{"operation":"document","citation":"CPF 12021046WL","title":"EQUITRANS MIDSTREAM CORPORATION — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-08-05","effective_on":null,"summary":"CLOSED warning letter citing 191.22(c)(1)(iv), 191.25(a), 192.12(b)(2), 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021046wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021046wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021046wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12021046WL","body":"Warning Letter involving EQUITRANS MIDSTREAM CORPORATION. PHMSA's enforcement data identifies the cited regulations as 191.22(c)(1)(iv),  191.25(a),  192.12(b)(2),  192.12(c). The case was opened on 2021-08-05 and is reported as closed as of 2021-08-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12021046WL_Operator Response to Notice_09232021_(20-172148).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021046WL/12021046WL_Operator%20Response%20to%20Notice_09232021_(20-172148).pdf\n\n12021046WL_Warning Letter_08052021_(20-172148).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021046WL/12021046WL_Warning%20Letter_08052021_(20-172148).pdf\n\n12021046WL_Warning Letter_08052021_(20-172148)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021046WL/12021046WL_Warning%20Letter_08052021_(20-172148)_text.pdf\n\n12021046WL_Warning Letter_08052021_(20-172148)_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nAugust 5, 2021\nMr. Gregg West\nVice President Midstream Operations\nEquitrans Midstream Corporation\n2200 Energy Drive\nCanonsburg, PA 15317\nCPF 1-2021-046-WL\nDear Mr. West:\nFrom October 6 through October 9, 2020, representatives 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 (EQT) Rhodes and Skin Creek underground natural\ngas storage fields in Lewis County, 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. § 191.22 National Registry of Operators.\n(a) …\n(c) Changes. Each operator of a gas pipeline, gas pipeline facility,\nUNGSF, LNG plant, or LNG facility must notify PHMSA electronically\nthrough the National Registry of Operators at\nhttps://portal.phmsa.dot.gov of certain events.\n(1) An operator must notify PHMSA of any of the following events\nnot later than 60 days before the event occurs:\n(i) …\n12021046WL_Warning Letter_08052021_(20-172148)_text Page 1 of 7\n\n\n\nCPF 1-2021-046-WL\n(iv) Maintenance of a UNGSF that involves the plugging or\nabandonment of a well, or that requires a workover rig and costs\n$200,000or more for an individual well, including its wellhead. If 60-\ndays' notice is not feasible due to an emergency, an operator must\npromptly respond to the emergency and notify PHMSA as soon as\npracticable.\nEQT failed to file a required 60-day notification for the abandonment of underground natural gas\nwells.\nDuring the inspection, the inspection team reviewed the 2020 annual report filed for Rhodes and\nSkin Creek storage fields, which noted that one well in each of the fields was plugged and\nabandoned in 2019. The PHMSA Pipeline Data Mart database does not document that any\nnotifications were filed for either of these abandonments. EQT could not produce any\ndocumentation of the notifications, and later confirmed that no filings were made. Skin Creek\nWell 7757 was plugged and abandoned in 2019. The field operations to plug and abandon Rhodes\nWell 8164 were started in late 2019 and completed in early 2020. Both well abandonments were\nconducted in the course of other well integrity investigation activities.\nTherefore, EQT failed to file the appropriate notification for changes to its system as required\nby § 191.22(c)(1)(iv).\n2. § 191.25 Filing safety-related condition reports.\nEach report of a safety-related condition under § 191.23(a)(1)\nthrough (9) must be filed (received by the Associate Administrator) in\nwriting within 5 working days (not including Saturday, Sunday, or\nFederal holidays) after the day a representative of an operator first\ndetermines that the condition exists, but not later than 10 working days\nafter the day a representative of an operator discovers the condition.\nSeparate conditions may be described in a single report if they are\nclosely related. Reporting methods and report requirements are\ndescribed in paragraph(c) of this section.\nEQT failed to report a safety related condition within 5 working days after determination that the\ncondition existed.\nDuring the inspection, the inspection team reviewed records regarding safety related conditions.\nBased on integrity assessment data provided by Baker Hughes for Skin Creek Well 7757, EQT\ndiscovered a Class 4 corrosion condition on 10-18-2018, and determined that a safety-related\ncondition existed on the same date. EQT filed Safety Related Condition Report #20180189 on\nOctober 28, 2018. Although EQT did report the safety related condition 7 working days after\ndiscovery, it did not file the report within the required timeframe of 5 working days after\ndetermination the condition existed.\nTherefore, EQT failed to report a safety related condition in accordance with § 191.25.\n12021046WL_Warning Letter_08052021_(20-172148)_text Page 2 of 7\n\n\n\nCPF 1-2021-046-WL\n3. § 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.\nEQT failed to meet the provisions of API RP1171, Section 9. Specifically, EQT failed to\ndemonstrate that it evaluated occurrences that exceeded threshold levels in accordance with API\nRP 1171, Section 9.3.2 (Section 9.3.2).\nSection 9.3.2 states in part: \"The operator shall monitor for presence of annular gas by measuring\nand recording annular pressure and/or annular gas flow. The operator shall evaluate each annular\ngas occurrence that exceeds operator- or regulatory-defined threshold levels determined from well\nintegrity evaluation and from risk assessment. The operator should test wellhead seals when\nannulus pressure is detected and where injectable packing and/or test ports are present.\"\nThe EQT Integrity Management Program for Underground Gas Storage (SIMP), Section 5.2,\naddresses monthly well inspections. One of the inspection items to be noted and recorded is the\nannular vent gas volume.\nThere are 15 well locations in Rhodes Storage noted for presence of annular gas: 8200, 8168,\n8165, 8185, 8170, 8180, 8198, 8193, 7473, 8192, 8162, 8163, 8188, 8181, 8161. The pressures\nthat are monitored, or other inspection data, are not documented in the work orders.\nThe records do not explicitly indicate that a threshold was exceeded or what further evaluations\nwere conducted. EQT did not have any other records demonstrating they evaluated each annual\ngas occurrence that exceeds their thresholds.\nTherefore, EQT failed to follow the provisions of API RP1171, Section 9.3.2.\n4. § 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.\n12021046WL_Warning Letter_08052021_(20-172148)_text Page 3 of 7\n\n\n\nCPF 1-2021-046-WL\nEQT failed to meet the provisions of API RP1171, Section 11. Specifically, EQT failed to\nincorporate site security safeguards into its operations by failing to record site security status of\nwell sites.\nSection 11.9.1 states: “The operator shall develop programs incorporating safeguards to the\nenvironment, site security, and safety and health into storage design, construction, and operations.\nThe operator’s programs should incorporate in a plan, or plans, operator-established procedures\nthat are founded on industry recommended practices and applicable to process safety in storage\noperations.”\nThe EQT Integrity Management Program for Underground Gas Storage (SIMP), Section 5.2,\naddressed monthly well inspections. One of the inspection items to be noted and recorded was to\nverify well security. If there were indications of vandalism, follow-up notification with the\nsupervisor or manager was required.\nThe inspection team reviewed random Monthly Well Inspection work orders for documentation\nthat the site security was evaluated at the well site. No documentation was noted in the work\norder. In our discussion for this question, the operator indicated that there was no specific check-\noff box or tab included in the work order to explicitly document that this element was\ninspected. The operator further indicated this element would normally be included in the monthly\ninspection and would have been performed for all the wells in the storage field. Any negative\nresults for this element of the inspection would be documented by comments (failure notation and\ngeneration of follow-up work order).\nTherefore, EQT failed to meet the provisions of Section 11.9.1, because the inspection records fail\nto note and record site security status at the well site.\n5. § 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.\nEQT failed to meet the provisions § 192.12(c)1 by January 18, 2018. Specifically, EQT failed to\nhave procedures developed and implemented by this date regarding various operations and\nmaintenance activities.\nDuring the inspection, the inspection team reviewed the following EQT procedures via its\nSharePoint:\n STR-01 Inventory Verification Shut-In Test, no effective date noted; PPE specified;\npotential ignition hazards noted in Safety, Health and Environmental.\n12021046WL_Warning Letter_08052021_(20-172148)_text Page 4 of 7\n\n\n\nCPF 1-2021-046-WL\n STR-02 Maintaining Annular Gel Volumes, no effective date noted; pressure on annulus\nrecording is required; PPE; ignition hazard and environmental hazards noted.\n STR-03, Monthly Inspection of Storage Wells, effective date, revision date not stated.\n STR-04, Well Entry, no effective date or revision date noted.\n STR-05 Well Mechanical Integrity Test, 4 pages, no effective date noted; performed after\nwell workover, typically by contractor; consultant and company rep oversees\nperformance of this procedure\n STR-06, P/A Storage Well Inspection, effective date 5-13-20, next review 5-15-21.\nThe absence of effective dates in 5 of 6 procedures, and the May 13, 2020 effective date for STR-\n06, did not demonstrate that the procedures were developed and implemented as of January 18,\n2018, and retained for both operator personnel and contractors.\nTherefore, EQT failed to meet the provisions of § 192.12(c) by January 18, 2018.\n6. § 192.12 Underground natural gas storage facilities.\n(a) …\n(c) Procedural manuals. Each operator of a UNGSF must prepare\nand follow for each facility one or more manuals of written procedures\nfor conducting operations, maintenance, and emergency preparedness\nand response activities under paragraphs (a) and (b) of this section.\nEach operator must keep records necessary to administer such\nprocedures and review and update these manuals at intervals not\nexceeding 15 months, but at least once each calendar year. Each\noperator must keep the appropriate parts of these manuals accessible\nat locations where UNGSF work is being performed. Each operator\nmust have written procedures in place before commencing operations\nor beginning an activity not yet implemented.\nEQT failed to follow its manual of written procedures for conducting maintenance activities under\n192.12(b)(2). Specifically, EQT failed to follow its Integrity Management Program for\nUnderground Gas Storage (SIMP), Section 5.2 regarding documenting monthly well inspections.\nEQT’s SIMP, Section 5.2 addressed monthly well inspections. This section noted 13 specific\nitems in the monthly well inspections that are to be noted and recorded [Emphasis added]. One\nof the inspection items to be noted and recorded was to verify that the well sign was visible, and\nto present data indicating the well name or ID number, the operator's name, and 24-hour contact\nnumber. If the sign was damaged or missing, a follow up with the supervisor or manager is\nrequired.\nThe inspection team reviewed EQT’s DataSplice, the field data logging application that would be\nused for documenting the monthly well inspections. The team noted 6 inspection items in the\nDataSplice field application that were noted and recorded in the monthly inspections. Seven (7)\nof the items were not explicitly noted and recorded.\n12021046WL_Warning Letter_08052021_(20-172148)_text Page 5 of 7\n\n\n\nCPF 1-2021-046-WL\nRandom Monthly Well Inspection work orders were also reviewed for appropriate signage\ndocumentation at the well site. No documentation was noted in the work order for signage\ninspection. EQT indicated that there was no specific check-off box or tab in the work order to\nexplicitly document that this element was inspected. EQT further indicated this element would\nnormally be included in the monthly inspection and would have been performed for all the wells\nin the storage field. Any negative results for this element of the inspection would be documented\nby comments (failure notation and generation of follow-up work order).\nTherefore, EQT failed to follow its SIMP, Section 5.2 regarding documenting its monthly well\ninspections.\n7. § 192.12 Underground natural gas storage facilities.\n(a) …\n(c) Procedural manuals. Each operator of a UNGSF must prepare\nand follow for each facility one or more manuals of written procedures\nfor conducting operations, maintenance, and emergency preparedness\nand response activities under paragraphs (a) and (b) of this section.\nEach operator must keep records necessary to administer such\nprocedures and review and update these manuals at intervals not\nexceeding 15 months, but at least once each calendar year. Each\noperator must keep the appropriate parts of these manuals accessible\nat locations where UNGSF work is being performed. Each operator\nmust have written procedures in place before commencing operations\nor beginning an activity not yet implemented.\nEQT failed to follow its manual of written procedures for conducting maintenance activities under\n192.12(b)(2). Specifically, EQT failed to follow its Integrity Management Program for\nUnderground Gas Storage (SIMP), Section 5.2 regarding documenting monthly well inspections\npursuant to API RP 1171, Section 9.3.2 (Section 9.3.2).\nSection 9.3.2 states in part: \"The operator shall monitor for presence of annular gas by measuring\nand recording annular pressure and/or annular gas flow. The operator shall evaluate each annular\ngas occurrence that exceeds operator- or regulatory-defined threshold levels determined from well\nintegrity evaluation and from risk assessment. The operator should test wellhead seals when\nannulus pressure is detected and where injectable packing and/or test ports are present.\"\nEQT’s SIMP, Section 5.2, addresses monthly well inspections. One of the inspection items to be\nnoted and recorded was the annular vent gas volume.\nThere are 15 well locations in Rhodes Storage noted for presence of annular gas: 8200, 8168,\n8165, 8185, 8170, 8180, 8198, 8193, 7473, 8192, 8162, 8163, 8188, 8181, 8161. The pressures\nthat are monitored, or other inspection data such as vent volumes, were not documented in the\nwork orders.\nTherefore, EQT failed to follow the provisions of API RP1171, Section 9.3.2.\n12021046WL_Warning Letter_08052021_(20-172148)_text Page 6 of 7\n\n\n\nCPF 1-2021-046-WL\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 item(s) 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 1-2021-046-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\n1 § 192.12 Underground natural gas storage facilities.\n(a)…\n(c) Procedural manuals. Each operator of a UNGSF must prepare and follow for each facility one or more manuals\nof written procedures for conducting operations, maintenance, and emergency preparedness and response activities\nunder paragraphs (a) and (b) of this section. Each operator must keep records necessary to administer such\nprocedures and review and update these manuals at intervals not exceeding 15 months, but at least once each\ncalendar year. Each operator must keep the appropriate parts of these manuals accessible at locations where UNGSF\nwork is being performed. Each operator must have written procedures in place before commencing operations or\nbeginning an activity not yet implemented.\n12021046WL_Warning Letter_08052021_(20-172148)_text Page 7 of 7","truncated":false,"body_characters":19077}