COLUMBIA GAS TRANSMISSION, LLC — Warning Letter

12022056WL_Warning Letter_06162022_(21-198993)_text.pdf, page 1Official PDFWARNING 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#

12022056WL_Warning Letter_06162022_(21-198993)_text.pdf, page 2CPF 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#

12022056WL_Warning Letter_06162022_(21-198993)_text.pdf, page 3CPF 1-2022-056-WL Sincerely, Robert Burrough Director, Eastern Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration 12022056WL_Warning Letter_06162022_(21-198993)_text Page 3 of 3#