{"operation":"document","citation":"CPF 320101005","title":"COLUMBIA GAS TRANSMISSION, LLC — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-11-05","effective_on":null,"summary":"CLOSED notice of probable violation citing 192.477, 192.479(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320101005.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320101005.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320101005","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320101005","body":"Notice of Probable Violation involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.477,  192.479(a). The case was opened on 2010-11-05 and is reported as closed as of 2012-06-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320101005_Final Order_06142012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320101005/320101005_Final%20Order_06142012.pdf\n\n320101005_Final Order_06142012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320101005/320101005_Final%20Order_06142012_text.pdf\n\n320101005_NOPV PCO_11052010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320101005/320101005_NOPV%20PCO_11052010.pdf\n\n320101005_NOPV PCO_11052010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320101005/320101005_NOPV%20PCO_11052010_text.pdf\n\n320101005_Operator Response to NOPV_12032010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320101005/320101005_Operator%20Response%20to%20NOPV_12032010.pdf\n\n320101005_Final Order_06142012_text.pdf\n\nJUNE 14, 2012\nMr. Robert C. Skaggs, Jr.\nPresident and Chief Executive Officer\nColumbia Gas Transmission, LLC\n1700 MacCorkle Avenue SE\nCharleston, WV 25314\nRe: CPF No. 3-2010-1005\nDear Mr. Skaggs:\nEnclosed please find the Final Order issued in the above-referenced case. It makes findings of\nviolation and finds that Columbia Gas Transmission, LLC, has completed the actions specified in\nthe Notice to comply with the pipeline safety regulations. Therefore, this case is now closed.\nService of the Final Order by certified mail is deemed effective upon the date of mailing, or as\notherwise provided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. David Barrett, Director, Central Region, OPS\nMr. Perry M. Hoffman, Manager – System Integrity, NiSource Gas Transmission &\nStorage\nMr. Alan Mayberry, Deputy Associate Administrator for Field Operations, OPS\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\n)\nIn the Matter of )\n)\nColumbia Gas Transmission, LLC, ) CPF No. 3-2010-1005\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nOn June 7-17, 2010, pursuant to 49 U.S.C. § 60117, representatives of the Ohio Public Utilities\nCommission (PUCO), as agent for the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety (OPS), conducted an on-site pipeline safety inspection of\nthe facilities and records of Columbia Gas Transmission, LLC (Columbia or Respondent) in\nCrawford, Ohio. Columbia, a subsidiary of NiSource Inc., owns and operates approximately\n11,453 miles of pipeline in Delaware, Kentucky, Maryland, New Jersey, New York, North\nCarolina, Ohio, Pennsylvania, Virginia, and West Virginia.1 Approximately 400 miles of\nColumbia’s pipelines are in High Consequence Areas.\n2\nAs a result of the inspection, the Director, Central Region, OPS (Director), issued to Respondent,\nby letter dated November 5, 2010, a Notice of Probable Violation and Proposed Compliance\nOrder (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that\nColumbia had violated 49 C.F.R. §§ 192.477 and 192.479(a) and proposed ordering Respondent\nto take certain measures to correct the alleged violations.\nNiSource Gas Transmission & Storage, also a subsidiary of NiSource Inc., responded to the\nNotice on behalf of Columbia, by letters dated December 3, 2010, and January 26, 2011\n(Response). The company did not contest one of the allegations of violation, contested the\nsecond, and offered additional information in response to the Notice.\n1 NiSource Inc. Form 10-K for the fiscal year ended December 31, 2011, filed with the Securities and Exchange\nCommission on February 24, 2012.\n2 49 CFR § 192.903.\n\n\n\n2\nFINDINGS OF VIOLATION\nThe Notice alleged that Respondent violated 49 C.F.R. Part 192, as follows:\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.477, which states:\n§ 192.477 Internal corrosion control: Monitoring.\nIf corrosive gas is being transported, coupons or other suitable means\nmust be used to determine the effectiveness of the steps taken to minimize\ninternal corrosion. Each coupon or other means of monitoring internal\ncorrosion must be checked two times each calendar year, but with\nintervals not exceeding 7½ months.\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.477 by failing to check each\ncoupon or other means of monitoring internal corrosion at least twice each calendar year, but\nwith intervals not exceeding 7½ months. Specifically, the Notice alleged that Columbia\ninspected a corrosion coupon known as asset #911063 at the Benton compressor station yard on\nSeptember 17, 2008, but did not inspect it again until June 4, 2009, which exceeded the\nmaximum allowable interval of 7½ months.\nIn its Response, Columbia stated that asset #911063 is a gas sampling point and not a corrosion\ncoupon, and provided records demonstrating that gas sampling was completed within the\nwork management records may not have accurately reflected the nature of the work completed\nrequired 7½ month interval.3 Columbia explained that at the time of the PUCO inspection, its\non asset #911063.\nAccordingly, after considering all of the evidence, I find that Columbia checked the means of\nmonitoring internal corrosion at asset #911063 at the required interval. Based upon the\nforegoing, I hereby order that Item 1 be withdrawn.\nItem 2: The Notice alleged that Respondent violated 49 C.F.R. § 192.479(a), which states:\n§ 192.479 Atmospheric corrosion control: General.\n(a) Each operator must clean and coat each pipeline or portion of\npipeline that is exposed to the atmosphere, except pipelines under\nparagraph (c) of this section.\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.479(a) by failing to clean and coat\neach portion of pipeline that is exposed to the atmosphere. Specifically, the Notice alleged that\nColumbia did not clean or coat three portions of pipeline that were exposed to the atmosphere,\nthat these locations were not included in Columbia’s atmospheric corrosion control program, and\nthat at least one of these locations exhibited corrosion pits. Respondent did not contest this\nallegation of violation, and stated that it had either repaired the identified locations or had\n3 Response at 2.\n\n\n\n3\nscheduled remedial action.\nRespondent violated 49 C.F.R. § 192.479(a) by failing to clean and coat each portion of pipeline\nthat is exposed to the atmosphere.\n4 Accordingly, based upon a review of all of the evidence, I find that\nThis finding of violation will be considered a prior offense in any subsequent enforcement action\ntaken against Respondent.\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Item 2 in the Notice for violation of\n49 C.F.R. § 192.479(a). Under 49 U.S.C. § 60118(a), each person who engages in the\ntransportation of gas or who owns or operates a pipeline facility is required to comply with the\napplicable safety standards established under chapter 601. The Director indicates that\nRespondent has taken the following actions that were specified in the proposed compliance\norder:\nWith respect to the violation of § 192.479(a) (Item 2), Respondent\nsubmitted a plan to evaluate and immediately address any areas of pipeline\nexposed to the atmosphere in the McArthur and Crawford operating areas,\nand to document the exposures in Respondent’s existing atmospheric\ncorrosion program. Respondent submitted the results of its evaluation on\nDecember 7, 2011, providing a summary of the exposure locations\nidentified, corrosion levels at each exposure, and the remedial actions\ntaken for each exposure. This evaluation included the three exposures that\nhad been identified during the PUCO inspection.\nAccordingly, I find that compliance has been achieved with respect to this violation. Therefore,\nthe compliance terms proposed in the Notice are not included in this Order.\nThe terms and conditions of this Final Order are effective upon service in accordance with\n49 C.F.R. § 190.5.\n___________________________________ __________________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n4 Response at 2-3.","truncated":false,"body_characters":8489}