{"operation":"document","citation":"CPF 12025046NOA","title":"EASTERN GAS TRANSMISSION AND STORAGE, INC. — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2025-12-02","effective_on":null,"summary":"OPEN notice of amendment citing 195.402(a), 195.452(f)(3), 195.452(f)(8), 195.452(l).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025046noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025046noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025046noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12025046NOA","body":"Notice of Amendment involving EASTERN GAS TRANSMISSION AND STORAGE, INC.. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.452(f)(3),  195.452(f)(8),  195.452(l). The case was opened on 2025-12-02 and is reported as open. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12025046NOA_Notice of Amendment_12022025_(25-329693).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025046NOA/12025046NOA_Notice%20of%20Amendment_12022025_(25-329693).pdf\n\n12025046NOA_Notice of Amendment_12022025_(25-329693)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025046NOA/12025046NOA_Notice%20of%20Amendment_12022025_(25-329693)_text.pdf\n\n12025046NOA_Operator Response to Notice_12292025_(25-329693).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025046NOA/12025046NOA_Operator%20Response%20to%20Notice_12292025_(25-329693).pdf\n\n12025046NOA_Notice of Amendment_12022025_(25-329693)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials\nSafety Administration\n840 Bear Tavern Road, Suite 300\nWest Trenton, NJ 08628\n609.771.7800\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: Paul.Ruppert@bhegts.com\nDecember 2, 2025\nMr. Paul Ruppert\nPresident, Gas Transmission & Storage\nEastern Gas Transmission and Storage, Inc.\n6603 West Broad Street\nRichmond, Virginia 23200\nCPF 1-2025-046-NOA\nDear Mr. Ruppert:\nFrom February 24 through April 2, 2025, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),\nconducted an inspection of Eastern Gas Transmission and Storage, Inc.’s (EGT&S) hazardous\nliquid integrity management procedures in Bridgeport, West Virginia.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nEGT&S’s plans or procedures. The items inspected and the alleged inadequacies and proposed\nrevisions are described below:\n1. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each\npipeline system a manual of written procedures for conducting normal\noperations and maintenance activities and handling abnormal\noperations and emergencies. This manual shall be reviewed at intervals\nnot exceeding 15 months, but at least once each calendar year, and\nappropriate changes made as necessary to insure that the manual is\neffective. This manual shall be prepared before initial operations of a\npipeline system commence, and appropriate parts shall be kept at\nlocations where operations and maintenance activities are conducted.\nEGT&S’s written procedures for operations, maintenance, and emergencies were inadequate to\nensure safe operation of a pipeline facility. Specifically, EGT&S’s written procedures, PIP-3504\n– Remediation (12/27/24) (Remediation) and PIP-3501 - HCA Identification (12/27/24) (HCA),\nfailed to require that the manual be reviewed at intervals not exceeding 15 months, but at least\nonce each calendar year in accordance with section 195.402(a).\n\n\n\nCPF 1-2025-046-NOA\nDuring the inspection, PHMSA reviewed the Remediation and HCA procedures. The HCA\nprocedure, section 5.9, and Remediation procedure, section 5.7, required reviews and updates\nannually or as needed. However, the HCA and Remediation procedures failed to require that the\nmanual be reviewed at intervals not exceeding 15 months, but at least once each calendar year.\nTherefore, EGT&S’s written procedures for operations, maintenance, and emergencies were\ninadequate to ensure safe operation of a pipeline facility. PHMSA proposes that EGT&S revise its\nprocedures to require that the manual be reviewed at intervals not exceeding 15 months, but at\nleast once each calendar year.\n2. § 195.452 Pipeline integrity management in high consequence areas.\n(a) . . .\n(f) What are the elements of an integrity management program? An\nintegrity management program begins with the initial framework. An\noperator must continually change the program to reflect operating\nexperience, conclusions drawn from results of the integrity\nassessments, and other maintenance and surveillance data, and\nevaluation of consequences of a failure on the high consequence area.\nAn operator must include, at minimum, each of the following elements\nin its written integrity management program:\n(1) . . .\n(3) An analysis that integrates all available information about the\nintegrity of the entire pipeline and the consequences of a failure (see\nparagraph (g) of this section);\nEGT&S’s procedures for integrity management were inadequate to ensure safe operation of a\npipeline facility. Specifically, EGT&S’s written procedure, PIP-3505 – Continual Evaluation and\nAssessment (12/27/24) (Continual Evaluation), failed to include an adequate process for\nperforming its information analysis in accordance with section 195.452(f)(3) and 195.452(g)(4).\nSection 195.452(g)(4) states that an information analysis must:\nIdentify spatial relationships among anomalous information (e.g., corrosion\ncoincident with foreign line crossings; evidence of pipeline damage where\naerial photography shows evidence of encroachment). Storing the\ninformation in a geographic information system (GIS), alone, is not\nsufficient. An operator must analyze for interrelationships among the data.\nDuring the inspection, PHMSA requested EGT&S’s procedures regarding the section\n195.452(g)(4) requirements. The Continual Evaluation procedure, section 5.1, required EGT&S to\nidentify spatial relationships among anomalous information and analyze for interrelationships\namong the data. The Continual Evaluation procedure, however, copied the regulatory text in\nsection 195.452(g)(4) without further details regarding EGT&S’s process for how and when it\nanalyzes and integrates its pipeline data regarding spatial relationships amongst the data.\n2\n\n\n\nCPF 1-2025-046-NOA\nTherefore, EGT&S’s procedures for integrity management were inadequate to ensure safe\noperation of a pipeline facility in accordance with section 195.452(f)(3). PHMSA proposes that\nEGT&S revise its procedures to include details regarding how and when it analyzes and integrates\nits pipeline data regarding spatial relationships amongst its data.\n3. § 195.452 Pipeline integrity management in high consequence areas.\n(a) . . .\n(f) What are the elements of an integrity management program? An\nintegrity management program begins with the initial framework. An\noperator must continually change the program to reflect operating\nexperience, conclusions drawn from results of the integrity\nassessments, and other maintenance and surveillance data, and\nevaluation of consequences of a failure on the high consequence area.\nAn operator must include, at minimum, each of the following elements\nin its written integrity management program:\n(1) . . .\n(8) A process for review of integrity assessment results and\ninformation analysis by a person qualified to evaluate the results and\ninformation (see paragraph (h)(2) of this section).\nEGT&S’s procedures for integrity management were inadequate to ensure safe operation of a\npipeline facility. Specifically, EGT&S’s written procedure, PIP-3702 – Liquid IMP Job\nSummaries (12/27/24) (Job Summaries), failed to include an adequate process for review of\nintegrity assessment results and information analysis by a person qualified to evaluate the results\nand information in accordance with section 195.452(f)(8).\nDuring the inspection, PHMSA requested EGT&S’s procedures regarding qualifications for\npersonnel who evaluate integrity assessments and information analysis. EGT&S provided the Job\nSummaries procedure which required a pipeline integrity engineer to attend at least one industry\ntraining of 18 hours or complete on the job training (OJT) with an in-line inspection (ILI) subject\nmatter expert (SME) in order to be qualified to review ILI assessment data. The procedure also\nrequired the documenting of the OJT ILI data review and process used to conduct the review, that\nthe ILI SME would assess and determine if the individual was competent to complete these reviews\nalone, and that EGT&S’s technical training department would maintain records associated with\nthis process.\nHowever, the Job Summaries procedure failed to specify qualification requirements for the\npersonnel who review and evaluate integrity assessment results and information analysis. When\nPHMSA asked for further details regarding the process used to conduct the OJT review as well as\nwhat the technical industry training was required to entail, EGT&S was unable to provide further\ndetails and stated that clarifications could be made to outline its current process being followed.\nTherefore, EGT&S’s procedures for integrity management were inadequate to ensure safe\noperation of a pipeline facility in accordance with section 195.452(f)(8). PHMSA proposes that\nEGT&S revise its procedures to include details which specify qualification requirements,\nincluding details on the required OJT and industry training, for the personnel who review and\nevaluate integrity assessment results and information analysis.\n3\n\n\n\nCPF 1-2025-046-NOA\n4. § 195.452 Pipeline integrity management in high consequence areas.\n(a) …\n(l) What records must an operator keep to demonstrate compliance?\n(1) An operator must maintain, for the useful life of the pipeline,\nrecords that demonstrate compliance with the requirements of this\nsubpart. At a minimum, an operator must maintain the following\nrecords for review during an inspection:\n(i) A written integrity management program in accordance with\nparagraph (b) of this section.\n(ii) Documents to support the decisions and analyses, including any\nmodifications, justifications, deviations and determinations made,\nvariances, and actions taken, to implement and evaluate each element\nof the integrity management program listed in paragraph (f) of this\nsection.\n(2) See Appendix C of this part for examples of records an\noperator would be required to keep.\nEGT&S’s procedures for integrity management were inadequate to ensure safe operation of a\npipeline facility. Specifically, EGT&S’s written procedure, PIP-3509 Record Keeping (12/27/24)\n(Record Procedure), failed to contain an adequate process for maintaining integrity management\nrecords in accordance with section 195.452(l).\nDuring the inspection, PHMSA requested EGT&S’s procedures regarding the section 195.452(l)\nrequirements. EGT&S provided the Record Procedure. Section 5 contained a list of examples of\nrecords EGT&S may maintain and identified that the various sections of its IMP describe what\ndocumentation is required, along with the location where it can be accessed. However, section 5.2\nof the Record Procedure copied the regulatory text from Part 195 Appendix C without details\nregarding EGT&S’s recordkeeping requirements.\nThe Record Procedure failed to provide any details regarding which integrity management records\nare required to be maintained, what records from Appendix C of Part 195 are maintained, what\nforms or documents EGT&S records its official records on, the locations these records will be\nretained at, and how EGT&S can access its records. When PHMSA requested further information\non which records EGT&S maintains for inspection, EGT&S stated that the procedures do not\ninclude these details.\nFurthermore, each section of the integrity management procedures failed to list the location where\nall documents can be accessed or found. EGT&S provided various written procedures, PIP-3507\nProgram Evaluation (12/27/24) (Program Evaluation) and PIP-3504 – Remediation (12/27/24)\n(Remediation) and PIP-3501 - HCA Identification (12/27/24) (HCA). These procedures in section\n7 included the same language as in the Record Procedure and all failed to mention the required\ndocumentation requirements.\nTherefore, EGT&S’s procedures for integrity management were inadequate to ensure safe\noperation of a pipeline facility in accordance with section 195.452(l). PHMSA proposes that\nEGT&S revise its procedures to provide details regarding which integrity management records are\n4\n\n\n\nCPF 1-2025-046-NOA\nrequired to be maintained, what records from Appendix C of Part 195 are maintained, what forms\nor documents EGT&S records its official records on, the locations these records will be retained\nat, and how EGT&S can access its records.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 CFR § 190.206. Enclosed as part\nof 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 49 CFR § 190.211. If you do not respond within 30\ndays of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in\nthis Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged\nin this Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 CFR § 190.206). If you are not contesting\nthis Notice, 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 Eastern Gas Transmission and Storage, Inc. maintain\ndocumentation of the safety improvement costs associated with fulfilling this Notice of\nAmendment (preparation/revision of plans, procedures) and submit the total to the Director,\nEastern Region, Pipeline and Hazardous Materials Safety Administration, Office of Pipeline\nSafety. In correspondence concerning this matter, please refer to CPF 1-2025-046-NOA and, for\neach document you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n5","truncated":false,"body_characters":14947}