{"operation":"document","citation":"CPF 42024034NOPV","title":"COLUMBIA GAS TRANSMISSION, LLC — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-08-27","effective_on":null,"summary":"CLOSED notice of probable violation citing 191.17(b), 193.2503, 193.2505(b), 193.2521, 193.2801.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42024034nopv.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42024034nopv.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42024034nopv","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42024034NOPV","body":"Notice of Probable Violation involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 191.17(b),  193.2503,  193.2505(b),  193.2521,  193.2801. The case was opened on 2024-08-27 and is reported as closed as of 2026-07-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42024034NOPV_Closure Letter_07102026_(24-299840).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024034NOPV/42024034NOPV_Closure%20Letter_07102026_(24-299840).pdf\n\n42024034NOPV_Closure Letter_07102026_(24-299840)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024034NOPV/42024034NOPV_Closure%20Letter_07102026_(24-299840)_text.pdf\n\n42024034NOPV_Consent Agreement and Order_07092025_(24-299840).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024034NOPV/42024034NOPV_Consent%20Agreement%20and%20Order_07092025_(24-299840).pdf\n\n42024034NOPV_Consent Agreement and Order_07092025_(24-299840)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024034NOPV/42024034NOPV_Consent%20Agreement%20and%20Order_07092025_(24-299840)_text.pdf\n\n42024034NOPV_Operator Response to Notice and Request for an Informal Conference_10092024_(24-299840).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024034NOPV/42024034NOPV_Operator%20Response%20to%20Notice%20and%20Request%20for%20an%20Informal%20Conference_10092024_(24-299840).pdf\n\n42024034NOPV_PCO_08272024_(24-299840).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024034NOPV/42024034NOPV_PCO_08272024_(24-299840).pdf\n\n42024034NOPV_PCO_08272024_(24-299840)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024034NOPV/42024034NOPV_PCO_08272024_(24-299840)_text.pdf\n\n42024034NOPV_Closure Letter_07102026_(24-299840)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials\nSafety Administration\n8701 S. Gessner, Suite 630\nHouston TX 77074\nVIA ELECTRONIC MAIL TO: tina_faraca@tcenergy.com\nJuly 10, 2026\nTina Faraca\nExecutive Vice President & President\nColumbia Gas Transmission, LLC\n700 Louisiana Street, Suite 700\nHouston, Texas 77002\nCPF 4-2024-034-NOPV\nDear Ms. Faraca:\nOn July 9, 2025, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to\nColumbia Gas Transmission, LLC, (a TC Energy subsidiary), Consent Order in the above-\nreferenced case. This Order included a Compliance Order requirement to amend your procedures\nand the requirement to take corrective actions on your LNG Facility.\nBased on our review of the documentation you provided, it has been determined that you have\ncomplied with the terms of this Order.\nAccordingly, this case is now closed, and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nR. M. Seeley\nActing Director, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Dan Cerkoney, Sr. Manager, Regulatory Compliance, Columbia Gas Transmission, LLC,\ndan_cerkoney@tcenergy.com\nAndrew Kohout, Director, Division of LNG Facility Reviews and Inspections Office of\nEnergy Projects, Federal Energy Regulatory Commission,\nAndrew.Kohout@ferc.gov\n\n42024034NOPV_Consent Agreement and Order_07092025_(24-299840)_text.pdf\n\nJuly 9, 2025\nVIA ELECTRONIC MAIL TO: tina faraca@tcenergy.com\nTina Faraca\nExecutive Vice President & President\nU.S. Natural Gas Pipelines\nTC Energy Corporation\n700 Louisiana Street\nHouston, Texas 77002\nCPF No. 4-2024-034-NOPV\nDear Ms. Faraca:\nEnclosed please find a Consent Order incorporating the terms of the Consent Agreement between\nthe Pipeline and Hazardous Materials Safety Administration (PHMSA) and Columbia Gas\nTransmission, LLC, which was executed on June 23, 2025. Service of the Consent Order and\nConsent Agreement by electronic mail is deemed effective upon the date of transmission and\nacknowledgement of receipt, or as otherwise provided under 49 CFR § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nLinda Daugherty\nActing Associate Administrator\nfor Pipeline Safety\nEnclosure: Consent Order and Consent Agreement\ncc: Mr. Bryan Lethcoe, Director, Southwest Region, Office of Pipeline Safety, PHMSA\nAmy Willis, Director, Pipeline Safety Compliance, U.S. Natural Gas, TC Energy\n\n\n\nCorporation, amy_willis@tcenergy.com\nMr. Daniel Cerkoney, Senior Manager, Pipeline Safety Compliance, U.S. Natural Gas, TC\nEnergy Corporation, dan_cerkoney@tcenergy.com\nCONFIRMATION OF RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nColumbia Gas Transmission, LLC, ) CPF No. 4-2024-034-NOPV\na subsidiary of TC Energy Corp )\n)\n)\n)\nRespondent. )\n____________________________________)\nCONSENT ORDER\nBy letter dated August 27, 2024, pursuant to 49 CFR § 190.207, the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), issued a Notice of\nProbable Violation and Proposed Compliance Order (Notice) to Columbia Gas Transmission,\nLLC1 (Columbia Gas or Respondent).\nIn response to the Notice, Respondent contested one of the alleged violations and its associated\nproposed compliance actions, and did not request a hearing(Response). Columbia Gas also\nrequested to meet informally with PHMSA to discuss the matters raised in its Response.\nRespondent and PHMSA (the Parties) subsequently met on December 19, 2024. As a result of\nthose discussions, the Parties have agreed to a Consent Agreement by which PHMSA makes\nfindings of violations for each of the Items alleged in the Notice, and Respondent will complete\ncertain compliance actions.\nAccordingly, the Consent Agreement is hereby approved and incorporated by reference into this\nConsent Order issued pursuant to § 190.219. Columbia Gas is hereby ordered to comply with\nthe terms of the Consent Agreement pursuant to its terms. Pursuant to 49 U.S.C. § 60101, et\nseq., failure to comply with this Consent Order may result in the assessment of civil penalties as\nset forth in 49 U.S.C. § 60122 and 49 CFR § 190.223, or in referral to the Attorney General for\nappropriate relief in a district court of the United States.\nThe terms and conditions of this Consent Order are effective upon service in accordance with\n49 CFR § 190.5.\n______________________ ______________________\nLinda Daugherty Date Issued\nActing Associate Administrator\nfor Pipeline Safety\n1 Columbia Gas is a subsidiary of TC Energy Corporation.\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nColumbia Gas Transmission, LLC, ) CPF No. 4-2024-034-NOPV\na subsidiary of TC Energy Corp. )\n)\n)\n)\nRespondent. )\n____________________________________)\nCONSENT AGREEMENT\nFrom March 11 through 15, 2024, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of\nTitle 49, United States Code (U.S.C.), conducted an on-site pipeline safety inspection of the\nChesapeake LNG facility and records of Columbia Gas Transmission, LLC2 (Columbia Gas or\nRespondent) in Chesapeake, Virginia.\nAs a result of the inspection, the Director, Southwest Region, OPS (Director), issued to\nRespondent, by letter dated August 27, 2024, a Notice of Probable Violation and Proposed\nCompliance Order (Notice), which also included a warning pursuant to 49 CFR § 190.205. In\naccordance with 49 CFR § 190.207, the Notice proposed finding that Columbia Gas committed\none violation of 49 CFR Part 191 (Item 2), two violations of 49 CFR Part 193 (Items 1 and 4),\nand proposed ordering Respondent to take certain measures to correct the alleged violations.\nOther probable violations (Items 3 and 5) were brought as warnings, advising the operator to\ncorrect the probable violations or face potential future enforcement action.\nTC Energy Corporation (TC Energy) responded to the Notice on behalf of Columbia Gas by\nletter dated October 9, 2024 (Response). Respondent contested one of the alleged violations and\nthe proposed compliance order without requesting a hearing. Respondent also requested to meet\ninformally with PHMSA to discuss the matters raised in its Response.\nPHMSA and Respondent (the Parties) subsequently met to discuss the issues raised in the\nResponse on December 19, 2024 and April 7, 2025. As a result of those discussions and as\nexplained in more detail below, the Parties have agreed to a Consent Agreement by which\nPHMSA makes findings of violations for each of the Items alleged in the Notice, and\nRespondent will complete certain compliance actions.\n2 Columbia Gas is a subsidiary of TC Energy Corporation.\n\n\n\nHaving agreed that settlement of this proceeding will avoid further administrative proceedings or\nlitigation and will serve the public interest by promoting safety and protection of the\nenvironment, pursuant to 49 U.S.C. § 60101, et seq. and 49 CFR Part 190, and upon consent and\nagreement, the Parties hereby agree as follows:\nI. General Provisions\n1. Respondent acknowledges that as the operator of the pipeline facilities subject to\nthe Notice, Respondent and its referenced pipeline facilities are subject to the jurisdiction of the\nFederal pipeline safety laws, 49 U.S.C. § 60101, et seq., and the regulations and administrative\norders issued thereunder. For purposes of this Consent Agreement (Agreement), Respondent\nacknowledges that it received proper notice of PHMSA’s action in this proceeding and that the\nNotice states claims upon which relief may be granted pursuant to 49 U.S.C. § 60101, et seq.,\nand the regulations and orders issued thereunder.\n2. After Respondent returns this signed Agreement to PHMSA, the Agency’s\nrepresentative will present it to the Associate Administrator for Pipeline Safety, recommending\nthat the Associate Administrator adopt the terms of this Agreement by issuing an administrative\norder (Consent Order) incorporating the terms of this Agreement. The terms of this Agreement\nconstitute an offer of settlement until accepted by the Associate Administrator. Once accepted,\nthe Associate Administrator will issue a Consent Order incorporating the terms of this Agreement.\n3. Respondent consents to the issuance of the Consent Order, and hereby waives any\nfurther procedural requirements with respect to its issuance. Respondent waives all rights to\ncontest the adequacy of notice, or the validity of the Consent Order or this Agreement, including\nall rights to administrative or judicial hearings or appeals, except for the Dispute Resolution\nprovisions set forth herein. Respondent agrees to withdraw its request for an administrative\nhearing regarding the Notice.\n4. This Agreement shall apply to and be binding upon PHMSA and Respondent, its\nofficers, directors, and employees, and its successors, assigns, or other entities or persons\notherwise bound by law. Respondent agrees to provide a copy of this Agreement and any\nincorporated work plans and schedules to all of Respondent’s officers, employees, and agents\nwhose duties might reasonably include compliance with this Agreement.\n5. This Agreement constitutes the final, complete and exclusive agreement and\nunderstanding between the Parties with respect to the settlement embodied in this Agreement.\nThe Parties acknowledge that there are no representations, agreements or understandings relating\nto settlement other than those expressly contained in this Agreement, except that the terms of this\nAgreement may be construed by reference to the Notice.\n6. Nothing in this Agreement affects or relieves Respondent of its responsibility to\ncomply with all applicable requirements of the Federal pipeline safety laws, 49 U.S.C. § 60101,\net seq., and the regulations and orders issued thereunder. Nothing in this Agreement alters\nPHMSA's right of access, entry, inspection, and information gathering or PHMSA's authority to\n\n\n\nbring enforcement actions against Respondent pursuant to the Federal pipeline safety laws, the\nregulations and orders issued thereunder, or any other provision of Federal or State law.\n7. For all transfers of ownership or operating responsibility of Respondent’s pipeline\nsystem referenced herein, Respondent will provide a copy of this Agreement to the prospective\ntransferee at least 30 days prior to such transfer. Respondent will provide written notice of the\ntransfer to the Director no later than 60 days after the transfer occurs.\n8. This Agreement does not waive or modify any Federal, State, or local laws or\nregulations that are applicable to Respondent’s pipeline systems. This Agreement is not a\npermit, or a modification of any permit, under any Federal, State, or local laws or regulations.\nRespondent remains responsible for achieving and maintaining compliance with all applicable\nFederal, State, and local laws, regulations and permits.\n9. This Agreement does not create rights in, or grant any cause of action to, any third\nparty not party to this Agreement. The U.S. Department of Transportation is not liable for any\ninjuries or damages to persons or property arising from acts or omissions of Respondent or its\nofficers, employees, or agents carrying out the work required by this Agreement. Respondent\nagrees to hold harmless the U.S. Department of Transportation, its officers, employees, agents,\nand representatives from any and all causes of action arising from any acts or omissions of\nRespondent or its contractors in carrying out any work required by this Agreement.\n10. Except as set forth herein, this Agreement does not constitute a finding of\nviolation of any other federal law or regulation and may not be used in any civil proceeding of\nany kind as evidence or proof of any fact, fault or liability, or as evidence of a violation of any\nlaw, rule, regulation, or requirement, except in a proceeding to enforce the provisions of this\nAgreement or in future PHMSA enforcement actions.\nII. Findings of Violation:\n11. Item 1 - 49 CFR § 193.2503: The Notice alleged Columbia Gas failed to follow\none or more manuals of written procedures to provide safety in normal operation and in\nresponding to an abnormal operation that would affect safety in accordance with § 193.2503.\nSpecifically, the Notice alleged that Columbia Gas failed to follow section 4.7 of its LNG O&M\nManual Chesapeake; 193.2503 Operating Procedures (Operations) (US) (Rev. 4; Dec. 1, 2023),\nwhich included requirements for maintaining temperatures, pressures, pressure differentials and\nflow rates within its design limits because it operated above the stated maximum liquefaction\nrate of 5 MMCF/D. Respondent initially contested the allegation of violation and the associated\nProposed Compliance Order. Respondent provided additional information in its Response and\nduring settlement discussions, including records documenting the design basis of its feed\npretreatment and liquefaction system, and an analysis of its liquefaction system prepared by a\nthird-party engineering firm. As a result of those discussions, the Parties agree that PHMSA\nwill find a violation as alleged in the Notice and Columbia Gas will take alternative actions to\nremediate the violation. As such, PHMSA finds a violation of 49 CFR § 193.2503.\n12. Item 2 - 49 CFR § 191.17: The Notice alleged that Columbia Gas failed to submit\nan accurate annual report for calendar years 2021 and 2023 in accordance with § 191.17(b).\n\n\n\nSpecifically, the Notice alleged that Columbia Gas’s annual reports indicated a maximum daily\nliquefaction rate of 5 MMCF/D, but records reviewed during the inspection show that this daily rate\nwas exceeded. Respondent does not contest the allegation of violation as alleged in the Notice.\nAs such, PHMSA finds a violation of 49 CFR § 191.17.\n13. Item 4 - 49 CFR § 193.2801: The Notice alleged Columbia Gas failed to provide\nand maintain fire protection at its LNG plant according to sections 9.1 through 9.7 and section\n9.9 of NFPA-59A-2001 in accordance with § 193.2801. Specifically, the Notice alleged that\nColumbia Gas failed to provide fire protection as determined by an evaluation based on sound fire\nprotection engineering principles, analysis of local conditions, hazards within the facility, and\nexposure to or from other property in accordance with section 9.1.2 of NFPA-59A-2001.\nRespondent does not contest the allegation of violation as alleged in the Notice. As such,\nPHMSA finds a violation of 49 CFR § 193.2801.\n14. Items 1, 2, and 4 will be considered by PHMSA as prior offenses in any future\nPHMSA enforcement action taken against Respondent.\nIII. Warning Items:\n15. Item 3 - 49 CFR § 193.2503: The Notice alleged that Columbia Gas failed to\nfollow one or more manuals of written procedures to provide safety in normal operation and in\nresponding to an abnormal operation that would affect safety in accordance with § 193.2503.\nSpecifically, the Notice alleged that Columbia Gas failed to follow section 4.1 of its LNG O&M\nManual Chesapeake; 193.2611 Fire Protection. (Maintenance) (US) (Rev. 4; Dec. 1, 2023)\nwhich requires firewater pumps to be acceptance tested when installed or after major repairs.\nThis Item was brought as a warning Item and does not constitute a finding of violation.\nRespondent accepts the warning as alleged in the Notice.\n16. Item 5 - 49 CFR § 193.2505: The Notice alleged that Columbia Gas failed to\ncheck its cryogenic piping systems for leaks in areas of flanges, valves, and seals after cooldown\nstabilization was reached in accordance with § 193.2505(b). Specifically, the notice alleged that\nColumbia Gas failed to provide records indicating that leak checks were performed after\ncooldown stabilization of the vaporizer between November 27 and 28, 2023. This Item was\nbrought as a warning Item and does not constitute a finding of violation. Respondent accepts the\nwarning as alleged in the Notice.\n17. For Warning Items 3 and 5, if OPS finds a violation of these provisions in a\nsubsequent inspection, Respondent may be subject to future enforcement action.\nV. Compliance Order:\n18. Item 1: The Notice proposed certain compliance order actions to address the non-\ncompliance alleged in the Notice. Respondent initially contested the Proposed Compliance\nOrder. Following informal discussions, the Parties agreed to modify the proposed compliance\nactions for Item 1. As such, Respondent agrees to undertake the following corrective measures:\n\n\n\na. b. c. d. e. Revise its manuals of written procedures to update maximum refrigerant flow\nrates, maximum refrigerant suction pressure, and maximum amps on the driver\nfor the refrigerant compressor. The revised procedures must include procedural\nsafeguards to ensure that operating parameters are not exceeded. In addition,\nColumbia Gas agrees to post the revised procedures in its Control Center for\ncontrollers and operations personnel to easily reference. Columbia Gas must\nsubmit its updated procedures to the Director within 180 days after the Effective\nDate of this Agreement.\nIdentify the normal range operating values for liquefaction equipment, and\nidentify out of normal range operating values as abnormal operation conditions in\nthe liquefaction system. Columbia Gas must submit a report of its identification\nof normal operating ranges and designation of out of normal operating ranges as\nabnormal operation conditions to the Director within 180 days after the Effective\nDate of this Agreement.\nDevelop a uniform measurement methodology to determine if current operating\nparameters are outside of the normal range of operating values. This\ndetermination must take into account current operating parameters and include all\nadditional instruments readings and redundant information on key design\nparameters for the liquefaction system. Columbia Gas must submit its\nmethodology for approval by the Director within 180 days after the Effective Date\nof this Agreement.\nTrain all controllers and operations personnel on the revised liquefaction\noperating procedures, abnormal operation conditions, and measurement\nmethodology described in subparagraphs (a) – (c). Columbia Gas must complete\ntraining of all personnel within 180 days after receiving the Director’s approval of\nthe methodology developed under subparagraph (c), and submit training records\nto the Director within 30 days of completing training.\nEvaluate all liquefaction equipment and components to determine whether the\nequipment and components are operating within design parameters, and repair all\ninstruments that are determined to be not correctly operating within 180 days after\nthe Effective Date of this Agreement. Columbia Gas must submit a report\ndetailing the evaluation and any repair records to Director within 30 days after all\nrepairs are made in accordance with this Corrective Measure. If Columbia Gas\ndetermines that any repairs will take longer than 180 days to complete, Columbia\nGas will provide in its report to the Director justification for the delay and a\nschedule for completing the repair.\n19. Item 2: The Notice proposed certain compliance order actions to address the non-\ncompliance alleged in the Notice. Respondent did not contest the Proposed Compliance Order\n\n\n\nand has completed the actions proposed. Specifically, Respondent revised and re-submitted the\nannual reports for 2021 and 2023 to reflect its production records to PHMSA and provided\ncopies to the Director, Southwest Region on May 14, 2025.\n20. Item 4: The Notice proposed certain compliance order actions to address the non-\ncompliance alleged in the Notice. Respondent did not contest the Proposed Compliance Order\nand has completed the actions proposed. Specifically, Respondent revised its written procedure\nto require an annual fire water flushing and provided the revised procedure to the Director,\nSouthwest Region on May 14, 2025.\nVI. Enforcement:\n21. This Agreement is subject to all enforcement authorities available to PHMSA\nunder 49 U.S.C. § 60101, et seq., and 49 CFR Part 190, including administrative civil penalties\nunder 49 U.S.C. § 60122, of up to $272,926 per violation for each day the violation continues and\nreferral of the case to the Attorney General for judicial enforcement, if PHMSA determines that\nRespondent is not complying with the terms of this Agreement in accordance with the\ndeterminations made by the Director, or in accordance with decisions of the Associate\nAdministrator if resolved pursuant to the Dispute Resolution process herein. The maximum civil\npenalty amounts are adjusted annually for inflation. See 49 CFR § 190.223. All work plans and\nassociated schedules set forth or referenced in Section V (Compliance Order) are automatically\nincorporated into this Agreement and are enforceable in the same manner.\nVII. Review and Approval Process:\n22. With respect to any submission under Section V (Compliance Order) of this\nAgreement that requires the approval of the Director, the Director may: (a) approve, in whole or\nin part, the submission; (b) approve the submission on specified, reasonable conditions; (c)\ndisapprove, in whole or in part, the submission; or (d) any combination of the foregoing. If the\nDirector approves, approves in part, or approves with conditions, Respondent will take all\nactions as approved by the Director, subject to Respondent’s right to invoke the dispute\nresolution procedures with respect to any conditions the Director identifies. If the Director\ndisapproves all or any portion of the submission, the Director will provide Respondent a written\nnotice of the deficiencies. Respondent will correct all deficiencies within the time specified by\nthe Director and resubmit it for approval.\nVIII. Dispute Resolution:\n23. The Director and Respondent will informally attempt to resolve any disputes\narising under this Agreement, including any decision of the Director under the terms of Sections\nV (Compliance Order) and VII (Review and Approval Process). If Respondent and the Director\nare unable to informally resolve the dispute within 15 calendar days after the dispute is first\nraised, in writing, to the Director, Respondent may submit a written request for a determination\nresolving the dispute from the Associate Administrator. Such request must be made in writing\nand provided to the Director, counsel for the Southwest Region, and to the Associate\nAdministrator, no later than 10 calendar days from the 15-day deadline for informal resolution\nreferenced in this paragraph. Along with its request, Respondent must provide the Associate\n\n\n\nAdministrator with all information Respondent believes is relevant to the dispute. Decisions of\nthe Associate Administrator under this paragraph will constitute final agency action. The\nexistence of a dispute and PHMSA’s consideration of matters placed in dispute will not excuse,\ntoll, or suspend any term or timeframe for completion of any work to be performed under this\nAgreement during the pendency of the dispute resolution process.\nIX. Effective Date:\n24. The term “Effective Date,” as used herein, is the date on which the Consent Order\nis issued by the Associate Administrator incorporating the terms of this Agreement.\nX. Recordkeeping and Information Disclosure:\n25. Unless otherwise required in this Agreement, Respondent agrees to maintain\nrecords demonstrating compliance with all requirements of this Agreement for a period of at\nleast five (5) years following completion of all work to be performed, unless a longer period of\ntime is required pursuant to 49 CFR parts 190-199. For any reports, plans, or other deliverables\nrequired to be submitted to PHMSA pursuant to this Agreement, Respondent may assert a claim\nof business confidentiality or other protections applicable to the release of information by\nPHMSA, covering part or all of the information required to be submitted to PHMSA pursuant to\nthis Agreement in accordance with 49 CFR Part 7. Respondent must mark the claim of\nconfidentiality in writing on each page, and include a statement specifying the grounds for each\nclaim of confidentially. PHMSA determines release of any information submitted pursuant to\nthis Agreement in accordance with 49 CFR Part 7, the Freedom of Information Act, 5 U.S.C. §\n552, DOT and PHMSA policies, and other applicable regulations and Executive Orders.\nXI. Modification:\n26. The terms of this Agreement may be modified by mutual agreement of the Parties.\nSuch modifications must be in writing and signed by both parties.\nXII. Termination:\n27. This Agreement will remain in effect until the Compliance Order in Section V is\nsatisfied, as determined by the Director. The Agreement shall not terminate until the Director\nconfirms, in writing, that the Agreement is terminated in accordance with this paragraph.\nNothing in this Agreement prevents Respondent from completing any of the obligations earlier\nthan the deadlines provided for in this Agreement.\nXIII. Ratification:\n28. The Parties’ undersigned representatives certify that they are fully authorized to\nenter into the terms and conditions of this Agreement and to execute and legally bind such party\nto this document.\n29. The Parties hereby agree to all findings, conditions, and terms of this Agreement.\n\n\n\n[Signature Lines on Following Page]\n\n\n\nFor Columbia Gas Transmission, LLC:\n___________________________________\nBrianne Metzger-Doran, Vice President, TC Energy\n________________________\nDate\nFor PHMSA:\n________________________________________\nBryan Lethcoe, Director, Southwest Region, Office of Pipeline Safety\n________________________\nDate","truncated":false,"body_characters":27702}