{"operation":"document","citation":"CPF 120131016W","title":"EQUITRANS MIDSTREAM CORPORATION — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-08-20","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a), 192.605(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120131016w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120131016w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120131016w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120131016W","body":"Warning Letter involving EQUITRANS MIDSTREAM CORPORATION. PHMSA's enforcement data identifies the cited regulations as 192.605(a),  192.605(b). The case was opened on 2013-08-20 and is reported as closed as of 2013-08-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120131016W_Warning Letter_08202013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120131016W/120131016W_Warning%20Letter_08202013.pdf\n\n120131016W_Warning Letter_08202013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120131016W/120131016W_Warning%20Letter_08202013_text.pdf\n\n120131016W_Warning Letter_08202013_text.pdf\n\nU.S. Department 820 Bear Tavern Road,\nSuite 103\nOf Transportation West Trenton, NJ\n08628\nPipeline and 609.989.2171\nHazardous Materials\nSafety Administration\nWARNING LETTER\nEXPRESS OVERNIGHT DELIVERY\nAugust 20, 2013\nRobert Cooper, VP of Engineering\nEQT Midstream\n625 Liberty Avenue,\nPittsburgh, PA 15222\nCPF 1-2013-1016W\nDear Mr. Cooper:\nOn July 13-14, 2011, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety (OPS), and interstate agents from the Public\nService Commission of West Virginia, pursuant to Chapter 601 of 49 United States Code\ninspected your Copley Compressor Station in Lewis County, West Virginia and your Pratt\nCompressor Station in Green County, Pennsylvania.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\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 procedures\nfor handling abnormal operations. This manual must be reviewed and updated by the\noperator at intervals not exceeding 15 months, but at least one each calendar\nyear. This manual must be prepared before operations of a pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\n(b) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following, if applicable, to provide safety\nduring maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in accordance with each of the\nrequirements of this subpart and Subpart M of this part.\n\n\n\n1-2013-1016W\nEQT Midstream failed to follow its manual of written procedures for ensuring safety during\nmaintenance and normal operations. Specifically, EQT Midstream failed to follow its procedures\nfor valve maintenance, Operations and Maintenance Manual Section 7.29 Valve Maintenance –\nTransmission Lines [§192.745] paragraph 7.29.3, by not remediating three (3) emergency valves\n(valves: 33, 1068 and 1002) at the Pratt Compressor Station prior to the next inspection date.\nEQT Midstream’s procedure, Operations and Maintenance Manual Section 7.29 Valve\nMaintenance – Transmission Lines [§192.745], requires each valve to be “inspected at intervals\nnot exceeding 15 months, but at least once each calendar year.” Also, EQT Midstream’s\nprocedure, Operations and Maintenance Manual Section 7.29 Valve Maintenance – Transmission\nLines [§192.745], requires remediation of a valve that does not operate properly to “take place\nprior to the next inspection date.”\nA PHMSA representative reviewed the last three (3) years of valve inspection records. Those\nrecords revealed that there were three (3) emergency valves at Pratt Compressor Station that were\ndifficult to turn for three (3) consecutive years/inspections. According to EQT Midstream’s\nprocedure, it should have remediated those valves by the next inspection date. However, EQT\nMidstream did not produce any work orders or other documentation to show that those valves\nwere remediated in accordance with its procedure.\n2. §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 procedures\nfor handling abnormal operations. This manual must be reviewed and updated by the\noperator at intervals not exceeding 15 months, but at least one each calendar year. This\nmanual must be prepared before operations of a pipeline system commence.\nAppropriate parts of the manual must be kept at locations where operations and\nmaintenance activities are conducted.\n(b) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following, if applicable, to provide safety during\nmaintenance and operations. . .\n(2) Controlling corrosion in accordance with the operations and maintenance\nrequirements of Subpart I of this part.\nEQT Midstream failed to follow its manual of written procedures for ensuring safety during\nmaintenance and normal operations. Specifically, EQT Midstream failed to follow its corrosion\nprocedure, Operations and Maintenance Manual October 2009, 8.15 Atmospheric Corrosion\nControl - Monitoring [§192.481] paragraph 8.15.1, which requires all aboveground pipelines or\nportions of pipeline that are exposed to the atmosphere to be inspected at least once every 3\ncalendar years, but with intervals not exceeding 39 months, as prescribed in §192.481(a). EQT\ndid not inspect a drip at its Pratt Storage Field in Pennsylvania that was exposed to the\natmosphere for evidence of atmospheric corrosion within the specified interval.\nDuring the field review at Pratt Storage Field on July 14, 2011, a PHMSA inspector observed and\ntook photographs of an aboveground piping associated with the storage well 2976 that had a drip\nwith a valve. The PHMSA inspector asked the EQT Midstream field technician whether this drip\nwas inspected. The EQT Midstream field technician stated that the drip was not monitored for\natmospheric corrosion. The PHMSA inspector reviewed EQT Midstream atmospheric corrosion\nrecords. These records did not show any indication that the drip was inspected in accordance\nwith its procedure.\n120131016W_WL_08202013 Page 2 of 4\n\n\n\n1-2013-1016W\n3. §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 procedures\nfor handling abnormal operations. This manual must be reviewed and updated by the\noperator at intervals not exceeding 15 months, but at least one each calendar year. This\nmanual must be prepared before operations of a pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where operations\nand maintenance activities are conducted.\n(b) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following, if applicable, to provide safety during\nmaintenance and operations. . .\n(2) Controlling corrosion in accordance with the operations and maintenance\nrequirements of Subpart I of this part.\nEQT Midstream failed to follow its manual of written procedures for ensuring safety during\nmaintenance and normal operations. Specifically, EQT Midstream failed to follow its corrosion\nprocedure, Operations and Maintenance Manual October 2009, 8.15 Atmospheric Corrosion\nControl - Monitoring [§192.481] second paragraph 8.15.2, which requires to “pay special\nattention” to piping under thermal insulation during inspections, as prescribed in\n§192.481(b). EQT Midstream did not pay special attention to piping under thermal insulation\nduring its atmospheric corrosion inspections at its Copley Compressor Station and Pratt\nCompressor Station.\nDuring the field review at the Copley Compressor Station on July 13, 2011, WVPSC and\nPHMSA inspectors observed and took photographs of piping with thermal insulation wraps. The\ninspectors asked whether any portion of the thermal insulation was ever removed to inspect\nunderneath it. EQT Midstream indicated that it did not remove the thermal insulation. EQT\nMidstream did not produce documentation that showed it paid special attention to pipe under\nthermal insulation during the atmospheric corrosion inspection.\nDuring the field review at Pratt Compressor Station on July 14, 2011, a PHMSA inspector\nobserved and took photographs of insulated piping connected to a knockout scrubber at the\nsuction line. EQT Midstream’s atmospheric corrosion records from 2006 to 2011 provided no\nindication that the piping under thermal insulations was inspected. EQT Midstream did not\nproduce documentation that showed it paid special attention to pipe under thermal insulation\nduring the atmospheric corrosion inspection\nAt the Pratt Compressor Station, a PHMSA inspector observed and took photographs of thermal\ninsulation that was associated with two dry bed dehydrators (A&B). An EQT field staff indicated\nthat particular attention was not given to the piping under thermal insulation. According to EQT\nMidstream field staff, these pipes were inactive and no attention was given to them since the early\n2000s. Although inactive, they are still connected to the pipeline system (not being disconnected\nor blind flanged).\nEQT Midstream did not provide any justification for why it did not pay special attention to piping\nunderneath thermal insulation as stated in its procedure.\n120131016W_WL_08202013 Page 3 of 4\n\n\n\n1-2013-1016W\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the items identified in this letter.\nFailure to do so will result in EQT Midstream 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 1-2013-1016W. 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 original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nByron Coy, P.E.\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120131016W_WL_08202013 Page 4 of 4","truncated":false,"body_characters":11412}