COLUMBIA GAS TRANSMISSION, LLC — Warning Letter

42021088WL_Warning Letter_12222021_(21-215015)_text.pdf, page 1Official PDFWARNING LETTER ELECTRONIC MAIL - RETURN RECEIPT REQUESTED December 22 , 2021 Stan Chapman Executive Vice-President and President U.S. and Mexico Natural Gas Pipelines, TC Energy 700 Louisiana Street Houston, Texas 77002 CPF 4-2021-088-WL Dear Mr. Chapman: From August 2, 2021 through August 6, 2021, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected Columbia Gas Transmission, LLC’s (Columbia) Chesapeake LNG plant to include procedures and records in Chesapeake, Virginia. As a result of the inspection, it is alleged that Columbia has committed a probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item insepcted and the probable violation is: 1. § 193.2613 Auxiliary power sources. Each auxiliary power source must be tested monthly to check its operational capability and tested annually for capacity. The capacity test must take into account the power needed to start up and simultaneously operate equipment that would have to be served by that power source in an emergency. Columbia failed to test its auxiliary power source for capacity for calendar year 2020 as required by § 193.2613. Columbia’s written procedures, TC Energy LNG OM Manual, Item ID: 1014508094, 193.2445 Sources of Power (Equipment), 4.3.1 Testing of Auto Switch-Over Functionality (Publish Date: 2021/02/01), states, “The auto switch over function [for the alternate source of power] will be tested annually by manually initiating the auto transfer of the two (2) feeds and verifying that the critical systems can continue to be powered.” During the PHMSA inspection it was determined that the annual test was deleted from the maintenance scheduler in calendar year 2020, and was not performed as required by § 193.2613 and Columbia’s own operations and maintenance manual. The annual test has been conducted for calendar year 2021. Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related series of violations. For violation occurring on or after January 11, 2021 and before May 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation persists, up to#

42021088WL_Warning Letter_12222021_(21-215015)_text.pdf, page 2a maximum of $2,225,034 for a related series of violations. For violation occurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related series of violations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to exceed $2,132,679. For violation occurring on or after November 2, 2015 and before November 27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum penalty not to exceed $2,090,022. Also, for each violation involving LNG facilities, and additional penalty of not more than $82,245 occurring on or after May 3, 2021 may be imposed. For each violation involving LNG facilities, an additional penalty of not more than $81,284 occurring on or after January 11, 2021 and before May 3, 2021 may be imposed. For each violation involving LNG facilities, an additional penalty of not more than $79,875 occurring on or after July 31, 2019 and before January 11, 2021 may be imposed. For each violation involving LNG facilities, an additional penalty of not more than $77,910 occurring on or after November 27, 2018 and before July 31,2019 may be imposed. For each violation involving LNG facilities occurring on or after November 2, 2015 and before November 27, 2018, an additional penalty of not more than $76,352 may be imposed. 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 4-2021-088-WL. 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, Mary L. McDaniel, P.E. Director, Southwest Region Pipeline and Hazardous Materials Safety Administration cc: Chris Humes, Sr. VP, Operations, Engineering, and Technical Services, TC Energy, chris humes@tcenergy.com Lee Romack, Director of US Regulatory Compliance, TC Energy, lee romack@tcenergy.com Erik Hughes, Sr. Manager US Regulatory Compliance, TC Energy, erik_hughes@tcenergy.com Mark Newman, Compliance Specialist, TC Energy, mark_newman@tcenergy.com#