{"operation":"document","citation":"CPF 120181023W","title":"EASTERN GAS TRANSMISSION AND STORAGE, INC. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-11-23","effective_on":null,"summary":"CLOSED warning letter citing 191.23(a)(9).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181023w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181023w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181023w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120181023W","body":"Warning Letter involving EASTERN GAS TRANSMISSION AND STORAGE, INC.. PHMSA's enforcement data identifies the cited regulation as 191.23(a)(9). The case was opened on 2018-11-23 and is reported as closed as of 2018-11-23. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120181023W_Operator Response to Notice_12172018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181023W/120181023W_Operator%20Response%20to%20Notice_12172018.pdf\n\n120181023W_Warning Letter_11232018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181023W/120181023W_Warning%20Letter_11232018.pdf\n\n120181023W_Warning Letter_11232018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181023W/120181023W_Warning%20Letter_11232018_text.pdf\n\n120181023W_Warning Letter_11232018_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nNovember 23, 2018\nMr. Brian Sheppard\nVice President, Eastern Pipeline Operations\nDominion Energy Transmission, Inc.\n925 White Oaks Boulevard\nBridgeport, WV 26330\nCPF 1-2018-1023W\nDear Mr. Sheppard:\nFrom January 17, 2018 to June 18, 2018, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Office of Pipeline Safety (OPS) and an Interstate Agent from\nNew York State Department of Public Service pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) inspected Dominion Energy Transmission, Inc.’s (Dominion) procedures and records in\nBridgeport, West Virginia.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulation, Title 49, Code of Federal Regulations (CFR). The item inspected and\nthe probable violation is:\n1. § 191.23 Reporting safety-related conditions.\n(a) Except as provided in paragraph (b) of this section, each operator shall report in\naccordance with §191.25 the existence of any of the following safety-related conditions\ninvolving facilities in service:\n(1) …\n(9) Any safety-related condition that could lead to an imminent hazard and causes\n(either directly or indirectly by remedial action of the operator), for purposes other\nthan abandonment, a 20% or more reduction in operating pressure or shutdown of\noperation of a pipeline or an underground natural gas storage facility, including\ninjection, withdrawal, monitoring, or observation well for an underground natural\ngas storage facility, or an LNG facility that contains or processes gas or LNG.\n\n\n\nCPF 1-2018-1023W\nDominion failed to report in accordance with § 191.25 the existence of a safety-related condition\nthat could lead to an imminent hazard and caused a 20% or more reduction in operating pressure\nor shutdown the operation of its LN24 pipeline. Specifically, Dominion identified a dent with\nmetal loss that could lead to an immediate hazard, reduced operating pressure by 20% or more\nalong pipeline LN24 begining June 21, 2017, and completed replacement of the section of pipeline\non September 18, 2017, but failed to report the safety-related condition.\nDuring the inspection, the PHMSA inspector reviewed a management of change record, CAF Entry\nForm dated June 21, 2017 (CAF Number: T&S 1429). The CAF Number: T&S 1429 stated in\npart:\n“several anomalies of immediate concern (all outside of HCA) were identified during the recent\nILI run on the section of LN24… A temporary reduction in operating pressure (20% lower than\nthe highest operating pressure since the ILI run… 574 psig @ Stateline and 557 psig @ Angelica)\nhas been implemented until all the limiting concerns are addressed.”\nLN24 is a 20-inch diameter transmission pipeline with a maximum allowable operating pressure\nof 850 pounds per square inch gauge (psig).\nSubsequently, the PHMSA inspector reviewed a final ILI report dated June 30, 2017 that identified\nthe anomalies noted in the CAF Number: T&S 1429. The ILI report revealed an anomaly was a\n1.2% dent with 32% metal loss at the 6:24 o’clock position on LN24 pipeline. The anomaly was\nnot in a high consequence area but within 220 yards from a bulding intended for human occupancy\nnear the corner of Stone Dam Road and Graves Road in Wellsville, New York. Dominion\nexplained to the PHMSA inspector that it excavated and evaluated the anomaly on LN24 pipeline\n(referred to as “Dig 10”). According to Dominion’s record Corrosion Pipe Evaluation Report –\nPipeline Number LN24 Report ID: 4597 dated September 14, 2017 (Report ID: 4597), a B31G\nevaluation concluded that the MAOP was too high and exceeded design pressure on LN24 pipeline\nat the anomaly location. In addition, Report ID: 4597 stated that Dig 10 involved major pitting in\nelectric resistance welding seam. A record titled Transmission Field Inspection Report Incident\nID: 87997 stated that Dominion replaced the section of pipeline where the anomaly was located\non September 18, 2017.\nDominion identified a dent with metal loss that could lead to an immediate hazard, reduced\noperating pressure by 20% or more along pipeline LN24 begining June 21, 2017, and completed\nreplacement of the section of pipeline on September 18, 2017. Dominion did not have\ndocumentation to demonstrate that it reported the safety-related condition. Therefore, Dominion\nfailed to report in accordance with § 191.25 the existence of a safety-related condition that could\nlead to an imminent hazard and cause a 20% or more reduction in operating pressure or shutdown\nthe operation of its LN24 pipeline, as prescribed in § 191.23(a)(9).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$209,002 per violation per day the violation persists, up to a maximum of $2,090,022 for a related\nseries of violations. For violations occurring prior to November 2, 2015, the maximum penalty\nmay not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000\nfor a related 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 item identified in this letter.\nFailure to do so will result in Dominion, being subject to additional enforcement action.\n120181023W_Warning Letter_11232018_text Page 2 of 3\n\n\n\nCPF 1-2018-1023W\nPlease be advised that all material you submit in response to this enforcement action is subject to\nbeing made publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential 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 confidential\ntreatment redacted and an explanation of why you believe the redacted information qualifies for\nconfidential treatment under 5 U.S.C. 552(b).\nNo reply to this letter is required. If you choose to reply, please submit all correspondence in this\nmatter to Robert Burrough, Director, PHMSA Eastern Region, 840 Bear Tavern Road, Suite 300,\nWest Trenton, NJ 08628. Please refer to CPF 1-2018-1023W on each document you submit, and\nwhenever possible provide a signed PDF copy in electronic format. Smaller files may be emailed\nto robert.burrough@dot.gov. Larger files should be sent on a CD accompanied by the original\npaper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120181023W_Warning Letter_11232018_text Page 3 of 3","truncated":false,"body_characters":7521}