{"operation":"document","citation":"CPF 12022029WL","title":"EQUITRANS MIDSTREAM CORPORATION — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-03-15","effective_on":null,"summary":"CLOSED warning letter citing 192.12(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022029wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022029wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022029wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022029WL","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 2022-03-15 and is reported as closed as of 2022-03-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022029WL_Warning Letter_03152022_(20-173105).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022029WL/12022029WL_Warning%20Letter_03152022_(20-173105).pdf\n\n12022029WL_Warning Letter_03152022_(20-173105)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022029WL/12022029WL_Warning%20Letter_03152022_(20-173105)_text.pdf\n\n12022029WL_Warning Letter_03152022_(20-173105)_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nMarch 15, 2022\nMr. Gregg West\nVice President Midstream Operations\nEquitrans Midstream Corporation\n2200 Energy Drive\nCanonsburg, Pennsylvania 15317\nCPF 1-2022-029-WL\nDear Mr. West:\nFrom October 13, 2020, through July 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 (ETRN) Tepe, Finleyville, and Webster\nUnderground Natural Gas Storage Fields in Pennsylvania.\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. § 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.\n\n\n\nCPF 1-2022-029-WL\nETRN failed to meet the provisions of API RP1171, Section 9. Specifically, ETRN failed to\ndemonstrate that wellhead assemblies are monitored for leaks as required under API 1171, Section\n9.3.2.\nSection 9.3.2 states “The operator shall visually inspect each wellhead assembly at least annually\nfor leaks.”\nDuring the inspection, ETRN stated that visual inspections are conducted in conjunction with the\nannulus gas inspections. However, the results of the wellhead leak inspections are not captured in\nthe record keeping database system (MAXIMO) due to a lack of fields to enter the data. No records\nwere available to demonstrate compliance. ETRN also indicated that MAXIMO is being updated\nto better reflect the actual work/inspections being done in the field.\nTherefore, ETRN failed to meet the provisions of Section 9.3.2.\n2. § 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.\nETRN failed to meet the provisions of API RP 1171, Section 8. Specifically, ETRN failed to\nprovide adequate documentation of the risk evaluation and decision basis for preventative and\nmitigative (P&M) measures, as required by API RP 1171, Section 8.5.2.\nSection 8.5.2 states “The operator shall review the results of the risk assessment to determine\nwhether the risk assessment, resulting prioritization, or ranking represents its facilities and\ncharacterizes the risks. Review may be performed by personnel familiar with storage operations,\nrisk management, and methods or analyzing risk and results.”\nDuring the inspection, assessment reviews were reviewed from 2018, 2019, and 2020. ETRN\nstated that risk assessment reviews consist of monthly and annual meetings and review of data as\nit becomes available. ETRN was unable to provide adequate documentation of the risk assessment\nreviews. No assessment review documentation, such as attendance sheets, meeting minutes, or\nreviewer logs were provided.\nTherefore, ETRN failed to meet the provisions of Section 8.5.2.\n12022029WL_Warning Letter_03152022_(20-173105)_text Page 2 of 4\n\n\n\nCPF 1-2022-029-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.\nETRN failed to meet the provisions of API RP1171, Section 9. Specifically, ETRN failed to test\nits master and wellhead pipeline isolation valves for proper function and ability to isolate the well\npursuant to API RP 1171, Section 9.3.2 (Section 9.3.2).\nSection 9.3.2 requires the operator to test the operation of the master valve and wellhead pipeline\nisolation valve for proper function and the ability to isolate the well.\nDuring the inspection, ETRN stated that the master valve and wellhead pipeline isolation valve(s)\nare only partially operated during valve inspections on storage wells. It is PHMSA’s position that\nthese valves must be fully operated (full open/full closed) to demonstrate the proper function of\nthe valve and the ability to isolate the well.\nTherefore, ETRN failed to meet the provisions of Section 9.3.2 regarding testing the operation of\nits wellhead valves.\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 items identified in this letter. Failure to do so will result in\nEquitrans Midstream Corporation being subject to additional enforcement action.\n12022029WL_Warning Letter_03152022_(20-173105)_text Page 3 of 4\n\n\n\nCPF 1-2022-029-WL\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2022-029-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\n12022029WL_Warning Letter_03152022_(20-173105)_text Page 4 of 4","truncated":false,"body_characters":8331}