{"operation":"document","citation":"CPF 12022064WL","title":"COLUMBIA GAS TRANSMISSION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-08-03","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a), 192.709(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022064wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022064wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022064wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022064WL","body":"Warning Letter involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.605(a),  192.709(c). The case was opened on 2022-08-03 and is reported as closed as of 2022-08-03. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022064WL_Warning Letter_08032022_(20-171881).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022064WL/12022064WL_Warning%20Letter_08032022_(20-171881).pdf\n\n12022064WL_Warning Letter_08032022_(20-171881)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022064WL/12022064WL_Warning%20Letter_08032022_(20-171881)_text.pdf\n\n12022064WL_Warning Letter_08032022_(20-171881)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: stanley chapman iii@tcenergy.com\nAugust 3, 2022\nMr. Stanley Chapman III\nExecutive Vice-President and President, U.S. and Mexico Natural Gas Pipelines\nColumbia Gas Transmission, LLC\n700 Louisiana Street\nHouston, Texas 77002\nCPF 1-2022-064-WL\nDear Mr. Chapman:\nFrom October 25, 2021 to March 1, 2022, representatives from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) inspected Columbia Gas Transmission, LLC’s (Columbia) pipeline facilities located in:\nBedford, Fayette, Greene and Summerset counties in Pennsylvania; Mineral, Monongalia and\nPreston Counties in West Virginia; and Allegany, Garret, Montgomery, Howard, Baltimore,\nHartford and Cecil Counties in Maryland.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each\npipeline, a manual of written procedures for conducting operations and\nmaintenance activities and for emergency response. For transmission\nlines, the manual must also include procedures for handling abnormal\noperations. This manual must be reviewed and updated by the operator\nat intervals not exceeding 15 months, but at least once each calendar\nyear. This manual must be prepared before operations of a pipeline\nsystem commence. Appropriate parts of the manual must be kept at\nlocations where operations and maintenance activities are conducted.\n\n\n\nColumbia failed to follow its manual of written procedures. Specifically, Columbia failed to\nfollow its Control and Monitoring Systems, Tests, and Inspections at Gas Facilities, dated\n11/01/18 (C&M Procedure), Section 4 ‘Work Instruction’, regarding documenting over pressure\nprotection device inspections as required by § 192.605(a).\nColumbia’s C&M Procedure contained procedures for inspecting both static pressure transmitters\n(Transmitters) and signal to pressure I/P transducers (Transducers). Section 4.1 of this procedure\nincluded steps for verifying operating point ‘As Found’ pressure and documenting this reading on\nthe inspection records for Transmitters. Section 4.6 included steps for verifying 3-point up range\nand operating point ‘As Found’ and ‘As Left’ measurements and documenting these readings on\nthe inspection records for Transducers.\nDuring the inspection, PHMSA requested records for the testing and inspection of overpressure\nprotection devices located at Bruceton Mills Compressor Station and Salisbury Compressor\nStation for calendar years of 2017-2020. Columbia provided Bruceton Mills CS records\n“10994398 Transducer, Pressure -- TP364-1” and “10994416 Transducer, Pressure -- TP364-2”,\nand Salisbury CS records “10994536 Transducer, Pressure -- TP364-1P” and “10994557\nTransducer, Pressure -- TP364-2P”.\nBased on PHMSA’s review of those records, Columbia failed to follow its C&M Procedure\nregarding documenting the operating point ‘As Found’ and other required measurements of these\ndevices at the time of the inspections. Records for (4) pressure transducers identified as Bruceton\nMills CS device tags TP364-1 and TP364-2, and Salisbury CS device tags TP364-1P and TP364-\n2P, were reviewed for calendar years 2017 - 2020 and were found to lack this information. There\nwere no data readings in the 2017 and 2018 inspection years. Further, work order fields for\nsubsequent records directed the technician to input measurement point data pursuant to Sections\n4.1.1.10 and 4.1.1.11 of the C&M Procedure which applies to Transmitters, despite these devices\nbeing documented as Transducers. The 2019 and 2020 records documented “0 PSIG” as the value\nfor the operating point ‘As Found’ reading, which may not be valid operating point(s) on a\npressurized system. It is unclear from these records as to the type of devices being inspected\n(Transmitters or Transducers), however, they were presented to the inspector to be over pressure\nprotection pressure Transducer devices. None of the records provided documented a 3-point up\nrange or ‘As Left’ values pursuant to Section 4.6 of the procedures. Overall, the records were\nunclear as to what inspection procedure was followed, and unclear as to what the operating point\n‘As Found’ pressure being recorded was.\nTherefore, Columbia failed to follow the applicable portions of its C&M Procedure regarding\ndocumenting its inspections of these devices, as required by § 192.605(a).\n2. § 192.709 Transmission lines: Record keeping.\nEach operator shall maintain the following records\nfor transmission lines for the periods specified:\n(a) …\n(c) A record of each patrol, survey, inspection, and test required by\nsubparts L and M of this part must be retained for at least 5 years or\n\n\n\nuntil the next patrol, survey, inspection, or test is completed, whichever\nis longer.\nColumbia failed to maintain records demonstrating leakage surveys were performed using leak\ndetector equipment on its MB transmission line (Potomac River to Rockville, MD) during 2019\npursuant to § 192.706(a).\nSection 192.706(a) states:\nLeakage surveys of a transmission line must be conducted at intervals not\nexceeding 15 months, but at least once each calendar year. However, in the case of\na transmission line which transports gas in conformity with §192.625 without an\nodor or odorant, leakage surveys using leak detector equipment must be\nconducted—\n(a) In Class 3 locations, at intervals not exceeding 7 ½ months, but at least twice\neach calendar year; and\nDuring the inspection, PHMSA requested Columbia’s 2018 to 2020 records related to\ninstrumented leakage surveys for the MB transmission line in a no-fly zone located between the\nPotomac River and Rockville, MD. This portion of the MB transmission line is a class 3 location\nwithout odorant and is in a designated no fly zone that stretches for approximately 9 miles.\nColumbia failed to provide records demonstrating that instrumented leak surveys were performed\nfor the MB pipeline during calendar year 2019.\nTherefore, Columbia failed to maintain 2019 records of leakage surveys utilizing leak detector\nequipment pursuant to § 192.706(a) for portions of its MB transmission line, as required by\n§ 192.709(c).\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 items identified in this letter. Failure to do so will result in\nColumbia Gas Transmission, LLC being subject to additional enforcement action.\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2022-064-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\nCc: Daniel Cerkoney <dan_cerkoney@tcenergy.com>\nAmy Willis <amy_willis@tcenergy.com>","truncated":false,"body_characters":9694}