{"operation":"document","citation":"CPF 120151016M","title":"EQUITRANS MIDSTREAM CORPORATION — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-07-29","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(2), 192.605(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120151016m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120151016m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120151016m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120151016M","body":"Notice of Amendment involving EQUITRANS MIDSTREAM CORPORATION. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(2),  192.605(e). The case was opened on 2015-07-29 and is reported as closed as of 2015-09-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120151016M_Closure Letter_09022015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151016M/120151016M_Closure%20Letter_09022015.pdf\n\n120151016M_Closure Letter_09022015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151016M/120151016M_Closure%20Letter_09022015_text.pdf\n\n120151016M_Notice of Amendment_07292015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151016M/120151016M_Notice%20of%20Amendment_07292015.pdf\n\n120151016M_Notice of Amendment_07292015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151016M/120151016M_Notice%20of%20Amendment_07292015_text.pdf\n\n120151016M_Operator_Response_to_Notice_08262015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151016M/120151016M_Operator_Response_to_Notice_08262015.pdf\n\n120151016M_Closure Letter_09022015_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\nSeptember 2, 2015\nGregg West\nVP, Midstream Operations\nEQT Midstream\n625 Liberty Avenue\nPittsburgh, PA 15222\nCPF 1-2015-1016M\nDear Mr. West:\nFrom May 5, 2014 through May 23, 2014, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of EQT Midstream’s (EQT) procedures in\nPittsburgh, Pennsylvania. As a result of the inspection, EQT was issued a Notice of Amendment\non July 29, 2015, which proposed amendment of your procedures.\nEQT submitted its amended procedures on August 26, 2015. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\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, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n120151016M_Notice of Amendment_07292015_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\nJuly 29, 2015\nRobert Cooper\nVice President of Engineering\nEQT Midstream\n625 Liberty Avenue\nPittsburgh, Pennsylvania 15222\nCPF 1-2015-1016M\nDear Mr. Cooper:\nFrom May 5, 2014 through May 23, 2014, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected EQT Midstream’s (EQT) Operations and Maintenance procedures in Pittsburgh,\nPennsylvania.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nEQT’s plans or procedures, as described below:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(e) Surveillance, emergency response, and accident investigation. The procedures\nrequired by §192.613(a), 192.615, and 192.617 must be included in the manual\nrequired by paragraph (a) of this section.\nEQT’s written procedures were inadequate in that they failed to describe what training was to be\nprovided on the emergency procedures, and how the effectiveness of that training was to be\nverified as prescribed in §192.615(b)(2).\nDuring the inspection, the PHMSA inspector reviewed EQT’s Emergency Plan Procedure\nRevision 18 dated March 13, 2014. Section 6.0 (Training and Review) of the procedure states\nthat training is being conducted, but it fails to mention how training takes place, and what\n\n\n\n1-2015-1016M\nmethods are utilized to conduct and document the training. The procedure also fails to\nadequately describe how the effectiveness of the training is verified.\n2. §192.605 Procedural manual for operations, maintenance, and emergencies.\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(2) Controlling corrosion in accordance with the operations and\nmaintenance requirements of Subpart I of this part.\nEQT’s corrosion control procedures were inadequate in that they failed to address how the\namount of cathodic protection is controlled so as not to damage the protective coating or the pipe\nas it relates to §192.463(c).\nDuring the inspection, the PHMSA inspector reviewed corrosion pipe-to-soil readings for EQT\njurisdictional pipelines in PA and WV from 2011 through 2014. The inspector noted that some\ninstant off readings were more negative than -1.2 volts. The inspector asked the operator if it\nwas aware of guidance material that suggested that these types of readings may lead to\ndisbonded coating on the pipe. EQT’s Corrosion Specialist for the West Virginia area stated that\nEQT was aware of this possibility, and that EQT investigates when it finds readings that are\nmore negative than -1.2 volts.\nSubsequently, the PHMSA inspector reviewed EQT’s corrosion control procedures in the O&M\nManual – Section 8 “Corrosion Control”, dated October 2009. Specifically, Sections 8.1 through\n8.6 were reviewed to verify whether the investigation of these low readings was described. The\nPHMSA inspector found no description in the procedures. The PHMSA inspector requested\nrecords of one of these investigations, but was told by EQT’s Compliance Specialist that none\nwere available because there has not been an investigation of a reading more negative than -1.2\nvolts to date. The PHMSA inspector requested any other procedures that cover this type of\ninvestigation. EQT stated that there were no procedures written that cover how to conduct this\ntype of investigation.\n120151016M_NOA_07292015 Page 2 of 3\n\n\n\n1-2015-1016M\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\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis 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\nthis Notice, you may be ordered to amend your plans or procedures to correct the inadequacies\n(49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that you submit your\namended procedures to my office within 60 days of receipt of this Notice. This period may be\nextended by written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement 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)\nand submit the total to Byron Coy, PE, Director, Eastern Region, Pipeline and Hazardous\nMaterials Safety Administration. In correspondence concerning this matter, please refer to CPF\n1-2015-1016M and, for each document you submit, please provide a copy in electronic format\nwhenever possible.\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120151016M_NOA_07292015 Page 3 of 3","truncated":false,"body_characters":8509}