphs (a) and (b) of this section.\nEach operator must keep records necessary to administer such\nprocedures and review and update these manuals at intervals not\nexceeding 15 months, but at least once each calendar year. Each\noperator must keep the appropriate parts of these manuals accessible\nat locations where UNGSF work is being performed. Each operator\nmust have written procedures in place before commencing operations\nor beginning an activity not yet implemented.\n\n\n\nCPF 1-2021-050-NOA\nColumbia’s written procedures for conducting activities under § 192.12(b)(1)1\nfailed to include sufficient details as required by API RP 1171, subsection 6.6.1. Specifically,\nColumbia’s Storage Integrity Management Framework (CDN-USMEX), Rev.: 00 and Publish\nDate: 2018/10/12 (SIMF), subsection 5.3.1.1 lacked information on what constitutes a condition\nof compromised mechanical integrity in a well.\nAPI RP 1171, subsection 6.6.1 states:\nA well identified as having compromised mechanical integrity shall be evaluated and\nresponsive action implemented within a timeframe and by method(s) determined by the\noperator and corresponding to the severity of the integrity risk.\nNOTE Section 8 assists the operator in characterizing risk and building integrity plans to\naddress integrity monitoring and treatment.\nDuring the inspection, PHMSA reviewed SIMF, subsection 5.3.1.1. That subsection included a\nlist of Well Issue and Reservoir Issue categories and a Reservoir Issues List, then proceeded to\npresent actions necessary when a well identified as having compromised mechanical integrity was\nidentified. However, details on what constitutes a well identified as having compromised\nmechanical integrity were not presented.\nThus, Columbia’s manual of written procedures required by § 192.12(c) was inadequate.\nColumbia must revise its SIMF to indicate what constitutes a condition of compromised\nmechanical integrity in a well.\n2. § 192.12 Underground natural gas storage facilities.\nUnderground natural gas storage facilities (UNGSFs), as\ndefined in § 192.3, are not subject to any requirements of this part aside\nfrom this section.\n(a) …\n(c) Procedural manuals. Each operator of a UNGSF must prepare\nand follow for each facility one or more manuals of written procedures\nfor conducting operations, maintenance, and emergency preparedness\nand response activities under paragraphs (a) and (b) of this section.\nEach operator must keep records necessary to administer such\nprocedures and review and update these manuals at intervals not\nexceeding 15 months, but at least once each calendar year. Each\noperator must keep the appropriate parts of these manuals accessible\nat locations where UNGSF work is being performed. Each operator\nmust have written procedures in place before commencing operations\nor beginning an activity not yet implemented.\n1 § 192.12 Underground natural gas storage facilities.\n(a) …\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs.\n(1) Each UNGSF that uses a depleted hydrocarbon reservoir or an aquifer reservoir for natural gas storage and was constructed\nafter July 18, 2017, must meet all provisions of API RP 1171 (incorporated by reference, see §192.7), and paragraphs (c) and (d)\nof this section, prior to commencing operations.\n12021050NOA_Notice of Amendment_10072021_(20-174592)_text Page 2 of 4\n\n\n\nCPF 1-2021-050-NOA\nColumbia’s written procedures for conducting activities under § 192.12(b)(1) failed to contain\nsufficient details to comply with API RP 1171, subsection 6.9.1 Testing Methods. Specifically,\nColumbia’s TES-PR-WESTS-G Gas Storage Well Casing Design Specification (CAN-US-MEX),\nRev.: 01 and Effective Date: 2018-Jun-01 (Casing Design Specification), subsection 2.3.7 failed\nto specify pressure testing duration and pressure requirements in detail.\nAPI RP 1171, subsection 6.9.1 Testing Methods states:\nA new well, or a well that has had its existing production casing modified from its previous\ncondition during workover activities, shall be tested to demonstrate mechanical integrity and\nsuitability for the designed operating conditions prior to commissioning by one of the\nfollowing tests.\na) For new well construction, the production casing shall be tested prior to drilling out the\nshoe, taking into account the cement design factors so that this test does not compromise the\ncement integrity.\nb) For existing production casing, the production casing shall be tested after setting a\nretrievable plug as close as practical to the top of the storage formation.\nNOTE A commonly used test parameter is an initial test pressure of 1.1 times the maximum\nallowable operating pressure, with test duration of at least 30 minutes and a pressure drop not\nexceeding 10% of the initial test pressure. Applicable regulations may stipulate other\nparameters.\nc) For a well completed with tubing and packer, the tubing-casing annulus shall be tested.\nThe operator shall design a test so the maximum pressure on the packer seat and the pressure\nat any point in the wellbore during the test does not compromise the mechanical integrity of\nthe well.\nDuring the inspection, PHMSA reviewed Casing Design Specification, subsection 2.3.7. It cited\nan example for pressure and duration that was taken from API RP 1171, subsection 6.9.1.\nHowever, Casing Design Specification, subsection 2.3.7 did not formally specify detailed pressure\ntesting duration and pressure requirements.\nTherefore, Columbia’s manual of written procedures required by § 192.12(c) was as inadequate.\nColumbia must revise its Casing Design Specification to specify pressure testing duration and\npressure requirements in detail.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. § 552(b), along with the complete original document you must provide a second copy of\n12021050NOA_Notice of Amendment_10072021_(20-174592)_text Page 3 of 4\n\n\n\nCPF 1-2021-050-NOA\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 U.S.C. § 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 30 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Columbia Gas Transmission, LLC maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director,\nEastern Region, Pipeline and Hazardous Materials Safety Administration, 840 Bear Tavern Road,\nSuite 300, West Trenton, NJ 08628. In correspondence concerning this matter, please refer to CPF\n1-2021-050-NOA and, for each document you submit, please provide a copy in electronic format\nwhenever possible. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should\nbe sent on USB flash drive accompanied by the original paper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n12021050NOA_Notice of Amendment_10072021_(20-174592)_text Page 4 of 4","truncated":false,"body_characters":12115}