{"operation":"document","citation":"CPF 12024028WL","title":"COLUMBIA GAS TRANSMISSION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-04-09","effective_on":null,"summary":"CLOSED warning letter citing 192.12(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024028wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024028wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024028wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12024028WL","body":"Warning Letter involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(b)(2). The case was opened on 2024-04-09 and is reported as closed as of 2024-04-09. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12024028WL_Warning Letter_04092024_(23-263997).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024028WL/12024028WL_Warning%20Letter_04092024_(23-263997).pdf\n\n12024028WL_Warning Letter_04092024_(23-263997)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024028WL/12024028WL_Warning%20Letter_04092024_(23-263997)_text.pdf\n\n12024028WL_Warning Letter_04092024_(23-263997)_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nApril 9, 2024\nMs. Tina Faraca\nPresident and Chief Executive Officer\nColumbia Gas Transmission, LLC\n700 Louisiana Street, Suite 700\nHouston, Texas 77002\nCPF 1-2024-028-WL\nDear Ms. Faraca:\nFrom September 19, 2023 to September 21, 2023 and December 5, 2023, to December 6, 2023, a\nrepresentative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant\nto Chapter 601 of 49 United States Code (U.S.C.) inspected Columbia Gas Transmission, LLC’s\n(CGT) Lucas Storage Facility in Ashland County, Ohio.\nAs a result of the inspection, it is alleged that you have a committed probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and\nthe probable violation is:\n1. § 192.12 Underground natural gas storage facilities.\n(a) …\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs.\n(1) …\n(2) Each UNGSF that uses a depleted hydrocarbon reservoir or an\naquifer reservoir for natural gas storage and was constructed on or\nbefore July 18, 2017, must meet the provisions of API RP 1171\n(incorporated by reference, see § 192.7), sections 8, 9, 10, and 11, and\nparagraph (c) of this section, by January 18, 2018, and must meet all\nprovisions of paragraph (d) of this section by March 13, 2021.\n\n\n\nCGT failed to meet the provisions of API RP 1171, Section 9. Specifically, CGT failed to perform\nadequate visual inspections of each wellhead assembly for leaks in accordance with API RP 1171,\nSection 9.3.2.\nSection 9.3.2 states, in part, “The operator shall visually inspect each wellhead assembly at least\nannually for leaks.”\nDuring the inspection, PHMSA reviewed records of leaks documented in SAP in 2022 and visited\n73 of 421 well sites at CGT’s Lucas Storage field. The well site visit inspections resulted in leaks\nbeing noted on 5 wellheads and pressure port valves not sealing properly on 12 wellheads. In\ncontrast, only one leak was noted in 2022 within the records that were reviewed. The process and\ndocumentation of the process was observed to not accurately reflect the conditions observed in the\nfield.\nTherefore, CGT’s failed to meet the provisions of API RP 1171, Section 9.3.2.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$266,015 per violation per day the violation persists, up to a maximum of $2,660,135 for a related\nseries of violations. For violation occurring on or after January 6, 2023 and before December 28,\n2023, the maximum penalty may not exceed $257,664 per violation per day the violation persists,\nup to a maximum of $2,576,627 for a related series of violations. For violation occurring on or\nafter March 21, 2022 and before January 6, 2023, the maximum penalty may not exceed $239,142\nper violation per day the violation persists, up to a maximum of $2,391,142 for a related series of\nviolations. For violation occurring on or after May 3, 2021 and before March 21, 2022, the\nmaximum penalty may not exceed $225,134 per violation per day the violation persists, up to a\nmaximum 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.\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 1-2024-028-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).\n\n\n\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":5751}