# SOUTH CAROLINA PIPELINE CORP — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 220071010
- **title:** SOUTH CAROLINA PIPELINE CORP — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2007-05-22
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 192.905(a), 192.911(m), 192.925(b), 192.935(a), 192.935(b).
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-220071010
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/220071010
**body:**

Notice of Probable Violation involving SOUTH CAROLINA PIPELINE CORP. PHMSA's enforcement data identifies the cited regulations as 192.905(a),  192.911(m),  192.925(b),  192.935(a),  192.935(b). The case was opened on 2007-05-22 and is reported as closed as of 2010-07-15. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220071010_ Final Order_07152010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071010/220071010_%20Final%20Order_07152010.pdf

220071010_ Final Order_07152010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071010/220071010_%20Final%20Order_07152010_text.pdf

220071010_notice letter_05222007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071010/220071010_notice%20letter_05222007.pdf

220071010_notice letter_05222007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071010/220071010_notice%20letter_05222007_text.pdf

220071010_Oper Resp to notice and req for exten_06182007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071010/220071010_Oper%20Resp%20to%20notice%20and%20req%20for%20exten_06182007.pdf

220071010_operator response and Request to cancel their previous hearing request _09212007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071010/220071010_operator%20response%20and%20Request%20to%20cancel%20their%20previous%20hearing%20request%20_09212007.pdf

220071010_ Final Order_07152010_text.pdf

JUL 15 2010
Mr. Samuel L. Dozier
Vice President, Commercial & Operations
Carolina Gas Transmission Corporation
105 New Way Road
Columbia, SC 29224-2407
RE: CPF No. 2-2007-1010
Dear Mr. Dozier:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation and concludes that Carolina Gas Transmission Corporation has completed the actions
specified in the Notice to comply with the pipeline safety regulations. Therefore, this case is
now closed. Service of the Final Order by certified mail is deemed effective upon the date of
mailing, or as otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Wayne Lemoi, Director, Southern Region, PHMSA
CERTIFIED MAIL - RETURN RECEIPT REQUESTED [7005 1160 0001 0039 0744]



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
__________________________________________
In the Matter of )
Carolina Gas Transmission Corporation, ) CPF No. 2-2007-1010
)
)
)
Respondent. )
_________________________________________ )
FINAL ORDER
On October 2-5 and October 23-26, 2006, pursuant to 49 U.S.C. § 60117, a representative of the
Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
(OPS), conducted an on-site pipeline safety inspection of Carolina Gas Transmission
Corporation’s (CGT or Respondent) gas integrity management program (IMP) at the company’s
offices in Columbia, South Carolina. CGT is an interstate natural gas company that delivers
natural gas throughout the Southeast.
As a result of the inspection, the Director, Southern Region, OPS (Director), issued to
Respondent, by letter dated May 22, 2007, a Notice of Probable Violation and Proposed
Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed
finding that Respondent had committed certain violations of 49 C.F.R. Part 192 and proposed
ordering Respondent to take measures to correct the alleged violations. The Notice also proposed
finding that Respondent had committed certain other probable violations of 49 C.F.R. Part 192
and warning Respondent to take appropriate corrective action to address them or be subject to
future enforcement action.
By letter dated June 18, 2007, Respondent requested an extension of time to respond to the
Notice. Respondent was granted an extension until December 31, 2007, and responded to the
Notice by letter dated September 21, 2007 (Response). CGT did not contest the allegations of
violation and expressed its intent to comply with the proposed corrective actions upon receipt of
a final order. Respondent did not request a hearing and has therefore waived its right to one.
FINDINGS OF VIOLATION
In its Response, CGT did not contest the allegations in the Notice that it violated 49 C.F.R. Part
192, as follows:
Item 2A: The Notice alleged that Respondent violated 49 C.F.R. § 192.925(b), which states:



2
§ 192.925 What are the requirements for using External Corrosion Direct
Assessment (ECDA)?
(a) ….
(b) General requirements. An operator that uses direct assessment to
assess the threat of external corrosion must follow the requirements in this
section, in [American Society of Mechanical Engineers]/[American National
Standards Institute] B31.8S (incorporated by reference, see § 192.7), section
6.4, and in NACE RP 0502-2002 (incorporated by reference, see § 192.7). An
operator must develop and implement a direct assessment plan that has
procedures addressing preassessment, indirect examination, direct
examination, and post-assessment. If the ECDA detects pipeline coating
damage, the operator must also integrate the data from the ECDA with other
information from the data integration (§ 192.917(b)) to evaluate the covered
segment for the threat of third party damage, and to address the threat as
required by § 192.917(e)(1).
The Notice alleged that Respondent violated 49 C.F.R. § 192.925(b) by failing to develop and
implement a direct assessment plan that adequately addressed indirect assessment, direct
examination, and post-assessment procedures. Specifically, it alleged that Respondent’s
procedures did not provide for integrating ECDA indirect inspection pipeline coating indication
data with encroachment and foreign line crossing data to evaluate covered segments for the
threat of third-party damage and did not address such threats, as required by § 192.917(e)(1).
The Notice also alleged that CGT had failed to develop and implement a process for requiring
indirect surveys of its lines that had been crossed during third-part excavation activities but
where CGT personnel had not been present to witness such activities. The Notice alleged, for
example, that third-party damage had occurred on Respondent’s pipeline because of the
placement of a power pole by CGT’s sister company.
Respondent did not contest this allegation of violation. Accordingly, after considering all of the
evidence, I find that Respondent violated 49 C.F.R. § 192.925(b) by failing to develop and
implement a direct assessment plan that adequately addressed indirect assessment, direct
examination, and post-assessment procedures.
Item 3A: The Notice alleged that Respondent violated 49 C.F.R. § 192.935(b), which states, in
relevant part:
§ 192.935 What additional preventive and mitigative measures must
an operator take?
(a) ….
(b) Third party damage and outside force damage—
(1) Third party damage. An operator must enhance its damage
prevention program, as required under § 192.614 of this part, with respect to a
covered segment to prevent and minimize the consequences of a release due to
third party damage. Enhanced measures to an existing damage prevention
program include, at a minimum—
. . ..
(ii) Collecting in a central database information that is location specific



3
on excavation damage that occurs in covered and non covered segments in the
transmission system and the root cause analysis to support identification of
targeted additional preventative and mitigative measures in the high
consequence areas. This information must include recognized damage that is
not required to be reported as an incident under part 191. . . .
1
The Notice alleged that Respondent violated 49 C.F.R. § 192.935(b) by failing to include
enhanced measures in its damage prevention program for collecting, in a central database,
location-specific information on excavation damage that had occurred in covered and non-
covered pipeline segments. Additionally, it alleged that CGT did not have a root cause analysis
to support the identification of targeted additional preventive and mitigative (P&M) measures in
High Consequence Areas (HCAs). Respondent did not contest this allegation of violation.
Accordingly, after considering all of the evidence, I find that Respondent violated 49 C.F.R.
§ 192.935(b) by failing to include enhanced measures in its damage prevention program for
collecting information on excavation damage that had occurred along its pipeline.
Item 3B: The Notice alleged that Respondent violated 49 C.F.R. § 192.935(a), which states:
§ 192.935 What additional preventive and mitigative measures must an
operator take?
(a) General requirements. An operator must take additional measures
beyond those already required by Part 192 to prevent a pipeline failure and to
mitigate the consequences of a pipeline failure in a high consequence area. An
operator must base the additional measures on the threats the operator has
identified to each pipeline segment. (See § 192.917). An operator must
conduct, in accordance with one of the risk assessment approaches in
ASME/ANSI B31.8S (incorporated by reference, see § 192.7), section 5, a
risk analysis of its pipeline to identify additional measures to protect the high
consequence area and enhance public safety. Such additional measures
include, but are not limited to, installing Automatic Shut-off Valves or
Remote Control Valves, installing computerized monitoring and leak
detection systems, replacing pipe segments with pipe of heavier wall
thickness, providing additional training to personnel on response procedures,
conducting drills with local emergency responders and implementing
additional inspection and maintenance programs.
The Notice alleged that Respondent violated 49 C.F.R. § 192.935(a) by failing to take additional
measures, beyond those already required by Part 192, to prevent pipeline failures and to mitigate
their consequences in HCAs. Specifically, it alleged that CGT’s IMP did not include an
evaluation of threats, a spectrum of P&M alternatives, and the potential impact of identified
risks, as outlined in § 192.917. The Notice also alleged that the determination of P&M measures
did not include appropriate factors of likelihood and consequence. Respondent did not contest
this allegation of violation. Accordingly, after considering all of the evidence, I find that
Respondent violated 49 C.F.R. § 192.935(a) by failing to take the additional P&M measures
discussed above to prevent pipeline failures and mitigate their consequences in HCAs.
1 Item 3A of the Notice correctly quoted § 192.935(b)(1)(ii) but then incorrectly referred to subparagraph (b)(2) as
the alleged violation.



4
Item 4A: The Notice alleged that Respondent violated 49 C.F.R. § 192.911(m), which states:
§ 192.911 What are the elements of an integrity management program?
An operator's initial integrity management program begins with a
framework (see § 192.907) and evolves into a more detailed and
comprehensive integrity management program, as information is gained and
incorporated into the program. An operator must make continual
improvements to its program. The initial program framework and subsequent
program must, at minimum, contain the following elements. (When indicated,
refer to ASME/ANSI B31.8S (incorporated by reference, see § 192.7) for
more detailed information on the listed element.) . . .
(m) A communication plan that includes the elements of ASME/ANSI
B31.8S, section 10, and that includes procedures for addressing safety
concerns raised by—
(1) OPS; and
(2) A State or local pipeline safety authority when a covered segment is
located in a State where OPS has an interstate agent agreement.
The Notice alleged that Respondent violated 49 C.F.R. § 192.911(m) by failing to develop and
implement an IMP that included a communications plan with procedures on how safety concerns
that had been raised by OPS or State authorities were to be documented, tracked, and addressed.
CGT did not contest this allegation of violation. Accordingly, after considering all of the
evidence, I find that Respondent violated 49 C.F.R. § 192.911(m) by failing to have a
communications plan with procedures for addressing safety concerns raised by OPS or State
authorities.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
COMPLIANCE ORDER
The Notice proposed a Compliance Order with regards to Items 2(A), 3(A), 3(B), and 4(A) in the
Notice for violations of 49 C.F.R. Part 192.
Under 49 U.S.C. § 60118(a), each person who engages in the transportation of gas or who owns
or operates a pipeline facility is required to comply with the applicable safety standards
established under chapter 601. The Director has indicated that Respondent has taken the
following actions specified in the proposed compliance order:
1. With respect to the violation of § 192.925(b) (Item 2A), CGT has developed a process
and procedures for integrating ECDA indirect inspection indications with encroachment
and foreign line crossing data to evaluate the covered segments for the threat of third-
party damage. These process and procedures require the following:
a) Actions to ensure the integrity of CGT’s pipelines when operator personnel are
not present during third-party excavation and construction activities that cross CGT
pipelines;



5
b) Indirect surveys of CGT pipelines crossed, to ensure safety and that
construction activity has not damaged its pipeline; and
c) Documenting these actions and incorporating them into CGT’s IMP, including
actions to ensure that CGT’s sister companies are aware of these requirements and to
prevent inadvertent damage to the pipelines when power poles are installed.
2. With respect to the violation of § 192.935(b) (Item 3A), CGT has developed
procedures for collecting, in a central database, location-specific information on
excavation damage that has occurred in covered and non-covered segments.
3. With respect to the violation of § 192.935(a) (Item 3B), CGT has fully developed a
threat evaluation process and a spectrum of preventative and mitigative alternatives with
appropriate risk factors, including the likelihood of failure and consequences.
4. With respect to the violation of § 192.911(m) (Item 4A), CGT has developed
procedures on how safety concerns raised by PHMSA or State authorities are to be
documented, tracked, and addressed.
Accordingly, since compliance has been achieved with respect to these violations, the
compliance terms are not included in this Order.
WARNING ITEMS
With respect to Item 1A, the Notice alleged a probable violation of Part 192 but did not propose
a civil penalty or compliance order for the item. Therefore, this is considered to be a warning
item. The warning was for:
49 C.F.R. § 192.905(a) (Item 1A) ─ Respondent’s alleged failure to identify the
HCAs along its pipeline, in accordance with method (1) or (2) from the definition
of HCA in Part 192.
CGT presented information in its Response showing that it had taken certain actions to address
the cited item. Accordingly, having considered such information, I find, pursuant to 49 C.F.R.
§ 190.205, that a probable violation of 49 C.F.R. § 192.905 (Notice Item 1A) has occurred and
Respondent is hereby advised to correct such condition. In the event that OPS finds a violation of
this provision in a subsequent inspection, Respondent may be subject to future enforcement
action.
The terms and conditions of this Final Order are effective upon receipt.
___________________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

220071010_Oper Resp to notice and req for exten_06182007.pdf

FROM
(MON) JUN 18 2007 14
/ST. 14:58/No. 6802438935 P
2
Sormol L Dozier
Commerciol & Field Operations
Vice President
TRANSMISSION +*
CAROLINA GAS
sdozier@scana.com
A SCANA COMPANY
June 18, 2007
VIA OVERNIGHT DELIVERY
AND FACSIMILE
Director, Southern Region
Ms. Linda Daugherty
Pipeline and Hazardous Material Safety Administration
233 Peachtree Street, Suite 600
U.S. Department of Transportation
Atlanta, GA 30303
Re:
Carolina Gas Transmission Corporation, CPF 2-2007-1010
Request For Hearing and Statement of Issues
Dear Ms. Daugherty:
robable Violation and Proposed Compliance Order ('Notice") dated May 22, 2007, issued |
n May 22, 2007, Carolina Gas Transmission Corporation ("CGT") received a Notice
Materials Safety Administration ("PHMSA"). In the Notice, based on its review of CGT'
he Southern Region of the Department of Transportation's Office of Pipeline and Hazardou
Integrity Management Program ("IMP") conducted in Columbia, South Carolina, during the
weeks of October 2-5 and 23-26, 2006, PHMSA states that it appears that CGT has committed
probable violations of the IMP provisions of the pipeline safety regulations.
4 within 90 days of the final notice. In addition, CGT will track and submit to the Regional
CGT will comply with the warning iter and Proposed Compliance Order Items 1, 2, and
additional Lime to comply with Proposed Compliance Order Item 3, which states that, in regard
Director all costs associated with fulfilling this Compliance Order. However, CGT requests
alternatives with all appropriate factors included into the evaluation, specially the likelihood
to Item Number 3B of the Notice, CGT must "fully develop a threat evaluation and P&M
process."
and consequence factors. The risk process should also be appropriately linked to the P&M
extension of time to December 31, 2007. This extension is needed so that CT can (1) obtain
In order to comply fully with Proposed Compliance Order Itcm 3, CGT requests an
from the vendor a new version of the risk ranking model; (2) populate the risk ranking model
management procedures to document the nature and operation of the new risk ranking model.
with the necessary data, including data regarding P&M measures; and (3) revise CGT's integrity
Order Item 3 is derried, CGT hereby requests a hearing pursuant to 49 C.F.R. § 190.211(a) and
To the extent this request for an extension of time to respond to Proposed Compliance
the Notice's instructions. The purpose of the hearing would be to discuss the scope and nature of
Carolina Gos Transmisson | P. O. Box 102407 - Columbia, South Corolina - 29224-2407. T (803) 217.6457 - F (803) 933.7460



FROM
(MON) JUN 18 2007 14
/ST. 14:58/No. 6802438935 P
• Ms. Linda Daugherty
Page 2
June 18, 2007
Proposed Compliance Order Item 3, and to explain the steps CGT believes are necessary to bring
COT into compliance with the IMP regulations. Pursuant to 49 C.F.R. § 190.211 (e), CGT
equests that the materials in the agency's case files be provided to CGT at least 30 days befor
ny hearing date. During the hearing process, CGT will be represented by counse
requcst for a hearing be directed to the following:
CGT respectfully requests that any correspondence and communications regarding this
Laura A. Comstock
Supervisor, Safety and Compliance
105 New Way Road
Carolina Gas Transmission Corporation
Columbia, South Carolina 29224-2407
Sufa
Samuel L. Dozier
Vice President,
Commercial and Field Operations
cc:
Craig Collin
Wayne Vermulle

220071010_notice letter_05222007_text.pdf

U 5 Department
of Transportation
Pipeline and
Hazardous Materials Safety
Administration
233 Peachtree Street Ste 600
Atlanta, GA 30303
NOTICE OF PROBABLE VIOLATION
And
PROPOSED COMPLIANCE ORDER
CERTIFIED MAIL - RETURN RECEIPT RE UESTED
May 22, 2007
Mr Samuel L Dozier
Vice President and Commercial Field Operations
Carohna Gas Transmission (CGT)
105 New Way Road
Columbia, South Carohna 29224-2407
CPF 2-2007-1010
Dear Mr Dozier
On October 2-5 aud October 23-26, 2006, representatives of the Pipehne and Hazardous
Matenals Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code
inspected your Gas integrity Management Program at your office in Columbia, South Carohna
As a result of the inspection, it appears that you have committed probable violations of the
Pipelme Safety Regulations, Tttle 49, Code of Federal Regulations The items inspected and the
probable violations are
1. High Consequence Area (HCA) Identification
I)192. 905 How does an operator identify a high consequence area (HCA)?
(a) General. To determine whtch segments of an operator's transmission pipehne
system are covered by this subpart, an operator must identify the high
consequence areas. An operator must use method (1) or (2) from the definition in
tt 192. 903 to idenhfy a high consequence area.



$192. 903 What definitions apply to this subparto
High consequence area means an area estabhshed by one of the methods described
m paragraphs (I) or (2) as follows.
(1) An area defined as—
(i) A Class 3 location under $192. 5; or
(u) A Class 4 location under (]192. 5, or
(ni) Any area m a Class I or Class 2 location where the potential impact radius is
greater than 660 feet (200 meters), and the area withm a potential impact circle
contains 20 or more buddings intended for human occupancy; or
(iv) Any area m a Class I or Class 2 location where the potenhal impact circle
contams an identified site.
(2) The area within a potenhal impact circle (PIC) containing—
(i) 20 or more buddings mtended for human occupancy, unless the exception in
paragraph (4) applies; or
(n) An identified site
(3) Where a potential impact circle is calculated under either method (I) or (2) to
estabhsh a high consequence area, the length of the high consequence area extends
axially along the length of the pipeline from the outermost edge of the first potential
impact circle that contains either an identified site or 20 or more buddmgs intended
for human occupancy to the outermost edge of the last contiguous potential impact
circle that contains either an identified site or 20 or more buddmgs mtended for
human occupancy. (See Figure E. I. A. in appendix E. )
(4) If in identifying a high consequence area under paragraph (1)(ni) of this
definition or paragraph (2)(i) of this definition, the radius of the potential impact
circle is greater than 660 feet (200 meters), the operator may identify a high
consequence area based on a prorated number of buddings intended for human
occupancy within a distance 660 feet (200 meters) from the centerhne of the pipelme
untd December 17, 2006. If an operator chooses this approach, the operator must
prorate the number of buddings intended for human occupancy based on the ratio
of an area with a radius of 660 feet (200 meters) to the area of the potential impact
circle (i. e.
,
the prorated number of buildings mtended for human occupancy is equal
to [20 x (660 feet [or 200 meters]/ potential impact radius in feet [or meters])**2])
Identified site means each of the following areas.
(a) An outside area or open structure that is occupied by twenty (20) or more
persons on at least 50 days in any twelve (12)-month period (The days need not be



consecutive. ) Examples include but are not hmited to, beaches, playgrounds,
recreational facihties, camping grounds, outdoor theaters, stadiums, recreational
areas near a body of water, or areas outside a rural budding such as a rehgious
facdity; or
(b) A budding that is occupied by twenty (20) or more persons on at least five (5)
days a week for ten (10) weeks in any twelve (12)- month period. (The days and
weeks need not be consecutive. ) Examples include, but are not limited to, rehgious
facilities, office buildmgs, community centers, general stores, 4-H facihties, or roller
skating rinks; or
(c) A facdity occupied by persons who are confined, are of impaired mobdity, or
would be difficult to evacuate. Examples include but are not hmited to hospitals,
prisons, schools, day-care facihties, retirement facihties or assisted-living facdities.
~ Item 1A: t'1 192. 905(a)
During a records review of HCAs, it was determined that the HCA identification process
had not appropnately identified a school playgrouncUathletic field as an HCA pipehne
segment on Rhame Road in Columbia, South Carohna
2. Direct Assessment (DA) Plan
$ 192. 925 What are the requirements for using External Corrosion Direct
Assessment (ECDA)?
(b) General reqrrrremenrs. An operator that uses direct assessment to assess the
threat of external corrosion must follow the requirements in this section, in
ASME/ANSI B31 SS (ibr, see (1 192. 7), sechon 6. 4, and in NACE RP 0502 — 2002 (ibr,
see t'1 192. 7). An operator must develop and implement a direct assessment plan that
has procedures addressmg pre-assessment, indirect examination, direct
exammation, and post-assessment. If the ECDA detects pipeline coatuig damage, the
operator must also integrate the data from the ECDA with other mformation from
the data mtegration (1'1 192. 917(b)) to evaluate the covered segment for the threat of
third party damage, and to address the threat as required by t'1 192. 917(e)(1).
~ Item 2A. g 192. 925(b)
CGT's ECDA procedures do not provide for integrating ECDA indirect mspection
pipeline coating indkcanon data with encroachment and foreign hne crossing data to
evaluate the covered segment for the threat of tlurd party damage, and to address this
threat as required by (192 917(e)(1) Further, a process is not in place to require an
indirect survey of CGT's lines crossed when operator personnel are not present dunng
third party construction activities As an additional note, it was learned that third party



damage occurred on the CGT pipehne as a result of power pole placement by CGT's
sister company, indicating lack of appropriate controls
3 Preventive and Mitigative Measures
t'l 192. 935 What additional preventive and mihgative measures must an operator
take"
(a) General requirements An operator must take additional measures beyond those
already required by Part 192 to prevent a pipehne fadure and to mitigate the
consequences of a pipehne failure in a high consequence area. An operator must
base the additional measures on the threats the operator has idenhfied to each
pipehne segment. (See g 192. 917) An operator must conduct, in accordance with one
of the risk assessment approaches m ASME/ANSI B31. 8S (ibr, see g 192. 7), section
5, a risk analysis of its pipeline to idenhfy additional measures to protect the high
consequence area and enhance public safety. Such additional measures include, but
are not hmited to, instalhng Automatic Shut-off Valves or Remote Control Valves,
mstalhng computeriaed monitoring and leak detection systems, replacing pipe
segments with pipe of heavier wall thickness, providing additional training to
personnel on response procedures, conducting drills with local emergency
responders and unplementing additional inspechon and maintenance programs.
(b) Third party damage and outside force damage — (1) Third party damage. An
operator must enhance its damage prevention program, as required under ('l 192. 614
of this part, with respect to a covered segment to prevent and mmimue the
consequences of a release due to third party damage. Enhanced measures to an
exishng damage prevention program include, at a mmimum—
(u) Collecting in a central database information that is location specific on
excavation damage that occurs in covered and non covered segments in the
transmission system and the root cause analysis to support identification of targeted
additional preventative and mihgative measures in the high consequence areas. This
information must include recognued damage that is not required to be reported as
an mcident under part 191.
~ Item 3A: t'l 192. 935(b)(2)
There are no procedures for collecting, in a cental database, location-specific
information on excavation damage that occurs in covered and non-covered segments and
the root cause analysis to support identification of targeted additional preventative and
mitigative measures in HCAs
~ Item 3B tl 192. 935(a)



The CGT IMP does not include an evaluation of threats, a spectrum of preventive and
nutigative (PkM) alternatives, and the potential impact on the identified risks for HCA
segments Specifically, the determination of appropnate P&M measures does not include
appropnatc factors of hkchhood and consequence
4. Communications Plan
g 192. 911 What are the elements of an integrity management program"
An operator's initial mtegrity management program begms with a framework (see g
192. 907) and evolves mto a more detailed and comprehensive integrity management
program, as information is gained and incorporated into the program. An operator
must make continual improvements to its program The initial program framework
and subsequent program must, at mmimum, contam the following elements. (When
indicated, refer to ASME/ANSI B31. 8S (ibr, see tl 192 7) for more detailed
information on the hsted element. )
(m) A communication plan that mcludes the elements of ASME/ANSI B31. 8S,
section 10, and that includes procedures for addressing safety concerns raised by—
(I) OPS; and (2) A State or local pipehne safety authority when a covered segment is
located in a State where OPS has an interstate agent agreement
~ Item 4A: I'I 192. 911(m)
The CGT IMP includes no procedures on how safety concerns raised by PHMSA or State
authonues are to be documented, tracked, and addressed
Pro osed Com bunce Order
Pursuant to 49 Umted States Code $ 60118, the Pipehne and Hazardous Materials Safety
Administration proposes to issue a Comphance Order to Carohna Gas Transmission Please
refer to the Proposed Complmnce Order that is enclosed and made a part of tlus Notice
WWW It
With respect to item number lA, 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 promptly correct tlus item Be advised
that failure to do so may result in Carohna Gas Transmission being sublect to additional
enforcement action



Res onse to this Notice
Enclosed as part of tlus Notice is a document entitled Response Options for Pipelme Operators
in Compliance Proceedmgs Please refer to this document and note the response options Be
advised that all matenal you submit in response to this enforcement action is sublect to bemg
made pubhcly available If you believe that any portion of your responsive matenal quahfies 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 beheve quahfy 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) If you do not respond within 30 days
of receipt of this Notice, tlus constitutes a waiver of your nght to contest the allegations in this
Notice and authorizes the Associate Administrator for Pipelme Safety to find facts as alleged in
tlus Notice without further notice to you and to issue a Final Order
In your correspondence on tins matter, please refer to CPF 2-2007-1010 and for each document
you submit, please provide a copy in electronic format whenever possible
Linda Daugherty
Director, Southern Region
Pipelme and Hazardous Materials Safety Administration
Enclosures Proposed Compliance Order
Response Options for Pipeline Operators m Compfiance Proceedmgs



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code $ 60118, the Pipehne and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Carohna Gas Transmission (CGT) a Compliance
Order incorporating the following remedial requirements to ensure the compliance of Carohna Gas
Transnussion with the pipeline safety regulations
In regard to Item Number 2A of the Notice pertaining to CGT's ECDA procedures not
providing for integrating ECDA indirect inspection pipelme coating indication data with
encroachment and foreign line crossing data to evaluate the covered segment for the
threat of third party damage A process and procedures must be developed for integrating
ECDA indirect inspection indications with encroachment and foreign lme crossing data to
evaluate the covered segments for the threat of third party damage Additionally, CGT
must require action to ensure the integrity of CGT pipehnes when operator personnel are not
present dunng third party construction activities that cross CGT pipelmes An indirect
survey of the CGT pipeline crossed could be performed to ensure safety and that the
construction activity dtd not damage the CGT pipehne CGT has taken steps to ensure that
the sister companies are aware of these reqmrements to prevent inadvertent damage to the
pipehnes when power poles are installed in the future CGT must document these
actions and incorporate into the CGT integnty management program
In regard to Item Number 3A of the Notice pertaining to CGT IMP having no procedures for
collecting, m a central database, location-specific information on excavation damage that
occurs in covered and non-covered segments and the root cause analysis to support
identification of targeted additional preventative and mitigative (P&M) measures in
HCAs CGT must develop procedures for collecting location — specific information on
excavation damage that occurs in covered and non-covered segments Root cause analysis
requirements should be developed and mtegrated into CGT procedures
In regard to Item Number 3B of the Notice pertaiiung to CGT IMP not including an
evaluation of threats, a spectrum of preventive and mitigative (PkM) alternatives, and the
potential impact on the identified nsks for HCA segments CGT must fully develop a
threat evaluation and PkM alternatives with all appropnate factors included mto the
evaluation, especially likelihood and consequence factors The nsk process should also be
appropnately hnked to the PkM process
In regard to Item Number 4A of the Notice pertauung to CGT IMP having no procedures on
how safety concerns raised by PHMSA or State authorities are to be documented, hacked,
and addressed CGT must develop procedures on how all safety concerns are to be
documented, tracked and addressed
Carohna Gas Transmission has 90 days after the receipt of the Final Order to complete the
above items
Carohna Gas Transmission shall maintain documentation of the safety unprovement costs
associated with fulfilhng this Comphance Order and submit the total to Linda Daugherty,
Director, Southern Region, Pipeline and Hazardous Matenals Safety Administration Costs
shall be reported in two categones 1) total cost associated with preparation/revision of plans,
procedures, studies and analyses, and 2) total cost associated with replacements, additions and
other changes to pipehne infrastructure
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