{"operation":"document","citation":"CPF 120031007H","title":"EASTERN GAS TRANSMISSION AND STORAGE, INC. — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2003-10-20","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120031007h.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120031007h.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120031007h","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120031007H","body":"Corrective Action Order involving EASTERN GAS TRANSMISSION AND STORAGE, INC.. The dataset does not identify a cited regulation for this case. The case was opened on 2003-10-20 and is reported as closed as of 2004-07-12. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120031007H_Corrective Action Order_10202003.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120031007H/120031007H_Corrective%20Action%20Order_10202003.pdf\n\n120031007h_corrective action order_10202003_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120031007H/120031007h_corrective%20action%20order_10202003_text.pdf\n\n120031007h_corrective action order_10202003_text.pdf\n\nU 5 Department\nof Transportats0n\nResearch and\nSpecial Programs\nAdministration\n400 sevenlh sl 5 w\nWaahingfon O C 20590\nOCT 20 2003\nMr Jeftrey L Barger\nVice President, Pipehne Operations\nDomuuon Transmission, Inc\n445 West Main Street\nClarksburg, WV 26301\nRe CPF No !-2003-1007-H\nDear Mr Barger\nEnclosed is a Corrective Action Order issued by the Associate Administrator for Pipeline\nSafety in the above-referenced case It requires you to take certain correcnve actions with respect\nto the operation o f your pipehne\nService is being made by certified mail and facsimile Your receipt of the enclosed document\nconstitutes service of that document The terms and conrhtions of tlus Corrective Action Order are\neffective upon receipt\nPipehne Compliance Registry\nOffice of Pipehne Safety\nEnclosure\nVIA CERTIFIED MAIL TURN RECEIPT RE UESTED AND TELECOPY\n\n\n\nDEPARTMENT OF TRANSPORTATION\nRESEARCH AND SPECIAL PROGRAMS ADMINISTRATION\nWASHINGTON, DC 20590\nIn the Matter of\nDominion Transmission, Inc.\n,\nRespondent. CPF No. 1-2003-1007-H\nCORRECTIVE ACTION ORDER\nPur ose and Back round\nThis Corrective Action Order is being issued, under authority of 49 U S C ( 60112, to reqiure\nDonumon Transmission, Inc (Respondent) to take the necessary corrective action to protect the\npublic and environment from potential hazards associated with Respondent's Ham son Storage Field\nm Potter County, Pennsylvama Pursuant to 49 U S C II 60117, the Eastern Region, Office of\nPipehne Safety (OPS), initiated an investigation of the failure\nPrehminar Fmdin s\nAbout 2 22 p m on October 10, 2003, a failure occurred m Respondent's HP 20 6-inch Line\nto Well H W7 within the Harrison Storage Field in Potter County, Pennsylvania\nThe failure resulted in a release of natural gas and a fire A trailer, car, and garage were\ndamaged Residents were not at home There were no deaths or in]uries\nFollowing the failure, Respondent isolated the HP 20 6-inch Line by closing valves\nRespondent cut out a 2-3 foot segment of pipehne that contained the failed pipe and sent the\nsegment to Ktefner & Associates Inc for metallurgical analysis Respondent took the HP\n20 6-inch Line out of service and tnchcated that it mtends to replace the line\nThe failure was a full circumferential rupture Respondent indicated to OPS staff that it\nsuspected corrosion (internal or external) as the probable cause Photographs of the failed\nsegment indicate some corrosion pitting and discoloration on the inside of the pipe that could\nbe mdicative of internal corrosion The metallurgical report should indicate the cause\n\n\n\nThe maximum allowable operating pressure (MAOP) of the storage field is 2200 psig (about\n56 lo of the specified minunum yield strength), which was established based on the lughest\nactual operating pressure The HP 20 6-inch Line was operating at 2124 psig at the time of\nfailure\nThe Harrison Storage Field is composed of three mainhnes and forty-three well lines,\nincluding the HP 20 6-inch Lme A smgle compressor station is used for moving gas\nthroughout the storage field\nAt the time of failure, Respondent was injecting gas into the storage pool of the Hamson\nStorage Field It is estimated to be about 95 '/o full Because of the amount of gas already\nin storage, the m]ection operation requires virtually full MAOP\nThe Hamson Storage Field is m a rural area, likely Class 1 However, Respondent indicates\nthat there are about 15 houses near the field Although the actual proximity of the houses is\nnot known, the damaged trailer was about 300 feet from the rupture\nBased on the information available at this time, the HP 20 6-inch Lme is made of seamless\npipe of 0 312\" wall tluckness, pipe grade X-42, of unknown manufacturer The hne was\ninstalled in 1955 and is bare It contains about 937 feet of pipe\nThere was a corrosion leak on another 6-inch well lme within the Hamson Storage Field in\nAugust 1995 The cause was external corrosion that resulted from tlnrd party damage to the\npipeline\nThere was an mternal corrosion leak in a drip on an 8-inch well hne within the Harrison\nStorage Field m August 2000 Respondent has a four-year drip removal program that will\nbe completed next year Eighteen drips have been removed so far\nThe well pipehnes m the Hamson Storage Field have never been pressure tested or internally\nmspected using an mstrumented device A large part, if not all, of the lines are bare They\nare cathodically protected by impressed current A close interval survey was done in\nSeptember 2002 The report sent to Respondent in February 2003, did not indicate any\ndeficiencies m HP 20 6-inch Line at the site of the failure However, as a result of the\nsurvey, Respondent mstalled an additional 22 anodes on the well pipelines to support the\ncathodic protection system\nDetermination of Necessi for Corrective Action Order and Ri ht to Hearin\nSection 60112 of Title 49, Uruted States Code, provides for the issuance of a Corrective Action\nOrder, after reasonable notice and the opportunity for a hearing, requiring corrective action, which\nmay include the suspended or restncted use of a pipeline facihty, physical inspection, testing, repair,\nre lacement or other action as appropnate The basis for making the determination that a pipehne\nfacihty is hazardous, requiring corrective action, is set forth both in the above referenced statute an\n49 C F R $190 233, a copy of which is enclosed\n\n\n\nSection 60112, and the regulations promulgated thereunder, provides for the issuance of a Corrective\nAction Order without prior opportunity for notice and heanng upon a finding that failure to issue the\nOrder expeditiously wfil result in likely senous harm to life, property or the environment In such\ncases, an opportumty for a hearing will be provided as soon as practicable afier the issuance of the\nOrder\nAfter evaluating the foregomg preliminary findings of fact, I find that the continued operation of the\nHamson Storage Field without corrective measures would be hazardous to life, property and the\nenvironment Additionally, after considenng the evidence of corrosion in the well lines, the\nproxnnity of the pipelme to people, the charactenstics o f natural gas, and the high pressures required\nin the field, I find that a failure to issue expeditiously this Order, requiring immediate corrective\naction, would result in hkely serious harm to life, property, and the environment\nAccordingly, this Corrective Action Order mandating needed immediate corrective action is issued\nwithout pnor notice and opportunity for a hearing The terms and conditions of this Order are\neffective upon receipt\nWithin 10 days of receipt of tlus Order, Respondent may request a hearing, to be held as soon as\npracticable, by notifying the Associate Administrator for Pipeline Safety m wnting, dehvered\npersonally, by mail or by telecopy at (202) 366-4566 The heanng will be held in Washington, DC\non a date that is mutually convenient to OPS and Respondent\nAfter receiving and analyzing additional data in the course of this investigation, OPS may identify\nother corrective measures that need to be taken In that event, Respondent wdl be notified of any\nadditional measures required and amendment of tins Order will be considered To the extent\nconsistent with safety, Respondent will be afforded notice and an opportunity for a heanng pnor to\nthe imposition of any additional corrective measures\nRe aired Corrective Action\nPursuant to 49 U S C ) 60112, I hereby order Respondent to immediately take the following\ncorrective actions with respect to its Hainson Storage Field\n1 Suspend the tnIectton operation in the storage field As gas is withdrawn from the field and the\npressure required to tn1ect addktMnal gas decreases, Respondent may ask to resume mjection at\na ressure not to exceed 80 lo of the operatmg pressure at the time of failure Upon confirming\napressur o\nthat Respondent is complying with other requirements of this order, the Regional Director,\nEastern Region, OPS, shall grant such a request In addition, Respondent may request, and the\nRegional Director grant, authority to operate at pressures that exceed 80 'lo of the failure pressure\nupon a showing that the corrective action reqmred by this order has been substantially completed,\nor, that completion of the corrective action is not needed to ensure safety at the higher pressure\n\n\n\n2 Conducts detailed metallurgical analysis of the pipe that failed on October 10, 2003 to determine\nthe cause and contnbutmg factors Submit a copy of the report of this analysis to the Regional\nDirector, Eastern Region, OPS, within one week of your receipt of the report\n3 Do not operate the HP 20 6-inch Line to Well HW 7 until doing the following\na Replace thepipe, or\nb Examine the pipe adlacent to the failure for any signs of corrosion, wall thinmng, or dents or\ngouges that could result in corrosion and take appropnate remedial action\n4 Identify all locations where people reside, work, or congregate in the vimnity of the well hnes\nwithin the Hamson Storage Field Identify the thermal radiation protection zone for each of\nthese locations For each of these identified zones, do the following\na Review the cathodic protection system to determine whether it is adequate to protect pipe that\ncould affe the zone Take into account the results of the 2002-close interval survey,\ncat odic protection readmgs, and rectifier size\nb If the review indicates questions about the adequacy of the cathodic protection system,\nexcavate the pipe and exannne it for evidence of corrosion\nc Take appropnate remedial action including improvements to the cathodic protection system\nor pipe replacement, if needed\n5 If the metallurgical analysis indicates that external corrosion was a factor m the failure, review\nthe report on the 2002-close interval survey and deternune why active corrosion was not\nidentified at the failure site\n6 Witlun 60 days o f receipt o f the metallurgical analysis reqmred by item 2, subnut a wntten plan\nto address the factors identified as causmg or contnbuting to the failure with respect to the well\nlmes withm the Hamson Storage Field\na This plan must include any evaluation, testing, repairs, or other remedial action necessary to\nverify the integrity of the segment as well as a schedule for completion of these actions\nb If external corrosion is a factor, mclude a program for mternal inspection to identify dents,\ngouges, and grooves and metal loss\nc To the extent a well line is not \"piggable\", include altemahve means such as pressure testing\nor direct assessment\nd If internal corrosion is a factor, include a schedule to expedite the removal of drips that could\naffect the zones identified in item 4\n\n\n\ne If internal corrosion is a factor, determine the causal factors of the internal corrosion, include\na methodology to identify other areas in the which those causal factors may be present, and\ninclude a program for addressing the nsk of internal corrosion m those areas\n7 Implement the plan required by item 6 after approval by the Regional Director The Regional\nDirector may approve the plan incrementally\n8 In order to allow OPS the opportuiuty to monitor the work, notify the Regional Director in\nadvance of any excavanons or pipe repairs or replacement required under this order\nThe Regional Director may, in wnting, grant an extension of time for compliance with any of the\nterms of this order for good cause The request for an extension must be m wnting Decisions of\nthe Regional Director may be appealed to the Associate Administrator for Pipehne Safety\nFailure to comply with this Order may result in the admnustrative assessment of civil penalties of\nnot more than $100, 000 per day and m referral to the Attorney General for appropnate rehef in\nUnited States District Court\ntacey Gerard\nsociate Admnnstrator\nfor Pipehne Safety\nDate Issued","truncated":false,"body_characters":12514}