{"operation":"document","citation":"CPF 12024029NOA","title":"COLUMBIA GAS TRANSMISSION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-04-16","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024029noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024029noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024029noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12024029NOA","body":"Notice of Amendment involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2024-04-16 and is reported as closed as of 2024-06-18. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12024029NOA_Closure Letter_06182024_(23-263997).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024029NOA/12024029NOA_Closure%20Letter_06182024_(23-263997).pdf\n\n12024029NOA_Closure Letter_06182024_(23-263997)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024029NOA/12024029NOA_Closure%20Letter_06182024_(23-263997)_text.pdf\n\n12024029NOA_Notice of Amendment_04162024_(23-263997).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024029NOA/12024029NOA_Notice%20of%20Amendment_04162024_(23-263997).pdf\n\n12024029NOA_Notice of Amendment_04162024_(23-263997)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024029NOA/12024029NOA_Notice%20of%20Amendment_04162024_(23-263997)_text.pdf\n\n12024029NOA_Operator Response to Notice_06142024_(23-263997).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024029NOA/12024029NOA_Operator%20Response%20to%20Notice_06142024_(23-263997).pdf\n\n12024029NOA_Notice of Amendment_04162024_(23-263997)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nApril 16, 2024\nMs. Tina Faraca\nExecutive Vice President and President\nU.S. Natural Gas Pipelines\nColumbia Gas Transmission, LLC, a subsidiary of TC Energy Corporation\n700 Louisiana Street, Suite 700\nHouston, Texas 77002\nCPF 1-2024-029-NOA\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) procedures for the Lucas Storage Facility in Ashland County, Ohio.\nAs a result of the inspection, PHMSA has identified an apparent inadequacy found within CGT’s\nplans or procedures. The item inspected and the inadequacy is described below:\n1. § 192.12 Underground natural gas storage facilities.\n(a) ….\n(c) Procedural manuals. Each operator of a UNGSF must prepare\nand follow for each facility one or more manuals of written procedures\nfor conducting operations, maintenance, and emergency preparedness\nand response activities under paragraphs (a) and (b) of this section.\nEach operator must keep records necessary to administer such\nprocedures and review and update these manuals at intervals not\nexceeding 15 months, but at least once each calendar year. Each\noperator must keep the appropriate parts of these manuals accessible\nat locations where UNGSF work is being performed. Each operator\nmust have written procedures in place before commencing operations\n\n\n\nor beginning an activity not yet implemented.\nCGT’s written procedures for underground natural gas storage were inadequate to assure the safe\noperation of a pipeline facility. Specifically, CGT’s Storage Well Site Inspection Task Package\n(WSITP), Section h (wellhead leak inspection) failed to contain adequate detail to satisfy the\nprovisions of American Petroleum Institute Recommended Practice 1171 (API RP 1171) (2015),\nSection 9.3.2 required by the regulation.\nSection 9.3.2 of API RP 1171 states, in part, “The operator shall visually inspect each wellhead\nassembly at least annually for leaks.”\nSection h (wellhead leak inspection) of CGT’s WSITP stated, in part:\nUsing visual and/or audible signals and smells; inspect for the presence of gas leaks\non the wellhead equipment.\n0) No evidence of a leak\n1) Minor leak\n2) Moderate leak\n3) Major leak\nNote: Leaks can occur at various locations, including flanges, fittings, bull plugs, and\nground level. Leak location and intensity should be considered. If there is a leak, it\nshould be reported immediately.\nDocumentation requirement:\nComplete the Sap Work Order.\nEnsure equipment/entity/device information is current.\nRecord discrepancies in SAP\nRecord relevant observations, deficiencies, anomalies, and repairs for each system\ninspected in SAP.\nSchedule any additional maintenance to be completed in a timely manner.\nDuring the inspection, PHMSA reviewed CGT’s WSITP, Section h (wellhead leak inspection) and\nCGT records of leaks documented in SAP in 2022. CGT’s Well Inspection Task, Section h\n(wellhead leak inspection) was found to lack adequate detail regarding how to conduct and\ndocument the visual inspections, including details on what constituted ‘no evidence of a leak’, a\n‘minor’, a ‘moderate’, and a ‘major’ leak. The procedure also lacked details about the timeframe\nfor repairing leaks, including consideration of the severity of the leak. The procedure only directed\nemployees to schedule additional maintenance in a timely manner.\nTherefore, CGT’s written procedures required by § 192.12(c) pursuant to meeting the\nrequirements of Section 9.3.2 were inadequate to assure public safety. CGT must revise its\nprocedures to address the discrepancy outlined above.\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 Enforcement\n\n\n\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\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 1-2024-029-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\nCc: Daniel Cerkoney <dan_cerkoney@tcenergy.com>\nAmy Willis <amy_willis@tcenergy.com>\n\n12024029NOA_Closure Letter_06182024_(23-263997)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJune 18, 2024\nMs. Tina Faraca\nPresident and Chief Executive Officer\nColumbia Gas Transmission, LLC\n700 Louisiana Street, Suite 700\nHouston, Texas 77002\nCPF 1-2024-029-NOA\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) procedures for Lucas Storage Facility in Ashland County, Ohio. As a result of the\ninspection, CGT was issued a Notice of Amendment on April 16, 2024, which proposed\namendment of your procedures.\nCGT submitted its amended procedures on June 14, 2024. 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\nCc: < amy_willis@tcenergy.com>","truncated":false,"body_characters":8898}