{"operation":"document","citation":"CPF 12021027WL","title":"EQUITRANS MIDSTREAM CORPORATION — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-03-25","effective_on":null,"summary":"CLOSED warning letter citing 192.12(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021027wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021027wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021027wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12021027WL","body":"Warning Letter involving EQUITRANS MIDSTREAM CORPORATION. PHMSA's enforcement data identifies the cited regulation as 192.12(b)(2). The case was opened on 2021-03-25 and is reported as closed as of 2021-03-25. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12021027WL_Warning Letter_03252021_(20-172565).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021027WL/12021027WL_Warning%20Letter_03252021_(20-172565).pdf\n\n12021027WL_Warning Letter_03252021_(20-172565)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021027WL/12021027WL_Warning%20Letter_03252021_(20-172565)_text.pdf\n\n12021027WL_Warning Letter_03252021_(20-172565)_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nMarch 25, 2021\nMr. Gregg West\nVice President Midstream Operations\nEquitrans Midstream Corporation\n2200 Energy Drive\nCanonsburg, PA 15317\nCPF 1-2021-027-WL\nDear Mr. West:\nFrom September 29 – October 2, 2020, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.)\ninspected Equitrans Midstream Corporation’s (Equitrans) underground natural gas storage facility\nin Shirley, West Virginia.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. § 192.12 Underground natural gas storage facilities.\n(a) …\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs.\n(1) …\n(2) Each UNGSF that uses a depleted hydrocarbon reservoir or an\naquifer reservoir for natural gas storage and was constructed on or\nbefore July 18, 2017, must meet the provisions of API RP 1171\n(incorporated by reference, see §192.7), sections 8, 9, 10, and 11, and\nparagraph (c) of this section, by January 18, 2018, and must meet all\nprovisions of paragraph (d) of this section by March 13, 2021.\nEquitrans failed to meet the provisions of API RP 1171, Section 9. Specifically, Equitrans failed\n\n\n\nCPF 1-2021-027-WL\nto document its monthly storage well inspections in accordance with its written procedures, as\nrequired by API RP 1171, Section 9.8.1 (Section 9.8.1).\nSection 9.8.1 states that “[i]nspections, tests, patrols, or analyses shall be documented according\nto the operator’s procedures.”\nDuring the inspection, Equitrans procedures for monthly well inspections were reviewed. The\nEquitrans Integrity Management Program for Underground Gas Storage (SIMP), Section 5.2,\naddressed monthly storage well inspections. This section noted 13 specific items in the monthly\nwell inspections that are to be noted and recorded.\nEquitrans personnel also demonstrated DataSplice, the field data logging application. The team\nobserved 6 inspection items in the DataSplice field application that were noted and recorded as\npart of the monthly inspections. Seven (7) of the items were not explicitly noted and recorded.\nThus, the inspection records fail to document all 13 items to be performed in the monthly well\ninspections required by its SIMP.\nTherefore, Equitrans failed to meet the provisions of Section 9.8.1.\n2. § 192.12 Underground natural gas storage facilities.\n(a) …\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs.\n(1) …\n(2) Each UNGSF that uses a depleted hydrocarbon reservoir or an\naquifer reservoir for natural gas storage and was constructed on or\nbefore July 18, 2017, must meet the provisions of API RP 1171\n(incorporated by reference, see §192.7), sections 8, 9, 10, and 11, and\nparagraph (c) of this section, by January 18, 2018, and must meet all\nprovisions of paragraph (d) of this section by March 13, 2021.\nEquitrans failed to meet the provisions of API RP1171, Section 11. Specifically, Equitrans failed\nto develop and implement O&M procedures covering storage wells and reservoirs prior to the\ncommissioning operations set forth in Section 7 [of API RP 1171], as required by API RP 1171,\nSection 11.3.1 (Section 11.3.1).\nProcedures are made available to Equitrans Midstream personnel through the company's\nSharePoint site, and are provided to contractors upon request (by email).\nThe inspection team reviewed the following procedures on SharePoint:\n STR-03, Monthly Inspection of Storage Wells. The effective date and the revision date\nwere not noted.\n STR-04, Well Entry. The effective date and the revision date were not noted.\n STR-06, P/A Storage Well Inspection. The effective date noted for this procedure was 5-\n13-20.\nSome of the procedures housed on the SharePoint site and made available to company personnel,\n12021027WL_Warning Letter_03252021_(20-172565)_text Page 2 of 3\n\n\n\nCPF 1-2021-027-WL\nand described as the official copies, were undated.\nThe lack of effective dates on the procedures did not establish that the procedures were developed\nand implemented prior to the effective date of the final rule, or were the current editions.\nTherefore, Equitrans failed to meet the provisions of Section 11.3.1.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for a related\nseries of violations. For violation occurring on or after July 31, 2019 and before January 11, 2021,\nthe maximum penalty may not exceed $218,647 per violation per day the violation persists, up to\na maximum of $2,186,465 for a related series of violations. For violation occurring on or after\nNovember 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per\nviolation per day, with a maximum penalty not to exceed $2,132,679. For violation occurring on\nor after November 2, 2015 and before November 27, 2018, the maximum penalty may not exceed\n$209,002 per violation per day, with a maximum penalty not to exceed $2,090,022.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the items identified in this letter. Failure to do so will result in\nEquitrans Midstream Corporation being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2021-027-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n12021027WL_Warning Letter_03252021_(20-172565)_text Page 3 of 3","truncated":false,"body_characters":7100}