{"operation":"document","citation":"CPF 12022011WL","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":"2022-02-08","effective_on":null,"summary":"CLOSED warning letter citing 192.461(a)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022011wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022011wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022011wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022011WL","body":"Warning Letter involving EASTERN GAS TRANSMISSION AND STORAGE, INC.. PHMSA's enforcement data identifies the cited regulation as 192.461(a)(2). The case was opened on 2022-02-08 and is reported as closed as of 2022-02-08. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022011WL_Operator Response to Notice_03162022_(20-171886).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022011WL/12022011WL_Operator%20Response%20to%20Notice_03162022_(20-171886).pdf\n\n12022011WL_Warning Letter_02082022_(20-171886).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022011WL/12022011WL_Warning%20Letter_02082022_(20-171886).pdf\n\n12022011WL_Warning Letter_02082022_(20-171886)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022011WL/12022011WL_Warning%20Letter_02082022_(20-171886)_text.pdf\n\n12022011WL_Warning Letter_02082022_(20-171886)_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nFebruary 8, 2022\nMr. Paul Ruppert\nPresident and Chief Executive Officer\nEastern Gas Transmission and Storage, Inc.\n6603 West Broad Street\nRichmond, Virginia 23200\nCPF 1-2022-011-WL\nDear Mr. Ruppert:\nFrom October 24, 2020 – October 28, 2021, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) inspected Eastern Gas Transmission and Storage, Inc.’s (EGTS) records and procedures\nfor PHMSA inspection units located in Clinton County, PA to Center County, PA; Juniata County,\nPA to Loudoun County, VA; and Loudoun County, VA, to Calvert County, MD.\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 inspected and\nthe probable violation is:\n1. § 192.461 External corrosion control: Protective coating.\n(a) Each external protective coating, whether conductive or\ninsulating, applied for the purpose of external corrosion control must –\n(1) …\n(2) Have sufficient adhesion to the metal surface to effectively\nresist underfilm migration of moisture.\nETGS failed to ensure the external coating on their PL-1x2 pipeline has sufficient adhesion to the\nmetal surface to effectively resist under film migration of moisture in accordance with\n§ 192.461(a)(2).\n\n\n\nCPF 1-2022-011-WL\nDuring the inspection, EGTS provided records that reflected that coating disbondments, in the\nform of osmotic blisters, are present on portions of their Fusion Bond Epoxy (FBE) coated PL-1x2\npipeline. PL-1x2 is a 24” diameter pipeline, approximately 80 miles in length, and installed in\n2008. The Maximum Allowable Operating Pressure varies between 1454psig and 1250 psig. The\nPL-1x2 pipeline is located in classes 1 through 3, with portions in an HCA, and is non-odorized.\nThe pipeline runs from Leidy Compressor Station in Clinton County, PA to the Centre Compressor\nStation in Centre County, PA. All 80 miles of PL-1x2 were under the same pipe specifications and\nprocedures for the mill coating process.\nThe Association for Materials Protection and Performance (AMPP) (formerly NACE) website\nreferences a 2019 publication Blister Initiation Mechanism of FBE Coatings which states in part,\n“FBE coating blistering is a common failure mode” and “Osmotic pressure is from the residual\nsoluble salts on steel surface”.\nEGTS stated that they have not conducted a root cause analysis for the osmotic blisters; however,\nthey have reviewed industry documents on the subject and have revised their procedures to help\nprevent future FBE coating blisters from occurring. EGTS stated that they have made revisions to\ntheir Mill Applied External Fusion Bond Coating specifications and the Quality Control Inspection\nTask for Fusion Bonded Epoxy procedures.\nRecords reflected that EGTS has monitored the blistered pipeline and has replaced sections of the\nblistered pipe in an HCA area. However, with blisters present and possible future blisters\ndeveloping on this pipe, timely and/or additional monitoring may be needed by EGTS to ensure\nconditions for corrosion are not present and appropriate mitigation is performed.\nBased on the osmotic blisters appearing under the FBE on the PL-1x2 pipe, EGTS failed to ensure\nthat coating applied to their PL-1x2 pipeline had sufficient adhesion to the metal surface to\neffectively resist under film migration of moisture in accordance with § 192.461(a)(2).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related\nseries of violations. For violation occurring on or after January 11, 2021 and before May 3, 2021,\nthe maximum penalty may not exceed $222,504 per violation per day the violation persists, up to\na maximum of $2,225,034 for a related series of violations. For violation occurring on or after\nJuly 31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per\nviolation per day the violation persists, up to a maximum of $2,186,465 for a related series of\nviolations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the\nmaximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to\nexceed $2,132,679. For violation occurring on or after November 2, 2015 and before November\n27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum\npenalty 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 identified in this letter. Failure to do so will result in\nEastern Gas Transmission and Storage, Inc. being subject to additional enforcement action.\n12022011WL_Warning Letter_02082022_(20-171886)_text Page 2 of 3\n\n\n\nCPF 1-2022-011-WL\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2022-011-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\n12022011WL_Warning Letter_02082022_(20-171886)_text Page 3 of 3","truncated":false,"body_characters":6842}