# EASTERN GAS TRANSMISSION AND STORAGE, INC. — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 120151012
- **title:** EASTERN GAS TRANSMISSION AND STORAGE, INC. — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2015-06-05
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 192.605(a), 192.709(c), 192.731(a), 192.743(a), 192.751(a).
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-120151012
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120151012
**body:**

Notice of Probable Violation involving EASTERN GAS TRANSMISSION AND STORAGE, INC.. PHMSA's enforcement data identifies the cited regulations as 192.605(a),  192.709(c),  192.731(a),  192.743(a),  192.751(a). The case was opened on 2015-06-05 and is reported as closed as of 2019-04-08. Proposed civil penalty: $152,600. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120151012_NOPV PCP PCO_06052015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151012/120151012_NOPV%20PCP%20PCO_06052015.pdf

120151012_NOPV PCP PCO_06052015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151012/120151012_NOPV%20PCP%20PCO_06052015_text.pdf

120151012_NOPV PCP PCO_Corrected PCP Total_06112015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151012/120151012_NOPV%20PCP%20PCO_Corrected%20PCP%20Total_06112015.pdf

120151012_NOPV PCP PCO_Corrected PCP Total_06112015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151012/120151012_NOPV%20PCP%20PCO_Corrected%20PCP%20Total_06112015_text.pdf

120151012_Operator Response to Notice_08312015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151012/120151012_Operator%20Response%20to%20Notice_08312015.pdf

120151012_Region Withdrawal of Notice Letter_04082019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151012/120151012_Region%20Withdrawal%20of%20Notice%20Letter_04082019.pdf

120151012_Region Withdrawal of Notice Letter_04082019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151012/120151012_Region%20Withdrawal%20of%20Notice%20Letter_04082019_text.pdf

120151012_NOPV PCP PCO_Corrected PCP Total_06112015_text.pdf

U.S. Department
820 Bear Tavern Road, Suite 103
Pipeline and
Of Transportation
West Trenton, NJ 08628
Safety Administration
Hazardous Materials
609.989.2171
OVERNIGHT EXPRESS DELIVERY
June 11, 2015
Brian Sheppard, VP, Pipeline Operations
445 West Main Street
Dominion Transmission, Inc.
Clarksburg, WV 26302-2450
CPF No.: 1-2015-1012
RE: Total assessed civil penalty (corrected) stated in the Notice of Probable Violation, Proposed Civil
Penalty and Proposed Compliance Order (Notice) letter dated June 5, 2015.
Dear Mr. Sheppard:
On June 5, 2015, Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety, Eastern
Region (N.J.), issued a Notice letter, in the above-referenced case, to Dominion Transmission, Inc. On page
4, in the section titled "Proposed Civil Penalty" of the Notice letter (see italicized excerpt below)
inadvertently states a total assessed civil penalty of $156,700. Please be advised, the correct total assessed
civil penalty is $152,600. The penalty stated for each item number is correct and thus remains the same.
Proposed Civil Penalty (Excerpt from CPF 1-2015-1012 June 5, 2015 letter (page 4)):
the violation persists up to a maximum of $2,000,000 for a related series of violations. For violations occurring prior
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per violation per day
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. The Compliance Officer has reviewed the circumstances and
supporting documentation involved in the above probable violation(s) and has recommended that you be preliminarily
Item number
PENALTY
3
2
$36,700
$43,200
5
$36,000
$36,700
Thank you for your ongoing cooperation in this matter.
Sincerely,
Byron Coy, PE
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration

120151012_Region Withdrawal of Notice Letter_04082019_text.pdf

WITHDRAWAL of NOTICE LETTER
OVERNIGHT EXPRESS DELIVERY
April 8, 2019
Brian Sheppard
Vice President, Eastern Pipeline Operations
Dominion Energy Transmission, Inc.
925 White Oaks Boulevard
Bridgeport, WV 26330
CPF 1-2015-1012
Dear Mr. Sheppard:
On June 5, 2015, Dominion Energy Transmission, Inc. (DETI) was issued a Notice of Probable
Violation, Proposed Civil Penalty, and Proposed Compliance Order letter for the case number
referenced above. This Notice cited DETI for 7 alleged violations of various portions of the
pipeline safety regulations found in 49 CFR Part 192.
This Notice alleged that DETI was in violation of § 192.605(a) for failing to follow its O&M and
failing to secure three separate relief valves in the open position as it relates to § 192.199(h); in
violation of § 192.605(a) for failing to follow its O&M and failing to verify the proper position of
an isolation valve under a relief device; in violation of § 192.605(a) for failing to follow its O&M
and failing to protect an emergency valve from unauthorized operation or damage; in violation of
§ 192.709(c) for failing to maintain transmission line records of each patrol, survey, inspection,
and test required by subparts L and M by failing to maintain MAOP records for 88 regulator
stations; in violation of § 192.731(a) for failing to inspect and test each pressure relieving device
in a compressor station in accordance with § 192.739(a); in violation of § 192.743(a) for failing to
ensure that the relief capacity of two relief devices was sufficient; and in violation of § 192.751 by
failing to take steps to minimize the danger of accidental ignition of gas in any structure or area
where the presence of gas constitutes a hazard of fire or explosion.
DETI responded to this Notice by letter, dated August 31, 2015. DETI provided information to
show it had taken action to address 6 of the 7 alleged violations and meet the terms of the original



Proposed Compliance Order for those items. In addition, DETI proposed a Consent Agreement to
address the remaining item. Upon further review, we have decided to withdraw the Notice.
This letter is to inform you that PHMSA hereby withdraws the Notice and that the case is now
closed.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
2

120151012_NOPV PCP PCO_06052015_text.pdf

U.S. Department Of Transportation Pipeline and 609.989.2171
Hazardous Materials
Safety Administration
820 Bear Tavern Road, Suite 103
West Trenton, NJ 08628
NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPLIANCE ORDER
OVERNIGHT EXPRESS DELIVERY
June 05, 2015
Brian Sheppard
Vice President, Pipeline Operations
Dominion Transmission, Inc.
445 West Main Street
Clarksburg, WV 26302-2450
CPF 1-2015-1012
Dear Mr. Sheppard:
Between August 26, 2013 to March 31, 2014, representatives of the Pipeline and Hazardous Materials
Safety Administration, and the West Virginia Public Service Commission (WV PSC), pursuant to Chapter
601 of 49 United States Code inspected the Dominion Transmission, Inc. (DTI) facilities and records in
the Bridgeport, Lightburn, Charleston, and Hastings operating areas of WV.
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.
(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 once 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.
DTI failed to follow its O&M procedures by failing to secure three isolation valves under three separate
relief valves at regulator station XS-2138 Cross in the open position. Also note the requirements of Part
192.199(h). DTI Procedure 210-02 Pressure Regulation revised 10152012 Page 10, section VI (A) 2,
states in part that “isolation valves under relief devices should be secured in the open position in a manner
that prevents operation by unauthorized personnel.”



1-2015-1012
During the field inspection, the WV PSC inspector visited the regulator station and noted that the
isolation valves under relief devices 002, 005, and 007 were in the open position but not locked or secured
in the open position in a manner that prevents operation by unauthorized personnel. The relief valves
were the primary means of over protection. The regulator station was not fenced in.
The WV PSC inspectors took photographs of the three unlocked isolation valves 002, 005, and 007 at
regulator station XS-2138 Cross.
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 once 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.
DTI failed to follow its O&M procedure by failing to verify the proper position of an isolation valve
under a relief device at Regulator station XS 1847 (White Day).
DTI Procedure 210-02 Pressure Regulation revised 10152012 Page 10 section VI (A) 1 states that the
final aspect of the inspection should include the following: “Verification for proper position for all valves
. . . ”
During the field inspection, the WVPSC inspector visited the regulator station and noted that an isolation
valve under relief valve 003 was locked in the closed position. According to DTI, the last relief valve
inspection was performed in August 2013. The isolation valve should have been in the open
position. Also note the requirements of Part 192.199(h).
WV PSC inspectors took photographs of the isolation valve in the closed position under relief device 003.
DTI did not offer an estimation of when the last time the isolation valve under relief device 003 was
locked in the open position.
3. §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 once 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.
DTI failed to follow its O&M procedure by failing to protect an emergency valve from unauthorized
operation or damage.
DTI Procedure Section:390/Valve Inspection and Maintenance SOP:01/Transmission, Storage, and
Jurisdictional Gathering Pipelines section IV (B) 2 states “An inspection shall not be considered
complete unless the valve and valve operator are readily accessible and protected from unauthorized
operation and damage (i.e. lock and/or chain of valve wheels and operator systems, wrench/wheel
operator removed and locked in another location, . . .
During the inspection, the WV PSC observed and photographed that emergency valve 664B, located
outside of the compressor station fencing, was not protected from unauthorized operation. Neither the
ESD air supply valve, nor the power gas valve was locked and the handles had not been removed and
locked in another location.
DTI stated that they had no reason why the valve was not secured.
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4. §192.709 Transmission lines: Record keeping.
Each operator shall maintain the following records for transmission lines for the periods specified:
(c) A record of each patrol, survey, inspection, and test required by subparts L and M of this part
must be retained for at least 5 years or until the next patrol, survey, inspection, or test is completed,
whichever is longer.
DTI failed to maintain transmission line records of each patrol, survey, inspection, and test required by
subparts L and M of this part. Specifically, DTI failed to maintain MAOP records for 88 regulator
stations.
When asked about the MAOP records by the PHMSA/WV PSC inspection team, a DTI representative
stated that DTI has not established MAOP records that are traceable, verifiable and complete to support
the MAOP for the 88 regulator stations, and DTI will not be able to begin an accelerated process of
verifying the MAOP on the 88 regulator stations until 2015. The DTI representative stated that DTI was
aware of this MAOP records problem and started taking action to address the problem. DTI could not
produce any written evidence of DTI’s awareness of their MAOP problem or of DTI actions taken.
5. §192.731 Compressor stations: Inspection and testing of relief devices.
(a) Except for rupture discs, each pressure relieving device in a compressor station must be
inspected and tested in accordance with §§192.739 and 192.743, and must be operated periodically
to determine that it opens at the correct set pressure.
DTI failed to inspect and test each pressure relieving device in a compressor station in accordance with
§192.739(a). §192.739(a) requires that each pressure limiting station, relief device (except rupture discs),
and pressure regulating station and its equipment be subjected to inspections and tests at intervals not
exceeding 15 months, but at least once each calendar year,.
DTI failed to inspect and test thermal relief device #419 at the Racket Newberne station at least once per
calendar year not exceeding 15 months. The relief device was installed 11/01/2009 and the first record of
inspection and testing was 09/09/2013. The relief device was not inspected in 2010, 2011 or 2012.
When asked by the PHMSA/WV PSC inspection team if DTI could supply a copy of the last 5 years of
the relief device inspection records, a DTI representative stated that the relief device was only inspected
twice, once on 09/09/2013 and once on 10/07/2013.
6. §192.743 Pressure limiting and regulating stations: Capacity of relief devices
(a) Pressure relief devices at pressure limiting stations and pressure regulating stations must have
sufficient capacity to protect the facilities to which they are connected. Except as provided in
§192.739(b), the capacity must be consistent with the pressure limits of §192.201(a). This capacity
must be determined at intervals not exceeding 15 months, but at least once each calendar year, by
testing the devices in place or by review and calculations
DTI failed to ensure that the relief capacity at regulator station XS-1719 Sylvester for relief devices 007
and 008, and at Regulator station XS-1709 Twilight for relief device 007, was sufficient.
The following information was taken from relief valve inspection reports.
XS-1719 Sylvester regulator station.
Relief valve 007 set point relief valves were calculated at
2011 60 PSI 2011 35 PSI
2012 40 PSI 2012 35 PSI
2013 60 PSI 2013 35 PSI
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Relief valve 008 set point relief valves were calculated at
2011 60 PSI 2011 35 PSI
2012 60 PSI 2012 35 PSI
2013 40 PSI 2013 35 PSI
XS-1709 Twilight regulator station.
Relief valve 007 set point relief valve 007 was calculated at
2011 40 PSI 2011 30 PSI
2012 60 PSI 2012 30 PSI
2013 60 PSI 2013 30 PSI
Relief device capacity must be calculated at the set point of the actual installed relief device. By example,
if the set point is 60 psig, capacity calculations should be performed using 60 psig. DTI used the
incorrect pressure in the calculation, thereby failing to meet the requirements of §192.743.
7. §192.751 Prevention of accidental ignition.
Each operator shall take steps to minimize the danger of accidental ignition of gas in any structure
or area where the presence of gas constitutes a hazard of fire or explosion, including the following:
When a hazardous amount of gas is being vented into open air, each potential source of ignition
must be removed from the area and a fire extinguisher must be provided.
DTI failed to take steps to minimize the danger of accidental ignition of gas in any structure or area where
the presence of gas constitutes a hazard of fire or explosion. Specifically, DTI failed to tighten 6 bolts on
the cover of an explosion proof box which contained the electrical switch for valve number 10 at the
Racket Newberne compressor station, thus negating the explosion proof feature of the box.
WV PSC inspectors observed and photographed the loose bolts on the switch box. DTI’s representative
said that DTI had no idea how long the bolts were loose on the switch box for valve number 10.
Proposed Civil Penalty
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.
The Compliance Officer has reviewed the circumstances and supporting documentation involved in the
above probable violation(s) and has recommended that you be preliminarily assessed a civil penalty of
$156,700 as follows:
Item number PENALTY
1 $36,700
2 $43,200
3 $36,000
5 $36,700
Proposed Compliance Order
With respect to items 1, 3, 4, 6, and 7 pursuant to 49 United States Code § 60118, the Pipeline and
Hazardous Materials Safety Administration proposes to issue a Compliance Order to Dominion
Transmission, Inc. (DTI). Please refer to the Proposed Compliance Order, which is enclosed and made a
part of this Notice.
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Response to this Notice
Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in
Compliance Proceedings. Please refer to this document and note the response options. All material you
submit in response to this enforcement action may be 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). If you do not respond within 30
days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this
Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this
Notice without further notice to you and to issue a Final Order.
Please submit all correspondence in this matter to Byron Coy, PE, Director, PHMSA Eastern Region, 820
Bear Tavern Road, Suite 103, W. Trenton, NJ 08628. Please refer to CPF 1-2015-1012 on each
document you submit, and please whenever possible provide a signed PDF copy in electronic format.
Smaller files may be emailed to Byron.Coy@dot.gov. Larger files should be sent on a CD accompanied
by the original paper copy to the Eastern Region Office.
Additionally, if you choose to respond to this (or any other case), please ensure that any response letter
pertains solely to one CPF case number.
Sincerely,
Byron Coy, PE
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
Cc: Mary Friend, WV PSC
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Compliance Proceedings
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PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration
(PHMSA) proposes to issue to Dominion Transmission, Inc. (DTI) a Compliance Order incorporating the
following remedial requirements to ensure the compliance of DTI with the pipeline safety regulations:
1. 2. 3. 4. 5. 6. 7. In regard to Item Number 1 of the Notice pertaining to DTI’s failure to follow its O&M
procedures by failing to secure three isolation devices, DTI must secure those three
isolation devices. This is to be accomplished within 90 days receipt of the Final Order.
In regard to Item Number 3 of the Notice pertaining to DTI’s failure to follow its O&M
procedures by failing to protect an emergency valve from unauthorized operation, DTI
must protect the emergency valve from unauthorized operation. This is to be
accomplished within 90 days receipt of the Final Order.
In regard to Item Number 4 of the Notice pertaining to DTI’s failure to maintain MAOP
records for eighty eight (88) regulator stations, DTI must resolve the MAOP issues with
these 88 regulator stations, and establish/maintain a credible MAOP record for each of
the regulator stations noted. DTI must prioritize the work to address the 88 regulator
stations by which regulator station piping is operating closer to the piping SMYS. This is
to be accomplished within 24 months receipt of the Final Order.
In regard to Item Number 6 of the Notice pertaining to DTI’s failure to ensure that the
relief capacity of the devices noted was sufficient, DTI must perform and document
calculations to establish the proper relief capacity for each relief device. This is to be
accomplished within 90 days receipt of the Final Order.
In regard to Item Number 7 of the Notice pertaining to DTI’s failure to take steps to
minimize the danger of accidental ignition, DTI must take actions to ensure that the
enclosure cited equipment meets National Electrical Code (NEC) standards. This is to be
accomplished within 90 days receipt of the Final Order.
DTI must complete the requirements as outlined above. All documentation
demonstrating compliance with each of the items outlined in this proposed compliance
order must be submitted to Byron Coy, PE, Director, Eastern Region , Pipeline and
Hazardous Materials Safety Administration, Suite 103, Bear Tavern Road, West Trenton,
NJ for review.
It is requested (not mandated) that DTI maintain documentation of the safety
improvement costs associated with fulfilling this Compliance Order and submit the total
to Byron Coy, PE, Director, Eastern Region, Pipeline and Hazardous Materials Safety
Administration. It is requested that these costs be reported in two categories: 1) total cost
associated with preparation/revision of plans, procedures, studies and analyses, and 2)
total cost associated with replacements, additions and other changes to pipeline
infrastructure.
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