{"operation":"document","citation":"CPF 120181019M","title":"EQUITRANS MIDSTREAM CORPORATION — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-08-22","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181019m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181019m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181019m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120181019M","body":"Notice of Amendment involving EQUITRANS MIDSTREAM CORPORATION. PHMSA's enforcement data identifies the cited regulation as 192.12(e). The case was opened on 2018-08-22 and is reported as closed as of 2018-11-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120181019M_Closure Letter_11022018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181019M/120181019M_Closure%20Letter_11022018.pdf\n\n120181019M_Notice of Amendment_08222018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181019M/120181019M_Notice%20of%20Amendment_08222018.pdf\n\n120181019M_Notice of Amendment_08222018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181019M/120181019M_Notice%20of%20Amendment_08222018_text.pdf\n\n120181019M_Operator Response to Notice_09172018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181019M/120181019M_Operator%20Response%20to%20Notice_09172018.pdf\n\n120181019M_Notice of Amendment_08222018_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nAugust 22, 2018\nMr. Gregg West\nVice President, Midstream Operations\nEQT Midstream\n2200 Energy Drive\nCanonsburg, PA 15317\nCPF 1-2018-1019M\nDear Mr. West:\nFrom April 16–20, 2018, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the\nEQT Midstream (EQT) procedures for the operation of the Gamble-Hayden Natural Gas Storage\nFacilities. The specific purpose of the inspection was to evaluate the compliance with 49 CFR\n§ 192.12 and associated references in § 192.7. The inspection was conducted at the EQT Offices\nin Jefferson Hills, Pennsylvania and at the Gamble-Hayden storage facility in Allegheny County,\nPennsylvania.\nBased on the results of the inspection, PHMSA has identified the apparent inadequacies found\nwithin the EQT Underground Natural Gas Storage (UNGS) procedures, as described below:\n1. § 192.12 Underground natural gas storage facilities.\n(e) Operators of underground gas storage facilities must establish and follow written\nprocedures for operations, maintenance, and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171, as required under this section,\nincluding the effective dates as applicable, and incorporate such procedures into their\nwritten procedures for operations, maintenance, and emergencies established\npursuant to § 192.605.\nEQT’s written procedures for operations, maintenance and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171 were inadequate. Specifically, EQT did not\nestablish a written Blowout Contingency Plan (BCP), as directed by API RP 1171, Section 10.6.3,\ncovering the wells in the Gamble-Hayden storage facility.\n\n\n\nCPF 1-2018-1019M\n2. The BCP was phased out of the Emergency Response Plan (ERP) even though it was still\nreferenced in the ERP. The BCP is not included in the Emergency Table-Top Exercise program.\n§ 192.12 Underground natural gas storage facilities.\n(e) Operators of underground gas storage facilities must establish and follow written\nprocedures for operations, maintenance, and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171, as required under this section,\nincluding the effective dates as applicable, and incorporate such procedures into their\nwritten procedures for operations, maintenance, and emergencies established\npursuant to § 192.605.\nEQT’s written procedures for operations, maintenance and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171 were inadequate. Specifically, EQT’s written\nprocedures did not provide details on how to determine operator familiarity with UNGS emergency\nplans, procedures and periodic testing of the effectiveness of the plan, as directed by API RP 1171,\nSection 11.4.2.\n3. § 192.12 Underground natural gas storage facilities.\n(e) Operators of underground gas storage facilities must establish and follow written\nprocedures for operations, maintenance, and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171, as required under this section,\nincluding the effective dates as applicable, and incorporate such procedures into their\nwritten procedures for operations, maintenance, and emergencies established\npursuant to § 192.605.\nEQT’s written procedures for operations, maintenance and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171 were inadequate. Specifically, EQT’s written\nprocedures did not incorporate safety and environmental programs, as directed by API RP 1171,\nSection 11.9.1.\nEQT’s environmental engineer evaluated new construction, but EQT was unable to show where\nHealth, Safety, and Environment (HSE) programs were included in UNGS procedures.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this 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\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\n120181019M_Notice of Amendment_08222018_text Page 2 of 3\n\n\n\nCPF 1-2018-1019M\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 60 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that EQT Corporation Company, EQT Midstream maintain\ndocumentation of the safety improvement costs associated with fulfilling this Notice of\nAmendment (preparation/revision of plans, procedures) and submit the total to Robert Burrough,\nDirector, Eastern Region, Pipeline and Hazardous Materials Safety Administration. In\ncorrespondence concerning this matter, please refer to CPF 1-2018-1019M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120181019M_Notice of Amendment_08222018_text Page 3 of 3\n\n120181019M_Closure Letter_11022018.pdf\n\nU.S. Department\n840 Bear Tavern Road, Suite 300\nof Transportation\nWest Trenton, NJ 08628\nPipeline and\n609.771.7800\nHazardous Materials\nSafety Administration\nOVERNIGHT EXPRESS DELIVERY\nNovember 2, 2018\nMr Gregg West\nVice President, Midstream Operations\nEQT Midstream\n2200 Energy Drive\nCanonsburg, PA 15317\nCPF 1-2018-1019M\nDear Mr. West:\nFrom April 16-20, 2018 representatives from the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site\npipeline safety inspection of EQT Midstream (EQT) procedures for the operations of the Gamble-\nHayden Natural Gas Storage Facilities. The specific purpose of the audit was to evaluate the\nprogress EQT Midstream has made to be in compliance with API RP 1171 (incorporated in\n49 CFR 192.12 by reference, see §192.7). The audit was conducted at the QT Training Center\nOffices at 4029 Ridge Road, Jefferson Hills, Pennsylvania and on-site at the Gamble-Hayden\nstorage facility in Allegheny county Pennsylvania. As a result of the inspection, EQT was issued\na Notice of Amendment on August 22, 2018, which proposed amendment of your procedures.\nEQT submitted a response to the NOA and amended procedures to satisfy the NOA on\ninadequacies outlined in this Notice of Amendment have been corrected\nSeptember 17, 2018. My staff reviewed the amended procedures, and it appears that the\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely.\nCaht Burn\nRobert Burroug\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":9076}