EQUITRANS MIDSTREAM CORPORATION — Notice of Amendment

party submissionOfficial PDF12022030NOA_Operator Response to Notice_04142022_(21-200902).pdf#

12022030NOA_Closure Letter_05262022_(20-173105)_text.pdf, page 1Official PDFOVERNIGHT EXPRESS DELIVERY May 26, 2022 Mr. Gregg West Vice President Midstream Operations Equitrans Midstream Corporation 2200 Energy Drive Canonsburg, PA 15317 CPF 1-2022-030-NOA Dear Mr. West: From October 13, 2020, through July 15, 2020, a representative 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 Equitrans Midstream Corporation’s (ETRN) procedures for the Tepe, Finleyville, and Webster Underground Storage Fields in Pennsylvania. As a result of the inspection, ETRN was issued a Notice of Amendment on March 15, 2022, which proposed amendment of your procedures. ETRN submitted its amended procedures on April 14, 2022. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. 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#

12022030NOA_Notice of Amendment_03152022_(20-173105)_text.pdf, page 1Official PDFNOTICE OF AMENDMENT OVERNIGHT EXPRESS DELIVERY March 15, 2022 Mr. Gregg West Vice President, Environmental, Safety & Compliance Equitrans Midstream Corporation 2200 Energy Drive Canonsburg, Pennsylvania 15317 CPF 1-2022-030-NOA Dear Mr. West: From October 13, 2020, through July 15, 2021, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Equitrans Midstream Corporation’s (ETRN) procedures for the Tepe, Finleyville, and Webster Underground Storage Fields in Pennsylvania. On the basis of the inspection, PHMSA has identified the apparent inadequacies found within ETRN’s plans or procedures, as described below: 1. § 192.12 Underground natural gas storage facilities. (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.#

12022030NOA_Notice of Amendment_03152022_(20-173105)_text.pdf, page 2CPF 1-2022-030-NOA ETRN’s written procedures for conducting operations, maintenance, and emergency preparedness and response activities were inadequate to ensure safe operation of a pipeline facility in accordance with § 192.12(c). Specifically, ETRN’s procedures failed to address third-party emergencies in accordance with API RP 1171, Section 10.6.1.1 During the inspection, PHMSA reviewed ETRN’ Emergency Response Plan (ERP) and found that it did not contain provisions for third-party emergencies that may impact storage operations. Third- party emergencies can include third-party owned/operated pipelines, wells, above-ground valve stations, regulating stations or other third-party owned facilities within the storage field that may threaten ETRN’s underground natural gas storage operations. Therefore, ETRN’s written procedures for conducting operations, maintenance, and emergency preparedness and response activities were inadequate to ensure safe operation of a pipeline facility in accordance with § 192.12(c). ETRN must revise its procedures to address this requirement. 2. § 192.12 Underground natural gas storage facilities. (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. ETRN’s written procedures for conducting operations, maintenance, and emergency preparedness and response activities were inadequate to ensure safe operation of a pipeline facility in accordance with § 192.12(c). Specifically, ETRN’s procedures failed to address how the effectiveness evaluation of the Emergency Response Plan is conducted and failed to include details on the required documentation of the effectiveness evaluation in accordance with API RP 1171, Section 11.4.2.2 Therefore, ETRN’s written procedures for conducting operations, maintenance, and emergency preparedness and response activities were inadequate to ensure safe operation of a pipeline facility in accordance with § 192.12(c). ETRN’s must revise its procedures to address this requirement. 1 API RP 1171, Section 10.6.1, Emergency Preparedness/Emergency Response Plan, states in part, “[f]or 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.” 2 API RP 1171, Section 11.4.2, Plan Effectiveness 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. 12022030NOA_Notice of Amendment_03152022_(20-173105)_text Page 2 of 3#

12022030NOA_Notice of Amendment_03152022_(20-173105)_text.pdf, page 3CPF 1-2022-030-NOA 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 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 ETRN 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 1-2022-030-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 12022030NOA_Notice of Amendment_03152022_(20-173105)_text Page 3 of 3#