{"operation":"document","citation":"CPF 12022075WL","title":"COLUMBIA GAS TRANSMISSION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-11-03","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022075wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022075wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022075wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022075WL","body":"Warning Letter involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2022-11-03 and is reported as closed as of 2022-11-03. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022075WL_Warning Letter_11032022_(21-198991).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022075WL/12022075WL_Warning%20Letter_11032022_(21-198991).pdf\n\n12022075WL_Warning Letter_11032022_(21-198991)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022075WL/12022075WL_Warning%20Letter_11032022_(21-198991)_text.pdf\n\n12022075WL_Warning Letter_11032022_(21-198991)_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nNovember 3, 2022\nMr. Stanley Chapman III\nPresident US & Mexico Natural Gas\nColumbia Gas Transmission, LLC\n700 Louisiana Street\nHouston, Texas 77002\nCPF 1-2022-075-WL\nDear Mr. Chapman:\nFrom August 9, 2021 to May 16, 2022, representatives 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) PHMSA\ninspection system #1753, which included pipeline facilities inspected in Gragston, West Virginia\nand Paris, Kentucky.\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. § 192.605 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 Valve Numbering and Tagging Procedure, dated 07/01/19 (Valve Tag Procedure) for\ntagging valves at its Gragston and Paris mainline valve settings that may be necessary in an\nemergency, in accordance with § 192.605(a).\nColumbia’s Valve Tag Procedure identified that each designated emergency valve, among several\nother valve types, requires a tag. The procedure goes on to describe requirements for the design\nand installation of temporary and permanent tags.\nDuring the field inspections conducted during the weeks of August 9, 2021, and May 16, 2022,\nPHMSA observed that Columbia failed to adequately place or replace legible valve identification\nnumbers on at least (4) valves that could be used in an emergency at the Gragston MLV P-280\nvalve setting, and at least (1) valve at the Paris, Kentucky MLV 130 valve setting. For the Gragston\nvalve station, Columbia discussed that temporary valve tags were installed after the field\ninspection that correspond to the pipeline system mapping. Permanent valve tags would be\ninstalled immediately upon delivery. For the Paris valve station, Columbia discussed concerns\nabout providing an MLV ID tag as they are not the owner of the asset. However, Columbia is the\noperator of this asset, and the TC Energy sign was permanently attached to the fence surrounding\nthe valve site.\nTherefore, Columbia failed to follow its manual of written procedures for tagging valves, in\naccordance with § 192.605(a).\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 1-2022-075-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\n\n\n\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","truncated":false,"body_characters":6254}