# EASTERN GAS TRANSMISSION AND STORAGE, INC. — Notice of Probable Violation - **operation:** document - **citation:** CPF 12026012NOPV - **title:** EASTERN GAS TRANSMISSION AND STORAGE, INC. — Notice of Probable Violation - **source type:** enforcement - **agency:** Pipeline and Hazardous Materials Safety Administration - **status:** historical - **official:** true - **published on:** 2026-02-06 - **effective on:** Not available - **summary:** CLOSED notice of probable violation citing 195.452(b)(5). - **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-12026012nopv.json - **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-12026012nopv.md - **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-12026012nopv - **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/12026012NOPV **body:** Notice of Probable Violation involving EASTERN GAS TRANSMISSION AND STORAGE, INC.. PHMSA's enforcement data identifies the cited regulation as 195.452(b)(5). The case was opened on 2026-02-06 and is reported as closed as of 2026-04-24. Open the official case record for notices, responses, orders, and the latest status. Official case documents: 12026012NOPV_Closure Letter_04242026_(25-329693).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026012NOPV/12026012NOPV_Closure%20Letter_04242026_(25-329693).pdf 12026012NOPV_Closure Letter_04242026_(25-329693)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026012NOPV/12026012NOPV_Closure%20Letter_04242026_(25-329693)_text.pdf 12026012NOPV_Final Order_04142026_(25-329693).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026012NOPV/12026012NOPV_Final%20Order_04142026_(25-329693).pdf 12026012NOPV_Final Order_04142026_(25-329693)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026012NOPV/12026012NOPV_Final%20Order_04142026_(25-329693)_text.pdf 12026012NOPV_Operator Response to Notice_02272026_(25-329693).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026012NOPV/12026012NOPV_Operator%20Response%20to%20Notice_02272026_(25-329693).pdf 12026012NOPV_PCO_02062026_(25-329693).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026012NOPV/12026012NOPV_PCO_02062026_(25-329693).pdf 12026012NOPV_PCO_02062026_(25-329693)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026012NOPV/12026012NOPV_PCO_02062026_(25-329693)_text.pdf 12026012NOPV_Closure Letter_04242026_(25-329693)_text.pdf U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 840 Bear Tavern Road, Suite 300 West Trenton, New Jersey 08628 609.771.7800 VIA ELECTRONIC MAIL TO: paul.ruppert@bhegts.com April 24, 2026 Mr. Paul Ruppert, President, Gas Transmission & Storage Eastern Gas Transmission and Storage, Inc. 6603 West Broad Street Richmond, VA 23200 RE: CPF 1-2026-012-NOPV Dear Mr. Ruppert: On April 14, 2026, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a Final Order to Eastern Gas Transmission and Storage, Inc. (EGT&S) in the above-referenced case. This Order included a Compliance Order. Based on our review of the documentation provided, it has been determined that EGT&S has complied with the terms of this Order. Accordingly, this case is now closed, and no further action is contemplated with respect to the matters involved in this case. Thank you for your cooperation in this matter. Sincerely, Robert Burrough Director, Eastern Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration cc: Daniel Stahl, Pipeline Integrity Engineer, EGT&S, Daniel.Stahl@bhegts.com Eric Taylor, Director, Engineering Services, EGT&S, eric.taylor@bhegts.com 12026012NOPV_Final Order_04142026_(25-329693)_text.pdf U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, S.E. Washington, D.C. 20590 April 14, 2026 VIA ELECTRONIC MAIL: paul.ruppert@bhegts.com Paul Ruppert President, Gas, Transmission, & Storage Eastern Gas Transmission and Storage, Inc. 10700 Energy Way Glen Allen, Virginia 23606 Re: CPF No. 1-2026-012-NOPV Dear Mr. Ruppert: Enclosed please find the Final Order issued in the above-referenced case. It makes a finding of violation and specifies actions that need to be taken to comply with the pipeline safety regulations. When the terms of the compliance order are completed, as determined by the Director, Eastern Region, this enforcement action will be closed. Service of the Final Order by e- mail is effective upon the date of transmission and acknowledgement of receipt as provided under 49 CFR § 190.5. Thank you for your cooperation in this matter. Sincerely, Linda Daugherty Acting Associate Administrator for Pipeline Safety Enclosures (Final Order and NOPV) cc: Robert Burrough, Director, Eastern Region, Office of Pipeline Safety, PHMSA Eric Taylor, Director, Pipeline Integrity & Records, EGTS eric.taylor@bhegts.com CONFIRMATION OF RECEIPT REQUESTED U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 __________________________________________ In the Matter of ) Eastern Gas Transmission and Storage, Inc., ) CPF No. 1-2026-012-NOPV ) ) ) Respondent. ) __________________________________________) FINAL ORDER On February 6, 2026, pursuant to 49 CFR § 190.207, the Director, Eastern Region, Office of Pipeline Safety (OPS), issued a Notice of Probable Violation (Notice) to Eastern Gas Transmission and Storage, Inc. (Respondent). The Notice proposed finding that Respondent had violated the pipeline safety regulations in 49 CFR Part 195. The Notice also proposed certain measures to correct the violation. Respondent did not contest the allegation of violation or corrective measures. Based upon a review of all of the evidence, pursuant to section 190.213, I find Respondent violated the pipeline safety regulation listed below, as more fully described in the enclosed Notice, which is incorporated by reference: 49 CFR § 195.452(b)(5) (Item 1) ─ Respondent failed to follow its integrity management program as it related to preventative and mitigative measures. This finding of violation will be considered a prior offense in any subsequent enforcement action taken against Respondent. Compliance Actions Pursuant to 49 U.S.C. § 60118(b) and 49 CFR § 190.217, Respondent is ordered to take the actions proposed in the enclosed Notice to correct the violation. The Director may grant an extension of time to comply with any of the required items upon a written request timely submitted by the Respondent and demonstrating good cause for an extension. Upon completion of the ordered actions, Respondent may request that the Director close the case. Respondent previously submitted evidence to show appropriate actions have been taken to correct the violations. This evidence is currently under review by the Director. Failure to comply with this Order may result in the assessment of civil penalties under 49 CFR § 190.223 or in referral to the Attorney General for appropriate relief in a district court of the United States. 2 The terms and conditions of this order are effective upon service in accordance with 49 CFR § 190.5. ___________________________________ _________________________ Linda Daugherty Date Issued Acting Associate Administrator for Pipeline Safety U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 840 Bear Tavern Road, Suite 300 West Trenton, NJ 08628 609.771.7800 NOTICE OF PROBABLE VIOLATION and PROPOSED COMPLIANCE ORDER VIA ELECTRONIC MAIL TO: paul.ruppert@bhegts.com February 6, 2026 Paul Ruppert President, Gas Transmission & Storage Eastern Gas Transmission and Storage, Inc. 6603 West Broad Street Richmond, VA 23200 CPF 1-2026-012-NOPV Dear Mr. Ruppert: From February 24 through April 2, 2025, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code (U.S.C.), conducted an inspection of Eastern Gas Transmission and Storage, Inc.’s1 (EGT&S) hazardous liquid integrity management procedures in Bridgeport, West Virginia. As a result of the inspection, it is alleged that EGT&S has committed a probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and the probable violation is: 1. § 195.452 Pipeline integrity management in high consequence areas. (a) . . . . (b) What program and practices must operators use to manage pipeline integrity? Each operator of a pipeline covered by this section must: (1) . . . . (5) Implement and follow the program. EGT&S failed to follow its integrity management program in accordance with section 195.452(b)(5). Specifically, EGT&S failed to conduct and document a periodic review of its 1 Eastern Gas Transmission and Storage, Inc. is a subsidiary of Berkshire Hathaway Energy, Inc. preventive and mitigative (P&M) measures, failed to propose new P&M measures for consideration of implementation, and failed to document the decision-making process regarding measures not selected for implementation as required by section 5.2.7 in its integrity management program, PIP-3506 – Preventive and Mitigative Measures (12/27/24) (P&M Procedure). During the inspection, PHMSA requested records demonstrating that EGT&S had conducted the requisite periodic review of its P&M measures. EGT&S’s P&M Procedure, section 5.2.7, required that EGT&S conduct a periodic review to: (1) evaluate existing P&M measures; (2) propose new P&M measures for implementation; and (3) discuss P&M measures considered but not implemented. EGT&S’s PIP-3616 Process to Identify Additional P&M Actions on Hazardous Liquid Pipelines (12/27/24) (P&M Flowchart) required that this review be formally documented at “Step 26.” When PHMSA requested documentation of the periodic review, EGT&S stated that the review process is conducted via emails and spreadsheets, though they noted this methodology is not detailed in their written procedures. EGT&S then provided two records: LIMP P&M Measures Evaluation Distribution Email (11/16/22) (12/15/23) (P&M Email) and PIP-3506 Section Excel Spreadsheet (2024) (P&M Spreadsheet). However, the records provided by EGT&S failed to demonstrate compliance with section 5.2.7 of the P&M Procedure. The P&M Email constitutes only the initiation of a request for information; it does not represent a completed review. While it establishes that a review was launched, EGT&S provided no subsequent correspondence, meeting minutes, or response emails to demonstrate that the P&M periodic review was conducted, discussed, or concluded. The P&M Spreadsheet is a static inventory of P&M measures rather than a record of evaluation. It lists various P&M measures but fails to contain timestamps, authorship, or decision logic indicating when these measures were reviewed or how their continued effectiveness was evaluated. Section 5.2.7 requires a discussion of P&M measures not considered for implementation. The provided records contain no data regarding measures that were proposed and subsequently rejected. Without a record of the alternatives considered and the rationale for their rejection, EGT&S cannot demonstrate compliance with section 5.2.7. When PHMSA requested further records regarding the P&M measure periodic review, EGT&S was unable to provide additional records. Moreover, EGT&S failed to provide records that included specific details on each current P&M measure. For example, section 5, table 1 of the P&M Procedure does not list specific implemented P&M measures but instead references generic company compliance procedures. Similarly, the P&M Spreadsheet fails to indicate when specific P&M measures were identified, the date of implementation, or their current status (e.g., active, pending, or completed). Compounding these documentation failures, section 5.2.7 of the P&M Procedure was inadequate because it failed to define the term “periodic” or establish a specific time interval for the required periodic review. By failing to specify a frequency and failing to include detailed steps for how the review is to be conducted and documented, the procedure failed to ensure the consistent and verifiable implementation of the process. This lack of specificity contributed to EGT&S’s failure CPF 1-2026-012-NOPV to generate records demonstrating that the required P&M measure periodic review actually occurred. Therefore, EGT&S failed to follow its integrity management program in accordance with section 195.452(b)(5). Proposed Civil Penalty Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a related series of violations. For violation occurring on or after December 28, 2023 and before December 30, 2024, the maximum penalty may not exceed $266,015 per violation per day the violation persists, up to a maximum of $2,660,135 for a related series of violations. For violation occurring on or after January 6, 2023 and before December 28, 2023, the maximum penalty may not exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related series of violations. For violation occurring on or after March 21, 2022 and before January 6, 2023, the maximum penalty may not exceed $239,142 per violation per day the violation persists, up to a maximum of $2,391,412 for a related series of violations. For violation occurring on or after May 3, 2021 and before March 21, 2022, the maximum penalty may not exceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related series of violations. For violation occurring on or after January 11, 2021 and before May 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for a related series of violations. For violation occurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related series of violations. We have reviewed the circumstances and supporting documents involved in this case and have decided not to propose a civil penalty assessment at this time. Proposed Compliance Order With respect to Item 1, pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials Safety Administration proposes to issue a Compliance Order to Eastern Gas Transmission and Storage, Inc. Please refer to the Proposed Compliance Order, which is enclosed and made a part of this Notice. Response to this Notice Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement Proceedings. Please refer to this document and note the response options. All material you submit in response to this enforcement action may be made publicly available. If you believe that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. § 552(b), along with the complete original document you must provide a second copy of the document with the portions you believe qualify for confidential treatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatment under 5 U.S.C. § 552(b). 12026012NOPV_PCO_02062026_(25-329693) Page 3 of 5 Following your receipt of this Notice, you have 30 days to respond as described in the enclosed Response Options. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue a Final Order. If you are responding to this Notice, we propose that you submit your correspondence to my office within 30 days from receipt of this Notice. The Region Director may extend the period for responding upon a written request timely submitted demonstrating good cause for an extension. In your correspondence on this matter, please refer to CPF 1-2026-012-NOPV and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Robert Burrough Director, Eastern Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration Enclosures: Proposed Compliance Order Response Options for Pipeline Operators in Enforcement Proceedings CPF 1-2026-012-NOPV PROPOSED COMPLIANCE ORDER Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposes to issue to Eastern Gas Transmission and Storage, Inc. (EGT&S) a Compliance Order incorporating the following remedial requirements to ensure the compliance of EGT&S with the pipeline safety regulations: A. In regard to Item 1 of the Notice pertaining to EGT&S’s failure to follow its integrity management program, EGT&S must amend its written integrity management program, specifically section 5.2.7 of PIP-3506 – Preventive and Mitigative Measures, to include a specific definition for the term “periodic” that establishes a clear, fixed frequency for the review of P&M measures. The amended procedure must also detail the methodology for conducting this review that should include (1) the date the review was conducted; (2) the specific P&M measures evaluated; (3) any new P&M measures proposed for implementation; (4) the rationale for any P&M measures considered but rejected; and (5) the status of implementation for all selected measures. Following these procedural amendments, EGT&S must conduct a P&M measure periodic review, documenting the process in accordance with the revised procedures, and submit the records to the Director, Eastern Region, within 60 days of receipt of the Final Order. B. It is requested (not mandated) that EGT&S maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and Hazardous Materials Safety Administration. It is requested that these costs be reported in two categories: 1) total cost associated with preparation/revision of plans, procedures, studies and analyses, and 2) total cost associated with replacements, additions and other changes to pipeline infrastructure. 12026012NOPV_PCO_02062026_(25-329693) Page 5 of 5 - **truncated:** false - **body characters:** 17779