CPF 320111003W
CPF 320111003W
320111003W_Warning Letter_03212011_text.pdf, page 1Official PDFWARNING LETTER CERTIFIED MAIL - RETURN RECEIPT REQUESTED March 21, 2011 Mr. Victor Gaglio Senior Vice President - Operations Columbia Gas Transmission, LLC 1700 MacCorkle Avenue, SE Charleston, WV 25314 CPF 3-2011-1003W Dear Mr. Gaglio: On July 6-7 and July 12-19, 2010, a representative of the Ohio Public Utilities Commission (OH-PUC) ), acting as an interstate agent for the Pipeline and Hazardous Materials Safety Administration, Central Region (PHMSA), pursuant to Chapter 601 of 49 United States Code inspected your records and field facilities in Cambridge, OH. As a result of the inspection, it appears that you have committed probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the probable violation is: 1. §192.491 Corrosion control records. (c) Each operator shall maintain a record of each test, survey, or inspection required by this subpart in sufficient detail to demonstrate the adequacy of corrosion control measures or that a corrosive condition does not exist. These records must be retained for at least 5 years, except that records related to §§192.465(a) and (e) and 192.475(b) must be retained for as long as the pipeline remains in service.#
320111003W_Warning Letter_03212011_text.pdf, page 2Columbia Gas Transmission did not maintain a record of the atmospheric corrosion evaluation for two above ground facilities in 2006. A review of the corrosion records identified that two above-ground inactive service tap risers did not have any documentation of an atmospheric survey in 2006. The two taps were as follows: (a). Asset - #14661197 (b). Asset - #146620 Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000 for each violation for each day the violation persists up to a maximum of $1,000,000 for any 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 Columbia Gas Transmission, LLC 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 3-2011-1003W. 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, David Barrett Director, Central Region Pipeline and Hazardous Materials Safety Administration 2#
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