{"operation":"document","citation":"CPF 120131017M","title":"EQUITRANS MIDSTREAM CORPORATION — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-08-20","effective_on":null,"summary":"CLOSED notice of amendment citing 192.225(a), 192.605(b)(1), 192.605(b)(2), 192.605(c)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120131017m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120131017m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120131017m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120131017M","body":"Notice of Amendment involving EQUITRANS MIDSTREAM CORPORATION. PHMSA's enforcement data identifies the cited regulations as 192.225(a),  192.605(b)(1),  192.605(b)(2),  192.605(c)(4). The case was opened on 2013-08-20 and is reported as closed as of 2014-01-30. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120131017M_Closure Letter_01302014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120131017M/120131017M_Closure%20Letter_01302014.pdf\n\n120131017M_Closure Letter_01302014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120131017M/120131017M_Closure%20Letter_01302014_text.pdf\n\n120131017M_Notice of Amendment_08202013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120131017M/120131017M_Notice%20of%20Amendment_08202013.pdf\n\n120131017M_Notice of Amendment_08202013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120131017M/120131017M_Notice%20of%20Amendment_08202013_text.pdf\n\n120131017M_Operator Response_09162013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120131017M/120131017M_Operator%20Response_09162013.pdf\n\n120131017M_Notice of Amendment_08202013_text.pdf\n\nU.S. Department Of Transportation Pipeline and 609.989.2171\nHazardous Materials\nSafety Administration\n820 Bear Tavern Road, Suite 103\nWest Trenton, NJ 08628\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nAugust 20, 2013\nRobert Cooper, VP of Engineering\nEQT Midstream\n625 Liberty Avenue,\nPittsburgh, PA 15222\nCPF 1-2013-1017M\nDear Mr. Cooper:\nFrom May to September 2011, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety (OPS), and interstate agents from the Public Service\nCommission of West Virginia, pursuant to Chapter 601 of 49 United States Code inspected EQT\nMidstream’s (EQT’s) procedures and records for Operations and Maintenance, as well as Design and\nConstruction, at its headquarter office in Pittsburgh, Pennsylvania, and a portion of its pipeline facilities\nin Pennsylvania and West Virginia.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within EQT’s\nplans or procedures, as described below:\n1. §192.225 Welding Procedures.\n(a) Welding must be performed by a qualified welder in accordance with welding procedures\nqualified under section 5 of API 1104 (incorporated by reference, see §192.7) or section IX of\nthe ASME Boiler and Pressure Vessel Code \" Welding and Brazing Qualifications\"\n(incorporated by reference, see §192.7) to produce welds meeting the requirements of this\nsubpart. The quality of the test welds used to qualify welding procedures shall be determined by\ndestructive testing in accordance with the applicable welding standard(s).\nEQT’s welding procedures, Design & Construction Manual – Welding & Joining, was inadequate\nbecause it did not mention the API 1104 version incorporated by reference in 49 C.F.R. 192 for the\nwelder and the welding procedures.\n2. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(b) Maintenance and normal operations. The manual required by paragraph (a) of this section\nmust include procedures for the following, if applicable, to provide safety during maintenance\nand 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\nEQT’s procedures for inspecting and testing relief devices in a compressor station in its manual,\nspecifically Operations and Maintenance Manual, Section 7.23 Compressor Stations: Inspection and\nTesting of Pressure Relief Devices [§192.731], was inadequate because the guidelines in the supplemental\nprocedure did not ensure that the gauge was calibrated to accurately determine and adjust the shutdown\nswitch trips at the proper set point. Particularly, EQT’s supplemental procedure, MP085 Maintain, Test\nand Repair Overpressure Protection Devices under Engine/Compressor High Discharge Pressure\nShutdown Test General Procedure, lacks specific details on the use of a calibrated gauge to test the\nshutdown set point.\n3. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(b) Maintenance and normal operations. The manual required by paragraph (a) of this section\nmust include procedures for the following, if applicable, to provide safety during maintenance\nand operations. . .\n(2) Controlling corrosion in accordance with the operations and maintenance requirements of\nSubpart I of this part.\nEQT’s procedure for corrosion control in its manual of written procedures, specifically Operations and\nMaintenance Manual October 2009, Section 8.15 Atmospheric corrosion Control – Monitoring\n[§192.481], and related procedure, Inspect for Atmospheric Corrosion, Revision No. 0, Revision Date\nOctober 30, 2009, was inadequate because it lacked detailed instructions to monitor atmospheric\ncorrosion.\nThe aforementioned procedures were general and provided no guidance on how to give particular\nattention to pipe at soil-to-air interfaces, under thermal insulation, under disbonded coatings, at pipe\nsupports in splash zones and in spans over water in accordance with section 192.481(b). EQT’s corrosion\ncontrol procedure does not specify how it determines where to give particular attention to piping under\nthermal insulation such as by sampling inspection checkpoints prone to corrosion. Furthermore, EQT’s\ncorrosion control procedure refers to above-ground pipeline and does not consider portions of below-\nground pipeline that are exposed to the atmosphere.\nEQT only requires a visual “[examination of] exposed portions of pipelines and soil-to-air interfaces\nlocated at aboveground block valves, pig traps and station piping.” During the field inspection at Copley\nCompressor Station and Pratt Compressor Station, PHMSA inspectors observed pipe under thermal\ninsulation and pipe supports.\nAlso, EQT’s procedure for corrosion control only requires that “[r]egular inspections should be made to\nensure above-ground pipeline facilities are protected against atmospheric corrosion.” (emphasis added).\nDuring the field inspection, PHMSA inspectors observed portions of below-ground pipeline that were\nexposed to the atmosphere.\n4. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(c) Abnormal operation. For transmission lines, the manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety when operating design limits\nhave been exceeded: . . .\n(4) Periodically reviewing the response of operator personnel to determine the effectiveness of\nthe procedures controlling abnormal operation and taking corrective action where deficiencies\nare found.\n120131017M_NOA_08202012 Page 2 of 3\n\n\n\nEQT’s procedure for abnormal operation in its manual, specifically Operations and Maintenance (O&M)\nManual October 2009, Section 4.4 Reviewing the Effectiveness of Abnormal Operating Procedures\n[§192.605(c)(4)], is inadequate because it does not specify the job title(s) of the individual(s) who are\nresponsible for reviewing and correcting the abnormal operating procedures.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed as part of\nthis Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all material\nyou submit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C.\n552(b), along with the complete original document you must provide a second copy of the document with\nthe portions you believe qualify for confidential treatment redacted and an explanation of why you\nbelieve the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not\nrespond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the\nallegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as\nalleged in this Notice without further notice to you and to issue a Final Order.\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in this Notice,\nyou may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.237).\nIf you are not contesting this Notice, we propose that you submit your amended procedures to my office\nwithin 45 days of receipt of this Notice. This period may be extended by written request for good cause.\nOnce the inadequacies identified herein have been addressed in your amended procedures, this\nenforcement action will be closed.\nIt is requested (not mandated) that EQT maintain documentation of the safety improvement costs\nassociated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and\nsubmit the total to Byron Coy, PE, Director, Eastern Region, Pipeline and Hazardous Materials Safety\nAdministration. In correspondence concerning this matter, please refer to CPF 1-2013-1017M and, for\neach document you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nByron Coy, P.E.\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120131017M_NOA_08202013 Page 3 of 3\n\n120131017M_Closure Letter_01302014_text.pdf\n\nU.S. Department Of Transportation Pipeline and 609.989.2171\nHazardous Materials\nSafety Administration\n820 Bear Tavern Road, Suite 103\nWest Trenton, NJ 08628\nOVERNIGHT EXPRESS DELIVERY\nJanuary 30, 2014\nRobert Cooper\nVice President of Engineering\nEQT Midstream\n625 Liberty Avenue,\nPittsburgh, PA 15222\nCPF 1-2013-1017M\nDear Mr. Cooper:\nFrom May to September 2011, representatives from the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code, conducted an on-\nsite pipeline safety inspection of EQT Midstream procedures and records for Operations and\nMaintenance, as well as Design and Construction, at its headquarter office in Pittsburgh,\nPennsylvania, and a portion of its pipeline facilities in Pennsylvania and West Virginia. As a\nresult of the inspection, EQT Midstream was issued a Notice of Amendment on August 20, 2013,\nwhich proposed amendment of its procedures.\nEQT Midstream submitted its amended procedures on September 16, 2013. My staff reviewed\nthe amended procedures, and it appears that the inadequacies outlined in this Notice of\nAmendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nByron Coy, P.E.\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":10982}