# COLUMBIA GULF TRANSMISSION, LLC — Warning Letter

- **operation:** document
- **citation:** CPF 220141005W
- **title:** COLUMBIA GULF TRANSMISSION, LLC — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2014-09-23
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 191.22(c)(1)(i).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-220141005w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-220141005w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-220141005w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/220141005W
**body:**

Warning Letter involving COLUMBIA GULF TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 191.22(c)(1)(i). The case was opened on 2014-09-23 and is reported as closed as of 2014-09-23. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220141005W_warning letter_09232014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220141005W/220141005W_warning%20letter_09232014.pdf

220141005W_warning letter_09232014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220141005W/220141005W_warning%20letter_09232014_text.pdf

220141005W_warning letter_09232014_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
September 23, 2014
Mr. Shawn L. Patterson
President
Columbia Gulf Transmission Company
1700 MacCorkle Avenue, SE
Charleston, WV 25314
CPF 2-2014-1005W
Dear Mr. Patterson:
On September 23, 2014, Columbia Gulf Transmission, LLC (CGT) submitted an “Operator
Registry Notification” (Form PHMSA F 1000.2) to the Pipeline and Hazardous Materials
Safety Administration (PHMSA) electronically through the National Registry of Pipeline and
LNG Operators at http://opsweb.phmsa.dot.gov. The notification advised PHMSA of CGT’s
intent to modify station piping, valves, launchers/receivers, and other equipment and facilities
at multiple compressor stations along line 200 and 300 to enable bi-directional flow
capability. These compressor stations are located in Kentucky, Louisiana, Mississippi and
Tennessee.
As a result of this late submittal, it appears that CGT has committed a probable violation of
the Pipeline Safety Regulations, in Title 49 of the Code of Federal Regulations. The probable
violation is as follows:
1. § 191.22 National Registry of Pipeline and LNG Operators.
… (c) Changes. Each operator must notify PHMSA electronically through the
National Registry of Pipeline and LNG Operators at http://opsweb.phmsa.dot.gov, of
certain events.
(1) An operator must notify PHMSA of any of the following events not later than 60
days before the event occurs:
(i) Construction or any planned rehabilitation, replacement, modification, upgrade,
uprate, or update of a facility, other than a section of line pipe, that costs $10 million
or more. If 60 day notice is not feasible because of an emergency, an operator must
notify PHMSA as soon as practicable;…



CGT did not notify PHMSA of a planned rehabilitation, replacement, modification,
upgrade, uprate, or update of a facility, other than a section of line pipe, that costs $10
million or more not later than 60 days before the event occurs.
CGT notified PHMSA electronically on September 23, 2014, through the National
Registry of Pipeline and LNG Operators at http://opsweb.phmsa.dot.gov, of its intent to
modify compressor stations along its 200 and 300 lines at a cost over $18 million. The
notification stated that the field work activities started on August 4, 2014. This
notification was required not later than 60 days before the event was to occur; i.e. not later
than June 4, 2014. CGT’s failure to properly notify PHMSA not later than 60 days prior
to August 4, 2014, deprived PHMSA of its ability to properly plan for the inspection of
this construction related activity.
Under 49 United States Code, § 60122, CGT is subject to a civil penalty not to exceed
$ 200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a
related series of violations. For violations occurring prior to January 4, 2012, the maximum
penalty may not exceed $100,000 per violation per day, with a maximum penalty not to
exceed $1,000,000 for a related series of violations. 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 the CGT 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 2-2014-1005W. 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).
Sincerely,
Wayne T. Lemoi
Director, Office of Pipeline Safety
PHMSA Southern Region
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