EASTERN GAS TRANSMISSION AND STORAGE, INC. — Warning Letter

party submissionOfficial PDF120131014W_Operator Response_10042013.pdf#

120131014W_Warning Letter_08162013_text.pdf, page 1Official PDFU.S. Department Of Transportation Pipeline and 609.989.2171 Hazardous Materials Safety Administration 820 Bear Tavern Road, Suite 103 West Trenton, NJ 08628 WARNING LETTER EXPRESS OVERNIGHT DELIVERY August 16, 2013 Jeffrey L. Barger Vice President, Pipeline Operations Dominion Transmission, Inc. 445 West Main Street Clarksburg, WV 26302-2450 CPF 1-2013-1014W Dear Mr. Barger: During the week of March 5, 2012, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your gas transmission pipelines in the Westfield, PA area. As a result of the inspection, it appears that you have committed probable violations of the Pipeline Safety Regulations, Title 49 - Code of Federal Regulations. The items inspected and the probable violation(s) are: 1. 192.605 Procedural manual for operations, maintenance, and emergencies Each operator shall include the following in its operating and maintenance plan: (a) General. Each operator shall prepare and follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. For transmission lines, the manual must also include procedures for handling abnormal operations. This manual must be reviewed and updated by the operator at intervals not exceeding 15 months, but at least one each calendar year. This manual must be prepared before operations of a pipeline system commence. Appropriate parts of the manual must be kept at locations where operations and maintenance activities are conducted. Dominion failed to keep appropriate parts of the procedural manual for operations, maintenance, and emergencies at locations where operations and maintenance activities are conducted. Specifically, automatic shutdown and manual shutdown procedures were not kept at Harrison Station.#

120131014W_Warning Letter_08162013_text.pdf, page 2CPF 1-2013-1014W 2. 192.605 Procedural manual for operations, maintenance, and emergencies (a) General. Each operator shall prepare and follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. For transmission lines, the manual must also include procedures for handling abnormal operations. This manual must be reviewed and updated by the operator at intervals not exceeding 15 months, but at least one each calendar year. This manual must be prepared before operations of a pipeline system commence. Appropriate parts of the manual must be kept at locations where operations and maintenance activities are conducted. Dominion failed to follow its emergency plan revised 3/1/2006. That emergency plan required written directions (for field locations), developed either by field personnel or supervision, be available at field offices or support offices. Specifically, written directions were not available at Boom Station. Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a related series of violations. For violations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a related series of violations. No reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 1- 2013-1014W. Be advised that all material you submit in response to this enforcement action is subject to being made publicly available. If you believe that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original document you must provide a second copy of the document with the portions you believe qualify for confidential treatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b). Sincerely, Byron Coy, PE Director, Eastern Region Pipeline and Hazardous Materials Safety Administration 120131014W_Warning Ltr_08162013 Page 2 of 2#