{"operation":"document","citation":"CPF 120191009M","title":"EASTERN GAS TRANSMISSION AND STORAGE, INC. — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-04-08","effective_on":null,"summary":"CLOSED notice of amendment citing 192.613(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120191009m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120191009m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120191009m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120191009M","body":"Notice of Amendment involving EASTERN GAS TRANSMISSION AND STORAGE, INC.. PHMSA's enforcement data identifies the cited regulation as 192.613(a). The case was opened on 2019-04-08 and is reported as closed as of 2019-05-13. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120191009M_Closure Letter_05132019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191009M/120191009M_Closure%20Letter_05132019.pdf\n\n120191009M_Closure Letter_05132019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191009M/120191009M_Closure%20Letter_05132019_text.pdf\n\n120191009M_Notice of Amendment_04082019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191009M/120191009M_Notice%20of%20Amendment_04082019.pdf\n\n120191009M_Notice of Amendment_04082019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191009M/120191009M_Notice%20of%20Amendment_04082019_text.pdf\n\n120191009M_Operator Response to Notice_04172019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191009M/120191009M_Operator%20Response%20to%20Notice_04172019.pdf\n\n120191009M_Notice of Amendment_04082019_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nApril 8, 2019\nMr. Brian Sheppard\nVP, Eastern Pipeline Operations\nDominion Energy Transmission, Inc.\n925 White Oaks Boulevard\nBridgeport, WV 26330\nCPF 1-2019-1009M\nDear Mr. Sheppard:\nFrom November 14 – 15, 2017, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of Title 49 of the United States Code (U.S.C.)\ninspected Dominion Energy Transmission, Inc.’s (Dominion) TL-342 Retest & Replacement\nconstruction project in Wetzel County, WV, and reviewed Dominion’s procedures for continuing\nsurveillance subsequent to the inspection.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nDominion’s plans or procedures, as described below:\n1. § 192.613 Continuing surveillance.\n(a) Each operator shall have a procedure for continuing surveillance of its facilities\nto determine and take appropriate action concerning changes in class location,\nfailures, leakage history, corrosion, substantial changes in cathodic protection\nrequirements, and other unusual operating and maintenance conditions.\nDominion’s procedures for continuing surveillance of its facilities were inadequate. Specifically,\nDominion’s Standard Operating Procedure 01/Continuing Surveillance of Pipeline Facilities,\nSection 065/Continuing Surveillance, revised 8/2/2018 (SOP), failed to include continuing\nsurveillance provisions for unusual operating and maintenance conditions such as soil erosion,\nreplacement of a pipeline segment, or other circumstances. The SOP failed to include guidance on\nwhen and how to evaluate the depth of cover of facilities experiencing these conditions and to take\nappropriate actions when discovered.\n\n\n\nCPF 1-2019-1009M\nFollowing the construction project inspection conducted in November of 2017, PHMSA requested\nand reviewed Dominion’s SOP. Based on that review, Dominion’s procedures were deemed\ninadequate for addressing the unusual operating and maintenance condition of replacing a pipeline\nsegment. Dominion should consider adding provisions in its SOP for addressing this condition,\nincluding steps such as:\n Performing an analysis to assess the potential safety impacts of inadequate depth of cover\nresulting from erosion, short pipeline segment replacements, or other circumstances.\n Implementing measures to address these potential safety impacts, when appropriate.\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\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 Dominion maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please refer\nto CPF 1-2019-1009M and, for each document you submit, please provide a copy in electronic\nformat whenever possible.\n120191009M_Notice of Amendment_04082019_text Page 2 of 3\n\n\n\nCPF 1-2019-1009M\nIf you have any questions, please contact us at 609-771-7800.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120191009M_Notice of Amendment_04082019_text Page 3 of 3\n\n120191009M_Closure Letter_05132019_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nMay 13, 2019\nMr. Brian Sheppard\nVP, Eastern Pipeline Operations\nDominion Energy Transmission, Inc.\n925 White Oaks Boulevard\nBridgeport, WV 26330\nCPF 1-2019-1009M\nDear Mr. Sheppard:\nOn November 14 – 15, 2017, a representative 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 Dominion Energy Transmission, Inc.’s (Dominion) procedures in\nBridgeport, WV. As a result of the inspection, Dominion was issued a Notice of Amendment on\nApril 8, 2019, which proposed amendment of your procedures.\nDominion submitted its amended procedures on April 17, 2019. 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,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":7389}