{"operation":"document","citation":"CPF 12022018WL","title":"COLUMBIA GAS TRANSMISSION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-03-15","effective_on":null,"summary":"CLOSED warning letter citing 191.25(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022018wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022018wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022018wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022018WL","body":"Warning Letter involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 191.25(a). The case was opened on 2022-03-15 and is reported as closed as of 2022-03-30. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022018WL_Warning Letter (Amended)_03302022_(21-231686).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022018WL/12022018WL_Warning%20Letter%20(Amended)_03302022_(21-231686).pdf\n\n12022018WL_Warning Letter (Amended)_03302022_(21-231686)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022018WL/12022018WL_Warning%20Letter%20(Amended)_03302022_(21-231686)_text.pdf\n\n12022018WL_Warning Letter_03152022_(21-231686).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022018WL/12022018WL_Warning%20Letter_03152022_(21-231686).pdf\n\n12022018WL_Warning Letter_03152022_(21-231686)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022018WL/12022018WL_Warning%20Letter_03152022_(21-231686)_text.pdf\n\n12022018WL_Warning Letter (Amended)_03302022_(21-231686)_text.pdf\n\nAMENDED WARNING LETTER\nVIA ELECTRONIC MAIL TO: stanley chapman iii@tcenergy.com\nMarch 30, 2022\nMr. Stanley Chapman\nExecutive Vice President & President US & Mexico Natural Gas\nColumbia Gas Transmission, LLC\n7000 Louisiana Street\nHouston, Texas 77002\nCPF 1-2022-018-WL\nDear Mr. Chapman:\nOn May 10, 2021, Columbia Gas Transmission, LLC (Columbia) submitted to PHMSA a letter\nrelated to Safety-Related Condition Reports. A representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter\n601 of 49 United States Code (U.S.C.) reviewed the submission and investigated these conditions.\nAs a result of the investigation, PHMSA issued to Columbia a Warning Letter (Original Notice)\non March 15, 2022. PHMSA is issuing this Amended Warning Letter to correct errors in Well\nnumbers that were present in the table below.\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. § 191.25 Filing safety-related condition reports.\n(a) Each report of a safety-related condition under § 191.23(a)(1)\nthrough (9) must be filed (received by the Associate Administrator) in\nwriting within 5 working days (not including Saturday, Sunday, or\nFederal holidays) after the day a representative of an operator first\ndetermines that the condition exists, but not later than 10 working days\nafter the day a representative of an operator discovers the condition.\nSeparate conditions may be described in a single report if they are\n\n\n\nCPF 1-2022-018-WL\nclosely related. Reporting methods and report requirements are\ndescribed in paragraph (c) of this section.\nColumbia failed to file 14 safety related condition (SRC) reports within the reporting requirements\nof § 191.25(a). Specifically, Columbia failed to file reports within 5 working days after the day a\nrepresentative first determined that the conditions existed, but not later than 10 working days after\nthe day a representative of Columbia discovered the conditions.\nOn May 10, 2021, PHMSA received a letter from Columbia reporting the discovery of 14 SRCs\nin which underground natural gas storage wells were not isolated from the storage horizon within\n5 business days or reported to PHMSA within the required 10 days of discovery. The following\ntable is a list of SRCs identified and submitted by Columbia on May 10, 2021.\nWell\nName\n7152 Date of\nDiscovery\n11/30/2020 Date of\nDetermination\nDate Well out of\nservice\nNotification\ndate\n11/30/2020 1/11/2021 5/10/2021\n7220 1/31/2020 1/31/2020 4/19/2021 5/10/2021\n4337 6/8/2020 6/8/2020 4/1/2020 5/10/2021\n12430 1/31/2020 1/31/2020 7/15/2020 5/10/2021\n4275 5/1/2020 5/1/2020 7/24/2020 5/10/2021\n11176 6/8/2020 6/8/2020 4/1/2021 5/10/2021\n1194 9/2/2020 9/2/2020 4/8/2021 5/10/2021\n10001 6/13/2019 6/13/2019 2/8/2021 5/10/2021\n11418 5/1/2020 4/28/2021 11/13/2020 5/10/2021\n3762 9/2/2020 1/20/2021 1/26/2021 5/10/2021\n10374 10/20/2020 11/6/2020 6/4/2020 5/10/2021\n10729 1/31/2020 1/31/2020 4/16/2021 5/10/2021\n10817 5/1/2020 5/1/2020 2/6/2020 5/10/2021\n548 4/26/2019 1/11/2020 4/1/2020 5/10/2021\nTherefore, Columbia failed to report 14 safety related conditions in accordance with the\nreporting requirements of § 191.25.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related\nseries of violations. For violation occurring on or after January 11, 2021 and before May 3, 2021,\nthe maximum penalty may not exceed $222,504 per violation per day the violation persists, up to\na maximum of $2,225,034 for a related series of violations. For violation occurring on or after\nJuly 31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per\nviolation per day the violation persists, up to a maximum of $2,186,465 for a related series of\nviolations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the\nmaximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to\nexceed $2,132,679. For violation occurring on or after November 2, 2015 and before November\n12022018WL_Warning Letter (Amended)_03302022_(21-231686)_text Page 2 of 3\n\n\n\nCPF 1-2022-018-WL\n27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum\npenalty 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 1-2022-018-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\n12022018WL_Warning Letter (Amended)_03302022_(21-231686)_text Page 3 of 3\n\n12022018WL_Warning Letter_03152022_(21-231686)_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nMarch 15, 2022\nMr. Stanley Chapman\nExecutive Vice President & President US & Mexico Natural Gas\nColumbia Gas Transmission, LLC\n7000 Louisiana Street\nHouston, Texas 77002\nCPF 1-2022-018-WL\nDear Mr. Chapman:\nOn May 10, 2021, Columbia Gas Transmission, LLC (Columbia) submitted to PHMSA a letter\nrelated to Safety-Related Condition Reports. A representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter\n601 of 49 United States Code (U.S.C.) reviewed the submission and investigated these conditions.\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. § 191.25 Filing safety-related condition reports.\n(a) Each report of a safety-related condition under § 191.23(a)(1)\nthrough (9) must be filed (received by the Associate Administrator) in\nwriting within 5 working days (not including Saturday, Sunday, or\nFederal holidays) after the day a representative of an operator first\ndetermines that the condition exists, but not later than 10 working days\nafter the day a representative of an operator discovers the condition.\nSeparate conditions may be described in a single report if they are\nclosely related. Reporting methods and report requirements are\ndescribed in paragraph (c) of this section.\nColumbia failed to file 13 safety related condition (SRC) reports within the reporting requirements\n\n\n\nCPF 1-2022-018-WL\nof § 191.25(a). Specifically, Columbia failed to file reports within 5 working days after the day a\nrepresentative first determined that the conditions existed, but not later than 10 working days after\nthe day a representative of Columbia discovered the conditions.\nOn May 10, 2021, PHMSA received a letter from Columbia reporting the discovery of 13 SRCs\nin which underground natural gas storage wells were not isolated from the storage horizon within\n5 business days or reported to PHMSA within the required 10 days of discovery. The following\ntable is a list of SRCs identified and submitted by Columbia on May 10, 2021.\nWell\nName\nDate of\nDiscovery\nDate of\nDetermination\nDate Well out of\nservice\nNotification\ndate\n7152 11/30/2020 11/30/2020 1/11/2021 5/10/2021\n7220 1/31/2020 1/31/2020 4/19/2021 5/10/2021\n12430 1/31/2020 1/31/2020 7/15/2020 5/10/2021\n11176 6/8/2020 6/8/2020 4/1/2021 5/10/2021\n1194 9/2/2020 9/2/2020 4/8/2021 5/10/2021\n10001 6/13/2019 6/13/2019 2/8/2021 5/10/2021\n11418 5/1/2020 4/28/2021 11/13/2020 5/10/2021\n3762 9/2/2020 1/20/2021 1/26/2021 5/10/2021\n10374 10/20/2020 11/6/2020 6/4/2020 5/10/2021\n10729 1/31/2020 1/31/2020 4/16/2021 5/10/2021\n10817 5/1/2020 5/1/2020 2/6/2020 5/10/2021\n548 4/26/2019 1/11/2020 4/1/2020 5/10/2021\n9409 2/7/2020 2/7/2020 4/1/2020 5/10/2021\nTherefore, Columbia failed to report 13 safety related conditions in accordance with the\nreporting requirements of § 191.25.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related\nseries of violations. For violation occurring on or after January 11, 2021 and before May 3, 2021,\nthe maximum penalty may not exceed $222,504 per violation per day the violation persists, up to\na maximum of $2,225,034 for a related series of violations. For violation occurring on or after\nJuly 31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per\nviolation per day the violation persists, up to a maximum of $2,186,465 for a related series of\nviolations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the\nmaximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to\nexceed $2,132,679. For violation occurring on or after November 2, 2015 and before November\n27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum\npenalty 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\n12022018WL_Warning Letter_03152022_(21-231686)_text Page 2 of 3\n\n\n\nCPF 1-2022-018-WL\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 1-2022-018-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\n12022018WL_Warning Letter_03152022_(21-231686)_text Page 3 of 3","truncated":false,"body_characters":12311}