# CRANBERRY PIPELINE CORP (WV) — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 12026022NOPV
- **title:** CRANBERRY PIPELINE CORP (WV) — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** current
- **official:** true
- **published on:** 2026-02-24
- **effective on:** Not available
- **summary:** OPEN notice of probable violation citing 192.12(d)(2).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-12026022nopv.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-12026022nopv.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-12026022nopv
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/12026022NOPV
**body:**

Notice of Probable Violation involving CRANBERRY PIPELINE CORP (WV). PHMSA's enforcement data identifies the cited regulation as 192.12(d)(2). The case was opened on 2026-02-24 and is reported as open. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

12026022NOPV_Final Order_04212026_(25-330072).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026022NOPV/12026022NOPV_Final%20Order_04212026_(25-330072).pdf

12026022NOPV_Final Order_04212026_(25-330072)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026022NOPV/12026022NOPV_Final%20Order_04212026_(25-330072)_text.pdf

12026022NOPV_Operator Response to Notice_03242026_(25-330072).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026022NOPV/12026022NOPV_Operator%20Response%20to%20Notice_03242026_(25-330072).pdf

12026022NOPV_PCO_02242026_(25-330072).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026022NOPV/12026022NOPV_PCO_02242026_(25-330072).pdf

12026022NOPV_PCO_02242026_(25-330072)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026022NOPV/12026022NOPV_PCO_02242026_(25-330072)_text.pdf

12026022NOPV_Final Order_04212026_(25-330072)_text.pdf

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Avenue, S.E.
Washington, D.C. 20590
April 21, 2026
VIA ELECTRONIC MAIL TO: bgray@dgoc.com
Bradley Gray
Executive VP/COO
Cranberry Pipeline Corporation
1800 Corporate Drive
Birmingham, AL 35242
Re: CPF No. 1-2026-022-NOPV
Dear Mr. Gray:
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
James S. Bailey, VP, Midstream Operations (Compliance), Diversified Energy,
jsbailey@dgoc.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 )
Cranberry Pipeline Corporation, ) CPF No. 1-2026-022-NOPV
a subsidiary of Diversified Midstream, LLC, )
)
)
)
Respondent. )
__________________________________________)
FINAL ORDER
On February 24, 2026, pursuant to 49 C.F.R. § 190.207, the Director, Eastern Region, Office of
Pipeline Safety (OPS), issued a Notice of Probable Violation (Notice) to Cranberry Pipeline
Corporation (Respondent), a subsidiary of Diversified Midstream, LLC. The Notice proposed
finding that Respondent had violated the pipeline safety regulations in 49 CFR Part 192. The
Notice also proposed certain measures to correct the violation. Diversified Midstream LLC
(Diversified) and Respondent collectively responded to the Notice. Diversified and Respondent
did not contest the allegation of violation or corrective measures but did provide additional
information regarding its compliance with Part 192.
The allegation of violation being uncontested, 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 § 192.12(d)(2) (Item 1) ─ Respondent failed to complete the baseline
risk assessment for at least 40% of its underground natural gas storage facility
wells by March 13, 2024. Specifically, Respondent failed to evaluate the
mechanical integrity of any of its wells with a downhole inspection and failed to
incorporate the results of any of these evaluations into the baseline risk
assessments.
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. 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.
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: bgray@dgoc.com
February 24, 2026
Bradley Gray
Executive VP/COO
Cranberry Pipeline Corporation
1800 Corporate Drive
Birmingham, AL 35242
CPF 1-2026-022-NOPV
Dear Mr. Gray:
From August 12 through 14, 2025, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected
Cranberry Pipeline Corporation’s (CPC)1 Heizer Creek Storage and Maxton underground natural
gas storage facilities (UNGSFs) in Putnam and Raleigh Counties, West Virginia.
As a result of the inspection, it is alleged that CPC 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. § 192.12 Underground natural gas storage facilities.
Underground natural gas storage facilities (UNGSFs), as defined in § 192.3,
are not subject to any requirements of this part aside from this section.
(a) . . . .
(d) Integrity management program —
(1) . . . .
(2) Integrity management baseline risk-assessment intervals. No later than
March 13, 2024, each UNGSF operator must complete the baseline risk
assessments of all reservoirs and caverns, and at least 40% of the baseline risk
assessments for each of its UNGSF wells (including wellhead assemblies),
beginning with the highest-risk wells, as identified by the risk analysis process.
1 CPC is a subsidiary of Diversified Midstream LLC.



CPF 1-2026-022-NOPV
No later than March 13, 2027, an operator must complete baseline risk
assessments on all its wells (including wellhead assemblies). Operators may use
prior risk assessments for a well as a baseline (or part of the baseline) risk
assessment in implementing its initial integrity management program, so long
as the prior assessments meet the requirements of API RP 1171 (incorporated
by reference, see § 192.7), section 8, and continue to be relevant and valid for
the current operating and environmental conditions. When evaluating prior
risk-assessment results, operators must account for the growth and effects of
indicated defects since the time the assessment was performed.
CPC failed to complete the baseline risk assessment for at least 40% of its UNGSF wells by March
13, 2024, in accordance with section 192.12(d)(2). Specifically, CPC failed to evaluate the
mechanical integrity of any of its wells with a downhole inspection and failed to incorporate the
results of any of these evaluations into the baseline risk assessments.
As a subsidiary, CPC uses Diversified Midstream LLC’s Storage Integrity Management Plan
(02/01/2025) (SIMP) and section 8.3.3 notes in part that:
[CPC] shall evaluate the mechanical integrity of each active well, including each
third-party well, that penetrates the storage reservoir and buffer zone, or areas
influenced by storage operations.
• Well integrity evaluation methods typically used include but are not limited to
review of design, completion and well work records, wellhead and downhole
inspection, well pressure monitoring and testing, and gas sampling.
•
. . .
• Active well mechanical integrity evaluations shall include initial and
subsequent evaluations as determined using the risk assessment and the
information derived from the initial evaluation.
During the inspection, PHMSA noted that CPC’s baseline risk assessments did not incorporate
downhole mechanical integrity inspection methods into the risk evaluation for any of the 16 active
wells in the two fields, which would have allowed CPC to monitor for tubular corrosion and
evaluate corrosion impact on well integrity and operating pressure. Consequently, without the
downhole inspection method such as a casing corrosion log to support the assumptions made and
the methodology used to complete the calculations in the risk model, CPC lacked any historical
data that may have been relevant and valid for current operating and environmental conditions, or
any current data. No downhole mechanical integrity evaluations (casing logs) had been conducted
by March 13, 2024.
Therefore, CPC failed to complete the baseline risk assessment for at least 40% of its UNGSF
wells by March 13, 2024, in accordance with section 192.12(d)(2).
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
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CPF 1-2026-022-NOPV
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 Cranberry Pipeline Corporation. 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).
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.
Page 3 of 5



CPF 1-2026-022-NOPV
In your correspondence on this matter, please refer to CPF 1-2026-022-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
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CPF 1-2026-022-NOPV
PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Cranberry Pipeline Corporation (CPC) a
Compliance Order incorporating the following remedial requirements to ensure the compliance of
CPC with the pipeline safety regulations:
A. In regard to Item 1 of the Notice pertaining to CPC’s failure to complete the baseline
risk assessment for at least 40% of its UNGSF wells by March 13, 2024, CPC must
complete the baseline risk assessment for the seven highest-risk wells by September
26, 2026, or within 180 days of receipt of the Final Order, whichever is later.
B. It is requested (not mandated) that CPC 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.
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