EASTERN GAS TRANSMISSION AND STORAGE, INC. — Notice of Amendment

party submissionOfficial PDF120191009M_Operator Response to Notice_04172019.pdf#

120191009M_Notice of Amendment_04082019_text.pdf, page 1Official PDFNOTICE OF AMENDMENT OVERNIGHT EXPRESS DELIVERY April 8, 2019 Mr. Brian Sheppard VP, Eastern Pipeline Operations Dominion Energy Transmission, Inc. 925 White Oaks Boulevard Bridgeport, WV 26330 CPF 1-2019-1009M Dear Mr. Sheppard: From November 14 – 15, 2017, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of Title 49 of the United States Code (U.S.C.) inspected Dominion Energy Transmission, Inc.’s (Dominion) TL-342 Retest & Replacement construction project in Wetzel County, WV, and reviewed Dominion’s procedures for continuing surveillance subsequent to the inspection. On the basis of the inspection, PHMSA has identified the apparent inadequacies found within Dominion’s plans or procedures, as described below: 1. § 192.613 Continuing surveillance. (a) Each operator shall have a procedure for continuing surveillance of its facilities to determine and take appropriate action concerning changes in class location, failures, leakage history, corrosion, substantial changes in cathodic protection requirements, and other unusual operating and maintenance conditions. Dominion’s procedures for continuing surveillance of its facilities were inadequate. Specifically, Dominion’s Standard Operating Procedure 01/Continuing Surveillance of Pipeline Facilities, Section 065/Continuing Surveillance, revised 8/2/2018 (SOP), failed to include continuing surveillance provisions for unusual operating and maintenance conditions such as soil erosion, replacement of a pipeline segment, or other circumstances. The SOP failed to include guidance on when and how to evaluate the depth of cover of facilities experiencing these conditions and to take appropriate actions when discovered.#

120191009M_Notice of Amendment_04082019_text.pdf, page 2CPF 1-2019-1009M Following the construction project inspection conducted in November of 2017, PHMSA requested and reviewed Dominion’s SOP. Based on that review, Dominion’s procedures were deemed inadequate for addressing the unusual operating and maintenance condition of replacing a pipeline segment. Dominion should consider adding provisions in its SOP for addressing this condition, including steps such as:  Performing an analysis to assess the potential safety impacts of inadequate depth of cover resulting from erosion, short pipeline segment replacements, or other circumstances.  Implementing measures to address these potential safety impacts, when appropriate. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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. Be advised that all material you submit in response to this enforcement action is subject to being 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). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. 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 an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 60 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that Dominion maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 1-2019-1009M and, for each document you submit, please provide a copy in electronic format whenever possible. 120191009M_Notice of Amendment_04082019_text Page 2 of 3#

120191009M_Notice of Amendment_04082019_text.pdf, page 3CPF 1-2019-1009M If you have any questions, please contact us at 609-771-7800. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings 120191009M_Notice of Amendment_04082019_text Page 3 of 3#

120191009M_Closure Letter_05132019_text.pdf, page 1Official PDFOVERNIGHT EXPRESS DELIVERY May 13, 2019 Mr. Brian Sheppard VP, Eastern Pipeline Operations Dominion Energy Transmission, Inc. 925 White Oaks Boulevard Bridgeport, WV 26330 CPF 1-2019-1009M Dear Mr. Sheppard: On November 14 – 15, 2017, a representative from the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site pipeline safety inspection of Dominion Energy Transmission, Inc.’s (Dominion) procedures in Bridgeport, WV. As a result of the inspection, Dominion was issued a Notice of Amendment on April 8, 2019, which proposed amendment of your procedures. Dominion submitted its amended procedures on April 17, 2019. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration#