{"operation":"document","citation":"CPF 120191016W","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":"2019-09-13","effective_on":null,"summary":"CLOSED warning letter citing 192.12(d).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120191016w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120191016w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120191016w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120191016W","body":"Warning Letter involving EASTERN GAS TRANSMISSION AND STORAGE, INC.. PHMSA's enforcement data identifies the cited regulation as 192.12(d). The case was opened on 2019-09-13 and is reported as closed as of 2019-09-13. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120191016W_Operator Response to Notice_10212019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191016W/120191016W_Operator%20Response%20to%20Notice_10212019.pdf\n\n120191016W_Warning Letter_09132019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191016W/120191016W_Warning%20Letter_09132019.pdf\n\n120191016W_Warning Letter_09132019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191016W/120191016W_Warning%20Letter_09132019_text.pdf\n\n120191016W_Warning Letter_09132019_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nSeptember 13, 2019\nMr. Brian Sheppard\nVice President, Eastern Pipeline Operations\nDominion Energy Transmission, Inc.\n925 White Oak Boulevard\nBridgeport, WV 26330\nCPF 1-2019-1016W\nDear Mr. Sheppard:\nFrom June 24th-27th, 2019, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nDominion Energy Transmission, Inc.’s (DETI) Fink-Kennedy-Lost Creek Underground Natural\nGas Storage Field. The inspection was conducted at the DETI office in Bridgeport, West Virginia\nand the Fink-Kennedy-Lost Creek field located in Lewis County, West Virginia.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violation is:\n1. § 192.12 Underground natural gas storage facilities.\n(d) Each underground natural gas storage facility that uses a depleted hydrocarbon\nreservoir or an aquifer reservoir for gas storage, including those constructed not later\nthan July 18, 2017 must meet the operations, maintenance, integrity demonstration\nand verification, monitoring, threat and hazard identification, assessment,\nremediation, site security, emergency response and preparedness, and recordkeeping\nrequirements and recommendations of API RP 1171, sections 8, 9, 10, and 11\n(incorporated by reference, see §192.7) by January 18, 2018.\n\n\n\nCPF 1-2019-1016W\nDETI failed to monitor for the presence of annular gas as directed by API RP 1171, Section 9.3.2\non 46% of the wells in the field.\nSection 9.3.2 of API RP 1171, Well Integrity Monitoring, states:\nThe operator shall monitor for presence of annular gas by measuring and recording annular\npressure and/or annular gas flow.\nDuring the field inspection at Fink-Kennedy-Lost Creek UGS field, PHMSA discovered that DETI\nwas unable to monitor for the presence of annular gas at the surface due to a lack of pressure test\nports or other means of measuring annular gas flow.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related\nseries of violations. For violation occurring on or after November 27, 2018 and before July 31,\n2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum\npenalty not to exceed $2,132,679. For violation occurring on or after November 2, 2015 and before\nNovember 27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a\nmaximum penalty not to exceed $2,090,022. For violations occurring prior to November 2, 2015,\nthe maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty\nnot to exceed $2,000,000 for a related series of violations.We have reviewed the circumstances\nand supporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct the\nitem(s) identified in this letter. Failure to do so will result in Dominion Energy Transmission, Inc.\nbeing subject to additional enforcement action.\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 1-2 019-1016W 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 USB flash drive accompanied by the\noriginal paper copy to the Eastern Region Office.\n120191016W_Warning Letter_09132019_text Page 2 of 3\n\n\n\nCPF 1-2019-1016W\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120191016W_Warning Letter_09132019_text Page 3 of 3","truncated":false,"body_characters":5419}