{"operation":"document","citation":"CPF 12020019WL","title":"EQUITRANS MIDSTREAM CORPORATION — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-11-24","effective_on":null,"summary":"CLOSED warning letter citing 192.731(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12020019wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12020019wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12020019wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12020019WL","body":"Warning Letter involving EQUITRANS MIDSTREAM CORPORATION. PHMSA's enforcement data identifies the cited regulation as 192.731(a). The case was opened on 2020-11-24 and is reported as closed as of 2020-11-24. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12020019WL_Operator Response to Notice_02172021_(20-171845).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12020019WL/12020019WL_Operator%20Response%20to%20Notice_02172021_(20-171845).pdf\n\n12020019WL_Warning Letter_11242020_(20-171845).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12020019WL/12020019WL_Warning%20Letter_11242020_(20-171845).pdf\n\n12020019WL_Warning Letter_11242020_(20-171845)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12020019WL/12020019WL_Warning%20Letter_11242020_(20-171845)_text.pdf\n\n12020019WL_Warning Letter_11242020_(20-171845)_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nNovember 24, 2020\nMr. Gregg West\nVice President, Midstream Operations\nEquitrans Midstream Corporation\n2200 Energy Drive\nCanonsburg, PA 15317\nCPF 1-2020-019-WL\nDear Mr. West:\nFrom July 27-31, 2020, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nEquitrans Midstream Corporation’s (Equitrans) procedures and records.\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 item(s) inspected\nand the probable violation(s) are:\n1. § 192.731 Compressor stations: Inspection and testing of relief devices.\n(a) Except for rupture discs, each pressure relieving device in a\ncompressor station must be inspected and tested in accordance with\n§§192.739 and 192.743, and must be operated periodically to determine\nthat it opens at the correct set pressure.\nEquitrans failed to inspect and test each pressure relieving device in a compressor station in\naccordance with § 192.743. Specifically, Equitrans failed to determine if three relief devices\nlocated in compressor stations were adequate from the standpoint of capacity by not considering\nrelief valve inlet and outlet piping in capacity calculations required under § 192.743.\nSection 192.743 states in part:\n\n\n\nCPF 1-2020-019-WL\n(a) Pressure relief devices at pressure limiting stations and pressure regulating\nstations must have sufficient capacity to protect the facilities to which they are\nconnected. Except as provided in §192.739(b), the capacity must be consistent\nwith the pressure limits of §192.201(a). This capacity must be determined at\nintervals not exceeding 15 months, but at least once each calendar year, by\ntesting the devices in place or by review and calculations.\n(b) If review and calculations are used to determine if a device has sufficient\ncapacity, the calculated capacity must be compared with the rated or\nexperimentally determined relieving capacity of the device for the conditions\nunder which it operates. After the initial calculations, subsequent calculations\nneed not be made if the annual review documents that parameters have not\nchanged to cause the rated or experimentally determined relieving capacity to\nbe insufficient.\nEquitrans’ Design and Construction Manual, Design Standard, Pressure Control, 7.2 Relief\nDevice Design and Installation, Section 6.1 Relief Valve Capacity Calculation, Revision Date\n8/27/20, required a Relief Valve Calculation form to be created for each new relief device. The\nnamed procedure required the Relief Valve Calculation form to be reviewed if changes occur that\naffect the required capacity or releieving capacity.\nWith regard to inlet piping losses, Equitrans’ Design and Construction Manual, Design Standard,\nPressure Control, 7.2 Relief Device Design and Installation, Section 4. Installation Requirements,\nRevision Date 8/27/20, required that the total of all inlet pressure losses not exceed 3% of the relief\ndevice set pressure. The named procedure required that Crane Technical Paper No. 410, Eqn 3-5,\nor another approved method be utilized to calculate Inlet Losses at the rated device capacity for\nthe relieving medium.\nWith regard to outlet piping losses, Equitrans’ Design and Construction Manual, Design Standard,\nPressure Control, 7.2 Relief Device Design and Installation, Section 4. Installation Requirements,\nRevision Date 8/27/20, required that Crane Technical Paper No. 410, Eqn. 3-5, or another\napproved method be utilized to calculate pressure losses in vent piping, and that Company\napproved software be used to calculate vent piping backpressure.\nDuring the inspection, the PHMSA inspector requested records for capacity calculations of certain\nrelief valves at compressor stations. The PHMSA inspector reviewed the Required Capacity and\nthe Calculated Capacity documented within the Equitable Resources Annual Relief Valve/Auto\nShut-off Device Inspection and Capacity Verification Reports for 3 relief valves located at Comet\nCompressor Station, Hartson Compressor Station, and Jefferson Compressor Station. The PHMSA\ninspector requested the supporting data for the calculations of both required capacity of the source\nof overpressure, and calculated capacity of the relief valve. Calculated capacity of the relief valve\nreferenced the orifice area; however, the calculations were for the relieving device only and did\nnot include consideration of inlet and outlet piping pressure losses which can limit relieving\ncapacity.\n12020019WL_Warning Letter_11242020_(20-171845)_text Page 2 of 3\n\n\n\nCPF 1-2020-019-WL\nTherefore, Equitrans failed to determine the adequacy of the capacity of three relief devices located\nat compressor stations by failing to consider inlet and outlet piping pressure losses in its\ncalculations performed pursuant to § 192.743.\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 Equitrans Midstream Corporation\nbeing subject to additional enforcement action.\nBe advised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you must\nprovide 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 1-2020-019-WL 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.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n12020019WL_Warning Letter_11242020_(20-171845)_text Page 3 of 3","truncated":false,"body_characters":8286}