{"operation":"document","citation":"CPF 12022012WL","title":"EQUITRANS MIDSTREAM CORPORATION — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-02-22","effective_on":null,"summary":"CLOSED warning letter citing 192.12(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022012wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022012wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022012wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022012WL","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 2022-02-22 and is reported as closed as of 2022-02-22. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022012WL_Warning Letter_02222022_(21-200902).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022012WL/12022012WL_Warning%20Letter_02222022_(21-200902).pdf\n\n12022012WL_Warning Letter_02222022_(21-200902)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022012WL/12022012WL_Warning%20Letter_02222022_(21-200902)_text.pdf\n\n12022012WL_Warning Letter_02222022_(21-200902)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: GWest@equitransmidstream.com\nFebruary 22, 2022\nMr. Gregg West\nVice President Midstream Operations\nEquitrans Midstream Corporation\n2200 Energy Drive\nCanonsburg, PA 15317\nCPF 1-2022-012-WL\nDear Mr. West:\nFrom June 14, 2021 through June 17, 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 Equitrans Midstream Corporation’s (EQT) Pratt Storage Field located in\nGreene County, Pennsylvania.\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. § 192.12 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 RP 1171, Section 9. Specifically, during 2018 through\n\n\n\nCPF 1-2022-012-WL\n2019 EQT failed to test the operation of the master valves at least annually for proper function and\nability to isolate the wells, as required by API RP 1171 Section 9.3.21 (Section 9.3.2). This\noccurred at 331 well locations throughout 18 EQT storage facilities in Pennsylvania, including the\nPratt Storage Field.\nAccording to records reviewed by PHMSA during the inspection, a review of EQT’s master gate\nvalve inspections on storage wells in Pennsylvania were first performed by EQT in 2020. EQT\npersonnel stated that prior to 2020, the inspections did not include the master gate valves on storage\nwells in Pennsylvania. Storage wells located outside Pennsylvania were not affected. According\nto EQT personnel, prior to the Underground Natural Gas Storge (UNGS) regulations, master gates\non wells in Pennsylvania were not considered emergency valves and were not inspected as part of\nthe annual inspections. Only the side-gate valves were classified as “emergency” valves at that\ntime and inspected to 49 CFR Part 192 requirements. With the onset of the UNGS regulations that\ncame into affected January 18, 2018, the Maximo Database System, which is used by EQT to\nmonitor and maintain inspection records throughout the company, was not updated to include the\nmaster-gates in Pennsylvania as assets requiring annual inspections per the new regulations.\nDuring 2020, actions were taken by EQT midstream to correct these deficiencies within the\nMaximo System and inspections were performed including master-gate valves at all well locations\nthroughout the State.\nTherefore, EQT failed to meet the provisions of Section 9.3.2 from 2018 through 2019 for 331\nwells at 18 storage facilities within Pennsylvania.\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\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 1-2022-012-WL. Be advised that all material you submit in response to this enforcement\n1 API RP 1171, Section 9.3.2 Well Integrity Monitoring states in part that “[t]he operator shall test the operation of\nthe master valve and wellhead pipeline isolation valve at least annually for proper function and ability to isolate the\nwell.”.\n12022012WL_Warning Letter_02222022_(21-200902)_text Page 2 of 3\n\n\n\nCPF 1-2022-012-WL\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\n12022012WL_Warning Letter_02222022_(21-200902)_text Page 3 of 3","truncated":false,"body_characters":6455}