{"operation":"document","citation":"CPF 12022030NOA","title":"EQUITRANS MIDSTREAM CORPORATION — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-03-15","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022030noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022030noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022030noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022030NOA","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 2022-03-15 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\n12022030NOA_Closure Letter_05262022_(20-173105).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022030NOA/12022030NOA_Closure%20Letter_05262022_(20-173105).pdf\n\n12022030NOA_Closure Letter_05262022_(20-173105)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022030NOA/12022030NOA_Closure%20Letter_05262022_(20-173105)_text.pdf\n\n12022030NOA_Notice of Amendment_03152022_(20-173105).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022030NOA/12022030NOA_Notice%20of%20Amendment_03152022_(20-173105).pdf\n\n12022030NOA_Notice of Amendment_03152022_(20-173105)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022030NOA/12022030NOA_Notice%20of%20Amendment_03152022_(20-173105)_text.pdf\n\n12022030NOA_Operator Response to Notice_04142022_(21-200902).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022030NOA/12022030NOA_Operator%20Response%20to%20Notice_04142022_(21-200902).pdf\n\n12022030NOA_Closure Letter_05262022_(20-173105)_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 1-2022-030-NOA\nDear Mr. West:\nFrom October 13, 2020, through July 15, 2020, 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 (ETRN)\nprocedures for the Tepe, Finleyville, and Webster Underground Storage Fields in Pennsylvania.\nAs a result of the inspection, ETRN was issued a Notice of Amendment on March 15, 2022, which\nproposed amendment of your procedures.\nETRN 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\n12022030NOA_Notice of Amendment_03152022_(20-173105)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nMarch 15, 2022\nMr. Gregg West\nVice President, Environmental, Safety & Compliance\nEquitrans Midstream Corporation\n2200 Energy Drive\nCanonsburg, Pennsylvania 15317\nCPF 1-2022-030-NOA\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\ninspected Equitrans Midstream Corporation’s (ETRN) procedures for the Tepe, Finleyville, and\nWebster Underground Storage Fields in Pennsylvania.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nETRN’s plans or procedures, as described below:\n1. § 192.12 Underground natural gas storage facilities.\n(a) …\n(c) Procedural manuals. Each operator of a UNGSF must prepare\nand follow for each facility one or more manuals of written procedures\nfor conducting operations, maintenance, and emergency preparedness\nand response activities under paragraphs (a) and (b) of this section.\nEach operator must keep records necessary to administer such\nprocedures and review and update these manuals at intervals not\nexceeding 15 months, but at least once each calendar year. Each\noperator must keep the appropriate parts of these manuals accessible\nat locations where UNGSF work is being performed. Each operator\nmust have written procedures in place before commencing operations\nor beginning an activity not yet implemented.\n\n\n\nCPF 1-2022-030-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 in accordance\nwith § 192.12(c). Specifically, ETRN’s procedures failed to address third-party emergencies in\naccordance with API RP 1171, Section 10.6.1.1\nDuring the inspection, PHMSA reviewed ETRN’ Emergency Response Plan (ERP) and found that\nit did not contain provisions for third-party emergencies that may impact storage operations. Third-\nparty emergencies can include third-party owned/operated pipelines, wells, above-ground valve\nstations, regulating stations or other third-party owned facilities within the storage field that may\nthreaten ETRN’s underground natural gas storage operations.\nTherefore, ETRN’s written procedures for conducting operations, maintenance, and emergency\npreparedness and response activities were inadequate to ensure safe operation of a pipeline facility\nin accordance with § 192.12(c). ETRN must revise its procedures to address this requirement.\n2. § 192.12 Underground natural gas storage facilities.\n(a) …\n(c) Procedural manuals. Each operator of a UNGSF must prepare\nand follow for each facility one or more manuals of written procedures\nfor conducting operations, maintenance, and emergency preparedness\nand response activities under paragraphs (a) and (b) of this section.\nEach operator must keep records necessary to administer such\nprocedures and review and update these manuals at intervals not\nexceeding 15 months, but at least once each calendar year. Each\noperator must keep the appropriate parts of these manuals accessible\nat locations where UNGSF work is being performed. Each operator\nmust have written procedures in place before commencing operations\nor beginning an activity not yet implemented.\nETRN’s written procedures for conducting operations, maintenance, and emergency preparedness\nand response activities were inadequate to ensure safe operation of a pipeline facility in accordance\nwith § 192.12(c). Specifically, ETRN’s procedures failed to address how the effectiveness\nevaluation of the Emergency Response Plan is conducted and failed to include details on the\nrequired documentation of the effectiveness evaluation in accordance with API RP 1171, Section\n11.4.2.2\nTherefore, ETRN’s written procedures for conducting operations, maintenance, and emergency\npreparedness and response activities were inadequate to ensure safe operation of a pipeline facility\nin accordance with § 192.12(c). ETRN’s must revise its procedures to address this requirement.\n1 API RP 1171, Section 10.6.1, Emergency Preparedness/Emergency Response Plan, states in part, “[f]or site\nsecurity and safety, the operator shall develop and implement a structured emergency preparedness/response plan in\norder to address accidental releases, equipment failures, natural disasters, and third-party emergencies.”\n2 API RP 1171, Section 11.4.2, Plan Effectiveness\nThe operator shall establish a program to determine operator familiarity with emergency plans and procedures and\nperiodic testing of the effectiveness of the plan in accordance with 10.6.\n12022030NOA_Notice of Amendment_03152022_(20-173105)_text Page 2 of 3\n\n\n\nCPF 1-2022-030-NOA\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 submit\nin response to this enforcement action is subject to being made publicly available. If you believe\nthat any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. §\n552(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\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 ETRN Midstream Corporation maintain documentation of the\nsafety 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\n1-2022-030-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\n12022030NOA_Notice of Amendment_03152022_(20-173105)_text Page 3 of 3","truncated":false,"body_characters":10062}