# COLUMBIA GAS TRANSMISSION, LLC — Warning Letter

- **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:** Not available
- **summary:** CLOSED warning letter citing 192.13(c).
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- **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.

Official case documents:

420091013W_Warning_05222009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420091013W/420091013W_Warning_05222009.pdf

420091013W_Warning_05222009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420091013W/420091013W_Warning_05222009_text.pdf

420091013W_Warning_05222009_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
May 22, 2009
Mr. Victor Gaglio
Sr. Vice President Operations & Engineering
Columbia Gas Transmission Company
P.O. Box 1273
Charleston, WV 25314
CPF 4-2009-1013W
Dear Mr. Gaglio:
On July 28-31, 2008, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your
Columbia Gas Transmission Company (CGT) and its subsidiaries’ Operator Qualification (OQ)
Plan at your office in Charleston, West Virginia.
As a result of the inspection, it appears that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the
probable violation is:
1. §192.13 General
c) Each operator shall maintain, modify as appropriate, and follow the plans,
procedures, and programs that it is required to establish under this part.
CGT did not modify or amend its Operator Qualification (OQ) plan after a periodic review had
been performed.
CGT’s OQ plan includes provisions for periodic review of its OQ plan. Therefore, CGT
reviewed its OQ plan and did not modify or amend its OQ plan to incorporate the revision to the
rule (Docket No. RSPA-03-15734; Amendment. 192-100) that was effective July 1, 2005. The
revised 2008 edition of CGT’s OQ plan, reviewed at the time of the inspection, did not include
procedures to inform the Administrator if CGT significantly modifies it OQ program, as required
by 192.805(i).



CGT has provided a revised OQ Plan with the corrections made as requested during the
inspection in July 2008.
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 advised you to correct the item identified in this letter.
Failure to do so would result in Columbia Gas Transmission Company 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 4-2009-1013W. 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,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous
Materials Safety Administration
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