# COLUMBIA GAS TRANSMISSION, LLC — Notice of Amendment

- **operation:** document
- **citation:** CPF 42024028NOA
- **title:** COLUMBIA GAS TRANSMISSION, LLC — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2024-08-26
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 191.5(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-42024028noa.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-42024028noa.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-42024028noa
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/42024028NOA
**body:**

Notice of Amendment involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 191.5(a). The case was opened on 2024-08-26 and is reported as closed as of 2024-10-22. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

42024028NOA_Closure Letter_10222024_(24-299840).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024028NOA/42024028NOA_Closure%20Letter_10222024_(24-299840).pdf

42024028NOA_Closure Letter_10222024_(24-299840)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024028NOA/42024028NOA_Closure%20Letter_10222024_(24-299840)_text.pdf

42024028NOA_Notice of Amendment_08262024_(24-299840).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024028NOA/42024028NOA_Notice%20of%20Amendment_08262024_(24-299840).pdf

42024028NOA_Notice of Amendment_08262024_(24-299840)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024028NOA/42024028NOA_Notice%20of%20Amendment_08262024_(24-299840)_text.pdf

42024028NOA_Operator Response to Notice_09232024_(24-299840).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024028NOA/42024028NOA_Operator%20Response%20to%20Notice_09232024_(24-299840).pdf

42024028NOA_Notice of Amendment_08262024_(24-299840)_text.pdf

NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: Tina faraca@tcenergy.com
August 26, 2024
Tina Faraca
Executive Vice President & President
Columbia Gas Transmission LLC
700 Louisiana Street, Suite 700
Houston, Texas 77002
CPF 4-2024-028-NOA
Dear Ms. Faraca:
From March 11 through March 15, 2024, of the on-site inspection, 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 Gas) procedures
for operations and maintenance in Chesapeake, Virginia.
As a result of the inspection, PHMSA has identified an apparent inadequacy found within
Columbia Gas’s plans or procedures. The item inspected and the inadequacy is described below:
1. § 191.5 Immediate notice of certain incidents.
(a) At the earliest practicable moment following discovery, but no
later than one hour after confirmed discovery, each operator must give
notice in accordance with paragraph (b) of this section of each incident
as defined in § 191.3.
Columbia Gas’s written procedures for conducting operations and maintenance activities were
inadequate to assure safe operation of a pipeline facility in accordance with § 191.5(a).
Specifically, Columbia Gas’s LNG Operations and Maintenance (O&M): 191.05 Immediate
Notice of Certain Incidents (US) (Rev. 4; 12/1/23), section 4.0, failed to specify that certain
incidents must be immediately reported, no later than one hour after confirmed discovery, in
accordance with § 191.5(a). Columbia Gas must revise its procedure to clarify that certain
incidents must be immediately reported no later than one hour after confirmed discovery in
accordance with § 191.5(a).



Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as
part of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement
Proceedings.
Please refer to this document and note the response options. 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).
Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of
receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice
and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice
without further notice to you and to issue an Order Directing Amendment. If your plans or
procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans
or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this
Notice, we propose that you submit your amended procedures to my office within 30 days of
receipt of this Notice. This period may be extended by written request for good cause. Once the
inadequacies identified herein have been addressed in your amended procedures, this enforcement
action will be closed.
It is requested (not mandated) that Columbia Gas maintain documentation of the safety
improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of
plans, procedures) and submit the total to Bryan Lethcoe, Director, Southwest Region, Pipeline
and Hazardous Materials Safety Administration. In correspondence concerning this matter, please
refer to CPF 4-2024-028-NOA and, for each document you submit, please provide a copy in
electronic format whenever possible.
Sincerely,
Bryan Lethcoe
Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
cc: Dan Cerkoney, Sr. Manager, Regulatory Compliance, dan_cerkoney@tcenergy.com

42024028NOA_Closure Letter_10222024_(24-299840)_text.pdf

VIA ELECTRONIC MAIL TO: tina faraca@tcenergy.com
October 22, 2024
Tina Faraca
Executive Vice President & President
Columbia Gas Transmission, LLC
700 Louisiana Street, Suite 700
Houston, Texas 77002
CPF 4-2024-028-NOA
Dear Ms. Faraca:
From March 11 through March 15, 2024, a representative from the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,
conducted an on-site pipeline safety inspection of Columbia Gas Transmission, LLC’s (Columbia
Gas) procedures in Chesapeake, Virginia. As a result of the inspection, Columbia Gas was issued
a Notice of Amendment on August 26, 2024, proposing amendment of Columbia Gas’ operations
and maintenance procedures.
Columbia Gas, through its parent company TC Energy, submitted its amended procedures on
September 23, 2024. PHMSA has reviewed the amended procedure, and it appears that the
inadequacy outlined in this Notice of Amendment has been corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely,
Bryan Lethcoe
Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Dan Cerkoney, Sr. Manager, Regulatory Compliance, dan_cerkoney@tcenergy.com
- **truncated:** false
- **body characters:** 6989
