{"operation":"document","citation":"CPF 12022056WL","title":"COLUMBIA GAS TRANSMISSION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-06-16","effective_on":null,"summary":"CLOSED warning letter citing 192.705(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022056wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022056wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022056wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022056WL","body":"Warning Letter involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.705(b). The case was opened on 2022-06-16 and is reported as closed as of 2022-06-16. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022056WL_Warning Letter_06162022_(21-198993).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022056WL/12022056WL_Warning%20Letter_06162022_(21-198993).pdf\n\n12022056WL_Warning Letter_06162022_(21-198993)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022056WL/12022056WL_Warning%20Letter_06162022_(21-198993)_text.pdf\n\n12022056WL_Warning Letter_06162022_(21-198993)_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nJune 16, 2022\nMr. Francois Poirier\nPresident and Chief Executive Officer\nColumbia Gas Transmission, LLC\n700 Louisiana Street\nHouston, Texas 77002\nCPF 1-2022-056-WL\nDear Mr. Poirier:\nFrom May 17, 2021 to October 13, 2021 a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.)\nperformed an integrated inspection of Columbia Gas Transmission, LLC’s (Columbia) records and\nprocedures for Columbia’s facilities located in the: Strasburg Area, Virginia; Draniesville Area,\nVirginia; Lexington Area, Virginia; Petersburg District, Virginia; and Richmond to Louisa,\nVirginia.\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. § 192.705 Transmission lines: Patrolling.\n(a) …\n(b) The frequency of patrols is determined by the size of the line,\nthe operating pressures, the class location, terrain, weather, and other\nrelevant factors, but intervals between patrols may not be longer than\nprescribed in the following table:\nMaximum interval between patrols\nClass location of\nline\nAt highway and railroad\ncrossings\nAt all other places\n1,2 7 1/2 months; but at least twice\neach calendar year\n15 months; but at least once\neach calendar year\n\n\n\nCPF 1-2022-056-WL\n7 1/2 months; but at least\ntwice each calendar year\n4 1/2 months; but at least four\ntimes each calendar year\n3 4 1/2 months; but at least four\ntimes each calendar year\n4 4 1/2 months; but at least four\ntimes each calendar year\nColumbia failed to patrol the right-of-way of portions of its VB pipeline at the maximum intervals\nrequired by § 192.705(b) during 2018.\nDuring the inspection, PHMSA requested right-of-way patrolling records for Columbia’s VB\npipeline, which includes Class 3 locations identified as located in a no-fly zone. Columbia’s\nrecords demonstrated that the right-of-way for portions of the line at Class 3 highway and railroad\ncrossings was only patrolled 3 times in calendar year 2018. This failed to meet the frequency\nspecified in § 192.705(b) for Class 3 highway/railroad crossings of at least four times each\ncalendar year.\nTherefore, Columbia failed to perform patrols of the right-of-way of its VB pipeline at least as\nfrequently as required by § 192.705(b).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$239,142 per violation per day the violation persists, up to a maximum of $2,391,142 for a related\nseries of violations. For violation occurring on or after May 3, 2021 and before March 21, 2022,\nthe maximum penalty may not exceed $225,134 per violation per day the violation persists, up to\na maximum of $2,251,334 for a related series of violations. For violation occurring on or after\nJanuary 11, 2021 and before May 3, 2021, the maximum penalty may not exceed $222,504 per\nviolation per day the violation persists, up to a maximum of $2,225,034 for a related series of\nviolations. For violation occurring on or after July 31, 2019 and before January 11, 2021, the\nmaximum penalty may not exceed $218,647 per violation per day the violation persists, up to a\nmaximum 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 1-2022-056-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).\n12022056WL_Warning Letter_06162022_(21-198993)_text Page 2 of 3\n\n\n\nCPF 1-2022-056-WL\nSincerely,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n12022056WL_Warning Letter_06162022_(21-198993)_text Page 3 of 3","truncated":false,"body_characters":5768}