{"operation":"document","citation":"CPF 42021088WL","title":"COLUMBIA GAS TRANSMISSION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-12-22","effective_on":null,"summary":"CLOSED warning letter citing 193.2613.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021088wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021088wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021088wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42021088WL","body":"Warning Letter involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 193.2613. The case was opened on 2021-12-22 and is reported as closed as of 2021-12-22. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42021088WL_Warning Letter_12222021_(21-215015).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021088WL/42021088WL_Warning%20Letter_12222021_(21-215015).pdf\n\n42021088WL_Warning Letter_12222021_(21-215015)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021088WL/42021088WL_Warning%20Letter_12222021_(21-215015)_text.pdf\n\n42021088WL_Warning Letter_12222021_(21-215015)_text.pdf\n\nWARNING LETTER\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nDecember 22 , 2021\nStan Chapman\nExecutive Vice-President and President\nU.S. and Mexico Natural Gas Pipelines, TC Energy\n700 Louisiana Street\nHouston, Texas 77002\nCPF 4-2021-088-WL\nDear Mr. Chapman:\nFrom August 2, 2021 through August 6, 2021, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\n(U.S.C.), inspected Columbia Gas Transmission, LLC’s (Columbia) Chesapeake LNG plant to\ninclude procedures and records in Chesapeake, Virginia.\nAs a result of the inspection, it is alleged that Columbia has committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item insepcted and\nthe probable violation is:\n1. § 193.2613 Auxiliary power sources.\nEach auxiliary power source must be tested monthly to check its operational\ncapability and tested annually for capacity. The capacity test must take into account\nthe power needed to start up and simultaneously operate equipment that would have\nto be served by that power source in an emergency.\nColumbia failed to test its auxiliary power source for capacity for calendar year 2020 as\nrequired by § 193.2613. Columbia’s written procedures, TC Energy LNG OM Manual, Item\nID: 1014508094, 193.2445 Sources of Power (Equipment), 4.3.1 Testing of Auto Switch-Over\nFunctionality (Publish Date: 2021/02/01), states, “The auto switch over function [for the\nalternate source of power] will be tested annually by manually initiating the auto transfer of\nthe two (2) feeds and verifying that the critical systems can continue to be powered.”\nDuring the PHMSA inspection it was determined that the annual test was deleted from the\nmaintenance scheduler in calendar year 2020, and was not performed as required by § 193.2613\nand Columbia’s own operations and maintenance manual. The annual test has been conducted\nfor calendar year 2021.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related\nseries of violations. For violation occurring on or after January 11, 2021 and before May 3, 2021,\nthe maximum penalty may not exceed $222,504 per violation per day the violation persists, up to\n\n\n\na maximum of $2,225,034 for a related series of violations. For violation occurring on or after\nJuly 31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per\nviolation per day the violation persists, up to a maximum of $2,186,465 for a related series of\nviolations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the\nmaximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to\nexceed $2,132,679. For violation occurring on or after November 2, 2015 and before November\n27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum\npenalty not to exceed $2,090,022. Also, for each violation involving LNG facilities, and additional\npenalty of not more than $82,245 occurring on or after May 3, 2021 may be imposed. For each\nviolation involving LNG facilities, an additional penalty of not more than $81,284 occurring on or\nafter January 11, 2021 and before May 3, 2021 may be imposed. For each violation involving\nLNG facilities, an additional penalty of not more than $79,875 occurring on or after July 31, 2019\nand before January 11, 2021 may be imposed. For each violation involving LNG facilities, an\nadditional penalty of not more than $77,910 occurring on or after November 27, 2018 and before\nJuly 31,2019 may be imposed. For each violation involving LNG facilities occurring on or after\nNovember 2, 2015 and before November 27, 2018, an additional penalty of not more than $76,352\nmay be imposed.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the item identified in this letter. Failure to do so will result in\nColumbia Gas Transmission, LLC being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2021-088-WL. 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 the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\ncc: Chris Humes, Sr. VP, Operations, Engineering, and Technical Services, TC Energy,\nchris humes@tcenergy.com\nLee Romack, Director of US Regulatory Compliance, TC Energy, lee romack@tcenergy.com\nErik Hughes, Sr. Manager US Regulatory Compliance, TC Energy, erik_hughes@tcenergy.com\nMark Newman, Compliance Specialist, TC Energy, mark_newman@tcenergy.com","truncated":false,"body_characters":6093}