{"operation":"document","citation":"CPF 12022020WL","title":"EQUITRANS MIDSTREAM CORPORATION — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-02-15","effective_on":null,"summary":"CLOSED warning letter citing 191.22(c)(1)(iv).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022020wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022020wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022020wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022020WL","body":"Warning Letter involving EQUITRANS MIDSTREAM CORPORATION. PHMSA's enforcement data identifies the cited regulation as 191.22(c)(1)(iv). The case was opened on 2022-02-15 and is reported as closed as of 2022-02-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022020WL_Warning Letter_02152022_(21-200481).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022020WL/12022020WL_Warning%20Letter_02152022_(21-200481).pdf\n\n12022020WL_Warning Letter_02152022_(21-200481)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022020WL/12022020WL_Warning%20Letter_02152022_(21-200481)_text.pdf\n\n12022020WL_Warning Letter_02152022_(21-200481)_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nFebruary 15, 2022\nMr. Gregg West\nVice President Midstream Operations\nEquitrans Midstream Corporation\n2200 Energy Drive\nCanonsburg, Pennsylvania 15317\nCPF 1-2022-020-WL\nDear Mr. West:\nFrom August 9, 2021 to September 15, 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) Logansport, Mobley, and Hayes\nunderground natural gas storage facilities in Wetzel and Marion Counties, West Virginia.\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. §191.22 National Registry of Operators1\n(a) …\n(c) Changes. Each operator of a gas pipeline, gas pipeline facility,\nUNGSF, LNG plant, or LNG facility must notify PHMSA electronically\n1 In the Interim Final Rule effective January 18, 2017, which was superseded on March 13, 2020, this requirement\nwas present but read:\n(c) Changes. Each operator of a gas pipeline, gas pipeline facility, underground natural gas storage facility, LNG\nplant, or LNG facility must notify PHMSA electronically through the National Registry of Pipeline, Underground\nNatural Gas Storage Facility, and LNG Operators at http://opsweb.phmsa.dot.gov of certain events.\n(1) …\n(iv) Construction of a new underground natural gas storage facility or the abandonment, drilling or well workover\n(including replacement of wellhead, tubing, or a new casing) of an injection, withdrawal, monitoring, or observation\nwell for an underground natural gas storage facility.\n\n\n\nCPF 1-2022-020-WL\nthrough the National Registry of Operators\nat https://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) …\n(iv) Maintenance of a UNGSF that involves the plugging or\nabandonment of a well, or that requires a workover rig and costs\n$200,000 or 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 provide a written notification to PHMSA of certain maintenance activities, including\nthe plugging or abandonment of a well, not later than 60 days before that activity occurs.\nDuring the inspection, PHMSA reviewed the annual reports submitted by EQT for its underground\nnatural gas storage facilities for calendar years 2018, 2019, and 2020. Among other items, the\noperator is required to report in line C.10 of the report form the number of wells that were plugged\nand abandoned in the calendar year. EQT reported that 2 wells were plugged and abandoned in\nthe Logansport storage field. Well 8271 was plugged and abandoned in 2018, and Well 6190 was\nplugged and abandoned in 2019. No notification was made for either of these events; the plugging\nand abandonments were documented, after the fact, in the annual reports.\nTherefore, EQT failed in 2 instances to provide notification to PHMSA of the maintenance\nactivities, plugging and abandonment of 2 wells, either 60 days in advance, or as soon as\npracticable if due to an emergency, as required by § 191.22(c)(iv).\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.\n12022020WL_Warning Letter_02152022_(21-200481)_text Page 2 of 3\n\n\n\nCPF 1-2022-020-WL\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2022-020-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\n12022020WL_Warning Letter_02152022_(21-200481)_text Page 3 of 3","truncated":false,"body_characters":6495}