EQUITRANS MIDSTREAM CORPORATION — Notice of Amendment

party submissionOfficial PDF12021047NOA_Operator Response to Notice_08312021_(20-172148).pdf#

12021047NOA_Closure Letter_12162021_(20-172148)_text.pdf, page 1Official PDFOVERNIGHT EXPRESS DELIVERY December 16, 2021 Mr. Gregg West Vice President Midstream Operations Equitrans Midstream Corporation 2200 Energy Drive Canonsburg, PA 15317 CPF 1-2021-047-NOA Dear Mr. West: From October 6 through October 9, 2020, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Equitrans Midstream Corporation’s (EQT) procedures for operations, maintenance, and emergency response at Rhodes and Skin Creek underground natural gas storage fields in Lewis County, West Virginia. As a result of the inspection, EQT was issued a Notice of Amendment on August 5, 2021, which proposed amendment of your procedures. EQT submitted its response to the Notice of Amendment on August 31, 2021. My staff reviewed the response, and it appears that the inadequacies outlined in this Notice of Amendment have been addressed. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration#

12021047NOA_Notice of Amendment_08052021_(20-172148)_text.pdf, page 1Official PDFNOTICE OF AMENDMENT OVERNIGHT EXPRESS DELIVERY August 5, 2021 Mr. Gregg West Vice President Midstream Operations Equitrans Midstream Corporation 2200 Energy Drive Canonsburg, PA 15317 CPF 1-2021-047-NOA Dear Mr. West: From October 6 through October 9, 2020, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Equitrans Midstream Corporation’s (EQT) procedures for operations, maintenance, and emergency response at Rhodes and Skin Creek underground natural gas storage fields in Lewis County, West Virginia. On the basis of the inspection, PHMSA has identified apparent inadequacies found within EQT’s plans or procedures, as described below: 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) … (c) Procedural manuals. Each operator of a UNGSF must prepare and follow for each facility one or more manuals of written procedures for conducting operations, maintenance, and emergency preparedness and response activities under paragraphs (a) and (b) of this section. Each operator must keep records necessary to administer such procedures and review and update these manuals at intervals not exceeding 15 months, but at least once each calendar year. Each#

12021047NOA_Notice of Amendment_08052021_(20-172148)_text.pdf, page 2CPF 1-2021-047-NOA operator must keep the appropriate parts of these manuals accessible at locations where UNGSF work is being performed. Each operator must have written procedures in place before commencing operations or beginning an activity not yet implemented. EQT’s written procedures for conducting operations, maintenance, and emergency preparedness and response activities under § 192.12(b) failed to address third-party emergencies as required by Section 10.6.1 of API RP 1171 (Section 10.6.1), and failed to define a review interval as required by Section 11.4.2 of API RP 1171 (Section 11.4.2), and were therefore inadequate. Specifically, EQT’s Standard 10.12, Emergency Plan, Revision Number 31, dated May 7, 2019 (Emergency Plan) did not address all required types of emergencies or define a review interval. Section 10.6.1 states in part: "For site security and safety, the operator shall develop and implement a structured emergency preparedness/response plan in order to address accidental releases, equipment failures, natural disasters, and third-party emergencies." Section 11.4.2 states: "The operator shall establish a program to determine operator familiarity with emergency plans and procedures and periodic testing of the effectiveness of the plan in accordance with 10.6." During the inspection, PHMSA reviewed EQT’s Emergency Plan. The applicability of the Emergency Plan to UNGSFs, noted on pages 7 and 8 of the plan, addressed 3 of the 4 required types of emergencies noted in API RP 1171, but did not address third-party emergencies. The Emergency Plan, Section 6.3 also addressed an effectiveness review after actual incidents, but did not define a periodic effectiveness review interval. Therefore, EQT’s written procedures required by § 192.12(c) were inadequate. EQT must revise its Emergency Plan to address third-party emergencies in accordance with Section 10.6.1 and define a review interval in accordance with Section 11.4.2. 2. § 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) … (c) Procedural manuals. Each operator of a UNGSF must prepare and follow for each facility one or more manuals of written procedures for conducting operations, maintenance, and emergency preparedness and response activities under paragraphs (a) and (b) of this section. Each operator must keep records necessary to administer such procedures and review and update these manuals at intervals not exceeding 15 months, but at least once each calendar year. Each operator must keep the appropriate parts of these manuals accessible at locations where UNGSF work is being performed. Each operator must have written procedures in place before commencing operations or beginning an activity not yet implemented. 12021047NOA_Notice of Amendment_08052021_(20-172148)_text Page 2 of 6#

12021047NOA_Notice of Amendment_08052021_(20-172148)_text.pdf, page 3CPF 1-2021-047-NOA EQT’s written procedures for conducting operations, maintenance, and emergency preparedness and response activities under § 192.12(b) failed to be company specific in accordance with Section 10.6.3 of API RP 1171 (Section 10.6.3) and were therefore inadequate. Specifically, EQT’s Storage Well Emergency Response Plan (SWERP) dated September 30, 2010 was not company specific to EQT storage facilities. Section 10.6.3 states in part: "The operator shall have a blowout contingency plan in place. A blowout contingency plan is company specific and should identify the procedures, equipment, and personnel needed to avoid or respond to a loss of well control situation." During the inspection, PHMSA reviewed EQT’s SWERP as it was identified as EQT’s active blowout contingency plan. EQT’s SWERP was originally prepared for EQT by a well control expert consultant; however, the PHMSA inspection team noted that the SWERP was not specific to the EQT storage facilities being inspected. The body of the SWERP and its appendices did not contain specific information relative to the Rhodes and Skin Creek storage facilities. The PHMSA inspection team further noted the revision log in the SWERP indicated that the plan was being rewritten as the EOP Draft Storage Well Emergency Plan and was in draft stage and was undergoing review. Therefore, EQT’s written procedures required by § 192.12(c) were inadequate as its blowout contingency plan failed to meet the provisions of Section 10.6.3. EQT must update its blowout contingency plan to meet the requirements set forth in API RP 1171 Section 10.6.3. 3. § 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) … (c) Procedural manuals. Each operator of a UNGSF must prepare and follow for each facility one or more manuals of written procedures for conducting operations, maintenance, and emergency preparedness and response activities under paragraphs (a) and (b) of this section. Each operator must keep records necessary to administer such procedures and review and update these manuals at intervals not exceeding 15 months, but at least once each calendar year. Each operator must keep the appropriate parts of these manuals accessible at locations where UNGSF work is being performed. Each operator must have written procedures in place before commencing operations or beginning an activity not yet implemented. EQT’s written procedures for conducting operations, maintenance, and emergency preparedness and response activities under § 192.12(b) failed to specify record retention intervals in accordance with Section 11.13.3 of API RP 1171 (Section 11.13.3) and were therefore inadequate. Specifically, EQT’s Integrity Management Program for Underground Gas Storage (SIMP)did not specify a records retention interval for training records. 12021047NOA_Notice of Amendment_08052021_(20-172148)_text Page 3 of 6#

12021047NOA_Notice of Amendment_08052021_(20-172148)_text.pdf, page 4CPF 1-2021-047-NOA Section 11.13.3 stated in part: "The operator shall establish retention intervals for records that meet regulatory requirements; where no regulatory requirements exist, retention intervals should be determined by the operator." During the inspection, PHMSA reviewed EQT’s SIMP. Section 10 of the SIMP applied to asset- based activities or tasks and noted a records retention requirement for the life of the facility. However, Section 8 of the SIMP addressed training requirements, but did not specify a records retention interval. Therefore, EQT’s written procedures required by § 192.12(c) were inadequate. EQT must revise its procedures to establish a record retention interval for training records in accordance with Section 11.13.3. 4. § 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) … (c) Procedural manuals. Each operator of a UNGSF must prepare and follow for each facility one or more manuals of written procedures for conducting operations, maintenance, and emergency preparedness and response activities under paragraphs (a) and (b) of this section. Each operator must keep records necessary to administer such procedures and review and update these manuals at intervals not exceeding 15 months, but at least once each calendar year. Each operator must keep the appropriate parts of these manuals accessible at locations where UNGSF work is being performed. Each operator must have written procedures in place before commencing operations or beginning an activity not yet implemented. EQT’s written procedures for conducting operations, maintenance, and emergency preparedness and response activities under § 192.12(b) failed to address training for storage operations and applicable staff for emergency response in accordance with Section 10.6.2 of API RP 1171 (Section 10.6.2) and were therefore inadequate. Specifically, Section 8.5 of EQT’s SIMP failed to address training for storage operations and applicable staff for the use of the emergency preparedness/response plan. Section 10.6.2 states in part: "Storage operations and applicable staff shall receive training in the use of the emergency preparedness/response plan. The training can include mock drills and participation in table-top exercises at regular intervals. The table-top exercises or mock drills can include civil emergency responders to enhance understanding and successful incident response." During the inspection, PHMSA reviewed the SIMP. Section 8.5 of the SIMP, covered training requirements in general but did not address specific training for storage operations, including how the company intended to conduct the training (e.g., using mock drills, table-top exercises, etc.), and applicable staff for emergency response. 12021047NOA_Notice of Amendment_08052021_(20-172148)_text Page 4 of 6#

12021047NOA_Notice of Amendment_08052021_(20-172148)_text.pdf, page 5CPF 1-2021-047-NOA Therefore, EQT’s written procedures required by § 192.12(c) were inadequate. EQT must revise its SIMP to address training for emergency response in accordance with Section 10.6.2. 5. § 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) … (4) Integrity management procedures and recordkeeping. Each UNGSF operator must establish and follow written procedures to carry out its integrity management program under API RP 1171 (incorporated by reference, see § 192.7), section 8 ("Risk Management for Gas Storage Operations"), and this paragraph (d). The operator must also maintain, for the useful life of the UNGSF, records that demonstrate compliance with the requirements of this paragraph (d). This includes records developed and used in support of any identification, calculation, amendment, modification, justification, deviation, and determination made, and any action taken to implement and evaluate any integrity management program element. EQT’s written procedures for carrying out its integrity management program under Section 8.7.2 of API RP 1171 (Section 8.7.2) did not include adequate provisions for performing periodic reviews, and were therefore inadequate under § 192.12(d)(4). Specifically, Section 4.6 of EQT’s SIMP did not specify the frequency of periodic reviews. Section 8.7.2 states: "The operator shall define a review frequency for the risk assessment and perform a review and update of the risk assessment in accordance with the defined frequency." During the inspection, PHMSA reviewed EQT’s SIMP.Section 4.6 of the SIMP, which provided for a periodic review, but does not specify the frequency. Therefore, EQT’s written procedures required by § 192.12(d)(4) were inadequate. EQT must revise its procedures to specific a frequency for review in accordance with Section 8.7.2. 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 Enforcement 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 12021047NOA_Notice of Amendment_08052021_(20-172148)_text Page 5 of 6#

12021047NOA_Notice of Amendment_08052021_(20-172148)_text.pdf, page 6CPF 1-2021-047-NOA 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 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 30 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 Equitrans Midstream Corporation 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, 840 Bear Tavern Road, Suite 300, West Trenton, NJ 08628. In correspondence concerning this matter, please refer to CPF 1-2021-047-NOA and, for each document you submit, please provide a copy in electronic format whenever possible. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should be sent on USB flash drive accompanied by the original paper copy to the Eastern Region Office. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings 12021047NOA_Notice of Amendment_08052021_(20-172148)_text Page 6 of 6#