{"operation":"document","citation":"CPF 120201012W","title":"EQUITRANS MIDSTREAM CORPORATION — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-04-14","effective_on":null,"summary":"CLOSED warning letter citing 192.303.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120201012w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120201012w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120201012w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120201012W","body":"Warning Letter involving EQUITRANS MIDSTREAM CORPORATION. PHMSA's enforcement data identifies the cited regulation as 192.303. The case was opened on 2020-04-14 and is reported as closed as of 2020-04-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120201012W_Operator Response to Notice and Request Withdrawal of Notice Letter_05072020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201012W/120201012W_Operator%20Response%20to%20Notice%20and%20Request%20Withdrawal%20of%20Notice%20Letter_05072020.pdf\n\n120201012W_Warning Letter_04142020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201012W/120201012W_Warning%20Letter_04142020.pdf\n\n120201012W_Warning Letter_04142020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201012W/120201012W_Warning%20Letter_04142020_text.pdf\n\n120201012W_Warning Letter_04142020_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nApril 14, 2020\nGregg West\nVice President, Midstream Operations\nEquitrans Midstream Corporation\n2200 Energy Drive\nCanonsburg, PA 15317\nCPF 1-2020-1012W\nDear Mr. West:\nOn August 6-8, 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\nEquitrans Midstream Corporation’s (EQT) Mountain Valley Pipeline project in Webster and\nBraxton Counties, 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 item(s) inspected\nand the probable violation(s) are:\n1. § 192.303 Compliance with specifications or standards.\nEach transmission line or main must be constructed in accordance\nwith comprehensive written specifications or standards that are\nconsistent with this part.\nEQT failed to construct the Mountain Valley Pipeline (MVP) in accordance with its\ncomprehensive written specifications or standards consistent with Part 192. Specifically, EQT\nfailed to follow its 10.2 Pipeline Construction Standard, Revision 4 – 1/22/19 (10.2 Standard)\nrequirements pertaining to § 192.319.\nSection 192.319(a) and (b) state:\n(a) When installed in a ditch, each transmission line that is to be operated at a\npressure producing a hoop stress of 20 percent or more of SMYS must be installed\n\n\n\nCPF 1-2020-1012W\nso that the pipe fits the ditch so as to minimize stresses and protect the pipe coating\nfrom damage.\n(b) When a ditch for a transmission line or main is backfilled, it must be backfilled\nin a manner that:\n(1) Provides firm support under the pipe; and\n(2) Prevents damage to the pipe and pipe coating from equipment or from the\nbackfill material.\nEQT’s 10.2 Standard includes requirements that pertain to § 192.319 and specifically requires that\nthe trench be wide enough and free from rock, gravel, and other objects that might damage the\npipe or the pipe’s coating. Notably, repeated references to trenching, quality of backfill material,\nsupport, damage prevention and spacing requirements are made in sections 9.1 - [Trenching]\nGeneral, 14.1 - Preparation for Lowering, 14.2 - Rocky Trench Bottom, and 15.3 - Padding.\nDuring the field inspection of MVP Spread C on August 6-8, 2019, the PHMSA inspector noted\nthe placement of pipe within ditches off Mudlick Run Road and Camp Creek Road was not\nperformed in a manner consistent with EQT’s procedures prescribed by § 192.303.\nAt Mudlick Run Road, 42-inch diameter pipe was noted to have been placed within a rock laden\ntrench without adequate support padding and/or backfill material to protect the pipe coating from\ndamage due to protruding rocks and spoils within the trench. Observations indicated that pipe\ninstalled at this location may be susceptible to stresses and/or damage that may incur as a result of\nmovement or settlement that is typical during required post installation hydrostatic\ntesting. Specifically, preparation of trench, padding height and clear spacing requirements\nbetween rock and pipe wall were inconsistent with the required minimum stipulated in EQT’s 10.2\nStandard, Sections 9.1, 14.1, 14.2 and 15.3. EQT’s response to an inquiry by the inspector noted\nthat the installation was a proposed tie-in location which was incomplete at the time of\ninspection. The location was subsequently remediated with supporting evidence provided at the\nrequest of the PHMSA inspector.\nAt Camp Creek Road, the PHMSA inspector observed 42-inch diameter pipe being placed within\na rock laden trench inconsistent with EQT’s construction standard requirements. Specifically, clear\nspacing requirements between pipe and rock wall, rock and/or rock fragments were inconsistent\nwith the required minimum stipulated in EQT’s 10.2 Standard, Sections 9.1, 14.1, 14.2 and 15.3\nObservations indicated that pipe installed at this location may be susceptible to stresses and/or\ndamage that may incur as a result of movement or settlement that is typical during required post\ninstallation hydrostatic testing.\nBecause the MVP was not being installed in accordance with EQT’s 10.2 Standard, and in a\nmanner that minimizes stresses and protects the pipe and pipe coating at certain locations, EQT\nfailed to comply with § 192.303.\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,\n120201012W_Warning Letter_04142020_text Page 2 of 3\n\n\n\nCPF 1-2020-1012W\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 1-2020-1012W 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\n120201012W_Warning Letter_04142020_text Page 3 of 3","truncated":false,"body_characters":7744}