COLUMBIA GAS TRANSMISSION, LLC — Warning Letter

12024028WL_Warning Letter_04092024_(23-263997)_text.pdf, page 1Official PDFWARNING LETTER OVERNIGHT EXPRESS DELIVERY April 9, 2024 Ms. Tina Faraca President and Chief Executive Officer Columbia Gas Transmission, LLC 700 Louisiana Street, Suite 700 Houston, Texas 77002 CPF 1-2024-028-WL Dear Ms. Faraca: From September 19, 2023 to September 21, 2023 and December 5, 2023, to December 6, 2023, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected Columbia Gas Transmission, LLC’s (CGT) Lucas Storage Facility in Ashland County, Ohio. As a result of the inspection, it is alleged that you have a committed probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and the probable violation is: 1. § 192.12 Underground natural gas storage facilities. (a) … (b) Depleted hydrocarbon and aquifer reservoir UNGSFs. (1) … (2) Each UNGSF that uses a depleted hydrocarbon reservoir or an aquifer reservoir for natural gas storage and was constructed on or before July 18, 2017, must meet the provisions of API RP 1171 (incorporated by reference, see § 192.7), sections 8, 9, 10, and 11, and paragraph (c) of this section, by January 18, 2018, and must meet all provisions of paragraph (d) of this section by March 13, 2021.#

12024028WL_Warning Letter_04092024_(23-263997)_text.pdf, page 2CGT failed to meet the provisions of API RP 1171, Section 9. Specifically, CGT failed to perform adequate visual inspections of each wellhead assembly for leaks in accordance with API RP 1171, Section 9.3.2. Section 9.3.2 states, in part, “The operator shall visually inspect each wellhead assembly at least annually for leaks.” During the inspection, PHMSA reviewed records of leaks documented in SAP in 2022 and visited 73 of 421 well sites at CGT’s Lucas Storage field. The well site visit inspections resulted in leaks being noted on 5 wellheads and pressure port valves not sealing properly on 12 wellheads. In contrast, only one leak was noted in 2022 within the records that were reviewed. The process and documentation of the process was observed to not accurately reflect the conditions observed in the field. Therefore, CGT’s failed to meet the provisions of API RP 1171, Section 9.3.2. Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $266,015 per violation per day the violation persists, up to a maximum of $2,660,135 for a related series of violations. For violation occurring on or after January 6, 2023 and before December 28, 2023, the maximum penalty may not exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related series of violations. For violation occurring on or after March 21, 2022 and before January 6, 2023, the maximum penalty may not 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. 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 1-2024-028-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).#

12024028WL_Warning Letter_04092024_(23-263997)_text.pdf, page 3Sincerely, Robert Burrough Director, Eastern Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration Cc: Daniel Cerkoney <dan_cerkoney@tcenergy.com> Amy Willis <amy_willis@tcenergy.com>#