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

- **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:** Not available
- **summary:** CLOSED notice of amendment citing 192.613(a).
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- **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.

Official case documents:

120191009M_Closure Letter_05132019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191009M/120191009M_Closure%20Letter_05132019.pdf

120191009M_Closure Letter_05132019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191009M/120191009M_Closure%20Letter_05132019_text.pdf

120191009M_Notice of Amendment_04082019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191009M/120191009M_Notice%20of%20Amendment_04082019.pdf

120191009M_Notice of Amendment_04082019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191009M/120191009M_Notice%20of%20Amendment_04082019_text.pdf

120191009M_Operator Response to Notice_04172019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191009M/120191009M_Operator%20Response%20to%20Notice_04172019.pdf

120191009M_Notice of Amendment_04082019_text.pdf

NOTICE 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.



CPF 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



CPF 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

OVERNIGHT 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
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