{"operation":"document","citation":"CPF 420091013W","title":"COLUMBIA GAS TRANSMISSION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2009-05-22","effective_on":null,"summary":"CLOSED warning letter citing 192.13(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420091013w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420091013w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420091013w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420091013W","body":"Warning Letter involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.13(c). The case was opened on 2009-05-22 and is reported as closed as of 2009-05-22. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420091013W_Warning_05222009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420091013W/420091013W_Warning_05222009.pdf\n\n420091013W_Warning_05222009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420091013W/420091013W_Warning_05222009_text.pdf\n\n420091013W_Warning_05222009_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 22, 2009\nMr. Victor Gaglio\nSr. Vice President Operations & Engineering\nColumbia Gas Transmission Company\nP.O. Box 1273\nCharleston, WV 25314\nCPF 4-2009-1013W\nDear Mr. Gaglio:\nOn July 28-31, 2008, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your\nColumbia Gas Transmission Company (CGT) and its subsidiaries’ Operator Qualification (OQ)\nPlan at your office in Charleston, West Virginia.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the\nprobable violation is:\n1. §192.13 General\nc) Each operator shall maintain, modify as appropriate, and follow the plans,\nprocedures, and programs that it is required to establish under this part.\nCGT did not modify or amend its Operator Qualification (OQ) plan after a periodic review had\nbeen performed.\nCGT’s OQ plan includes provisions for periodic review of its OQ plan. Therefore, CGT\nreviewed its OQ plan and did not modify or amend its OQ plan to incorporate the revision to the\nrule (Docket No. RSPA-03-15734; Amendment. 192-100) that was effective July 1, 2005. The\nrevised 2008 edition of CGT’s OQ plan, reviewed at the time of the inspection, did not include\nprocedures to inform the Administrator if CGT significantly modifies it OQ program, as required\nby 192.805(i).\n\n\n\nCGT has provided a revised OQ Plan with the corrections made as requested during the\ninspection in July 2008.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violation persists up to a maximum of $1,000,000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advised you to correct the item identified in this letter.\nFailure to do so would result in Columbia Gas Transmission Company being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2009-1013W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous\nMaterials Safety Administration\n2","truncated":false,"body_characters":3594}