{"operation":"document","citation":"CPF 12023032NOA","title":"COLUMBIA GAS TRANSMISSION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2023-05-04","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023032noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023032noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023032noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12023032NOA","body":"Notice of Amendment involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.605(b)(1). The case was opened on 2023-05-04 and is reported as closed as of 2023-11-09. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12023032NOA_Closure Letter_11092023_(21-213121).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023032NOA/12023032NOA_Closure%20Letter_11092023_(21-213121).pdf\n\n12023032NOA_Closure Letter_11092023_(21-213121)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023032NOA/12023032NOA_Closure%20Letter_11092023_(21-213121)_text.pdf\n\n12023032NOA_Notice of Amendment_05042023_(21-213121).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023032NOA/12023032NOA_Notice%20of%20Amendment_05042023_(21-213121).pdf\n\n12023032NOA_Notice of Amendment_05042023_(21-213121)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023032NOA/12023032NOA_Notice%20of%20Amendment_05042023_(21-213121)_text.pdf\n\n12023032NOA_Operator Response to Notice_06022023_(21-213121).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023032NOA/12023032NOA_Operator%20Response%20to%20Notice_06022023_(21-213121).pdf\n\n12023032NOA_Closure Letter_11092023_(21-213121)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nNovember 9, 2023\nMs. Tina Faraca\nExecutive Vice-President & President, U.S. Natural Gas Pipelines\nColumbia Gas Transmission, LLC\n700 Louisiana Street\nHouston, Texas 77002\nCPF 1-2023-032-NOA\nDear Ms. Faraca:\nFrom November 2, 2021, through July 22, 2022, a representative of 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 (TCO) procedures for compliance with\nnew rule titled Pipeline Safety: Safety of Gas Transmission Pipelines: MAOP Reconfirmation,\nExpansion of Assessment Requirements, and Other Related Amendments, in Houston, Texas. As\na result of the inspection, TCO was issued a Notice of Amendment on May 4, 2023, which\nproposed amendment of your procedures.\nTCO submitted its amended procedures on June 2, 2023. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n12023032NOA_Notice of Amendment_05042023_(21-213121)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: stanley chapman iii@tcenergy.com\nMay 4, 2023\nMr. Stanley Chapman III\nExecutive Vice President and President US & Mexico Natural Gas\nColumbia Gas Transmission, LLC\n700 Louisiana Street\nHouston, Texas 77002\nCPF 1-2023-032-NOA\nDear Mr. Chapman:\nFrom November 2, 2021, through July 22, 2022, a representative of 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 (TCO) procedures for compliance with\nnew rule titled Pipeline Safety: Safety of Gas Transmission Pipelines: MAOP Reconfirmation,\nExpansion of Assessment Requirements, and Other Related Amendments1\n,. in Houston, Texas.\nAs a result of the inspection, PHMSA has identified the apparent inadequacy found within TCO’s\nplans or procedures. The item inspected and the inadequacy is described below:\n1. 49 C.F.R. § 192.605 Procedural manual for operations, maintenance, and\nemergencies.\n(a) …\n(b) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following,\nif applicable, to provide safety during maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in\naccordance with each of the requirements of this subpart and Subpart\nM of this part.\nTCO’s written procedures for verifying material properties were inadequate. Specifically, TCO’s\n1 84 Fed. Reg. 52,180 (Oct. 1, 2019).\n\n\n\nmanual failed to include procedures presenting a process for verification of material properties and\nattributes when traceable, verifiable, and complete records are missing during MAOP\nreconfirmation efforts under § 192.607(c).\n2\nDuring the inspection, PHMSA reviewed TCO’s TEP-IN-MV-G Material Verification Procedure\n(US) (2020-Jul-24), TEP-IN-MAOP-G MAOP Verification Procedure (US) (2021-Sep-01),\nMaximum Allowable Operating Pressure Reconfirmation (US) (2020-Aug-07) and TEN-IN-\nMAOP-G MAOP Confirmation Standard (US) 2020-Aug-27 (Columbia Procedures). In instances\nwhere insufficient material properties records were noted, TCO procedures did not present a\nspecific process for attaining and/or establishing said records. Furthermore, details on how affected\ngas transmission pipeline segments would be flagged and/or scheduled for consideration\nopportunistically were lacking.\nTherefore, TCO’s written procedures were inadequate. TCO must amend its written procedures\nto comply with the requirements of § 192.605(b)(1) as it pertains to § 192.607(c).\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. § 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 U.S.C. § 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 30 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\n2 §192.607 Verification of Pipeline Material Properties and Attributes: Onshore steel transmission pipelines.\n…\n(c) Verification of material properties and attributes. If an operator does not have traceable, verifiable, and complete\nrecords required by paragraph (b) of this section, the operator must develop and implement procedures for\nconducting nondestructive or destructive tests, examinations, and assessments in order to verify the material\nproperties of aboveground line pipe and components, and of buried line pipe and components when excavations\noccur at the following opportunities: Anomaly direct examinations, in situ evaluations, repairs, remediations,\nmaintenance, and excavations that are associated with replacements or relocations of pipeline segments that are\nremoved from service. The procedures must also provide for the following:\n\n\n\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Columbia Gas Transmission, LLC maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director,\nEastern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 1-2023-032-NOA and, for each document you submit,\nplease provide a copy in electronic format whenever possible.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings","truncated":false,"body_characters":8519}