# COLUMBIA GAS TRANSMISSION, LLC — Notice of Probable Violation

- **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:** Not available
- **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.

Official case documents:

42024034NOPV_Closure Letter_07102026_(24-299840).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024034NOPV/42024034NOPV_Closure%20Letter_07102026_(24-299840).pdf

42024034NOPV_Closure Letter_07102026_(24-299840)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024034NOPV/42024034NOPV_Closure%20Letter_07102026_(24-299840)_text.pdf

42024034NOPV_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

42024034NOPV_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

42024034NOPV_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

42024034NOPV_PCO_08272024_(24-299840).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024034NOPV/42024034NOPV_PCO_08272024_(24-299840).pdf

42024034NOPV_PCO_08272024_(24-299840)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024034NOPV/42024034NOPV_PCO_08272024_(24-299840)_text.pdf

42024034NOPV_Closure Letter_07102026_(24-299840)_text.pdf

U.S. Department
of Transportation
Pipeline and
Hazardous Materials
Safety Administration
8701 S. Gessner, Suite 630
Houston TX 77074
VIA ELECTRONIC MAIL TO: tina_faraca@tcenergy.com
July 10, 2026
Tina Faraca
Executive Vice President & President
Columbia Gas Transmission, LLC
700 Louisiana Street, Suite 700
Houston, Texas 77002
CPF 4-2024-034-NOPV
Dear Ms. Faraca:
On July 9, 2025, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to
Columbia Gas Transmission, LLC, (a TC Energy subsidiary), Consent Order in the above-
referenced case. This Order included a Compliance Order requirement to amend your procedures
and the requirement to take corrective actions on your LNG Facility.
Based on our review of the documentation you provided, it has been determined that you have
complied with the terms of this Order.
Accordingly, this case is now closed, and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
R. M. Seeley
Acting Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Dan Cerkoney, Sr. Manager, Regulatory Compliance, Columbia Gas Transmission, LLC,
dan_cerkoney@tcenergy.com
Andrew Kohout, Director, Division of LNG Facility Reviews and Inspections Office of
Energy Projects, Federal Energy Regulatory Commission,
Andrew.Kohout@ferc.gov

42024034NOPV_Consent Agreement and Order_07092025_(24-299840)_text.pdf

July 9, 2025
VIA ELECTRONIC MAIL TO: tina faraca@tcenergy.com
Tina Faraca
Executive Vice President & President
U.S. Natural Gas Pipelines
TC Energy Corporation
700 Louisiana Street
Houston, Texas 77002
CPF No. 4-2024-034-NOPV
Dear Ms. Faraca:
Enclosed please find a Consent Order incorporating the terms of the Consent Agreement between
the Pipeline and Hazardous Materials Safety Administration (PHMSA) and Columbia Gas
Transmission, LLC, which was executed on June 23, 2025. Service of the Consent Order and
Consent Agreement by electronic mail is deemed effective upon the date of transmission and
acknowledgement of receipt, or as otherwise provided under 49 CFR § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Linda Daugherty
Acting Associate Administrator
for Pipeline Safety
Enclosure: Consent Order and Consent Agreement
cc: Mr. Bryan Lethcoe, Director, Southwest Region, Office of Pipeline Safety, PHMSA
Amy Willis, Director, Pipeline Safety Compliance, U.S. Natural Gas, TC Energy



Corporation, amy_willis@tcenergy.com
Mr. Daniel Cerkoney, Senior Manager, Pipeline Safety Compliance, U.S. Natural Gas, TC
Energy Corporation, dan_cerkoney@tcenergy.com
CONFIRMATION OF RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Columbia Gas Transmission, LLC, ) CPF No. 4-2024-034-NOPV
a subsidiary of TC Energy Corp )
)
)
)
Respondent. )
____________________________________)
CONSENT ORDER
By letter dated August 27, 2024, pursuant to 49 CFR § 190.207, the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), issued a Notice of
Probable Violation and Proposed Compliance Order (Notice) to Columbia Gas Transmission,
LLC1 (Columbia Gas or Respondent).
In response to the Notice, Respondent contested one of the alleged violations and its associated
proposed compliance actions, and did not request a hearing(Response). Columbia Gas also
requested to meet informally with PHMSA to discuss the matters raised in its Response.
Respondent and PHMSA (the Parties) subsequently met on December 19, 2024. As a result of
those discussions, the Parties have agreed to a Consent Agreement by which PHMSA makes
findings of violations for each of the Items alleged in the Notice, and Respondent will complete
certain compliance actions.
Accordingly, the Consent Agreement is hereby approved and incorporated by reference into this
Consent Order issued pursuant to § 190.219. Columbia Gas is hereby ordered to comply with
the terms of the Consent Agreement pursuant to its terms. Pursuant to 49 U.S.C. § 60101, et
seq., failure to comply with this Consent Order may result in the assessment of civil penalties as
set forth in 49 U.S.C. § 60122 and 49 CFR § 190.223, or in referral to the Attorney General for
appropriate relief in a district court of the United States.
The terms and conditions of this Consent Order are effective upon service in accordance with
49 CFR § 190.5.
______________________ ______________________
Linda Daugherty Date Issued
Acting Associate Administrator
for Pipeline Safety
1 Columbia Gas is a subsidiary of TC Energy Corporation.



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Columbia Gas Transmission, LLC, ) CPF No. 4-2024-034-NOPV
a subsidiary of TC Energy Corp. )
)
)
)
Respondent. )
____________________________________)
CONSENT AGREEMENT
From March 11 through 15, 2024, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of
Title 49, United States Code (U.S.C.), conducted an on-site pipeline safety inspection of the
Chesapeake LNG facility and records of Columbia Gas Transmission, LLC2 (Columbia Gas or
Respondent) in Chesapeake, Virginia.
As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to
Respondent, by letter dated August 27, 2024, a Notice of Probable Violation and Proposed
Compliance Order (Notice), which also included a warning pursuant to 49 CFR § 190.205. In
accordance with 49 CFR § 190.207, the Notice proposed finding that Columbia Gas committed
one violation of 49 CFR Part 191 (Item 2), two violations of 49 CFR Part 193 (Items 1 and 4),
and proposed ordering Respondent to take certain measures to correct the alleged violations.
Other probable violations (Items 3 and 5) were brought as warnings, advising the operator to
correct the probable violations or face potential future enforcement action.
TC Energy Corporation (TC Energy) responded to the Notice on behalf of Columbia Gas by
letter dated October 9, 2024 (Response). Respondent contested one of the alleged violations and
the proposed compliance order without requesting a hearing. Respondent also requested to meet
informally with PHMSA to discuss the matters raised in its Response.
PHMSA and Respondent (the Parties) subsequently met to discuss the issues raised in the
Response on December 19, 2024 and April 7, 2025. As a result of those discussions and as
explained in more detail below, the Parties have agreed to a Consent Agreement by which
PHMSA makes findings of violations for each of the Items alleged in the Notice, and
Respondent will complete certain compliance actions.
2 Columbia Gas is a subsidiary of TC Energy Corporation.



Having agreed that settlement of this proceeding will avoid further administrative proceedings or
litigation and will serve the public interest by promoting safety and protection of the
environment, pursuant to 49 U.S.C. § 60101, et seq. and 49 CFR Part 190, and upon consent and
agreement, the Parties hereby agree as follows:
I. General Provisions
1. Respondent acknowledges that as the operator of the pipeline facilities subject to
the Notice, Respondent and its referenced pipeline facilities are subject to the jurisdiction of the
Federal pipeline safety laws, 49 U.S.C. § 60101, et seq., and the regulations and administrative
orders issued thereunder. For purposes of this Consent Agreement (Agreement), Respondent
acknowledges that it received proper notice of PHMSA’s action in this proceeding and that the
Notice states claims upon which relief may be granted pursuant to 49 U.S.C. § 60101, et seq.,
and the regulations and orders issued thereunder.
2. After Respondent returns this signed Agreement to PHMSA, the Agency’s
representative will present it to the Associate Administrator for Pipeline Safety, recommending
that the Associate Administrator adopt the terms of this Agreement by issuing an administrative
order (Consent Order) incorporating the terms of this Agreement. The terms of this Agreement
constitute an offer of settlement until accepted by the Associate Administrator. Once accepted,
the Associate Administrator will issue a Consent Order incorporating the terms of this Agreement.
3. Respondent consents to the issuance of the Consent Order, and hereby waives any
further procedural requirements with respect to its issuance. Respondent waives all rights to
contest the adequacy of notice, or the validity of the Consent Order or this Agreement, including
all rights to administrative or judicial hearings or appeals, except for the Dispute Resolution
provisions set forth herein. Respondent agrees to withdraw its request for an administrative
hearing regarding the Notice.
4. This Agreement shall apply to and be binding upon PHMSA and Respondent, its
officers, directors, and employees, and its successors, assigns, or other entities or persons
otherwise bound by law. Respondent agrees to provide a copy of this Agreement and any
incorporated work plans and schedules to all of Respondent’s officers, employees, and agents
whose duties might reasonably include compliance with this Agreement.
5. This Agreement constitutes the final, complete and exclusive agreement and
understanding between the Parties with respect to the settlement embodied in this Agreement.
The Parties acknowledge that there are no representations, agreements or understandings relating
to settlement other than those expressly contained in this Agreement, except that the terms of this
Agreement may be construed by reference to the Notice.
6. Nothing in this Agreement affects or relieves Respondent of its responsibility to
comply with all applicable requirements of the Federal pipeline safety laws, 49 U.S.C. § 60101,
et seq., and the regulations and orders issued thereunder. Nothing in this Agreement alters
PHMSA's right of access, entry, inspection, and information gathering or PHMSA's authority to



bring enforcement actions against Respondent pursuant to the Federal pipeline safety laws, the
regulations and orders issued thereunder, or any other provision of Federal or State law.
7. For all transfers of ownership or operating responsibility of Respondent’s pipeline
system referenced herein, Respondent will provide a copy of this Agreement to the prospective
transferee at least 30 days prior to such transfer. Respondent will provide written notice of the
transfer to the Director no later than 60 days after the transfer occurs.
8. This Agreement does not waive or modify any Federal, State, or local laws or
regulations that are applicable to Respondent’s pipeline systems. This Agreement is not a
permit, or a modification of any permit, under any Federal, State, or local laws or regulations.
Respondent remains responsible for achieving and maintaining compliance with all applicable
Federal, State, and local laws, regulations and permits.
9. This Agreement does not create rights in, or grant any cause of action to, any third
party not party to this Agreement. The U.S. Department of Transportation is not liable for any
injuries or damages to persons or property arising from acts or omissions of Respondent or its
officers, employees, or agents carrying out the work required by this Agreement. Respondent
agrees to hold harmless the U.S. Department of Transportation, its officers, employees, agents,
and representatives from any and all causes of action arising from any acts or omissions of
Respondent or its contractors in carrying out any work required by this Agreement.
10. Except as set forth herein, this Agreement does not constitute a finding of
violation of any other federal law or regulation and may not be used in any civil proceeding of
any kind as evidence or proof of any fact, fault or liability, or as evidence of a violation of any
law, rule, regulation, or requirement, except in a proceeding to enforce the provisions of this
Agreement or in future PHMSA enforcement actions.
II. Findings of Violation:
11. Item 1 - 49 CFR § 193.2503: The Notice alleged Columbia Gas failed to follow
one or more manuals of written procedures to provide safety in normal operation and in
responding to an abnormal operation that would affect safety in accordance with § 193.2503.
Specifically, the Notice alleged that Columbia Gas failed to follow section 4.7 of its LNG O&M
Manual Chesapeake; 193.2503 Operating Procedures (Operations) (US) (Rev. 4; Dec. 1, 2023),
which included requirements for maintaining temperatures, pressures, pressure differentials and
flow rates within its design limits because it operated above the stated maximum liquefaction
rate of 5 MMCF/D. Respondent initially contested the allegation of violation and the associated
Proposed Compliance Order. Respondent provided additional information in its Response and
during settlement discussions, including records documenting the design basis of its feed
pretreatment and liquefaction system, and an analysis of its liquefaction system prepared by a
third-party engineering firm. As a result of those discussions, the Parties agree that PHMSA
will find a violation as alleged in the Notice and Columbia Gas will take alternative actions to
remediate the violation. As such, PHMSA finds a violation of 49 CFR § 193.2503.
12. Item 2 - 49 CFR § 191.17: The Notice alleged that Columbia Gas failed to submit
an accurate annual report for calendar years 2021 and 2023 in accordance with § 191.17(b).



Specifically, the Notice alleged that Columbia Gas’s annual reports indicated a maximum daily
liquefaction rate of 5 MMCF/D, but records reviewed during the inspection show that this daily rate
was exceeded. Respondent does not contest the allegation of violation as alleged in the Notice.
As such, PHMSA finds a violation of 49 CFR § 191.17.
13. Item 4 - 49 CFR § 193.2801: The Notice alleged Columbia Gas failed to provide
and maintain fire protection at its LNG plant according to sections 9.1 through 9.7 and section
9.9 of NFPA-59A-2001 in accordance with § 193.2801. Specifically, the Notice alleged that
Columbia Gas failed to provide fire protection as determined by an evaluation based on sound fire
protection engineering principles, analysis of local conditions, hazards within the facility, and
exposure to or from other property in accordance with section 9.1.2 of NFPA-59A-2001.
Respondent does not contest the allegation of violation as alleged in the Notice. As such,
PHMSA finds a violation of 49 CFR § 193.2801.
14. Items 1, 2, and 4 will be considered by PHMSA as prior offenses in any future
PHMSA enforcement action taken against Respondent.
III. Warning Items:
15. Item 3 - 49 CFR § 193.2503: The Notice alleged that Columbia Gas failed to
follow one or more manuals of written procedures to provide safety in normal operation and in
responding to an abnormal operation that would affect safety in accordance with § 193.2503.
Specifically, the Notice alleged that Columbia Gas failed to follow section 4.1 of its LNG O&M
Manual Chesapeake; 193.2611 Fire Protection. (Maintenance) (US) (Rev. 4; Dec. 1, 2023)
which requires firewater pumps to be acceptance tested when installed or after major repairs.
This Item was brought as a warning Item and does not constitute a finding of violation.
Respondent accepts the warning as alleged in the Notice.
16. Item 5 - 49 CFR § 193.2505: The Notice alleged that Columbia Gas failed to
check its cryogenic piping systems for leaks in areas of flanges, valves, and seals after cooldown
stabilization was reached in accordance with § 193.2505(b). Specifically, the notice alleged that
Columbia Gas failed to provide records indicating that leak checks were performed after
cooldown stabilization of the vaporizer between November 27 and 28, 2023. This Item was
brought as a warning Item and does not constitute a finding of violation. Respondent accepts the
warning as alleged in the Notice.
17. For Warning Items 3 and 5, if OPS finds a violation of these provisions in a
subsequent inspection, Respondent may be subject to future enforcement action.
V. Compliance Order:
18. Item 1: The Notice proposed certain compliance order actions to address the non-
compliance alleged in the Notice. Respondent initially contested the Proposed Compliance
Order. Following informal discussions, the Parties agreed to modify the proposed compliance
actions for Item 1. As such, Respondent agrees to undertake the following corrective measures:



a. b. c. d. e. Revise its manuals of written procedures to update maximum refrigerant flow
rates, maximum refrigerant suction pressure, and maximum amps on the driver
for the refrigerant compressor. The revised procedures must include procedural
safeguards to ensure that operating parameters are not exceeded. In addition,
Columbia Gas agrees to post the revised procedures in its Control Center for
controllers and operations personnel to easily reference. Columbia Gas must
submit its updated procedures to the Director within 180 days after the Effective
Date of this Agreement.
Identify the normal range operating values for liquefaction equipment, and
identify out of normal range operating values as abnormal operation conditions in
the liquefaction system. Columbia Gas must submit a report of its identification
of normal operating ranges and designation of out of normal operating ranges as
abnormal operation conditions to the Director within 180 days after the Effective
Date of this Agreement.
Develop a uniform measurement methodology to determine if current operating
parameters are outside of the normal range of operating values. This
determination must take into account current operating parameters and include all
additional instruments readings and redundant information on key design
parameters for the liquefaction system. Columbia Gas must submit its
methodology for approval by the Director within 180 days after the Effective Date
of this Agreement.
Train all controllers and operations personnel on the revised liquefaction
operating procedures, abnormal operation conditions, and measurement
methodology described in subparagraphs (a) – (c). Columbia Gas must complete
training of all personnel within 180 days after receiving the Director’s approval of
the methodology developed under subparagraph (c), and submit training records
to the Director within 30 days of completing training.
Evaluate all liquefaction equipment and components to determine whether the
equipment and components are operating within design parameters, and repair all
instruments that are determined to be not correctly operating within 180 days after
the Effective Date of this Agreement. Columbia Gas must submit a report
detailing the evaluation and any repair records to Director within 30 days after all
repairs are made in accordance with this Corrective Measure. If Columbia Gas
determines that any repairs will take longer than 180 days to complete, Columbia
Gas will provide in its report to the Director justification for the delay and a
schedule for completing the repair.
19. Item 2: The Notice proposed certain compliance order actions to address the non-
compliance alleged in the Notice. Respondent did not contest the Proposed Compliance Order



and has completed the actions proposed. Specifically, Respondent revised and re-submitted the
annual reports for 2021 and 2023 to reflect its production records to PHMSA and provided
copies to the Director, Southwest Region on May 14, 2025.
20. Item 4: The Notice proposed certain compliance order actions to address the non-
compliance alleged in the Notice. Respondent did not contest the Proposed Compliance Order
and has completed the actions proposed. Specifically, Respondent revised its written procedure
to require an annual fire water flushing and provided the revised procedure to the Director,
Southwest Region on May 14, 2025.
VI. Enforcement:
21. This Agreement is subject to all enforcement authorities available to PHMSA
under 49 U.S.C. § 60101, et seq., and 49 CFR Part 190, including administrative civil penalties
under 49 U.S.C. § 60122, of up to $272,926 per violation for each day the violation continues and
referral of the case to the Attorney General for judicial enforcement, if PHMSA determines that
Respondent is not complying with the terms of this Agreement in accordance with the
determinations made by the Director, or in accordance with decisions of the Associate
Administrator if resolved pursuant to the Dispute Resolution process herein. The maximum civil
penalty amounts are adjusted annually for inflation. See 49 CFR § 190.223. All work plans and
associated schedules set forth or referenced in Section V (Compliance Order) are automatically
incorporated into this Agreement and are enforceable in the same manner.
VII. Review and Approval Process:
22. With respect to any submission under Section V (Compliance Order) of this
Agreement that requires the approval of the Director, the Director may: (a) approve, in whole or
in part, the submission; (b) approve the submission on specified, reasonable conditions; (c)
disapprove, in whole or in part, the submission; or (d) any combination of the foregoing. If the
Director approves, approves in part, or approves with conditions, Respondent will take all
actions as approved by the Director, subject to Respondent’s right to invoke the dispute
resolution procedures with respect to any conditions the Director identifies. If the Director
disapproves all or any portion of the submission, the Director will provide Respondent a written
notice of the deficiencies. Respondent will correct all deficiencies within the time specified by
the Director and resubmit it for approval.
VIII. Dispute Resolution:
23. The Director and Respondent will informally attempt to resolve any disputes
arising under this Agreement, including any decision of the Director under the terms of Sections
V (Compliance Order) and VII (Review and Approval Process). If Respondent and the Director
are unable to informally resolve the dispute within 15 calendar days after the dispute is first
raised, in writing, to the Director, Respondent may submit a written request for a determination
resolving the dispute from the Associate Administrator. Such request must be made in writing
and provided to the Director, counsel for the Southwest Region, and to the Associate
Administrator, no later than 10 calendar days from the 15-day deadline for informal resolution
referenced in this paragraph. Along with its request, Respondent must provide the Associate



Administrator with all information Respondent believes is relevant to the dispute. Decisions of
the Associate Administrator under this paragraph will constitute final agency action. The
existence of a dispute and PHMSA’s consideration of matters placed in dispute will not excuse,
toll, or suspend any term or timeframe for completion of any work to be performed under this
Agreement during the pendency of the dispute resolution process.
IX. Effective Date:
24. The term “Effective Date,” as used herein, is the date on which the Consent Order
is issued by the Associate Administrator incorporating the terms of this Agreement.
X. Recordkeeping and Information Disclosure:
25. Unless otherwise required in this Agreement, Respondent agrees to maintain
records demonstrating compliance with all requirements of this Agreement for a period of at
least five (5) years following completion of all work to be performed, unless a longer period of
time is required pursuant to 49 CFR parts 190-199. For any reports, plans, or other deliverables
required to be submitted to PHMSA pursuant to this Agreement, Respondent may assert a claim
of business confidentiality or other protections applicable to the release of information by
PHMSA, covering part or all of the information required to be submitted to PHMSA pursuant to
this Agreement in accordance with 49 CFR Part 7. Respondent must mark the claim of
confidentiality in writing on each page, and include a statement specifying the grounds for each
claim of confidentially. PHMSA determines release of any information submitted pursuant to
this Agreement in accordance with 49 CFR Part 7, the Freedom of Information Act, 5 U.S.C. §
552, DOT and PHMSA policies, and other applicable regulations and Executive Orders.
XI. Modification:
26. The terms of this Agreement may be modified by mutual agreement of the Parties.
Such modifications must be in writing and signed by both parties.
XII. Termination:
27. This Agreement will remain in effect until the Compliance Order in Section V is
satisfied, as determined by the Director. The Agreement shall not terminate until the Director
confirms, in writing, that the Agreement is terminated in accordance with this paragraph.
Nothing in this Agreement prevents Respondent from completing any of the obligations earlier
than the deadlines provided for in this Agreement.
XIII. Ratification:
28. The Parties’ undersigned representatives certify that they are fully authorized to
enter into the terms and conditions of this Agreement and to execute and legally bind such party
to this document.
29. The Parties hereby agree to all findings, conditions, and terms of this Agreement.



[Signature Lines on Following Page]



For Columbia Gas Transmission, LLC:
___________________________________
Brianne Metzger-Doran, Vice President, TC Energy
________________________
Date
For PHMSA:
________________________________________
Bryan Lethcoe, Director, Southwest Region, Office of Pipeline Safety
________________________
Date
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