{"operation":"document","citation":"CPF 120081008W","title":"EASTERN GAS TRANSMISSION AND STORAGE, INC. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-12-30","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120081008w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120081008w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120081008w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120081008W","body":"Warning Letter involving EASTERN GAS TRANSMISSION AND STORAGE, INC.. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2008-12-30 and is reported as closed as of 2008-12-30. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120081008W_Operator Response Letter_01282009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120081008W/120081008W_Operator%20Response%20Letter_01282009.pdf\n\n120081008W_Warning Letter_12302008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120081008W/120081008W_Warning%20Letter_12302008.pdf\n\n120081008w_warning letter_12302008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120081008W/120081008w_warning%20letter_12302008_text.pdf\n\n120081008w_warning letter_12302008_text.pdf\n\nO\nU. S Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n409 3rd Street, SW, SUite 300\nWashington, DC 20024\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nDecember 30, 2008\nMr. Jeff Barger\nVice President, Operations\nDommion Transmission, Inc.\n445 West Main Street\nClarksburg, WV 26301\nCPF. No. 1-2008-1008W\nDear Mr. Barger:\nOn November 14, 2008, representatives from the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 Umted States Code conducted an\ninvestigation into the incident that occurred on the Dommion Transmission's (DTI) transmission\nline just outside the Cove Point, MD LNG Plant gate on November 13, 2008.\nAs a result of this investigation, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violation is:\n\n\n\n1. $192. 605 Procedural manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed\nand updated by the operator at intervals not exceeding 15 months, but at least\none each calendar year. This manual must be prepared before operations of a\npipeline system commence. Appropriate parts of the manual must be kept at\nlocations where operations and maintenance activities are conducted.\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in accordance with each of\nthe requirements of this subpart and subpart M of this part.\n(2) Controlling corrosion in accordance with the operations and maintenance\nrequirements of subpart I of this part.\n(3) Making construction records, maps, and operating history available to\nappropriate operating personnel\nSection $192. 605(b)(3) of the Pipehne Safety Regulations requires that the manual of written\nprocedures must be followed for making construction records, maps, and operatmg history\navailable to appropriate operating personnel.\nThe operator failed to provide adequate construction records and/or maps showing the location\nof the abandoned 2\" stub lme on the transmission line. The operator failed to communicate with\nits contractor, the exact location of an underground abandoned pipeline tap.\nOn November 13, 2008 DTI had an incident wherein a Dominion backhoe contractor rolled over\na below-grade 2\" abandoned stub piece connected to the transmission line causmg an mcident\n(NRC 889931). The 2\" stub fixture was apparently close enough to the surface that the weight of\nthe backhoe disturbed the fixture. Further investigation by DTI revealed that the prior operator\nused this stub piece for an instrumentation connection.\nAccording to DTI the instrumentation had later been removed by the prior owner, leaving the 2\"\nstub line in place just below grade. DTI should have used ILI data or other historical records to\nidentify appurtenances on the transmission line„and then account for them in current maps or\nrecords. The failure to identify and communicate the location of the abandoned tap was a\ncontributing factor which led to the incident.\n\n\n\nUnder 49 United States Code, ( 60122, you are subject to a civil penalty not to exceed $100, 000\nfor each violation for each day the violation persists up to a maximum of $1, 000, 000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved m this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedmgs at this time. We advise you to correct the item identified m this letter.\nFailure to do so will result in DTI being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 120081008W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U. S. C. 552(b), along with the\ncomplete origmal document you must provide a second copy of the document with the portions\nyou beheve quahfy for confidential treatment redacted and an explanation of why you believe\nthe redacted mformation quahfies for confidential treatment under 5 U. S. C. 552(b).\n&~Byron E. Coy, P. E.\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":5673}