{"operation":"document","citation":"CPF 220141001H","title":"COLUMBIA GULF TRANSMISSION, LLC — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-02-14","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220141001h.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220141001h.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220141001h","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220141001H","body":"Corrective Action Order involving COLUMBIA GULF TRANSMISSION, LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2014-02-14 and is reported as closed as of 2015-03-04. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220141001H_closure letter_03042015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220141001H/220141001H_closure%20letter_03042015.pdf\n\n220141001H_closure letter_03042015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220141001H/220141001H_closure%20letter_03042015_text.pdf\n\n220141001H_Corrective Action Order_02142014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220141001H/220141001H_Corrective%20Action%20Order_02142014.pdf\n\n220141001H_Corrective Action Order_02142014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220141001H/220141001H_Corrective%20Action%20Order_02142014_text.pdf\n\n220141001H_Corrective Action Order_02142014_text.pdf\n\nFebruary 14, 2014\nVIA CERTIFIED MAIL AND FAX TO: (304) 357-2644\nMr. Shawn L. Patterson\nPresident\nColumbia Gulf Transmission Company\n1700 MacCorkle Avenue, SE\nCharleston, WV 25314\nRe: CPF No. 2-2014-1001H\nDear Mr. Patterson:\nEnclosed is a Corrective Action Order issued by the Associate Administrator for Pipeline Safety\nin the above-referenced case. It requires you to take certain corrective actions with respect to the\noperation of Columbia Gulf Transmission’s Line 200 in Kentucky and Tennessee northeast of\nthe Hartsville Compressor Station. The Corrective Action Order requires you to take immediate\naction to protect the public, property, and environment in connection with the failure of this\npipeline on February 13, 2014, near Knifley, Kentucky.\nService is being made by certified mail and facsimile. Your receipt of this Corrective Action\norder constitutes service of that document under 49 C.F.R. § 190.5. The terms and conditions of\nthis Order are effective upon receipt. Please direct any questions on this matter to Wayne T.\nLemoi, Director, Southern Region, OPS, at (404) 832-1160.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. Wayne T. Lemoi, Southern Region Director, OPS\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n__________________________________________\nIn the Matter of )\nColumbia Gulf Transmission Company, ) CPF No. 2-2014-1001H\n)\n)\n)\n)\nRespondent )\n__________________________________________ )\nCORRECTIVE ACTION ORDER\nPurpose and Background\nThis Corrective Action Order is being issued, under authority of 49 U.S.C. § 60112, to require\nColumbia Gulf Transmission Company (Respondent or CGT), to take the necessary corrective\nactions to protect the public, property, and the environment from potential hazards associated\nwith a failure of CGT’s Line 200 natural gas pipeline, that occurred between the Clementsville\nCompressor Station and the first immediate downstream valve setting, near Knifley, Kentucky,\nin Adair County.\nOn February 13, 2014, a failure occurred on Respondent’s 30-inch line approximately 0.75 miles\nnorth of Knifley, Kentucky, and approximately 8.7 miles south of the Clementsville Compressor\nStation, resulting in the release of natural gas. The cause of the failure has not yet been\ndetermined.\nPursuant to 49 U.S.C. § 60117, the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety, Southern Region initiated an investigation of the incident.\nThe preliminary findings of the investigation are as follows:\nPreliminary Findings\n• The Columbia Gulf Transmission (CGT) natural gas pipeline system is part of the\nColumbia Pipeline Group. It originates along the Gulf Coast of the United States and\ntransports natural gas through Louisiana, Mississippi, Tennessee, and Kentucky. CGT’s\npipeline system terminates at the Leach Meter Station, approximately 3 miles south of\nCatlettsburg, Kentucky, where the natural gas is transferred to another Columbia Pipeline\nGroup company, Columbia Gas Transmission. The CGT pipeline system consists of\nthree natural gas transmission pipelines as follows:\n\n\n\n2\no Line 100, 30-inch outside diameter MAOP of 935 psig\no Line 200, 30-inch outside diameter, MAOP of 1,008 psig (the ruptured line)\no Line 300, 36-inch outside diameter, MAOP of 1,008 psig\n• At approximately 2:05 am EST on February 13, 2014, a rupture occurred on\nRespondent’s 30-inch 200 Line, resulting in a reported release of approximately 26.3\nMMCF of natural gas.\n• CGT reported the incident to the National Response Center on February 13, 2014 (NRC\nReport No. 1073825).\n• In Kentucky Line 200 is one of CGT’s three parallel natural gas transmission pipelines.\nThe other lines are Line 100 and Line 300. Line 200 crosses over the Tennessee/\nKentucky border northeast of Nashville and then runs from the southwest to the northeast\nthrough Kentucky terminating at the Leach Meter Station, approximately 3 miles south of\nCatlettsburg, KY.\n• The failure occurred in a remote location with several houses, several barns, and other\nbuildings within a mile of the pipeline.\no The released natural gas ignited causing a fire that destroyed two houses, three\nsmall buildings, one carport and four cars. It also damaged one other house and\nseveral other buildings.\no Two persons were injured, treated for burns at a local hospital, and released.\nThere were no reported fatalities. Four persons were unable to return to their\nhomes.\n• Following the February 13, 2014 failure, CGT personnel shut down compressor unit # 1\nat the Clementsville Compressor Station (CS) at 02:08 a.m. eliminating the discharge of\ngas. They then closed a valve on the discharge side of the station at 02:11 a.m. using a\nvalve actuator. Valve 313, approximately 13.92 miles downstream (south) of the CS,\nwas already closed at the time of the failure. CGT dispatched personnel to complete the\nisolation of the pipeline by closing the Adair Interconnect valve, approximately 11.81\nmiles south of the Clementsville Compressor Station. The isolation was complete\napproximately 30-35 minutes after the pressure drop. CGT later discovered that Valve\n313 was leaking so CGT personnel shut down valve 312, which was the next downstream\nmain line block valve and located approximately 25.20 miles downstream of the CS.\n• At the time of the incident, the estimated failure site operating pressure of Line 200 was\n961 psig. The reported maximum allowable operating pressure (MAOP) of this line\nsegment is 1008 psig.\n• Line 200 is shut-in from valve 312 at pipeline station number 3294 +56 (approximately\n25.20 miles south of the Clementsville Compressor Station to a discharge valve on the\n\n\n\n3\nsouth side of the Clementsville Compressor Station. When it is returned to service the\npressure will not exceed 769 psig.\n• The Line 200 pipe was manufactured by U.S. Steel in 1965. The pipe is 30-inch,\n0.323-inch w.t., X-65, coated with modified primer enamel with fiberglass and kraft\npaper.\n• The cause of the failure is unknown and the investigation is ongoing.\nDetermination of Necessity for Corrective Action Order and Right to Hearing\nSection 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action\nOrder, after reasonable notice and the opportunity for a hearing, requiring corrective action,\nwhich may include the suspended or restricted use of a pipeline facility, physical inspection,\ntesting, repair, replacement, or other action as appropriate. The basis for making the\ndetermination that a pipeline facility is hazardous, requiring corrective action, is set forth both in\nthe above referenced statute and 49 C.F.R. §190.233, a copy of which is enclosed.\nSection 60112, and the regulations promulgated thereunder, provide for the issuance of a\nCorrective Action Order without prior opportunity for notice and hearing upon a finding that\nfailure to issue the Order expeditiously will result in likely serious harm to life, property or the\nenvironment. In such cases, an opportunity for a hearing will be provided as soon as practicable\nafter the issuance of the Order.\nAfter evaluating the foregoing preliminary findings of fact, I find that the continued operation of\nportions of Respondent’s Line 200 in Tennessee and Kentucky, without corrective measures,\nwould be hazardous to life, property and the environment. Additionally, after considering the\nage of the pipe, circumstances surrounding this failure, the proximity of the pipeline to populated\nareas and public roadways the hazardous nature of the product the pipeline transports, the\npressure required for transporting the material, the uncertainties as to the cause of the failure, and\nthe ongoing investigation to determine the cause of the failure, I find that a failure to issue this\nOrder expeditiously to require immediate corrective action would result in likely serious harm to\nlife, property, and the environment.\nAccordingly, this Corrective Action Order mandating immediate corrective action is issued\nwithout prior notice and opportunity for a hearing. The terms and conditions of this Order are\neffective upon receipt.\nWithin 10 days of receipt of this Order, Respondent may request a hearing, to be held as soon as\npracticable, by notifying the Associate Administrator for Pipeline Safety in writing, delivered\npersonally, by mail or by telecopy at (202) 366-4566. The hearing will be held in Atlanta,\nGeorgia or Washington, D.C. on a date that is mutually convenient to PHMSA and Respondent.\n\n\n\n4\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective measures that need to be taken. CGT will be notified of any additional\nmeasures required and amendment of this Order will be considered. To the extent consistent\nwith safety, Respondent will be afforded notice and an opportunity for a hearing prior to the\nimposition of any additional corrective measures.\nRequired Corrective Action\nThe “Affected Segment” below means approximately 254.35 miles of CGT’s 30-inch Line 200\nfrom the Hartville Compressor Station in Tennessee to the Leach Meter Station, approximately 3\nmiles south of Catlettsburg, Kentucky.\nThe \"Isolated Segment\" means the 25.20-mile segment of CGTs 30-inch Line 200 from main\nline valve 312 at Station 3294+56 to a block valve on the discharge side of the Clementsville\nCompressor Station at station 4625+30. It is the portion of the \"Affected Segment\" that was\nshut-in after the failure on February 13, 2014, and that must remain shut-in until a restart plan is\napproved by the “Director.”\nThe \"Director\" means the Director, Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety, Southern Region. The Director’s address is 233 Peachtree\nSt., Suite 600, Atlanta, GA 30303.\nPursuant to 49 U.S.C. § 60112, I hereby order CGT to immediately take the following corrective\nactions with respect to the Line 200 pipeline:\n1. Isolated Segment Shut In. CGT must not operate the Isolated Segment until authorized to\ndo so by the Director.\nOperating Pressure Restriction. CGT must reduce and maintain a twenty percent (20%)\npressure reduction in the actual operating pressure along the entire length of the Affected\nSegment such that the operating pressure along the Affected Segment will not exceed eighty\npercent (80%) of the actual operating pressure in effect immediately prior to the failure on\nFebruary 13, 2014.\na. 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 obtained\nfrom the Director.\nBy February 20, 2014, CGT must provide the Director the actual operating\npressures of each compressor station and each main line pressure regulating\nstation on the Affected Segment at the time of failure and the reduced pressure\nrestriction 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-pressure\ndevices to be adjusted accordingly.\nWhen determining the pressure restriction set-points, CGT must take into account\nany in-line inspection (ILI) features or anomalies present in the Affected Segment\n2. b. c. d.\n\n\n\n5\n3. 4. to provide for continued safe operation while further corrective actions are\ncompleted.\ne. CGT must review the pressure restriction monthly by analyzing the operating\npressure data. Take into account any ILI features or anomalies present in the\nAffected Segment and immediately reduce the operating pressure to maintain the\nsafe operations of the Affected Segment, if warranted by the monthly review.\nSubmit the results of the monthly review to the Director. The results must include,\nat a minimum, the current discharge set-points (including any additional pressure\nreductions), and any pressure exceedance at discharge set-points.\nRestart Plan. Prior to resuming operation of the Isolated Segment, develop and submit a\nwritten 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\nPlan is approved in its entirety.\nb. Once approved by the Director, the Restart Plan will be incorporated by reference\ninto this Order.\nc. d. The Restart Plan must provide for adequate patrolling of the Isolated Segment\nduring the restart process and must include incremental pressure increases during\nstart-up, with each increment to be held for at least 2 hours.\nThe Restart Plan must include sufficient surveillance of the pipeline during each\npressure increment to ensure that no leaks are present when operation of the line\nresumes.\ne. f. g. h. The Restart Plan must specify a day-light restart and include advance\ncommunications with local emergency response officials.\nThe Restart Plan must provide for a review of the Isolated Segment for conditions\nsimilar to those of the failure including a review of construction, operating and\nmaintenance (O&M) and integrity management records such as ILI results,\nhydrostatic tests, root cause failure analysis of prior failures, aerial and ground\npatrols, corrosion, cathodic protection, excavations and pipe replacements.\nOperator must address any findings that require remedial measures to be\nimplemented prior to restart.\nThe Restart Plan must also include documentation of the completion of all\nmandated actions, and a management of change plan to ensure that all procedural\nmodifications are incorporated into CGT’s operations and maintenance\nprocedures manual.\nPrior to restart, submit to the Director a contingency plan to operate and monitor\nthe Isolated Segment during flooding conditions, including enhanced patrolling\nand surveillance.\nReturn to Service. After the Director approves the Restart Plan, CGT may return the\nIsolated Segment to service but the operating pressure must not exceed eighty percent (80%)\n\n\n\n6\nof the actual operating pressure in effect immediately prior to the failure on February 13,\n2014, in accordance with Item 2 above.\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 its\npre-failure operating pressure is justified based on a reliable engineering analysis\nshowing that the pressure increase is safe and considering all known defects,\nanomalies, 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 the failure cause and provision of evidence that\npreventative and mitigative actions taken by the operator provide for the safe\noperation of the Affected Segment during the temporary removal or modification\nof the pressure restriction. Appeals to determinations of the Director in this regard\nwill be decided by the Associate Administrator for Pipeline Safety.\n6. Instrumented Leakage Survey. Within 30 days of receipt of this Order, CGT must perform\nan aerial or ground instrumented leakage survey of the Affected Segment. CGT must\ninvestigate all leak indications and remedy all leaks discovered. CGT must submit\ndocumentation of this survey to the Director within 45 days of receipt of this Order.\n7. Records Verification. As recommended in PHMSA Advisory Bulletin 2012-06, verify the\nrecords for the Affected Segment to confirm the maximum allowable operating pressure\n(MAOP). CGT must submit documentation of this this record verification to the Director\nwithin 45 days of receipt of this Order.\n8. Review of Prior Inline Inspection (ILI) Results. Within 30 days of receipt of this Order,\nconduct a review of any previous ILI results of the Affected Segment. Re-evaluate all ILI\nresults from the past 10 calendar years; include a review of the ILI vendors' raw data and\nanalysis. Determine whether any features were present in the failed pipe joint and/or any\nother pipe removed. Also, determine if any features with similar characteristics are present\nelsewhere on the Affected Segment. CGT must submit documentation of this ILI review to\nthe Director within 45 days of receipt of this Order as follows:\na. List all ILI tool runs, tool types, and the calendar years of the tool runs.\nb. List, describe (type, size, wall loss, etc.), and identify the specific location of all\nILI features present in the failed joint and/or other pipe removed.\nc. List, describe (type, size, wall loss, etc.), and identify the specific location of all\nILI features with similar characteristics present elsewhere on the Affected\nSegment.\nd. Explain the process used to review the ILI results and the results of the\nreevaluation.\n\n\n\n9. 10. 11. 12. 13. 7\nMechanical and Metallurgical Testing. Within 45 days of receipt of this Order, complete\nmechanical and metallurgical testing and failure analysis of the failed pipe, including an\nanalysis of soil samples and any foreign materials. Complete the testing and analysis as\nfollows:\na. Document the chain-of-custody when handling and transporting the failed pipe\nsection and other evidence from the failure site.\nb. Within10 days of receipt of this Order, develop and submit the testing protocol\nand the proposed testing laboratory to the Director for prior approval.\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 their\nentirety to the Director at the same time they are made available to CGT.\nRoot Cause Failure Analysis. Within 90 days following receipt of this Order, complete a\nroot cause failure analysis (RCFA) and submit a final report of this RCFA to the Director.\nThe RCFA must be supplemented/facilitated by an independent third-party acceptable to the\nDirector and must document the decision making process and all factors contributing to the\nfailure. The final report must include findings and any lessons learned and whether the\nfindings and any lessons learned are applicable to other locations within CGT’s pipeline\nsystem.\nEmergency Response Plan and Training Review. CGT must review and assess the\neffectiveness of its emergency response plan with regards to the failure to include actions\nCGT took on February 13, 2014, to isolate and make the pipeline safe. Include in the review\nand assessment the on-scene response and support, coordination, and communication with\nemergency responders and public officials. Also, include a review and assessment of the\neffectiveness of its emergency training program. CGT must amend its emergency response\nplan and emergency training, if necessary, to reflect the results of this review. The\ndocumentation of this Emergency Response Plan and Training Review must be available for\ninspection by OPS or provided to the Director, if requested.\nPublic Awareness Program Review. CGT must review and assess the effectiveness of its\nPublic Awareness Program with regards to the failure. CGT must amend its Public\nAwareness Program, if necessary, to reflect the results of this review. The documentation of\nthis Public Awareness Program Review must be available for inspection by OPS or provided\nto the Director, if requested.\nIntegrity Verification and Remediation Plan (IVRP).\na. Within 90 days following receipt of this Order, CGT must submit an Integrity\nVerification and Remediation Plan (IVRP) to the Director for approval.\nb. The Director may approve the IVRP incrementally without approving the entire\nIVRP.\n\n\n\n8\nc. d. e. Once approved by the Director, the IVRP will be incorporated by reference into\nthis Order.\nThe IVRP must specify the tests, inspections, assessments, evaluations, and\nremedial measures CGT will use to verify the integrity of the Affected Segment.\nIt must address all known or suspected factors and causes of the February 13,\n2014, failure. CGT should consider both the risk of another failure and the\nconsequence of another failure to develop a prioritized schedule for IVRP related\nwork along the Affected Segment.\nThe IVRP must include a procedure or process to:\ni. Identify pipe in the Affected Segment with characteristics similar to the\ncontributing factors identified for the February 13, 2014, failure.\nii. Gather all data necessary to review the failure history (in service and\npressure test failures) of the Affected Segment and to prepare a written\nreport containing all the available information such as the locations, dates,\nand causes of leaks and failures.\niii. iv. v. Integrate the results of the metallurgical testing, root cause failure\nanalysis, and other corrective actions required by this Order with all\nrelevant pre-existing operational and assessment data for the Affected\nSegment. Pre-existing operational data includes, but is not limited to,\nconstruction, operations, maintenance, testing, repairs, prior metallurgical\nanalyses, and any third party consultation information. Pre-existing\nassessment data includes, but is not limited to, ILI tool runs, hydrostatic\npressure testing, direct assessments, close interval surveys, and\nDCVG/ACVG surveys.\nDetermine if conditions similar to those contributing to the failure on\nFebruary 13, 2014, are likely to exist elsewhere on the Affected Segment.\nConduct additional field tests, inspections, assessments, and/or evaluations\nto determine whether, and to what extent, the conditions associated with\nthe failure on February 13, 2014, and other failures from the failure history\n[see 13(e)(ii) above] or any other integrity threats are present elsewhere\non the Affected Segment. At a minimum, this process must consider all\nfailure causes and specify the use of one or more of the following:\n1. ILI tools that are technically appropriate for assessing the pipeline\nsystem based on the cause of failure on February 13, 2014, and that\ncan reliably detect and identify anomalies,\n2. Hydrostatic pressure testing,\n3. Close-interval surveys,\n4. Cathodic protection surveys, to include interference surveys in\ncoordination with other utilities (e.g. underground utilities,\noverhead power lines, etc.) in the area,\n\n\n\nf. g. h. 9\n5. Coating surveys,\n6. Stress corrosion cracking surveys,\n7. Selective seam corrosion surveys; and,\n8. Other tests, inspections, assessments, and evaluations appropriate\nfor the failure causes.\nvi. vii. Note: CGT may use the results of previous tests, inspections,\nassessments, and evaluations if approved by the Director, provided\nthe results of the tests, inspections, assessments, and evaluations\nare analyzed with regard to the factors known or suspected to have\ncaused the February 13, 2014, failure.\nDescribe the inspection and repair criteria CGT will use to prioritize,\nexcavate, evaluate, and repair anomalies, imperfections, and other\nidentified integrity threats. Include a description of how any defects will\nbe graded and a schedule for repairs or replacement.\nBased on the known history and condition of the Affected Segment,\ndescribe the methods CGT will use to repair, replace, or take other\ncorrective measures to remediate the conditions associated with the\npipeline failure on February 13, 2014, and to address other known\nintegrity threats along the Affected Segment. The repair, replacement, or\nother corrective measures must meet the criteria specified in 13(e)(vi)\nabove.\nviii. ix. Implement continuing long-term periodic testing and integrity verification\nmeasures to ensure the ongoing safe operation of the Affected Segment\nconsidering the results of the analyses, inspections, evaluations, and\ncorrective measures undertaken pursuant to the Order.\nImplement specific actions CGT will take on its entire pipeline system as a\nresult of the lessons learned from work on this Order.\nInclude a proposed schedule for completion of the IVRP.\nCGT must revise the IVRP as necessary to incorporate new information obtained\nduring the failure investigation and remedial activities, to incorporate the results\nof actions undertaken pursuant to this Order, and/or to incorporate modifications\nrequired by the Director.\ni. Submit any plan revisions to the Director for prior approval.\nii. The Director may approve plan revisions incrementally.\niii. Any and all revisions to the IVRP after it has been approved and\nincorporated by reference into this Order will be fully described and\ndocumented in the CAO Documentation Report (CDR).\nImplement the IVRP as it is approved by the Director, including any revisions to\nthe plan.\n\n\n\n10\n14. CAO Documentation Report (CDR). CGT must create and revise, as necessary, a CAO\nDocumentation Report (CDR). When CGT has concluded all the items in this Order it will\nsubmit the final CDR in its entirety to the Director. This will allow the Director to complete a\nthorough review of all actions taken by CGT with regards to this Order prior to approving the\nclosure of this Order. The intent is for the CDR to capture summations of all activities and\nthe documentation associated with this Order in one document.\na. The Director may approve the CDR incrementally without approving the entire\nCDR.\nb. Once approved by the Director, the CDR will be incorporated by reference into\nthis Order.\nc. The CDR must include but not be limited to:\ni. Table of Contents;\nii. Summary of the pipeline failure of February 13, 2014, and the response\nactivities;\niii. Summary of pipe data/properties and all prior assessments of the Affected\nSegment;\niv. Summary of all tests, inspections, assessments, evaluations, and analysis\nrequired by the Order;\nv. Summary of the Mechanical and Metallurgical Testing as required by the\nOrder;\nvi. vii. Summary of the RCFA with all root causes as required by the Order;\nDocumentation of all actions taken by CGT to implement the IVRP, the\nresults of those actions, and the inspection and repair criteria used;\nviii. Documentation of any revisions to the IVRP 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 description of the specific actions CGT will take on its entire pipeline\nsystem as a result of the lessons learned from work on this Order; and\nxi. Appendices (if required).\nOTHER REQUIREMENTS\n1. Reporting. Submit quarterly reports to the Director that: (1) include all available data and\nthe results of the testing and evaluations required by this Order; and (2) describe the progress\nof the repairs or other remedial actions being undertaken. The first quarterly report is due on\nApril 10, 2014. Subsequent quarterly reports are due 10 days after the close of the calendar\n\n\n\n2. 3. 4. 11\nquarter; e.g. 1st quarter - due April 10, 2014, 2nd quarter - due July 10, 2014, 3rd quarter - due\nOctober 10, 2014. The Director may change the interval for the submission of these reports.\nDocumentation of the Costs. It is requested but not required that Respondent maintain\ndocumentation of the costs associated with implementation of this Corrective Action Order.\nInclude in each quarterly report submitted, the to-date total costs associated with: (1)\npreparation and revision of procedures, studies and analyses; (2) physical changes to pipeline\ninfrastructure, including repairs, replacements and other modifications; and (3)\nenvironmental remediation, if applicable.\nApprovals. With respect to each submission that under this Order requires the approval of\nthe Director, the Director may: (a) approve, in whole or part, the submission; (b) approve the\nsubmission on specified conditions; (c) modify the submission to cure any deficiencies; (d)\ndisapprove in whole or in part, the submission, directing that Respondent modify the\nsubmission, or (e) any combination of the above. In the event of approval, approval upon\nconditions, or modification by the Director, Respondent shall proceed to take all action\nrequired by the submission as approved or modified by the Director. If the Director\ndisapproves all or any portion of the submission, Respondent must correct all deficiencies\nwithin the time specified by the Director, and resubmit it for approval.\nExtensions of Time. The Director may grant an extension of time for compliance with any\nof the terms of this Order upon a written request timely submitted demonstrating good cause\nfor an extension.\nThe actions required by this Order are in addition to and do not waive any requirements that\napply to Respondent’s pipeline system under 49 C.F.R. Part 192, under any other order issued to\nRespondent under authority of 49 U.S.C. § 60101 et seq., or under any other provision of Federal\nor State law.\nRespondent may appeal any decision of the Director to the Associate Administrator for Pipeline\nSafety. Decisions of the Associate Administrator are 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 Corrective Action Order are effective upon receipt.\n__________________________________ __________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n220141001H_closure letter_03042015_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 4, 2015\nMr. Shawn L. Patterson\nPresident\nColumbia Gulf Transmission Company\n1700 MacCorkle Avenue SE\nCharleston, WV 25314\nCPF 2-2014-1001H\nDear Mr. Patterson:\nThe Pipeline and Hazardous Materials Safety Administration (PHMSA) Southern Region,\nOffice of Pipeline Safety received correspondence from Columbia Gulf Transmission\nCompany (Columbia Gulf) dated January 22, 2015, regarding the above referenced Corrective\nAction order (CAO). The CAO was issued after a February 13, 2014, incident on Columbia\nGulf’s Line 200 in Knifley, Adair County, Kentucky. The correspondence included the CAO\nDocumentation Report (CDR) required by the CAO and a request to close the CAO.\nThe Southern Region has reviewed all the actions taken by Columbia Gulf with respect to the\nCAO and we find that Columbia Gulf has complied with the terms of the CAO. No further\nactions are necessary with regards to the CAO. This case is now closed. Accordingly, all\npressure restrictions established by the CAO are withdrawn.\nPlease be advised that this letter refers only to the CAO (CPF 2-2014-1011H) and not to any\nother PHMSA pending cases, if any.\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline\nPHMSA Southern Region","truncated":false,"body_characters":32042}