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

- **operation:** document
- **citation:** CPF 120191010M
- **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:** 2019-07-22
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 192.225(a).
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-120191010m.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-120191010m
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120191010M
**body:**

Notice of Amendment involving EASTERN GAS TRANSMISSION AND STORAGE, INC.. PHMSA's enforcement data identifies the cited regulation as 192.225(a). The case was opened on 2019-07-22 and is reported as closed as of 2019-09-12. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120191010M_Closure Letter_09122019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191010M/120191010M_Closure%20Letter_09122019.pdf

120191010M_Closure Letter_09122019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191010M/120191010M_Closure%20Letter_09122019_text.pdf

120191010M_Notice of Amendment_07222019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191010M/120191010M_Notice%20of%20Amendment_07222019.pdf

120191010M_Notice of Amendment_07222019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191010M/120191010M_Notice%20of%20Amendment_07222019_text.pdf

120191010M_Operator Response to Notice_08162019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191010M/120191010M_Operator%20Response%20to%20Notice_08162019.pdf

120191010M_Notice of Amendment_07222019_text.pdf

NOTICE OF AMENDMENT
OVERNIGHT EXPRESS DELIVERY
July 22, 2019
Mr. Brian Sheppard
VP, Pipeline Operations
Dominion Energy Transmission, Inc.
925 Whiteoaks Boulevard
Bridgeport, WV 26330
CPF 1-2019-1010M
Dear Mr. Sheppard:
From October 16 – 18, 2018, a representative from the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),
inspected Dominion Energy Transmission, Inc.’s (Dominion) procedures for welding in Loudoun
County, Virginia.
On the basis of the inspection, PHMSA has identified the apparent inadequacy found within
Dominion’s plans or procedures, as described below:
1. § 192.225 Welding procedures.
(a) Welding must be performed by a qualified welder or welding operator in
accordance with welding procedures qualified under section 5, section 12,
Appendix A or Appendix B of API Std 1104 (incorporated by reference, see §
192.7) or section IX of the ASME Boiler and Pressure Vessel Code (ASME BPVC)
(incorporated by reference, see § 192.7) to produce welds meeting the
requirements of this subpart. The quality of the test welds used to qualify welding
procedures must be determined by destructive testing in accordance with the
applicable welding standard(s).



CPF 1-2019-1010M
Dominion’s welding procedures qualified under section 5 of API Std 1104 were
inadequate. Specifically, Dominion’s Weld Procedure DT-312SC-WOL 04/01/07 Rev.: 0 and
DT-322SC-WOL 04/01/07 Rev.: 0 (Procedures) did not designate the maximum time between the
completion of the root pass and hot pass, and the hot pass and 3rd pass, as required by section 5 of
API Standard 1104 – Welding of Pipelines and Related Facilities, 20th Edition (API 1104).
API 1104, Section 5.3.2.10 states:
“The maximum time between the completion of the root bead and
the start of the second bead, as well as the maximum time between
the completion of the second bead and the start of other beads, shall
be designated.”
On January 15, 2016, API issued a technical interpretation clarifying the intent of Section 5.3.2.10
of API 1104 20th Edition, which stated “Yes, the intent of API 1104, Section 5.3.2.10 is to identify
the maximum time between the 1st pass and 2nd pass and the maximum time between the 2nd
pass and 3rd pass.”
During the inspection, the Procedures were reviewed. The Procedures stated under Time Between
Passes, “All passes for Fittings shall be completed without delay.” Therefore, DETI's Procedures
failed to designate the time between weld passes as required by section 5 of API 1104, referenced
in § 192.225(a).
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 Energy Transmission, Inc. maintain documentation
120191010M_Notice of Amendment_07222019_text Page 2 of 3



CPF 1-2019-1010M
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,
PHMSA Eastern Region, 840 Bear Tavern Road, Suite 300, West Trenton, NJ 08628. Please refer
to CPF 1-2019-1010M on each document you submit, and whenever possible provide a signed
PDF copy in electronic format. Smaller files may be emailed to robert.burrough@dot.gov. Larger
files should be sent on USB flash drive accompanied by the original paper copy to the Eastern
Region Office.
Additionally, if you choose to respond to this (or any other case), please ensure that any response
letter pertains solely to one CPF case number.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
120191010M_Notice of Amendment_07222019_text Page 3 of 3

120191010M_Closure Letter_09122019_text.pdf

OVERNIGHT EXPRESS DELIVERY
September 12, 2019
Mr. Brian Sheppard
VP, Pipeline Operations
Dominion Energy Transmission, Inc.
925 Whiteoaks Boulevard
Bridgeport, WV 26330
CPF 1-2019-1010M
Dear Mr. Sheppard:
On October 16 – 18, 2018, 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 Loudoun County, Virginia. As a result of the inspection, Dominion was issued a Notice of
Amendment on July 22, 2019, which proposed amendment of your procedures.
Dominion submitted its amended procedures on August 16, 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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