{"operation":"document","citation":"CPF 12022013NOA","title":"EQUITRANS MIDSTREAM CORPORATION — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-03-22","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022013noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022013noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022013noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022013NOA","body":"Notice of Amendment involving EQUITRANS MIDSTREAM CORPORATION. PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2022-03-22 and is reported as closed as of 2022-05-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022013NOA_Closure Letter_05262022_(21-200902).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022013NOA/12022013NOA_Closure%20Letter_05262022_(21-200902).pdf\n\n12022013NOA_Closure Letter_05262022_(21-200902)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022013NOA/12022013NOA_Closure%20Letter_05262022_(21-200902)_text.pdf\n\n12022013NOA_Notice of Amendment_03222022_(21-200902).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022013NOA/12022013NOA_Notice%20of%20Amendment_03222022_(21-200902).pdf\n\n12022013NOA_Notice of Amendment_03222022_(21-200902)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022013NOA/12022013NOA_Notice%20of%20Amendment_03222022_(21-200902)_text.pdf\n\n12022013NOA_Operator Response to Notice_04142022_(21-200902).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022013NOA/12022013NOA_Operator%20Response%20to%20Notice_04142022_(21-200902).pdf\n\n12022013NOA_Closure Letter_05262022_(21-200902)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nMay 26, 2022\nMr. Gregg West\nVice President Midstream Operations\nEquitrans Midstream Corporation\n2200 Energy Drive\nCanonsburg, PA 15317\nCPF 1-2022-013-NOA\nDear Mr. West:\nFrom June 14, 2021 through June 18, 2021, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of Equitrans Midstream Corporation’s (Equitrans)\nprocedures for the Pratt underground natural gas storage field located in Greene County,\nPennsylvania. As a result of the inspection, Equitrans was issued a Notice of Amendment on March\n22, 2022, which proposed amendment of your procedures.\nEquitrans submitted its amended procedures on April 14, 2022. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n12022013NOA_Notice of Amendment_03222022_(21-200902)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nMarch 22, 2022\nMr. Gregg West\nVice President Midstream Operations\nEquitrans Midstream Corporation\n2200 Energy Drive\nCanonsburg, PA 15317\nCPF 1-2022-013-NOA\nDear Mr. West:\nFrom June 14, 2021 through June 18, 2021, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected Equitrans Midstream Corporation’s (ETRN) operations, maintenance, and emergency\nresponse procedures for the Pratt underground natural gas storage field located in Greene County,\nPennsylvania.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within\nETRN’s plans or procedures, as described below:\n1. § 192.12 Underground natural gas storage facilities.\n(a) …\n(c) Each operator of a UNGSF must prepare and follow for each\nfacility one or more manuals of written procedures for conducting\noperations, maintenance, and emergency preparedness and response\nactivities under paragraphs (a) and (b) of this section. Each operator\nmust keep records necessary to administer such procedures and review\nand update these manuals at intervals not exceeding 15 months, but at\nleast once each calendar year. Each operator must keep the\nappropriate parts of these manuals accessible at locations where\nUNGSF work is being performed. Each operator must have written\nprocedures in place before commencing operations or beginning an\nactivity not yet implemented.\n\n\n\nCPF 1-2022-013-NOA\nETRN’s written procedures for conducting operations, maintenance, and emergency preparedness\nand response activities were inadequate to ensure safe operation of a pipeline facility. Specifically,\nETRN failed to include written procedures addressing the requirements of Section 11 of API RP\n1171 (Section 11)1\n.\nSection 192.12(b)(2) requires operators of depleted hydrocarbon and aquifer reservoir\nunderground natural gas storage facilities constructed on or before July 18, 2017 to meet the\nprovisions of section 11 of API RP 1171, and § 192.12(c) requires procedures pursuant to this\nrequirement. Section 11.2.1 of API RP 1171 states in relevant part that operators “…shall develop\nand follow procedures for the construction, operation, and maintenance of natural gas storage wells\nand reservoirs to establish and maintain functional integrity. When practicable, the operator’s\nprocedures should incorporate applicable industry recommended practices that promote personal\nand process safety, resource conservation, environmental stewardship, mechanical integrity, and\nreliable performance.”\nDuring the inspection, ETRN was unable to provide procedures related to the maintenance, repair,\nand remediation activities performed on the Pratt storage wells. Following the inspection, PHSMA\nrequested documentation of procedures used during the plugging and abandonment (P&A)\nactivities performed during 2020 and 2021 at the Pratt Storage Field. ETRN provided PHMSA\njob specific plans related to the P&A work performed. Procedures pertaining to the development,\nreview, and approval process for the job specific plans were not available.\nTherefore, ETRN’s procedures for underground storage were inadequate. ETRN must prepare\nprocedures addressing the development, review, and approval process for job plans associated with\nmaintenance, repair, and remediation activities. These procedures/processes must be included in\nETRN’s procedure manual for underground storage.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. 552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\n1 API 1171, Section 11 General: This section addresses requirements for the development, implementation, and\nmaintenance of programs, plans, and procedures intended to safely and effectively guide the operator in design,\nconstruction, operation, and maintenance of underground natural gas storage facilities.\n12022013NOA_Notice of Amendment_03222022_(21-200902)_text Page 2 of 3\n\n\n\nCPF 1-2022-013-NOA\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 30 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Equitrans Midstream Corporation maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director,\nEastern Region, Pipeline and Hazardous Materials Safety Administration, 840 Bear Tavern Road,\nSuite 300, West Trenton, NJ 08628. In correspondence concerning this matter, please refer to CPF\n1-2022-013-NOA and, for each document you submit, please provide a copy in electronic format\nwhenever possible. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should\nbe sent on USB flash drive accompanied by the original paper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n12022013NOA_Notice of Amendment_03222022_(21-200902)_text Page 3 of 3","truncated":false,"body_characters":9191}