{"operation":"document","citation":"CPF 12023051CAO","title":"COLUMBIA GAS TRANSMISSION, LLC — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2023-07-28","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023051cao.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023051cao.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12023051cao","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12023051CAO","body":"Corrective Action Order involving COLUMBIA GAS TRANSMISSION, LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2023-07-28 and is reported as closed as of 2025-04-25. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12023051CAO_Closure Letter_04252025_(23-282237).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023051CAO/12023051CAO_Closure%20Letter_04252025_(23-282237).pdf\n\n12023051CAO_Closure Letter_04252025_(23-282237)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023051CAO/12023051CAO_Closure%20Letter_04252025_(23-282237)_text.pdf\n\n12023051CAO_Corrective Action Order (Amended)_08152023_(23-282237).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023051CAO/12023051CAO_Corrective%20Action%20Order%20(Amended)_08152023_(23-282237).pdf\n\n12023051CAO_Corrective Action Order (Amended)_08152023_(23-282237)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023051CAO/12023051CAO_Corrective%20Action%20Order%20(Amended)_08152023_(23-282237)_text.pdf\n\n12023051CAO_Corrective Action Order_07282023_(23-282237).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023051CAO/12023051CAO_Corrective%20Action%20Order_07282023_(23-282237).pdf\n\n12023051CAO_Corrective Action Order_07282023_(23-282237)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023051CAO/12023051CAO_Corrective%20Action%20Order_07282023_(23-282237)_text.pdf\n\n12023051CAO_Corrective Action Order (Amended)_08152023_(23-282237)_text.pdf\n\nAugust 15, 2023\nVIA ELECTRONIC MAIL TO: stanley chapman III@tcenergy.com\nMr. Stanley Chapman III\nExecutive Vice President and President US & Mexico Natural Gas\nTC Energy Corporation\n700 Louisiana Street\nHouston, Texas 77002\nCPF No. 1-2023-051-CAO\nDear Mr. Chapman:\nEnclosed please find the Amended Corrective Action Order (ACAO or Order) issued by the\nPipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS), in the above-referenced case. It requires Columbia Gas Transmission, LLC (CGT or\nRespondent), a subsidiary of TC Energy Corporation, to take certain corrective actions with\nrespect to a rupture that occurred on the 26-inch Line VB pipeline located in Strasburg, Virginia.\nService of the A CAO by electronic transmission is deemed complete upon transmission\nand acknowledgment of receipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms\nand conditions of this Order are effective upon completion of service.\nSincerely,\nFor Alan Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure: CAO\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS\nMr. Robert Burrough, Director, Eastern Region, OPS\nMr. Dan Cerkoney, Senior Manager, Regulatory Compliance, TC Energy\nCorporation, dan_cerkoney@tcenergy.com\nCONFIRMATION OF RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATIO\nNOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nColumbia Gas Transmission, LLC, ) CPF No. 1-2023-051-CAO\na subsidiary of TC Energy Corporation, )\n)\n)\n)\nRespondent. )\n____________________________________ )\nAMENDED CORRECTIVE ACTION ORDER\nPurpose and Background\nThis Amended Corrective Action Order (ACAO or Order) is being issued under the authority of\n49 U.S.C. § 60112 and 49 C.F.R. § 190.233 to require Columbia Gas Transmission, LLC\n(CGT or Respondent) to take the necessary corrective actions to protect the public, property,\nand the environment from potential hazards associated with the July 25, 2023, rupture of its\n26-inch natural gas pipeline located in Strasburg, Virginia (Line VB).\nAt approximately 8:41 a.m. Eastern Daylight Time (EDT)1 on July 25, 2023, CGT’s Line VB\nruptured (the Incident). The Incident occurred near Interstate Highway 81 (I-81) in Strasburg,\nVA, and the resulting fire of the released gas caused I-81 to close in both directions for about\ntwo hours. The Incident resulted in the ejection of several pieces of 26-inch pipe, which landed\non the pipeline right-of-way. There were no reported injuries, fatalities, or evacuations.\nPursuant to 49 U.S.C. § 60117, PHMSA, Office of Pipeline Safety (OPS) initiated an investigation\nof the Incident and, on July 28, 2023, issued a Corrective Action Order (CAO). The ACAO\nincludes a minor revision to one preliminary finding and amends one (1) corrective action\nprescribed in the CAO.2 The preliminary findings of the agencies’ ongoing investigation are as\nfollows:\nAmended Preliminary Findings\n• At approximately 8:42 a.m. on July 25, 2023, CGT’s control room personnel observed a\n1 All times listed in this Order are EDT.\n2 With the exception of the amendment to the pressure restrictions in Required Corrective Measure 2 below, all other\nrelevant deadlines and required actions under the “Required Corrective Measures” section remain the same as\nordered in the initial July 28, 2023, CAO (i.e., the specified deadlines will still be calculated from the CAO’s July 28\nissuance date).\n\n\n\nsudden pressure drop on their SCADA screens indicating a possible failure of Line VB.\nAt 8:45 a.m. CGT personnel at the downstream, nearby Strasburg Compressor Station\n(Strasburg CS) observed the fire and smoke resulting from the failure. At 8:50 a.m.\nCGT’s control room initiated automated valve closure of Valve 3080 at the Dysart Gate\nMainline Valve site upstream of the failure location. At 9:06 a.m. CGT operational\npersonnel arrived at the scene of the failure.\n• CGT initially reported the Incident to the National Response Center (NRC) at 9:42 a.m.\non July 25, 2023 (NRC Report No. 1374102), indicating there was a fire and release of an\nunknown volume of natural gas greater than 3,000 MCF. In its 48-hour update to the\nNRC CGT identified the volume of gas released to be 70,478 MCF.\n• The natural gas was released to the atmosphere with no injuries, fatalities or evacuations\nassociated with this incident. CGT discovered ejected pipe from the VB pipeline in three\nsegments within the right of way totaling approximately 250 feet of pipe.\n• Prior to the rupture, Line VB was operating at 777 pounds per square inch gauge (psig).\nThe maximum allowable operating pressure (MAOP) of Line VB is 800 psig. Line VB\nwas out of service for a class location replacement from May 30, 2023 until July 24, 2023\nwhen the line was returned to service at approximately 7:43 p.m., about 13 hours prior\nto the Incident.\n• Line VB was shut in at approximately 9:17 a.m., when upstream Valve 3130 at the Moo\nManor Valve Setting and downstream Valve VB-013 at the Strasburg CS were manually\nclosed.\n• The failed portion of the pipeline was constructed in 1950 with a 26-inch nominal\ndiameter, 0.281-inch wall thickness, X-52 grade pipe that was manufactured by A.O.\nSmith. The pipe has an electric flash welded (EFW) longitudinal seam and has a coal\ntar coating. Alignment sheets reviewed for Line VB identified a significant portion of\nthe line is comprised of pipe of this vintage and manufacturer. Line VB originates at the\nDysart Gate Mainline valve site and terminates at the Virginia/Maryland border where it\nmoves into CGT’s Maryland system.\n• Pipe manufactured by A.O. Smith using flash welding has had in-service incidents\nreported for pipe manufactured in nearly every year from 1928 – 1971.\n• CGT also operates Lines VB-5, a 36-inch, double submerged arc welded (DSAW)\nnatural gas pipeline build in 1968 with a 1,000 psig MAOP, and Line VB-Loop, a 26-\ninch, submerged arc welded (SAW) natural gas pipeline built in 1958 with an 800 psig\nMAOP. Both of these lines are in the same right-of-way as Line VB. Line VB-5 is\napproximately 25 feet from Line VB at the failure location and is currently isolated from\nValve 4115 at the Dysart Gate Mainline Valve site to Valve 3643 at the Strasburg CS,\nand is holding pressure at approximately 476 psig. Line VB-Loop, located further from\nthe VB pipeline within the right-of-way, has remained in normal operation.\n\n\n\n• The Incident occurred in a Class 1 location, non-high consequence area. The isolated\nsegment of line VB from Valve 3130 at the Moo Manor valve to Valve VB-013 at the\nStrasburg CS contains both Class 3 and High Consequence Areas (HCA).\n• CGT completed a project in 2022 to make Line VB able to accept and utilize an in-\nline inspection (ILI) tool. The first in-line inspection integrity assessment was\nplanned for November 2023.\n• The cause of the failure is currently unknown, but based on initial observations of the\nfailed pipe, environmental cracking is the suspected cause of the Incident.\nOn August 3, 2023, CGT submitted a request for amendments to the CAO for PHMSA’s\nconsideration. The requested changes included revisions to Corrective Action 2 to clarify\naspects of the pressure restrictions imposed on the Affected Pipelines defined below.\nPursuant to this request, PHMSA is amending the CAO to specify the existing operating\nrestrictions that have been imposed on each of the three (3) pipelines within the VB system.\nThe amendment made below in Corrective Measure 2 is, in part, to reflect clarification\nregarding the pressure restrictions imposed in the July 28 CAO. The amendment is also to\nspecify the appropriate present operating pressure restrictions for pipelines VB-5 and VB\nLoop, as based on PHMSA's continuing investigation and additional pipeline integrity\ninformation provided by CGT since the incident on adjacent Line VB occurred.\nSection 60112 authorizes PHMSA to determine that a pipeline facility is or would be\nhazardous to life, property, or the environment and if there is a likelihood of serious harm,\nto issue an order without prior notice to the operator of the facility to take necessary\ncorrective action, including suspended or restricted use of the facility, physical inspection,\ntesting, repair, replacement, or other appropriate action. An order issued without notice\nmust provide an opportunity for a hearing as soon as practicable after the order is issued.\nIn deciding whether to issue an order, PHMSA must consider the following, if relevant: (1)\nthe characteristics of the pipe and other equipment used in the pipeline facility, including the\nage, manufacture, physical properties, and method of manufacturing, constructing, or\nassembling the equipment; (2) the nature of the material the pipeline facility transports, the\ncorrosive and deteriorative qualities of the material, the sequence in which the material are\ntransported, and the pressure required for transporting the material; (3) the aspects of the area\nin which the pipeline facility is located, including climatic and geologic conditions and soil\ncharacteristics; (4) the proximity of the area in which the natural gas pipeline facility is\nlocated to environmentally sensitive areas; (5) the population density and population and\ngrowth patterns of the area in which the pipeline facility is located; (6) any recommendation\nof the National Transportation Safety Board made under another law; and (7) other factors\nPHMSA may considers appropriate.\n\n\n\nAfter evaluating the foregoing preliminary findings of fact, and having considered the age of\nthe pipelines, the known issues with the manufacturing method of the failed pipeline\nsegment, the material properties of the pipelines, the significant length of the pipeline of this\nsame vintage and manufacturer, the hazardous nature of the product transported, the\nproximity of the pipelines to Class 3 and HCA populated areas, the pressure required for\ntransporting the material, the uncertainty as to the cause of the failure, the uncertainty of\npotential impacts of the Incident to the other two pipelines in the ROW and the similar pipe\ncharacteristics and integrity threats, the lack of any prior data from an in-line inspection on\nthe failed pipeline segment and other portions of the isolated segment of Line VB, and the\npossibility that the same condition(s) that may have caused the failure remain present in the\npipelines, I find that continued operation of the pipeline without corrective measures is or\nwould be hazardous to life, property, or the environment, and that failure to issue this Order\nwithout notice would result in the likelihood of serious harm.\nAccordingly, under 49 C.F.R. § 190.233(b), this Amended Order mandating immediate\ncorrective action is issued without prior notice and opportunity for a hearing. The terms and\nconditions of this Order are effective upon receipt.\nWithin 10 days of receipt of this Amended Order, Respondent may request a hearing, to be\nheld as soon as practicable, by notifying the Associate Administrator for Pipeline Safety in\nwriting, with a copy to the Director, Eastern Region, PHMSA (Director). If a hearing is\nrequested, it will be held in accordance with 49 C.F.R. § 190.211.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA\nmay identify other corrective measures that need to be taken. Respondent will be notified of\nany additional measures required and, if appropriate, PHMSA will consider amending this\nOrder. To the extent consistent with safety, Respondent will be afforded notice and an\nopportunity for a hearing prior to the imposition of any additional corrective measures.\nRequired Corrective Actions\nDefinitions:\nAffected Pipelines – The “Affected Pipelines” means the entire length of Line VB from\nthe Dysart Gate Mainline Valve setting to its termination at the Virginia/Maryland border,\nand Lines VB-5 and VB-Loop between the Dysart Valve setting and the Strasburg CS.\nIsolated Segment – The “Isolated Segment” means the shut-in segment of CGT’s Line\nVB from Valve 3130 at the Moo Manor valve setting to Valve VB-013 at the Strasburg\nCS.\nPursuant to 49 U.S.C. § 60112, I hereby order CGT to immediately take the following\ncorrective actions:\n\n\n\n1. 2. 3. Shutdown of the Isolated Segment. The Isolated Segment must remain shut in and\nmay not be operated until authorized to be restarted by the Director in accordance\nwith the terms of this Order.\nOperating Pressure Restriction. CGT must reduce and maintain pressure reduction in\nthe actual operating pressure along the Affected Pipelines, such that upon restart the\noperating pressure along this portion of Line VB will not exceed eighty percent (80%)\nof the actual operating pressure in effect at the failure location immediately prior to\nthe failure on July 25, 2023. Line VB-5 will not exceed eighty percent (80%) of the\nactual operating pressure recorded in the previous 60 days prior to the failure on July\n25, 2023. Line VB Loop will not exceed the actual operating pressure in effect at the\ntime of failure on July 25, 2023. As such the reduced operating pressure for the\nAffected Pipelines are as follows: Line VB: 621 psig, Line VB Loop: 769 psig and\nLine VB-5: 774 psig.\na. b. c. d. e. This pressure restriction is to remain in effect until written approval to increase\nthe pressure or return the pipeline to its pre-failure operating pressure is\nobtained from the Director. This written approval may be obtained on an\nindividual pipeline basis within the Affected Pipelines.\nWithin 15 days of receipt of the CAO, CGT must provide the Director the\nactual operating pressures of each compressor station and each main line\npressure regulating station on the Affected Pipelines at the time of failure and\nthe reduced pressure restriction set-points at these same locations.\nThis pressure restriction requires any relevant remote or local alarm limits,\nsoftware programming set-points or control points, and mechanical over-\npressure devices to be adjusted accordingly.\nWhen determining the pressure restriction set-points, CGT must take into\naccount any in-line inspection (ILI) features or anomalies present in the\nAffected Pipelines to provide for continued safe operation while further\ncorrective actions are completed.\nCGT must review the pressure restriction monthly by analyzing the operating\npressure data, taking into account any ILI features or anomalies present in the\nAffected Pipelines. CGT must immediately reduce the operating pressure further\nto maintain the safe operations of the Affected Pipelines, if warranted by the\nmonthly review. Further, CGT must submit the results of the monthly review to\nthe Director including, at a minimum, the current discharge set-points (including\nany additional pressure reductions), and any pressure exceedance at discharge\nset-points. Submittals may be made quarterly, in accordance with Item 15\nbelow.\nRestart Plan. Prior to resuming operation of the Isolated Segment, develop and submit\na written Restart Plan to the Director for prior approval.\na. The Director may approve the Restart Plan incrementally without approving the\nentire plan, but the Isolated Segment cannot resume operation until the Restart\n\n\n\nb. c. d. Plan is approved in its entirety.\nOnce approved by the Director, the Restart Plan will be incorporated\nby reference into this Order.\nThe Restart Plan must provide for adequate patrolling of the Isolated Segment\nduring the restart process and must include incremental pressure increases\nduring start up, with each increment to be held for at least 2 hours.\nThe Restart Plan must include sufficient surveillance of the pipeline during\neach pressure increment to ensure that no leaks are present when operation of\nthe line resumes.\ne. The Restart Plan must specify a day-light restart and include\nadvance communications with local emergency response officials\nand adjacent landowners.\nf. The Restart Plan must provide for a review of the Isolated Segment for\nconditions similar to those of the failure including a review of construction,\noperating and maintenance (O&M) and integrity management records such as\nILI results, hydrostatic tests, root cause failure analysis of prior failures, aerial\nand ground patrols, corrosion, cathodic protection, excavations and pipe\nreplacements. CGT must address any findings that require remedial measures to\nbe implemented prior to restart.\ng. The Restart Plan must also include documentation of the completion of all\nmandated actions, and a management of change plan to ensure that all\nprocedural modifications are incorporated into CGT’s O&M procedures\nmanual.\n4. Return to Service. After the Director approves the Restart Plan, CGT may\nreturn the Isolated Segment to service according to the terms of the Restart Plan,\nbut the operating pressure must not exceed the limit in accordance with Item 2\nabove.\n5. Removal of Pressure Restriction.\na. The Director may allow the removal or modification of the pressure restriction\nupon a written request from CGT demonstrating that restoring the pipeline to\nits pre-failure operating pressure is justified based on a reliable engineering\nanalysis showing that the pressure increase is safe considering all known\ndefects, anomalies, and operating parameters of the pipeline.\nb. The Director may allow the temporary removal or modification of the pressure\nrestrictions upon a written request from CGT demonstrating that temporary\nmitigative and preventive measures are implemented prior to and during the\ntemporary removal or modification of the pressure restriction. The Director's\ndetermination will be based on available information, including the failure\ncause and provision of evidence that preventative and mitigative actions taken\nby the operator provide for the safe operation of the Affected Pipelines during\nthe temporary removal or modification of the pressure restriction. Appeals of\n\n\n\n6. 7. 8. 9. determinations of the Director in this regard will be decided by the Associate\nAdministrator for Pipeline Safety.\nInstrumented Leakage Survey. Within 30 days of receipt of the CAO, CGT must\nperform an aerial or ground instrumented leakage survey of the Affected Pipelines.\nCGT must investigate all leak indications and remedy all leaks discovered. CGT\nmust submit documentation of this survey to the Director within 45 days of receipt\nof the CAO.\nRecords Verification. CGT must verify the records for the Affected Pipelines that\nwere used to establish the MAOP in accordance with § 192.619, including any\nadjustments needed for the current class locations per §§ 192.609 and 192.611.\nCGT must submit documentation of this this record verification to the Director\nwithin 45 days of receipt of the CAO.\nMechanical and Metallurgical Testing. Within 45 days of receipt of the CAO, CGT\nmust complete mechanical and metallurgical testing and failure analysis of the\nfailed pipe, including an analysis of soil samples and any foreign materials.\nMechanical and metallurgical testing must be conducted by an independent third-\nparty acceptable to the Director and must document the decision-making process\nand all factors contributing to the failure. CGT must complete the testing and\nanalysis as follows:\na. Document the chain-of-custody when handling and transporting the failed\npipe section and other evidence from the failure site.\nb. Within 10 days of receipt of the CAO, develop and submit the testing\nprotocol and the proposed testing laboratory to the Director for prior\napproval.\nc. Prior to beginning the mechanical and metallurgical testing, provide the Director\nwith the scheduled date, time, and location of the testing to allow for an OPS\nrepresentative to witness the testing.\nd. Ensure the testing laboratory distributes all reports whether draft or final in\ntheir entirety to the Director at the same time they are made available to\nCGT.\nRoot Cause Failure Analysis. Within 90 days following receipt of the CAO,\ncomplete a root cause failure analysis (RCFA) and submit a final report of this\nRCFA to the Director. The RCFA must be supplemented or facilitated by an\nindependent third-party acceptable to the Director and must document the decision-\nmaking process and all factors contributing to the failure. The final report must\ninclude findings and any lessons learned and whether the findings and lessons\nlearned are applicable to other locations within CGT’s pipeline system.\n10. Remedial Work Plan (RWP).\na. Within 90 days following receipt of the CAO, CGT must submit a\nremedial work plan (RWP) to the Director for approval.\n\n\n\nb. The Director may approve the RWP incrementally without approving the entire\nc. d. e. RWP.\nOnce approved by the Director, the RWP will be incorporated by\nreference into this Order.\nThe RWP must specify the tests, inspections, assessments, evaluations, and\nremedial measures CGT will use to verify the integrity of the Affected\nPipelines. It must address all known or suspected factors and causes of the\nJuly 25, 2023 failure. CGT must consider the risks and consequences of\nanother failure to develop a prioritized schedule for RWP-related work along\nthe Affected Pipelines.\nThe RWP must include a procedure or process to:\ni. Identify pipe in the Affected Pipelines with characteristics similar to the\ncontributing factors identified for the July 25, 2023 failure, including the\nage and manufacture of the entire length of the Affected Pipelines.\nii. Gather all data necessary to review the failure history (in service and pressure\ntest failures) of the Affected Pipelines and to prepare a written report\ncontaining all the available information such as the locations, dates, and\ncauses of leaks and failures.\niii. Integrate the results of the metallurgical testing, root cause failure analysis,\nand other corrective actions required by this Order with all relevant pre-\nexisting operational and assessment data for the Affected Pipelines. Pre-\nexisting operational data includes, but is not limited to, design, construction,\noperations, maintenance, testing, repairs, prior metallurgical analyses, and\nany third-party consultation information. Pre-existing assessment data\nincludes, but is not limited to, ILI tool runs, hydrostatic pressure testing,\ndirect assessments, close interval surveys, and DCVG/ACVG surveys.\niv. Determine if conditions similar to those contributing to the failure on July 25,\n2023 are likely to exist elsewhere on the Affected Pipelines.\nv. Conduct additional field tests, inspections, assessments, and evaluations to\ndetermine whether, and to what extent, the conditions associated with the\nfailure on July 25, 2023, and other failures from the failure history (see\n(e)(ii) above) or any other integrity threats are present elsewhere on the\nAffected Pipelines. At a minimum, this process must include hydrostatic\npressure testing of the Isolated Segment, must consider all failure causes\nand must specify the use of one or more of the following:\n1) ILI tools that are technically appropriate for assessing the pipeline system\nbased on the cause of failure on July 25, 2023, and that can reliably detect\nand identify anomalies,\n2) Close-interval surveys,\n3) Cathodic protection surveys, to include interference surveys in\ncoordination with other utilities (e.g. underground utilities, overhead\npower lines, etc.) in the area,\n\n\n\nh. 11. 4) Coating surveys,\n5) Stress corrosion cracking surveys,\n6) Selective seam corrosion surveys; and\n7) Other tests, inspections, assessments, and evaluations appropriate for\nthe failure causes.\nf. g. Note: CGT may use the results of previous tests, inspections, assessments,\nand evaluations if approved by the Director, provided the results of the\ntests, inspections, assessments, and evaluations are analyzed with regard to\nthe factors known or suspected to have caused the July 25, 2023, failure.\nvi. Describe the inspection and repair criteria CGT will use to prioritize,\nexcavate, evaluate, and repair anomalies, imperfections, and other identified\nintegrity threats. Include a description of how any defects will be graded and\na schedule for repairs or replacement.\nvii. Based on the known history and condition of the Affected Pipelines, describe\nthe methods CGT will use to repair, replace, or take other corrective\nmeasures to remediate the conditions associated with the pipeline failure on\nJuly 25, 2023 and to address other known integrity threats along the Affected\nPipelines. The repair, replacement, or other corrective measures must meet\nthe criteria specified in (e)(vi) above.\nviii. Implement continuing long-term periodic testing and integrity verification\nmeasures to ensure the ongoing safe operation of the Affected Pipelines\nconsidering the results of the analyses, inspections, evaluations, and\ncorrective measures undertaken pursuant to the Order.\nInclude a proposed schedule for completion of the RWP.\nCGT must revise the RWP as necessary to incorporate new information obtained during\nthe failure investigation and remedial activities, to incorporate the results of actions\nundertaken pursuant to this Order, and to incorporate modifications required by the\nDirector.\ni. Submit any plan revisions to the Director for prior approval.\nii. The Director may approve plan revisions incrementally.\niii. All revisions to the RWP after it has been approved and incorporated by\nreference into this Order will be fully described and documented in the\nCAO Documentation Report.\nImplement the RWP as it is approved by the Director, including any revisions to\nthe plan.\nCAO Documentation Report (CDR). CGT must create and revise, as necessary, a\nCAO Documentation Report (CDR). When CGT has concluded all the items in this\nOrder it will submit the final CDR in its entirety to the Director. This will allow the\nDirector to complete a thorough review of all actions taken by CGT with regards to\nthis Order prior to approving the closure of this Order. The intent is for the CDR to\nsummarize all activities and documentation associated with this Order in one\n\n\n\ndocument.\na. b. The Director may approve the CDR incrementally without approving the entire CDR.\nOnce approved by the Director, the CDR will be incorporated by reference into\nthis Order.\nc. The CDR must include, but is not necessarily limited to, the following:\ni. Table of Contents;\nii. iii. Summary of the pipeline failure of July 25, 2023 and the response activities;\nSummary of pipe data, material properties and all prior assessments of the\nAffected Pipelines;\niv. Summary of all tests, inspections, assessments, evaluations, and\nanalysis required by the Order;\nv. vi. vii. Summary of the mechanical and metallurgical testing as required by the Order;\nSummary of the RCFA with all root causes as required by the Order;\nDocumentation of all actions taken by CGT to implement the RWP, the results\nof those actions, and the inspection and repair criteria used;\nviii. Documentation of any revisions to the RWP including those necessary to\nincorporate the results of actions undertaken pursuant to this Order and\nwhenever necessary to incorporate new information obtained during the\nfailure investigation and remedial activities;\nix. x. Lessons learned while completing this Order;\nA path forward describing specific actions CGT will take on its entire\npipeline system as a result of the lessons learned from work on this Order;\nand\nxi. Appendices (if required).\nOther Requirements:\n12. Approvals. With respect to each submission that under this Order requires the\napproval of the Director, the Director may: (a) approve, in whole or part, the\nsubmission; (b) approve the submission on specified conditions; (c) modify the\nsubmission to cure any deficiencies; (d) disapprove in whole or in part, the\nsubmission, directing that Respondent modify the submission, or (e) any combination\nof the above. In the event of approval, approval upon conditions, or modification by\nthe Director, Respondent shall proceed to take all action required by the submission\nas approved or modified by the Director. If the Director disapproves all or any\nportion of the submission, Respondent must correct all deficiencies within the time\nspecified by the Director and resubmit it for approval.\n13. Extensions of Time. The Director may grant an extension of time for compliance\nwith any of the terms of this Order upon a written request timely submitted\ndemonstrating good cause for an extension.\n\n\n\n14. Reporting. Submit quarterly reports to the Director that: (1) include all available\ndata and results of the testing and evaluations required by this Order; and (2)\ndescribe the progress of the repairs or other remedial actions being undertaken.\nThe first quarterly report is due on September 30, 2023. The Director may change\nthe interval for the submission of these reports.\n15. Documentation of the Costs. It is requested that Respondent maintain documentation\nof the costs associated with implementation of this Corrective Action Order. Include\nin each monthly report submitted, the to-date total costs associated with: (1)\npreparation and revision of procedures, studies and analyses; (2) physical changes to\npipeline infrastructure, including repairs, replacements and other modifications; and\n(3) environmental remediation, if applicable.\nBe advised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. § 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for confidential\ntreatment redacted and an explanation of why you believe the redacted information qualifies for\nconfidential treatment under 5 U.S.C. § 552(b).\nIn your correspondence on this matter, please refer to “CPF No. 1-2023-051-CAO” and for each\ndocument you submit, please provide a copy in electronic format whenever possible. The actions\nrequired by this Order are in addition to and do not waive any requirements that apply to\nRespondent’s pipeline system under 49 C.F.R. Parts 190 through 199, under any other order\nissued to Respondent under authority of 49 U.S.C. Chapter 601, or under any other provision of\nfederal or state law.\nRespondent may appeal any decision of the Director to the Associate Administrator for Pipeline\nSafety. Decisions of the Associate Administrator shall be final.\nFailure to comply with this Order may result in the assessment of civil penalties and in referral to\nthe Attorney General for appropriate relief in United States District Court pursuant to 49 U.S.C.\n§ 60120.\nThe terms and conditions of this Order are effective upon service in accordance with 49 C.F.R.\n§ 190.5.\nAugust 15, 2023\n___________________________________ ______________________\nFor Alan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n12023051CAO_Closure Letter_04252025_(23-282237)_text.pdf\n\nVIA ELECTRONIC MAIL: david brast@tcenergy.com\nApril 25, 2025\nMr. David Brast\nChief Executive Officer\nColumbia Gas Transmission, LLC\n700 Louisiana Street\nHouston, Texas 77002\nCPF 1-2023-051-CAO\nDear Mr. Brast:\nOn July 28, 2023, and on August 15, 2023, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) issued a Corrective Action Order (CAO) and an Amended Corrective\nAction Order (ACAO), respectively, to Columbia Gas Transmission, LLC (CGT), with regard to\nthe July 25, 2023 rupture of its 26-inch natural gas pipeline located in Strasburg, Virginia (Line\nVB). The ACAO included a list of various required Corrective Actions.\nWe have received the CAO Documentation Report (CDR). Additionally, we have also received\nquarterly reports, monthly reports, and other information.\nBased on our review of the documentation you provided, it has been determined that you have\ncomplied with the terms of this Order. Accordingly, this CAO is now closed. Thank you for your\ncooperation in this matter.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nCc: Daniel Cerkoney: dan_cerkoney@tcenergy.com\nAmy Willis: amy_willis@tcenergy.com\nLinda Daugherty: linda.daugherty@dot.gov\n\n12023051CAO_Corrective Action Order_07282023_(23-282237)_text.pdf\n\nJuly 28, 2023\nVIA ELECTRONIC MAIL TO: stanley chapman III@tcenergy.com\nMr. Stanley Chapman III\nExecutive Vice President and President US & Mexico Natural Gas\nTC Energy Corporation\n700 Louisiana Street\nHouston, Texas 77002\nCPF No. 1-2023-051-CAO\nDear Mr. Chapman:\nEnclosed please find the Corrective Action Order (CAO or Order) issued by the Pipeline and\nHazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), in the\nabove-referenced case. It requires Columbia Gas Transmission, LLC (CGT or Respondent), a\nsubsidiary of TC Energy Corporation, to take certain corrective actions with respect to a rupture\nthat occurred on the 26-inch Line VB pipeline located in Strasburg, Virginia.\nService of the CAO by electronic transmission is deemed complete upon transmission and\nacknowledgment of receipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms and\nconditions of this Order are effective upon completion of service.\nSincerely,\nAlan Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure: CAO\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS\nMr. Robert Burrough, Director, Eastern Region, OPS\nMr. Dan Cerkoney, Senior Manager, Regulatory Compliance, TC Energy\nCorporation, dan_cerkoney@tcenergy.com\nCONFIRMATION OF RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATIO\nNOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nColumbia Gas Transmission, LLC, ) CPF No. 1-2023-051-CAO\na subsidiary of TC Energy Corporation, )\n)\n)\n)\nRespondent. )\n____________________________________)\nCORRECTIVE ACTION ORDER\nPurpose and Background\nThis Corrective Action Order (CAO or Order) is being issued under the authority of 49 U.S.C.\n§ 60112 and 49 C.F.R. § 190.233 to require Columbia Gas Transmission, LLC (CGT or\nRespondent) to take the necessary corrective actions to protect the public, property, and the\nenvironment from potential hazards associated with the July 25, 2023, rupture of its 26-inch\nnatural gas pipeline located in Strasburg, Virginia (Line VB).\nAt approximately 8:41 a.m. Eastern Daylight Time (EDT)1 on July 25, 2023, CGT’s Line VB\nruptured (the Incident). The Incident occurred near Interstate Highway 81 (I-81) in Strasburg,\nVA, and the resulting fire of the released gas caused I-81 to close in both directions for about\ntwo hours. The Incident resulted in the ejection of several pieces of 26-inch pipe, which landed\non the pipeline right-of-way. There were no reported injuries, fatalities, or evacuations.\nPursuant to 49 U.S.C. § 60117, PHMSA, Office of Pipeline Safety (OPS) initiated an investigation\nof the Incident. The preliminary findings of OPS’ ongoing investigation are as follows:\nPreliminary Findings\n• At approximately 8:42 a.m. on July 25, 2023, CGT’s control room personnel observed a\nsudden pressure drop on their SCADA screens indicating a possible failure of Line VB.\nAt 8:45 a.m. CGT personnel at the downstream, nearby Strasburg Compressor Station\n(Strasburg CS) observed the fire and smoke resulting from the failure. At 8:50 a.m.\nCGT’s control room initiated automated valve closure of Valve 3080 at the Dysart Gate\nMainline Valve site upstream of the failure location. At 9:06 a.m. CGT operational\npersonnel arrived at the scene of the failure.\n1 All times listed in this Order are EDT.\n\n\n\n• CGT initially reported the Incident to the National Response Center (NRC) at 9:42 a.m.\non July 25, 2023 (NRC Report No. 1374102), indicating there was a fire and release of an\nunknown volume of natural gas greater than 3,000 MCF. In its 48-hour update to the\nNRC CGT identified the volume of gas released to be 70,478 MCF.\n• The natural gas was released to the atmosphere with no injuries, fatalities or evacuations\nassociated with this incident. CGT discovered ejected pipe in three segments within the\nright of way totaling approximately 250 feet of pipe.\n• Prior to the rupture, Line VB was operating at 777 pounds per square inch gauge (psig).\nThe maximum allowable operating pressure (MAOP) of Line VB is 800 psig. Line VB\nwas out of service for a class location replacement from May 30, 2023 until July 24, 2023\nwhen the line was returned to service at approximately 7:43 p.m., about 13 hours prior\nto the Incident.\n• Line VB was shut in at approximately 9:17 a.m., when upstream Valve 3130 at the Moo\nManor Valve Setting and downstream Valve VB-013 at the Strasburg CS were manually\nclosed.\n• The failed portion of the pipeline was constructed in 1950 with a 26-inch nominal\ndiameter, 0.281-inch wall thickness, X-52 grade pipe that was manufactured by A.O.\nSmith. The pipe has an electric flash welded (EFW) longitudinal seam and has a coal\ntar coating. Alignment sheets reviewed for Line VB identified a significant portion of\nthe line is comprised of pipe of this vintage and manufacturer. Line VB originates at the\nDysart Gate Mainline valve site and terminates at the Virginia/Maryland border where it\nmoves into CGT’s Maryland system.\n• Pipe manufactured by A.O. Smith using flash welding has had in-service incidents\nreported for pipe manufactured in nearly every year from 1928 – 1971.\n• CGT also operates Lines VB-5, a 36-inch, double submerged arc welded (DSAW)\nnatural gas pipeline build in 1968 with a 1,000 psig MAOP, and Line VB-Loop, a 26-\ninch, submerged arc welded (SAW) natural gas pipeline built in 1958 with an 800 psig\nMAOP. Both of these lines are in the same right-of-way as Line VB. Line VB-5 is\napproximately 25 feet from Line VB at the failure location and is currently isolated from\nValve 4115 at the Dysart Gate Mainline Valve site to Valve 3643 at the Strasburg CS,\nand is holding pressure at approximately 476 psig. Line VB-Loop, located further from\nthe VB pipeline within the right-of-way, has remained in normal operation.\n• The Incident occurred in a Class 1 location, non-high consequence area. The isolated\nsegment of line VB from Valve 3130 at the Moo Manor valve to Valve VB-013 at the\nStrasburg CS contains both Class 3 and High Consequence Areas (HCA).\n•","truncated":true,"body_characters":62922}