EASTERN GAS TRANSMISSION AND STORAGE, INC. — Corrective Action Order

120031007h_corrective action order_10202003_text.pdf, page 1Official PDFU 5 Department of Transportats0n Research and Special Programs Administration 400 sevenlh sl 5 w Waahingfon O C 20590 OCT 20 2003 Mr Jeftrey L Barger Vice President, Pipehne Operations Domuuon Transmission, Inc 445 West Main Street Clarksburg, WV 26301 Re CPF No !-2003-1007-H Dear Mr Barger Enclosed is a Corrective Action Order issued by the Associate Administrator for Pipeline Safety in the above-referenced case It requires you to take certain correcnve actions with respect to the operation o f your pipehne Service is being made by certified mail and facsimile Your receipt of the enclosed document constitutes service of that document The terms and conrhtions of tlus Corrective Action Order are effective upon receipt Pipehne Compliance Registry Office of Pipehne Safety Enclosure VIA CERTIFIED MAIL TURN RECEIPT RE UESTED AND TELECOPY#

120031007h_corrective action order_10202003_text.pdf, page 2DEPARTMENT OF TRANSPORTATION RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION WASHINGTON, DC 20590 In the Matter of Dominion Transmission, Inc. , Respondent. CPF No. 1-2003-1007-H CORRECTIVE ACTION ORDER Pur ose and Back round This Corrective Action Order is being issued, under authority of 49 U S C ( 60112, to reqiure Donumon Transmission, Inc (Respondent) to take the necessary corrective action to protect the public and environment from potential hazards associated with Respondent's Ham son Storage Field m Potter County, Pennsylvama Pursuant to 49 U S C II 60117, the Eastern Region, Office of Pipehne Safety (OPS), initiated an investigation of the failure Prehminar Fmdin s About 2 22 p m on October 10, 2003, a failure occurred m Respondent's HP 20 6-inch Line to Well H W7 within the Harrison Storage Field in Potter County, Pennsylvania The failure resulted in a release of natural gas and a fire A trailer, car, and garage were damaged Residents were not at home There were no deaths or in]uries Following the failure, Respondent isolated the HP 20 6-inch Line by closing valves Respondent cut out a 2-3 foot segment of pipehne that contained the failed pipe and sent the segment to Ktefner & Associates Inc for metallurgical analysis Respondent took the HP 20 6-inch Line out of service and tnchcated that it mtends to replace the line The failure was a full circumferential rupture Respondent indicated to OPS staff that it suspected corrosion (internal or external) as the probable cause Photographs of the failed segment indicate some corrosion pitting and discoloration on the inside of the pipe that could be mdicative of internal corrosion The metallurgical report should indicate the cause#

120031007h_corrective action order_10202003_text.pdf, page 3The maximum allowable operating pressure (MAOP) of the storage field is 2200 psig (about 56 lo of the specified minunum yield strength), which was established based on the lughest actual operating pressure The HP 20 6-inch Line was operating at 2124 psig at the time of failure The Harrison Storage Field is composed of three mainhnes and forty-three well lines, including the HP 20 6-inch Lme A smgle compressor station is used for moving gas throughout the storage field At the time of failure, Respondent was injecting gas into the storage pool of the Hamson Storage Field It is estimated to be about 95 '/o full Because of the amount of gas already in storage, the m]ection operation requires virtually full MAOP The Hamson Storage Field is m a rural area, likely Class 1 However, Respondent indicates that there are about 15 houses near the field Although the actual proximity of the houses is not known, the damaged trailer was about 300 feet from the rupture Based on the information available at this time, the HP 20 6-inch Lme is made of seamless pipe of 0 312" wall tluckness, pipe grade X-42, of unknown manufacturer The hne was installed in 1955 and is bare It contains about 937 feet of pipe There was a corrosion leak on another 6-inch well lme within the Hamson Storage Field in August 1995 The cause was external corrosion that resulted from tlnrd party damage to the pipeline There was an mternal corrosion leak in a drip on an 8-inch well hne within the Harrison Storage Field m August 2000 Respondent has a four-year drip removal program that will be completed next year Eighteen drips have been removed so far The well pipehnes m the Hamson Storage Field have never been pressure tested or internally mspected using an mstrumented device A large part, if not all, of the lines are bare They are cathodically protected by impressed current A close interval survey was done in September 2002 The report sent to Respondent in February 2003, did not indicate any deficiencies m HP 20 6-inch Line at the site of the failure However, as a result of the survey, Respondent mstalled an additional 22 anodes on the well pipelines to support the cathodic protection system Determination of Necessi for Corrective Action Order and Ri ht to Hearin Section 60112 of Title 49, Uruted States Code, provides for the issuance of a Corrective Action Order, after reasonable notice and the opportunity for a hearing, requiring corrective action, which may include the suspended or restncted use of a pipeline facihty, physical inspection, testing, repair, re lacement or other action as appropnate The basis for making the determination that a pipehne facihty is hazardous, requiring corrective action, is set forth both in the above referenced statute an 49 C F R $190 233, a copy of which is enclosed#

120031007h_corrective action order_10202003_text.pdf, page 4Section 60112, and the regulations promulgated thereunder, provides for the issuance of a Corrective Action Order without prior opportunity for notice and heanng upon a finding that failure to issue the Order expeditiously wfil result in likely senous harm to life, property or the environment In such cases, an opportumty for a hearing will be provided as soon as practicable afier the issuance of the Order After evaluating the foregomg preliminary findings of fact, I find that the continued operation of the Hamson Storage Field without corrective measures would be hazardous to life, property and the environment Additionally, after considenng the evidence of corrosion in the well lines, the proxnnity of the pipelme to people, the charactenstics o f natural gas, and the high pressures required in the field, I find that a failure to issue expeditiously this Order, requiring immediate corrective action, would result in hkely serious harm to life, property, and the environment Accordingly, this Corrective Action Order mandating needed immediate corrective action is issued without pnor notice and opportunity for a hearing The terms and conditions of this Order are effective upon receipt Within 10 days of receipt of tlus Order, Respondent may request a hearing, to be held as soon as practicable, by notifying the Associate Administrator for Pipeline Safety m wnting, dehvered personally, by mail or by telecopy at (202) 366-4566 The heanng will be held in Washington, DC on a date that is mutually convenient to OPS and Respondent After receiving and analyzing additional data in the course of this investigation, OPS may identify other corrective measures that need to be taken In that event, Respondent wdl be notified of any additional measures required and amendment of tins Order will be considered To the extent consistent with safety, Respondent will be afforded notice and an opportunity for a heanng pnor to the imposition of any additional corrective measures Re aired Corrective Action Pursuant to 49 U S C ) 60112, I hereby order Respondent to immediately take the following corrective actions with respect to its Hainson Storage Field 1 Suspend the tnIectton operation in the storage field As gas is withdrawn from the field and the pressure required to tn1ect addktMnal gas decreases, Respondent may ask to resume mjection at a ressure not to exceed 80 lo of the operatmg pressure at the time of failure Upon confirming apressur o that Respondent is complying with other requirements of this order, the Regional Director, Eastern Region, OPS, shall grant such a request In addition, Respondent may request, and the Regional Director grant, authority to operate at pressures that exceed 80 'lo of the failure pressure upon a showing that the corrective action reqmred by this order has been substantially completed, or, that completion of the corrective action is not needed to ensure safety at the higher pressure#

120031007h_corrective action order_10202003_text.pdf, page 52 Conducts detailed metallurgical analysis of the pipe that failed on October 10, 2003 to determine the cause and contnbutmg factors Submit a copy of the report of this analysis to the Regional Director, Eastern Region, OPS, within one week of your receipt of the report 3 Do not operate the HP 20 6-inch Line to Well HW 7 until doing the following a Replace thepipe, or b Examine the pipe adlacent to the failure for any signs of corrosion, wall thinmng, or dents or gouges that could result in corrosion and take appropnate remedial action 4 Identify all locations where people reside, work, or congregate in the vimnity of the well hnes within the Hamson Storage Field Identify the thermal radiation protection zone for each of these locations For each of these identified zones, do the following a Review the cathodic protection system to determine whether it is adequate to protect pipe that could affe the zone Take into account the results of the 2002-close interval survey, cat odic protection readmgs, and rectifier size b If the review indicates questions about the adequacy of the cathodic protection system, excavate the pipe and exannne it for evidence of corrosion c Take appropnate remedial action including improvements to the cathodic protection system or pipe replacement, if needed 5 If the metallurgical analysis indicates that external corrosion was a factor m the failure, review the report on the 2002-close interval survey and deternune why active corrosion was not identified at the failure site 6 Witlun 60 days o f receipt o f the metallurgical analysis reqmred by item 2, subnut a wntten plan to address the factors identified as causmg or contnbuting to the failure with respect to the well lmes withm the Hamson Storage Field a This plan must include any evaluation, testing, repairs, or other remedial action necessary to verify the integrity of the segment as well as a schedule for completion of these actions b If external corrosion is a factor, mclude a program for mternal inspection to identify dents, gouges, and grooves and metal loss c To the extent a well line is not "piggable", include altemahve means such as pressure testing or direct assessment d If internal corrosion is a factor, include a schedule to expedite the removal of drips that could affect the zones identified in item 4#

120031007h_corrective action order_10202003_text.pdf, page 6e If internal corrosion is a factor, determine the causal factors of the internal corrosion, include a methodology to identify other areas in the which those causal factors may be present, and include a program for addressing the nsk of internal corrosion m those areas 7 Implement the plan required by item 6 after approval by the Regional Director The Regional Director may approve the plan incrementally 8 In order to allow OPS the opportuiuty to monitor the work, notify the Regional Director in advance of any excavanons or pipe repairs or replacement required under this order The Regional Director may, in wnting, grant an extension of time for compliance with any of the terms of this order for good cause The request for an extension must be m wnting Decisions of the Regional Director may be appealed to the Associate Administrator for Pipehne Safety Failure to comply with this Order may result in the admnustrative assessment of civil penalties of not more than $100, 000 per day and m referral to the Attorney General for appropnate rehef in United States District Court tacey Gerard sociate Admnnstrator for Pipehne Safety Date Issued#