# EQUITRANS MIDSTREAM CORPORATION — Notice of Amendment

**Citation:** CPF 120181019M  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2018-08-22

CLOSED notice of amendment citing 192.12(e).

## Document text

Notice of Amendment involving EQUITRANS MIDSTREAM CORPORATION. PHMSA's enforcement data identifies the cited regulation as 192.12(e). The case was opened on 2018-08-22 and is reported as closed as of 2018-11-02. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120181019M_Closure Letter_11022018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181019M/120181019M_Closure%20Letter_11022018.pdf

120181019M_Notice of Amendment_08222018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181019M/120181019M_Notice%20of%20Amendment_08222018.pdf

120181019M_Notice of Amendment_08222018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181019M/120181019M_Notice%20of%20Amendment_08222018_text.pdf

120181019M_Operator Response to Notice_09172018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181019M/120181019M_Operator%20Response%20to%20Notice_09172018.pdf

120181019M_Notice of Amendment_08222018_text.pdf

NOTICE OF AMENDMENT
OVERNIGHT EXPRESS DELIVERY
August 22, 2018
Mr. Gregg West
Vice President, Midstream Operations
EQT Midstream
2200 Energy Drive
Canonsburg, PA 15317
CPF 1-2018-1019M
Dear Mr. West:
From April 16–20, 2018, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the
EQT Midstream (EQT) procedures for the operation of the Gamble-Hayden Natural Gas Storage
Facilities. The specific purpose of the inspection was to evaluate the compliance with 49 CFR
§ 192.12 and associated references in § 192.7. The inspection was conducted at the EQT Offices
in Jefferson Hills, Pennsylvania and at the Gamble-Hayden storage facility in Allegheny County,
Pennsylvania.
Based on the results of the inspection, PHMSA has identified the apparent inadequacies found
within the EQT Underground Natural Gas Storage (UNGS) procedures, as described below:
1. § 192.12 Underground natural gas storage facilities.
(e) Operators of underground gas storage facilities must establish and follow written
procedures for operations, maintenance, and emergencies implementing the
requirements of API RP 1170 and API RP 1171, as required under this section,
including the effective dates as applicable, and incorporate such procedures into their
written procedures for operations, maintenance, and emergencies established
pursuant to § 192.605.
EQT’s written procedures for operations, maintenance and emergencies implementing the
requirements of API RP 1170 and API RP 1171 were inadequate. Specifically, EQT did not
establish a written Blowout Contingency Plan (BCP), as directed by API RP 1171, Section 10.6.3,
covering the wells in the Gamble-Hayden storage facility.



CPF 1-2018-1019M
2. The BCP was phased out of the Emergency Response Plan (ERP) even though it was still
referenced in the ERP. The BCP is not included in the Emergency Table-Top Exercise program.
§ 192.12 Underground natural gas storage facilities.
(e) Operators of underground gas storage facilities must establish and follow written
procedures for operations, maintenance, and emergencies implementing the
requirements of API RP 1170 and API RP 1171, as required under this section,
including the effective dates as applicable, and incorporate such procedures into their
written procedures for operations, maintenance, and emergencies established
pursuant to § 192.605.
EQT’s written procedures for operations, maintenance and emergencies implementing the
requirements of API RP 1170 and API RP 1171 were inadequate. Specifically, EQT’s written
procedures did not provide details on how to determine operator familiarity with UNGS emergency
plans, procedures and periodic testing of the effectiveness of the plan, as directed by API RP 1171,
Section 11.4.2.
3. § 192.12 Underground natural gas storage facilities.
(e) Operators of underground gas storage facilities must establish and follow written
procedures for operations, maintenance, and emergencies implementing the
requirements of API RP 1170 and API RP 1171, as required under this section,
including the effective dates as applicable, and incorporate such procedures into their
written procedures for operations, maintenance, and emergencies established
pursuant to § 192.605.
EQT’s written procedures for operations, maintenance and emergencies implementing the
requirements of API RP 1170 and API RP 1171 were inadequate. Specifically, EQT’s written
procedures did not incorporate safety and environmental programs, as directed by API RP 1171,
Section 11.9.1.
EQT’s environmental engineer evaluated new construction, but EQT was unable to show where
Health, Safety, and Environment (HSE) programs were included in UNGS procedures.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as
part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance
Proceedings. Please refer to this document and note the response options. Be advised that all
material you submit in response to this enforcement action is subject to being 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 the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of
120181019M_Notice of Amendment_08222018_text Page 2 of 3



CPF 1-2018-1019M
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 an Order Directing Amendment. If your plans or
procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans
or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this
Notice, we propose that you submit your amended procedures to my office within 60 days of
receipt of this Notice. This period may be extended by written request for good cause. Once the
inadequacies identified herein have been addressed in your amended procedures, this enforcement
action will be closed.
It is requested (not mandated) that EQT Corporation Company, EQT Midstream maintain
documentation of the safety improvement costs associated with fulfilling this Notice of
Amendment (preparation/revision of plans, procedures) and submit the total to Robert Burrough,
Director, Eastern Region, Pipeline and Hazardous Materials Safety Administration. In
correspondence concerning this matter, please refer to CPF 1-2018-1019M and, for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
120181019M_Notice of Amendment_08222018_text Page 3 of 3

120181019M_Closure Letter_11022018.pdf

U.S. Department
840 Bear Tavern Road, Suite 300
of Transportation
West Trenton, NJ 08628
Pipeline and
609.771.7800
Hazardous Materials
Safety Administration
OVERNIGHT EXPRESS DELIVERY
November 2, 2018
Mr Gregg West
Vice President, Midstream Operations
EQT Midstream
2200 Energy Drive
Canonsburg, PA 15317
CPF 1-2018-1019M
Dear Mr. West:
From April 16-20, 2018 representatives from the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site
pipeline safety inspection of EQT Midstream (EQT) procedures for the operations of the Gamble-
Hayden Natural Gas Storage Facilities. The specific purpose of the audit was to evaluate the
progress EQT Midstream has made to be in compliance with API RP 1171 (incorporated in
49 CFR 192.12 by reference, see §192.7). The audit was conducted at the QT Training Center
Offices at 4029 Ridge Road, Jefferson Hills, Pennsylvania and on-site at the Gamble-Hayden
storage facility in Allegheny county Pennsylvania. As a result of the inspection, EQT was issued
a Notice of Amendment on August 22, 2018, which proposed amendment of your procedures.
EQT submitted a response to the NOA and amended procedures to satisfy the NOA on
inadequacies outlined in this Notice of Amendment have been corrected
September 17, 2018. My staff reviewed the amended procedures, and it appears that the
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely.
Caht Burn
Robert Burroug
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/120181019M>
- Source ID: `phmsa-enforcement`
- SHA-256: `8f35b11e9d079530ce74fd5e1df262e7af8f34921a5eda30c4b256fdebf0ae87`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-24T03:01:38.218Z
- Document slug: `phmsa-enforcement-120181019m`

### Source metadata

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  "cpf": "120181019M",
  "operator": "EQUITRANS MIDSTREAM CORPORATION",
  "region": "Eastern",
  "pipelineType": "GAS INTERSTATE ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "192.12(e)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 4,
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  "extractedAgencyDocumentCount": 2,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "EQUITRANS MIDSTREAM CORPORATION"
}
```
