# COLUMBIA GAS TRANSMISSION, LLC — Warning Letter

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

Official case documents:

12022056WL_Warning Letter_06162022_(21-198993).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022056WL/12022056WL_Warning%20Letter_06162022_(21-198993).pdf

12022056WL_Warning Letter_06162022_(21-198993)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022056WL/12022056WL_Warning%20Letter_06162022_(21-198993)_text.pdf

12022056WL_Warning Letter_06162022_(21-198993)_text.pdf

WARNING LETTER
OVERNIGHT EXPRESS DELIVERY
June 16, 2022
Mr. Francois Poirier
President and Chief Executive Officer
Columbia Gas Transmission, LLC
700 Louisiana Street
Houston, Texas 77002
CPF 1-2022-056-WL
Dear Mr. Poirier:
From May 17, 2021 to October 13, 2021 a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.)
performed an integrated inspection of Columbia Gas Transmission, LLC’s (Columbia) records and
procedures for Columbia’s facilities located in the: Strasburg Area, Virginia; Draniesville Area,
Virginia; Lexington Area, Virginia; Petersburg District, Virginia; and Richmond to Louisa,
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. § 192.705 Transmission lines: Patrolling.
(a) …
(b) The frequency of patrols is determined by the size of the line,
the operating pressures, the class location, terrain, weather, and other
relevant factors, but intervals between patrols may not be longer than
prescribed in the following table:
Maximum interval between patrols
Class location of
line
At highway and railroad
crossings
At all other places
1,2 7 1/2 months; but at least twice
each calendar year
15 months; but at least once
each calendar year



CPF 1-2022-056-WL
7 1/2 months; but at least
twice each calendar year
4 1/2 months; but at least four
times each calendar year
3 4 1/2 months; but at least four
times each calendar year
4 4 1/2 months; but at least four
times each calendar year
Columbia failed to patrol the right-of-way of portions of its VB pipeline at the maximum intervals
required by § 192.705(b) during 2018.
During the inspection, PHMSA requested right-of-way patrolling records for Columbia’s VB
pipeline, which includes Class 3 locations identified as located in a no-fly zone. Columbia’s
records demonstrated that the right-of-way for portions of the line at Class 3 highway and railroad
crossings was only patrolled 3 times in calendar year 2018. This failed to meet the frequency
specified in § 192.705(b) for Class 3 highway/railroad crossings of at least four times each
calendar year.
Therefore, Columbia failed to perform patrols of the right-of-way of its VB pipeline at least as
frequently as required by § 192.705(b).
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$239,142 per violation per day the violation persists, up to a maximum of $2,391,142 for a related
series of violations. For violation occurring on or after May 3, 2021 and before March 21, 2022,
the maximum penalty may not exceed $225,134 per violation per day the violation persists, up to
a maximum of $2,251,334 for a related series of violations. For violation occurring on or after
January 11, 2021 and before May 3, 2021, the maximum penalty may not 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 1-2022-056-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).
12022056WL_Warning Letter_06162022_(21-198993)_text Page 2 of 3



CPF 1-2022-056-WL
Sincerely,
Robert Burrough
Director, Eastern Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
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