EQUITRANS MIDSTREAM CORPORATION — Notice of Probable Violation

party submissionOfficial PDF120141007_Operator Response Notice_07312014.pdf#

120141007_Closure Letter_04162015_text.pdf, page 1Official PDFU.S. Department Of Transportation Pipeline and 609.989.2171 Hazardous Materials Safety Administration 820 Bear Tavern Road, Suite 103 West Trenton, NJ 08628 OVERNIGHT EXPRESS DELIVERY April 16, 2015 Mr. Robert Cooper Chairman, VP of Engineering EQT Midstream 625 Liberty Avenue Suite 1700 Pittsburgh, PA 15222 CPF 1-2014-1007 Dear Mr. Cooper: On December 29, 2014, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to EQT Midstream Partners, LP a Final Order in the above-referenced case. This Order included a Compliance Order and Civil Penalty assessment. Based on our review of the documentation you provided and confirmation of payment of the civil penalty on July 31, 2014, it has been determined that you have 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, Byron Coy, P.E. Director, Eastern Region Pipeline and Hazardous Materials Safety Administration#

120141007_NOPV PCP PCO_07012014_text.pdf, page 1Official PDFU.S. Department Of Transportation Pipeline and 609.989.2171 Hazardous Materials Safety Administration 820 Bear Tavern Road, Suite 103 West Trenton, NJ 08628 NOTICE OF PROBABLE VIOLATION PROPOSED CIVIL PENALTY and PROPOSED COMPLIANCE ORDER OVERNIGHT EXPRESS DELIVERY July 1, 2014 Robert Cooper Vice President of Engineering EQT Midstream 625 Liberty Avenue Pittsburgh, PA 15222 CPF 1-2014-1007 Dear Mr. Cooper: On November 16, 2012, 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 reviewed EQT Midstream’s (EQT) Safety-Related Condition (SRC) Report ( Report # 2012106) submission for its Waynesburg, Pennsylvania Compressor Station (Pratt Compressor Station). As a result of the review and further analysis, it appears that you have committed a probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the probable violation is: 1. §192.605 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. For transmission lines, the manual must also include procedures for handling abnormal operations. This manual must be reviewed and updated by the operator at intervals not exceeding 15 months, but at least once each calendar year. This manual must be prepared before operations of a pipeline system commence. Appropriate parts of the manual must be kept at locations where operations and maintenance activities are conducted. (b) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following, if applicable, to provide safety during maintenance and operations. (1) Operating, maintaining, and repairing the pipeline in accordance with each of the requirements of this subpart and subpart M of this part.#

120141007_NOPV PCP PCO_07012014_text.pdf, page 21-2014-1007 EQT’s procedural manual for operations and maintenance (O&M) did not have a written process for the Pratt Compressor Station that addressed routing gas through the coolers before exiting the station. On November 14, 2012, EQT submitted a SRC Report to PHMSA. EQT reported that a safety- related condition1 existed at its Pratt Compressor Station on November 7, 2012. In the SRC Report, EQT stated that on November 7, 2012 it discovered pipeline #GSF-360 had elongated and shifted off pipeline supports. The pipeline had expanded longitudinally approximately seven (7) inches. EQT categorized the SRC as a “[c]ondition that could lead to an imminent hazard and cause a 20% or more reduction in operating pressure or shutdown of operation. . . .” EQT also stated in the report that it took corrective action by shutting down and blowing down (removing gas from) the pipeline. EQT reduced the pressure in #GSF-360 from 538 psig to 0 psig. Subsequently, on November 16, 2012, an EQT representative provided an update and a photograph showing that pipeline #GSF-360 had shifted off pipeline supports. During the period between December 26, 2012 and February 11, 2013, a PHMSA inspector exchanged emails with EQT representatives relating to the occurrence of the SRC. EQT determined the root cause of the line expansion and movement. The discharge temperature on #GSF-360 had reached approximately 180°F due to EQT personnel inadvertently bypassing the station coolers which caused the longitudinal expansion of the pipeline. EQT corrected the situation and placed the affected section of the pipeline back in service on December 21, 2012. The PHMSA inspector requested a copy of the O&M procedure for the operation of pipeline #GSF-360 at Pratt Compressor Station, including related equipment (e.g. the cooler) in effect at the time of this SRC. The EQT representative stated that the O&M procedure existing at the time of the SRC did not specifically require routing of gas through the coolers. The EQT representative also stated that EQT established a separate procedure for cooler operations at the Pratt Compressor Station following the SRC. The PHMSA inspector requested a copy of the original and supplemental procedure. The EQT representative provided the original start-up and shut-down procedure titled Start-up Shutdown Engine/ Compressor Units 1, 2, 3, 4 & 5 Pratt #47 and the new additional procedure titled Pratt Station Required Procedures For Operations. The PHMSA inspector reviewed the procedure, Start-up Shutdown Engine/ Compressor Units 1, 2, 3, 4 & 5 Pratt #47, and noted that the procedure did not have a process for routing gas through the coolers before exiting the station. The PHMSA inspector also reviewed the new additional procedure, Pratt Station Required Procedures For Operations, which does state that “the unit discharge must always be routed through a gas cooler before exiting the yard or entering the second unit when 2 staging is required.” The EQT representative indicated that the Pratt Compressor Station is the only facility that was designed to allow the gas to bypass the coolers. However, EQT’s O&M manual did not include a written process to require routing gas through the coolers before exiting the compressor station until after the SRC had occurred. 120141007 1 See, 49 CFR §191.23 Reporting safety-related conditions. _ NOPV-PCP-PCO_07012014 Page 2 of 4#

120141007_NOPV PCP PCO_07012014_text.pdf, page 31-2014-1007 Proposed Civil Penalty Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a related series of violations. For violations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a related series of violations. The Compliance Officer has reviewed the circumstances and supporting documentation involved in the above probable violation and has recommended that you be preliminarily assessed a civil penalty of $28,800 as follows: Item number PENALTY 1 $28,800 Proposed Compliance Order With respect to item 1 pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration proposes to issue a Compliance Order to EQT. 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 Compliance 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). 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. Please submit all correspondence in this matter to Byron Coy, PE, Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103, W. Trenton, NJ 08628. Please refer to CPF 1-2014-1007 on each document you submit and please, whenever possible, provide a signed PDF copy in electronic format. Smaller files may be emailed to Byron.Coy@dot.gov. Larger files should be sent on a CD accompanied by the original paper copy to the Eastern Region Office. Additionally, if you choose to respond to this (or any other case), please ensure that any response letter pertains solely to one CPF case number. Sincerely, Byron Coy, PE Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Enclosures: Proposed Compliance Order Response Options for Pipeline Operators in Compliance Proceedings 120141007 _ NOPV-PCP-PCO_07012014 Page 3 of 4#

120141007_NOPV PCP PCO_07012014_text.pdf, page 41-2014-1007 PROPOSED COMPLIANCE ORDER Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposes to issue to EQT Midstream (EQT) a Compliance Order incorporating the following remedial requirements to ensure the compliance of EQT with the pipeline safety regulations: 1. 2. 3. With regards to Item Number 1 of the Notice pertaining to EQT not having a written process for routing gas through the coolers before exiting the Pratt Compressor Station in its Operations and Maintenance (O&M) Manual, EQT must: a. Amend its procedure/s for Start-up Shutdown Engine/ Compressor Units 1, 2, 3, 4 & 5 Pratt #47 to include provisions for station cooler operations. Related procedures must include the date originated and the effective date of the last revision. b. Provide documentation that demonstrates it has reviewed the procedure(s) (e.g. Start- up Shutdown Engine/ Compressor Units 1, 2, 3, 4 & 5 Pratt #47 and Pratt Station Required Procedures For Operations) in accordance with section 49 CFR 192.605(a). EQT must submit amended procedure(s) and documentation that is stipulated in the above item within sixty (60) days after receipt of a Final Order. It is requested (not mandated) that EQT maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to Byron Coy, PE, 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. 120141007 _ NOPV-PCP-PCO_07012014 Page 4 of 4#

120141007_Final Order_12292014_text.pdf, page 1Official PDFDECEMBER 29, 2014 Mr. David L. Porges Chairman, President & CEO EQT Midstream Partners, LP 625 Liberty Avenue Suite 1700 Pittsburgh, PA 15222 Re: CPF No. 1-2014-1007 Dear Mr. Porges: Enclosed please find the Final Order issued in the above-referenced case. It makes a finding of violation, assesses a civil penalty of $28,800, and specifies actions that need to be taken by EQT Midstream Partners, LP, a subsidiary of EQT Corporation, to comply with the pipeline safety regulations. This is to acknowledge receipt of payment of the full penalty amount by wire transfer, dated July 31, 2014. When the terms of the compliance order have been completed, as determined by the Director, Eastern Region, this enforcement action will be closed. Service of the Final Order by certified mail is deemed effective upon the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5. Thank you for your cooperation in this matter. Sincerely, Jeffrey D. Wiese Associate Administrator for Pipeline Safety Enclosure cc: Mr. Byron Coy, P.E., Director, Eastern Region, OPS Mr. Robert Cooper, Vice President of Engineering, EQT Midstream Partners, LP CERTIFIED MAIL - RETURN RECEIPT REQUESTED#

120141007_Final Order_12292014_text.pdf, page 2U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 ____________________________________ ) In the Matter of ) ) EQT Midstream Partners, LP, ) CPF No. 1-2014-1007 a subsidiary of EQT Corporation, ) ) Respondent. ) ____________________________________) On November 16, 2012, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), conducted a review of a Safety-Related Condition Report (SRC)1 submitted by EQT Midstream Partners, LP (EQT or Respondent), involving an incident at its Pratt Compressor Station (PCS) in Waynesburg, Pennsylvania. EQT provides midstream services to its parent, EQT Corporation, and third-party companies.2 EQT operates approximately 27 miles of hazardous liquids pipelines, 741 miles of natural gas pipelines, and 119 miles of gas gathering pipelines in Kentucky, Pennsylvania, Virginia, and West Virginia.3 As a result of the review, the Director, Eastern Region, OPS (Director), issued to Respondent, by letter dated July 1, 2014, a Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that EQT had violated 49 C.F.R. § 192.605 and proposed assessing a civil penalty of $28,800 for the alleged violation. The Notice also proposed ordering Respondent to take certain measures to correct the alleged violation. EQT responded to the Notice by letter dated July 31, 2014 (Response). The company did not contest the allegation of violation, but provided information concerning the corrective actions it had taken. Respondent did not request a hearing and therefore has waived its right to one. The company also paid the proposed penalty of $28,800 by wire transfer dated July 31, 2014, which serves to close the case with prejudice as to any item for which a penalty was proposed. FINAL ORDER 1 Under 49 C.F.R. § 191.23, pipeline operators are required to report on specified safety-related conditions in accordance with 49 C.F.R. § 191.25. 2 EQT Midstream Partners, LP, website, available at http://www.eqtmidstreampartners.com/media-fast-facts.cfm (last accessed October 22, 2014). 3 2013 PHMSA Annual Report, as reported by EQT pursuant to 49 C.F.R. § 191.17.#

120141007_Final Order_12292014_text.pdf, page 3CPF No: 1-2014-1007 Page 2 FINDING OF VIOLATION In its Response, EQT did not contest the allegation in the Notice that it violated 49 C.F.R. Part 192, as follows: Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.605, which states, in relevant part: § 192.605 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. For transmission lines, the manual must also include procedures for handling abnormal operations. This manual must be reviewed and updated by the operator at intervals not exceeding 15 months, but at least once each calendar year. This manual must be prepared before operations of a pipeline system commence. Appropriate parts of the manual must be kept at locations where operations and maintenance activities are conducted. (b) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following, if applicable, to provide safety during maintenance and operations. (1) Operating, maintaining, and repairing the pipeline in accordance with each of the requirements of this subpart and subpart M of this part…. The Notice alleged that EQT violated 49 C.F.R. § 192.605(b)(1) by failing to have certain Operation and Maintenance (O&M) manual procedures providing for the safe operation of its #GSF-360 pipeline at the company’s Pratt Compressor Station (Pratt Station). Specifically, the Notice alleged that EQT’s O&M procedures applicable to the Pratt Station, Start-up Shutdown Engine/Compressor Units 1, 2, 3, 4, & 5 Pratt #47 (Pratt Procedures), did not have a process for routing gas through coolers before exiting the station. On November 7, 2012, the discharge temperature on pipeline #GSF-360 reached approximately 180 degrees Fahrenheit due to EQT personnel inadvertently bypassing the station coolers. According to PHMSA, this temperature increase resulted in a longitudinal expansion of the pipeline such that it shifted it off its pipeline supports, causing EQT to file an SRC Report with PHMSA. Respondent did not contest this allegation of violation, but provided information about remedial action it had taken in response to the incident. Accordingly, based upon a review of all of the evidence, I find that EQT violated 49 C.F.R. § 192.605(b)(1) by failing to have certain O&M procedures providing for the safe operation of pipeline #GSF-360 at its Pratt Station. This finding of violation will be considered a prior offense in any subsequent enforcement action taken against Respondent.#

120141007_Final Order_12292014_text.pdf, page 4CPF No: 1-2014-1007 Page 3 ASSESSMENT OF PENALTY Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed $200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any related series of violations. In determining the amount of a civil penalty under 49 U.S.C. § 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature, circumstances, and gravity of the violation, including adverse impact on the environment; the degree of Respondent’s culpability; the history of Respondent’s prior offenses; and any effect that the penalty may have on its ability to continue doing business; and the good faith of Respondent in attempting to comply with the pipeline safety regulations. In addition, I may consider the economic benefit gained from the violation without any reduction because of subsequent damages, and such other matters as justice may require. The Notice proposed a total civil penalty of $28,800 for the violation cited above. Item 1: The Notice proposed a civil penalty of $28,800 for EQT’s violation of 49 C.F.R. § 192.605(b)(1), for failing to have certain O&M manual procedures providing for the safe operation of its #GSF-360 pipeline at its Pratt Station. EQT paid the proposed penalty in full, which serves to close the case with prejudice to Respondent. Accordingly, having reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of $28,800 for violation of 49 C.F.R. § 192.605(b)(1). In summary, having reviewed the record and considered the assessment criteria for each of the Items cited above, I assess Respondent a total civil penalty of $28,800, which amount has been paid in full. COMPLIANCE ORDER The Notice proposed a compliance order with respect to Item 1 in the Notice for violation of 49 C.F.R. § 192.605(b)(1). Under 49 U.S.C. § 60118(a), each person who engages in the transportation of gas or who owns or operates a pipeline facility is required to comply with the applicable safety standards established under chapter 601. In its Response, EQT stated that it intended to comply with the proposed Compliance Order and had established a written procedure at the Pratt Station to provide guidance for routing gas through the facility’s coolers. Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following actions to ensure compliance with the pipeline safety regulations applicable to its operations: 1. With respect to the violation of § 192.605(b)(1) (Item 1), Respondent must: a. Amend its procedure, Start-up Shutdown Engine/Compressor Units 1, 2, 3, 4 & 5 Pratt #47, to include provisions for station cooler operations. Related procedures must include the date originated and the effective date of the last revision.#

120141007_Final Order_12292014_text.pdf, page 5CPF No: 1-2014-1007 Page 4 b. Provide documentation that demonstrates it has reviewed its related procedures (e.g., Start-up Shutdown Engine/Compressor Units 1, 2, 3, 4 & 5 Pratt #47 and Pratt Station Required Procedures for Operations) in accordance with 49 C.F.R. § 192.605(a). 2. EQT must submit amended procedure(s) and documentation that one stipulated in the above item within 60 days after receipt of the Final Order. 3. It is requested (not mandated) that EQT maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to Byron Coy, P.E., 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. 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. Failure to comply with this Order may result in the administrative assessment of civil penalties not to exceed $200,000 for each violation for each day the violation continues or in referral to the Attorney General for appropriate relief in a district court of the United States. The terms and conditions of this Final Order are effective upon service in accordance with 49 C.F.R. § 190.5. ___________________________________ __________________________ Jeffrey D. Wiese Date Issued Associate Administrator for Pipeline Safety#