{"operation":"document","citation":"CPF 12022080NOPSO","title":"EQUITRANS MIDSTREAM CORPORATION — Safety Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-12-29","effective_on":null,"summary":"CLOSED safety order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022080nopso.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022080nopso.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022080nopso","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022080NOPSO","body":"Safety Order involving EQUITRANS MIDSTREAM CORPORATION. The dataset does not identify a cited regulation for this case. The case was opened on 2022-12-29 and is reported as closed as of 2026-02-13. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022080NOPSO_Closure Letter_02132026_(22-259271).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022080NOPSO/12022080NOPSO_Closure%20Letter_02132026_(22-259271).pdf\n\n12022080NOPSO_Closure Letter_02132026_(22-259271)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022080NOPSO/12022080NOPSO_Closure%20Letter_02132026_(22-259271)_text.pdf\n\n12022080NOPSO_Consent Agreement and Order_05262023_(22-259271).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022080NOPSO/12022080NOPSO_Consent%20Agreement%20and%20Order_05262023_(22-259271).pdf\n\n12022080NOPSO_Consent Agreement and Order_05262023_(22-259271)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022080NOPSO/12022080NOPSO_Consent%20Agreement%20and%20Order_05262023_(22-259271)_text.pdf\n\n12022080NOPSO_Notice of Proposed Safety Order_12292022_(22-259271).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022080NOPSO/12022080NOPSO_Notice%20of%20Proposed%20Safety%20Order_12292022_(22-259271).pdf\n\n12022080NOPSO_Notice of Proposed Safety Order_12292022_(22-259271)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022080NOPSO/12022080NOPSO_Notice%20of%20Proposed%20Safety%20Order_12292022_(22-259271)_text.pdf\n\n12022080NOPSO_Consent Agreement and Order_05262023_(22-259271)_text.pdf\n\nMay 26, 2023\nVIA ELECTRONIC MAIL TO: rcooper@equitransmidstream.com\nRobert Cooper\nSenior Vice President, Construction Services\nEquitrans Midstream Corporation\n2200 Energy Drive\nCanonsburg, PA 15317\nCPF No. 1-2022-080-NOPSO\nDear Mr. Cooper:\nEnclosed please find a Consent Order incorporating the terms of the Consent Agreement between\nthe Pipeline and Hazardous Materials Safety Administration (PHMSA) and Equitrans Midstream\nCorporation, which was executed on May 25, 2023. Service of the Consent Order and Consent\nAgreement by electronic mail is deemed effective upon the date of transmission and\nacknowledgement of receipt, or as otherwise provided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosures: Consent Order and Consent Agreement\ncc: Mr. Robert Burrough, Director, Eastern Region, Office of Pipeline Safety, PHMSA\nMr. Matthew Eggerding, Deputy General Counsel, Environmental and Regulatory\nAffairs, Equitrans Midstream Corporation, meggerding@equitransmidstream.com\nMs. Brianne Kurdock, Outside Counsel for Equitrans Midstream Corporation,\nbkurdock@babstcalland.com\nCONFIRMATION OF RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\n)\nIn the Matter of )\n)\nEquitrans Midstream Corporation, ) CPF No. 1-2022-080-NOPSO\n)\nRespondent. )\n____________________________________)\nCONSENT ORDER\nBy letter dated December 29, 2022, the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety (OPS), issued a Notice of Proposed Safety Order (Notice) to\nEquitrans Midstream Corporation (Equitrans or Respondent).\nIn accordance with 49 C.F.R. § 190.239, the Notice alleged that conditions exist on\nRespondent’s Rager Mountain Storage Facility, an interstate underground natural gas storage\nfacility, that pose an integrity risk to public safety, property, or the environment. The Notice also\nproposed that Respondent take certain corrective measures to remedy the alleged conditions and\nensure that the public, property, and the environment are protected from the potential risk.\nIn response to the Notice, Respondent requested an informal consultation, whereupon the parties\nengaged in good-faith settlement discussions that have resulted in the Consent Agreement\nattached to this Consent Order that settles all of the allegations in the Notice.\nAccordingly, the Consent Agreement is hereby approved and incorporated by reference into this\nConsent Order. The Respondent is hereby ordered to comply with the terms of the Consent\nAgreement, effective immediately.\nPursuant to 49 U.S.C. § 60101, et seq., failure to comply with this Consent Order may result in\nthe assessment of civil penalties as set forth in 49 U.S.C. § 60122 and 49 C.F.R. § 190.223, or in\nreferral to the Attorney General for appropriate relief in a district court of the United States.\nThe terms and conditions of this Consent Order are effective upon service in accordance with\n49 C.F.R. § 190.5.\nMay 26, 2023\n______________________________ ______________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, DC 20590\n)\nIn the Matter of )\n)\nEquitrans Midstream Corporation, ) CPF No. 1-2022-080-NOPSO\n)\nRespondent. )\n)\nCONSENT AGREEMENT\nOn December 29, 2022, the Pipeline and Hazardous Materials Safety Administration (PHMSA),\nOffice of Pipeline Safety, Eastern Region issued a Notice of Proposed Safety Order (Notice) to\nEquitrans Midstream Corporation (Equitrans or Respondent). The Notice was issued after a\nreportable incident occurred on November 6, 2022, at Respondent’s Rager Mountain Storage\nFacility, an interstate underground natural gas storage facility (the Facility). The Facility includes\nten operating storage wells and two observation wells, and is connected via pipeline segments to\ninterstate gas transmission pipelines.\nOn November 6, 2022, Equitrans was notified that Well 2244 at the Facility was unintentionally\nventing natural gas to the atmosphere. Equitrans’s contractor, CUDD Pressure Control, Inc.\n(CUDD), responded to the scene. CUDD made multiple attempts to stop the venting by flooding\nthe well with fresh and brine water. On November 17, 2022, CUDD temporarily stopped the\nventing by flooding the well. On November 18, 2022, gas began flowing from the annulus. CUDD\nre-initiated dynamic kill activities and attempted to set a bridge plug. On November 19, 2022,\nCUDD set a plug at a depth of 5,875 feet. On November 20, 2022, CUDD set another plug at\n5,830 feet and had cement pumped into the well bore.\nAs a result of a preliminary investigation and in accordance with 49 C.F.R. § 190.239, PHMSA\nissued the Notice, which alleged that integrity risks to public safety, property, and the environment\nexisted at the Facility. PHMSA alleged that at the time the Notice was issued, the cause of the\nincident and the later venting of annulus gas from Wells 2248 and 2251 were unknown and it was\nnot clear whether other leaks were present at the Facility without a root cause analysis. The Notice\nproposed that Respondent take certain corrective measures, including retaining a third-party expert\nto conduct a root cause analysis, to remedy the alleged conditions and ensure that the public,\nproperty, and the environment are protected from the alleged integrity risks.\nOn January 16, 2023, Equitrans responded to the Notice requesting an informal consultation,\nwhereupon PHMSA and Respondent (the Parties) engaged in good-faith settlement discussions.\nInformal consultations were held virtually between February 16, 2023, and March 30, 2023. As a\n\n\n\nresult of the informal consultations, the Parties agreed that settlement of this proceeding will avoid\nfurther administrative proceedings or litigation of the Notice and that entry into this Consent\nAgreement (Agreement) is the most appropriate means of resolving the issues raised in the Notice.\nTherefore, without adjudication of any issue of fact or law, and upon consent and agreement of the\nParties, PHMSA and Equitrans agree to the terms and conditions set forth in this Agreement.\nI. General Provisions\n1. Respondent acknowledges that as the operator of the Facility, an interstate underground\nnatural gas storage facility, Respondent is subject to the jurisdiction of the Federal pipeline safety\nlaws, 49 U.S.C. § 60101, et seq., and the regulations and administrative orders issued thereunder.\nFor purposes of this Agreement, Respondent acknowledges that it received proper notice of\nPHMSA's action in this proceeding and that the Notice states claims upon which relief may be\ngranted pursuant to 49 U.S.C. 60101, et seq., and the regulations and orders issued thereunder.\n2. Respondent agrees, for the purposes of this Agreement, to address the alleged integrity\nrisks identified in the Notice by completing the actions specified in Section II of this Agreement\n(Corrective Measures) and to abide by the terms of this Agreement. This Agreement does not\nconstitute a finding of violation of any Federal law or regulation and may not be used in any civil\nor administrative proceeding of any kind as evidence or proof of any fact, fault, or liability, or as\nevidence of the violation of any law, rule, regulations, or requirement, except in a proceeding to\nenforce the provisions in the Agreement.\n3. After Respondent returns this signed Agreement to PHMSA, an agency representative will\npresent it to the Associate Administrator for Pipeline Safety recommending that the Associate\nAdministrator adopt the terms of this Agreement by issuing an administrative order (Consent\nOrder) incorporating the terms of this Agreement. The terms of this Agreement constitute an offer\nof settlement until accepted by the Associate Administrator. Once accepted, the Associate\nAdministrator will issue a Consent Order incorporating the terms of the Agreement.\n4. Respondent consents to the issuance of a Consent Order that is consistent with this\nAgreement, and hereby waives any further procedural requirements with respect to its issuance.\nRespondent waives all rights to contest the adequacy of notice, or the validity of the Consent Order\nor this Agreement, including all rights to administrative or judicial hearings or appeals in this case,\nexcept as set forth herein.\n5. This Agreement shall apply to and be binding upon PHMSA, and upon Respondent, its\nofficers, directors, and employees, and its successors, assigns, or other entities or persons\notherwise bound by law. Respondent agrees to provide a copy of this Agreement and any\nincorporated work plans and schedules to all of Respondent’s officers, employees, and agents\nwhose duties might reasonably include compliance with this Agreement.\n6. For all transfers of ownership or operating responsibility of the Facility, Respondent will\nprovide a copy of this Agreement to the prospective transferee at least 30 days prior to such transfer\nand provide written notice of the transfer within 30 days after the transfer to the PHMSA Eastern\nRegion Director.\n\n\n\n7. This Agreement constitutes the final, complete and exclusive agreement and understanding\nbetween the Parties with respect to the settlement embodied in this Agreement. The Parties\nacknowledge that there are no representations, agreements or understandings relating to settlement\nother than those expressly contained in this Agreement, except that the terms of this Agreement\nmay be construed by reference to the Notice.\n8. Nothing in this Agreement affects or relieves Respondent of its responsibility to comply\nwith all applicable requirements of the Federal pipeline safety laws, 49 U.S.C. § 60101, et seq.,\nand the regulations and orders issued thereunder. Nothing in this Agreement alters PHMSA’s right\nof access, entry, inspection, and information gathering or PHMSA's authority to bring enforcement\nactions against Respondent, pursuant to the Federal pipeline safety laws, the regulations and orders\nissued thereunder, or any other provision of Federal or State law.\n9. This Agreement does not waive or modify any Federal, State, or local laws or regulations\nthat are applicable to Respondent's underground natural gas storage facilities. This Agreement is\nnot a permit, or a modification of any permit, under any Federal, State, or local laws or regulations.\nRespondent remains responsible for achieving and maintaining compliance with all applicable\nFederal, State, and local laws, regulations and permits.\n10. This Agreement does not create rights in, or grant any cause of action to, any third party\nnot party to this Agreement. The U.S. Department of Transportation is not liable for any injuries\nor damages to persons or property arising from acts or omissions of Respondent or its officers,\nemployees, or agents carrying out the work required by this Agreement. Equitrans agrees to hold\nharmless the U.S. Department of Transportation, its officers, employees, agents, and\nrepresentatives from any and all causes of action arising from any acts or omissions of Respondent\nor its contractors in carrying out any work required by this Agreement.\n11. Upon issuance of the Consent Order, the Parties agree to the following terms.\nII. Corrective Measures\n12. Definitions.\nA. The “Director” means the Director, Eastern Region, Office of Pipeline Safety\n(OPS), PHMSA.\n“Effective Date” means the date the Consent Order was issued.\nThe “Facility” means Equitrans’s Rager Mountain Storage Facility.\nD. The “Incident” means the event reported in NRC Report #s 1351880 and 1352149\npursuant to 49 C.F.R. § 191.5, as well as the unexpected presence of annulus gas\nfrom Wells 2248 and 2251, or any other well at the Facility between November 6,\n2022, and the Effective Date.\nB. C.\n\n\n\n13. Root Cause Failure Analysis. Within 90 days of the Effective Date, Respondent must\ncomplete a root cause failure analysis (RCFA) examining the cause of the Incident. The RCFA\nmust also recommend corrective measures. Respondent must submit the RCFA to the Director.\nPHMSA has approved Equitrans’s selection of Blade Energy Partners as the third-party conducting\nthe RCFA on behalf of Equitrans.\nA. The RCFA must document the decision-making process and all factors contributing\nto the failures.\nB. The RCFA must include an analysis of the recent downhole inspections.\nC. The RCFA must analyze and document whether the findings and any lessons\nlearned are applicable to other locations within the Facility.\n14. Remedial Work Plan. Within 60 days after submission of the RCFA, Equitrans must\ndevelop and submit to the Director for approval a written Remedial Work Plan (RWP) that includes\ncorrective measures. The RWP can be submitted contemporaneous with the RCFA. The\nsubmitted RWP will be based on the relevant information available at that time. Equitrans will\nupdate the RWP with the information required below, as it becomes available, and will periodically\nresubmit the RWP to the Director until all required elements are complete. The Director may\napprove the RWP elements incrementally. Once approved, the RWP (including elements approved\nincrementally) shall become incorporated into this Agreement, including any revisions to the\nRWP. The RWP must include:\nA. A plan for completing inspections of Wells 2244, 2251, and 2248.\nB. A plan to inspect all other wells at the Facility for similar conditions and to\naddress any additional findings and associated repairs.\nC. A plan to address the final disposition of the temporary plugs in Wells 2244,\n2251, and 2248.\ni. The plan must consider the cause of the Incident, and describe\nwhether Equitrans will plug and abandon or reactivate Well 2244 for future use.\nii. The plan must consider the cause of annulus gas at Well 2251 and\ndescribe whether Equitrans will plug and abandon or reactivate Well 2251 for future\nuse.\niii. The plan must consider the cause of annulus gas at Well 2248 and\ndescribe whether Equitrans will plug and abandon or reactivate Well 2248 for future\nuse.\niv. The plan must include a list of all currently installed plugs at the\nFacility and their locations and Equitrans’s plan for their disposition.\n\n\n\nD. A plan to complete repairs and/or other corrective measures that may be\nneeded to address the alleged integrity risks listed in paragraph 3 on page 1 of this\nAgreement. This plan must also include provisions for continuing long-term and\nperiodic testing and integrity verification measures to ensure the ongoing safe\noperation of the Facility after injection resumes.\nE. Documentation of continuous, real time monitoring of annulus pressures at\nthe Facility (when the valves are closed).\nF. A proposed schedule for completion of the actions required by paragraphs (A),\n(B), (C), and (D) of this Item.\nG. The results of all inspections described in Paragraphs 14(A) and (B) must\nbe provided to the Director within 30 days of the inspection or the Effective Date,\nwhichever is later.\n15. Review of Records and Procedures. Equitrans must:\nA. Within 30 days of the Effective Date, conduct a review of the construction,\noperation, maintenance and integrity management records and procedures for\nthe Facility, make these records and procedures available for PHMSA’s\ninspection electronically or at a mutually acceptable date and location, and\nsubmit the analysis and findings from the records and procedures review to the\nDirector.\nB. Address any findings from the review that require remedial measures and\ncomplete any necessary procedural modifications prior to restarting injection.\nFindings that require remedial measures may be identified by either Equitrans\nor the Director (within 30 days of submission of the analysis).\n16. Assessment of Personnel Training. Within 30 days of the Effective Date, Equitrans must\nsubmit to the Director for review and approval an assessment of the training of operations,\nmaintenance, and supervisory personnel (to include Equitrans contractors) who perform work at\nthe Facility. This assessment must be performed by Blade Energy Partners. The Assessment must\ninclude a review of the training of the employees involved in the implementation of all applicable\nEmergency Response Plans.\n17.Injection Plan. Prior to injecting any gas into the Facility and resuming injection\noperations, Equitrans must submit a written Injection Plan to the Director for approval. The\nDirector may approve the Injection Plan incrementally without approving the entire plan, but\nEquitrans cannot begin injecting until the Injection Plan is approved in its entirety. The Injection\nPlan must include:\nA. The day-light hour schedule to begin the injection into the Facility including a plan\nfor providing advance communication to local emergency response officials and\nthe Director before beginning any injection.\n\n\n\nB. Documentation that verifies the submission of the obligations in Paragraph 13\n(RCFA), Paragraph 14 (RWP), Paragraph 15 (Review of Records and Procedures),\nand Paragraph 16 (Assessment of Personnel Training).\nC. Documentation of the real-time monitoring results at the Facility (See Paragraph\n14(E)).\nD. Documentation that Equitrans has implemented the corrective measures from its\nRWP necessary to provide a safe storage field operation and well integrity for the\nwells to be operated, as determined by the Director.\n18. Return to Full Operations. After the Director approves the Injection Plan, Equitrans\nmay inject gas into the Facility, but the operating pressure must not initially exceed\neighty percent (80%) of the actual operating pressure in effect immediately prior to the\nIncident.\nA. After reaching 80% of the actual operating pressure in effect at the time of\nthe Incident, Equitrans must complete a 7-day shut-in test to determine all storage\nwells used for injection, withdrawal, and/or observation are not leaking and are\notherwise safe to operate.\nB. Equitrans must submit the results of the shut-in test to the Director for\napproval prior to resuming operation at the Maximum Allowable Operating Pressure.\n19. Monthly Reports. Equitrans must submit monthly reports to the Director that: (1)\ndescribe the progress of the repairs and other long-term remedial actions being undertaken and (2)\nprovide the results of the inspections required by this Agreement (if not already provided through\ncompliance with Paragraph 14(G)). The first report is due 30 days from the Effective Date.\n20. Extensions of Time. The Director may grant an extension of time for compliance with\nany of the terms of the Agreement upon a written request timely submitted demonstrating good\ncause for an extension. The Director shall respond in writing to any such request within 30 days.\n21. Documentation of the Costs. It is requested but not mandated that Equitrans maintain\ndocumentation of the safety improvement costs associated with fulfilling this Agreement and\nsubmit the total to the Director. It is requested that these costs be reported in two categories: (1)\ntotal cost associated with preparation and revision of plans, procedures, studies, and analyses and\n(2) total cost associated with replacement, additions, or other changes to underground natural gas\nstorage infrastructure.\nIII. Review and Approval Process\n22. With respect to any submission under Section II (Corrective Measures) of this\nAgreement that requires the approval of the Director, the Director may: (a) approve, in whole or\nin part, the submission, (b) approve the submission on specified, reasonable conditions, (c)\n\n\n\ndisapprove, in whole or in part, the submission, or (d) any combination of the foregoing. If the\nDirector approves, approves in part, or approves with conditions, Equitrans will take all action as\napproved by the Director, subject to Respondent's right to invoke the dispute resolution procedures\nin Section IV. If the Director disapproves all or any portion of the submission, the Director will\nprovide Equitrans with a written notice of the deficiencies. Respondent will correct all deficiencies\nwithin the time specified by the Director and resubmit it for approval.\nIV. Dispute Resolution\n23. The Director and Equitrans will informally attempt to resolve any disputes arising under\nthis Agreement. If Respondent and the Director are unable to informally resolve the dispute within\n15 business days, Respondent may request in writing, within 10 days from the 15 business day\ndeadline, a written determination resolving the dispute from the Associate Administrator. The\nDirector and counsel for the Eastern Region should be copied on any such request. Along with its\nrequest, Respondent will provide all information that Respondent reasonably believes is relevant\nto the dispute. If the request is submitted as provided herein, the Associate Administrator will\nissue a final determination in writing. This determination will constitute final agency action. The\nexistence of a dispute and PHMSA's consideration of matters placed in dispute will not excuse,\ntoll, or suspend any term or timeframe for completion of any work to be performed under this\nAgreement during the pendency of the dispute resolution process except as agreed by the Director\nor the Associate Administrator in writing.\nV. Enforcement\n24. This Agreement is subject to all enforcement authorities available to PHMSA under 49\nU.S.C. § 60101, et seq., and 49 C.F.R. Part 190, including administrative civil penalties under 49\nU.S.C. § 60122, of up to $257,664 per violation for each day the violation continues and referral\nof the case to the Attorney General for judicial enforcement, if PHMSA determines that\nRespondent is not complying with the terms of this Agreement in accordance with the\ndeterminations made by the Director, or in accordance with decisions of the Associate\nAdministrator if resolved pursuant to the Dispute Resolution process herein. All work plans and\nassociated schedules set forth or referenced in Section II are automatically incorporated into this\nAgreement and are enforceable in the same manner.\nVI. Recordkeeping and Information Disclosure\n25. Unless otherwise required in this Agreement or the pipeline safety regulations, Equitrans\nagrees to maintain records demonstrating compliance with all requirements of this Agreement for\na period of at least five years following completion of all work to be performed. For any reports,\nplans, or other deliverables required to be submitted to PHMSA pursuant to this Agreement,\nEquitrans may assert a claim of business confidentiality or other protections applicable to the\nrelease of information by PHMSA, covering part or all of the information required to be submitted\nto PHMSA pursuant to this Agreement in accordance with 49 C.F.R. Part 7. Equitrans must mark\nthe claim of confidentiality in writing on each page, and include a statement specifying the grounds\n\n\n\nfor each claim of confidentially. PHMSA determines release of any information submitted\npursuant to this Agreement in accordance with 49 C.F.R. Part 7, the Freedom of Information Act,\n5 U.S.C. § 552, DOT and PHMSA policies, and other applicable regulations and Executive Orders.\nVII. Effective Date\n26. The term \"Effective Date,\" as used herein, is the date on which the Consent Order is\nissued by the Associate Administrator incorporating the terms of this Agreement. Unless specified\nto the contrary, all deadlines for actions required by this Agreement run from the Effective Date\nof the Consent Order. Nothing in this Agreement prevents Equitrans from completing any of the\nobligations earlier than the deadlines provided for in this Agreement.\nVIII. Modification\n27. The terms of this Agreement may be modified by mutual agreement of the Parties. Such\nmodifications must be in writing and signed by both parties.\nIX. Termination\n28. This Agreement shall remain in effect until the Corrective Measures set forth in Section\nII are satisfied, as determined by the Director.\nX. Ratification\n29. The Parties' undersigned representatives certify that they are fully authorized to enter\ninto the terms and conditions of this Agreement and to execute and legally bind such party to this\ndocument.\n30. The Parties hereby agree to all conditions and terms of this Agreement.\n\n\n\nFor Respondent:\n___________________________________\nRobert Cooper\nSenior Vice President, Construction Services\nEquitrans Midstream Corporation\n___________________________________\nDate\nFor PHMSA:\n___________________________________\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\n___________________________________\nDate\n\n12022080NOPSO_Notice of Proposed Safety Order_12292022_(22-259271)_text.pdf\n\nVIA ELECTRONIC MAIL TO: cbaker@equitransmidstream.com\nDecember 29, 2022\nClifford Baker\nSenior Vice President, Commercial Development & Operations\nEquitrans Midstream Corporation\n2200 Energy Drive\nCanonsburg, PA 15317\nCPF 1-2022-080-NOPSO\nDear Mr. Baker:\nEnclosed is a Notice of Proposed Safety Order (Notice) issued in the above-referenced case. The\nNotice proposes that you take certain measures with respect to your Rager Mountain underground\nnatural gas storage facility and wells to ensure safety. Your options for responding are set forth in\nthe Notice. Your receipt of the Notice constitutes service of that document under 49 C.F.R. §\n190.5.\nWe look forward to a successful resolution to ensure pipeline safety. Please direct any questions\non this matter to me at 609-771-7809.\nSincerely,\nRobert Burrough, Director, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosures: Notice of Proposed Safety Order\n49 C.F.R. § 190.239\nCc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, Office of\nPipeline Safety <linda.daugherty@dot.gov>\nMr. Jake Lyons, Manager Pipeline Safety and Compliance, Equitrans Midstream\nCorporation <jlyons@equitransmidstream.com>\nCONFIRMATION OF RECEIPT REQUESTED\n\n\n\nDEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nEASTERN REGION\nWEST TRENTON, NJ 08628\n__________________________________________\n)\nIn the Matter of )\n)\nEquitrans Midstream Corporation, ) CPF No. 1-2022-080-NOPSO\n)\nRespondent. )\n__________________________________________)\nNOTICE OF PROPOSED SAFETY ORDER\nBackground and Purpose\nPursuant to Chapter 601 of title 49, United States Code, the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) has initiated an investigation and review of the safety of\nEquitrans Midstream Corporation’s (ETRN) Rager Mountain Storage (RMS) Facility after\nNovember 2022 failure incidents resulting in the leak of a large amount of natural gas.\nAs a result of PHMSA’s preliminary investigation, it appears that a condition or conditions exist\nat your RMS Facility that poses a pipeline integrity risk to public safety, property, or the\nenvironment.\nPursuant to 49 U.S.C. § 60117(m), PHMSA issues this Notice of Proposed Safety Order (Notice)\nnotifying you of the preliminary findings of the investigation, and proposing that you take\nmeasures to ensure that the public, property, and the environment are protected from the potential\nrisk.\nPreliminary Findings\n• ETRN owns and operates an interstate natural gas transportation system spanning\nseveral states. ETRN’s system includes the RMS Facility located in Cambria County,\nPennsylvania. The RMS Facility is an underground natural gas storage facility\n(UNGSF; see 49 C.F.R. § 192.3) which includes ten operating storage wells and two\nobservation wells, and is connected via pipeline segments to interstate gas transmission\npipelines. The RMS Facility is an interstate gas pipeline facility subject to the Federal\n\n\n\nPipeline Safety Regulations.\n1 This facility is located within a Pennsylvania state park,\nin a remote area.\n• On November 6, 2022, ETRN was notified that Well 22442 (also known as the George\nL. Reade No. 1 Well) at the RMS Facility was unintentionally venting natural gas (the\nIncident) to the atmosphere through a 1 5/8-inch vent located on the annulus of the well\nat a pressure of approximately 1,300 pounds per square inch gauge (psig).\n• ETRN reported the Incident to the National Response Center (NRC) on November 6,\n2022.\n3 ETRN’s contractor, Wild Well Control, indicated it would be unable to arrive\nat the RMS Facility until Tuesday, November 8, 2022. Another contractor, CUDD\nWell Services (CUDD), was in the area and responded to the Incident on Monday,\nNovember 7, 2022. Beginning on November 10, 2022, CUDD made multiple attempts\nto stop the leak by flooding the well with either fresh water or varying salinities of brine\nwater. These attempts to stop the leak were unsuccessful.\n• On November 19, 2022, CUDD temporarily stopped the leak of gas out of the vent of\nWell 2244 by successfully setting a temporary bridge plug in the well bore. This was\nCUDD’s second attempt to set a plug to stop the leak. The first attempt failed due to\na mechanical failure. This secondary plug was set at a depth of 5,875 feet and a\ntertiary plug was set at 5,830 feet. On November 20, 2022, ETRN had cement\npumped into the well bore.\n• ETRN estimates that Well 2244 vented over one billion cubic feet (BCF) of natural\ngas to the atmosphere before the leak was halted on November 19, 2022.\n• During the Incident, based on PHMSA’s observations at the site, it appears that ETRN\ndid not review its up-to-date schematics of Well 2244 before attempting to stop the\nleak. ETRN and Cudd also did not follow all of the procedures in the facility’s “Storage\nWell Emergency Response Plan”. The failure to follow all of the \"Storage Well\nEmergency Response Plan\" procedures may have been a factor contributing to the\ndelay in stopping the leak. The initial attempt to temporarily plug the well failed due to\nthe plug being stuck on an obstruction not previously identified by ETRN prior to\ninitiating repairs.\n1 ETRN Underground Natural Gas Storage Facility Annual Report for Calendar Year 2021 (OMB No. 2137-0522)\n(submitted Mar. 14, 2022).\n2 The production string well tubulars for Well 2244 were constructed in 1965 (1,875 feet) and 1993 (5,950 feet),\nrespectively. The tubulars from both years were 7-inch, N-80, 26 pounds per square foot, and cemented partially.\nThe cement is present from the bottom of the well to a depth of 2,940 feet. From the depth of approximately 10 feet\nto 2,940 feet, a gel was installed to fill the void. The maximum allowable operating pressure (MAOP) of the\nunderground natural gas storage facility is 3,200 psig. Gas is stored in well composed of Oriskany sandstone\nlocated at a minimum depth of 7,601 feet to a maximum depth of 8,060 feet, per ETRN’s annual report.\n3 NRC Report No. 1351880.\n\n\n\n• On November 22, 2022, it was discovered another well in the RMS Facility, Well 2251\n(also known as the Peoples Natural Gas No. 1 Well), which previously did not have\nany flow out of its annulus, was flowing gas at a rate of seven percent gas in air, which\nis above the Lower Explosive Limit (LEL) for natural gas. Well 2251 was temporarily\nplugged on December 7, and later an additional well, Well 2248, was also temporarily\nplugged after a leak was discovered. These additional events may be an indication that\nsome of the escaping natural gas that was exposed to the annulus in Well 2244 and\nvented to the atmosphere may have leaked to additional formations. This may also\nindicate there is an additional casing integrity issue.\n• To date, the exact causes of the casing failure in Well 2244 and leaks during the\nIncident and at Wells 2251 and 2248, are unknown. It is also presently unknown if\nthe natural gas leak from Well 2244 has affected other portions of the RMS Facility,\nincluding Wells 2251 and 2248. At present, PHMSA is gathering additional data\nregarding the Incident and the leaks at the additional wells and is continuing its\ninvestigation. ETRN has reported that is it not presently injecting natural gas into the\nRMS Facility. Further, the Commonwealth of Pennsylvania’s Department of\nEnvironmental Protection has alerted PHMSA to other alleged natural gas leaks and\npotential integrity issues within the RMS Facility at present.4\nProposed Issuance of Safety Order\nSection 60117(m) of Title 49, United States Code, provides for the issuance of a safety order, after\nreasonable notice and the opportunity for a hearing, requiring corrective measures, which may\ninclude physical inspection, testing, repair, or other action, as appropriate. The basis for making\nthe determination that a pipeline facility, including an underground natural gas storage facility, has\na condition or conditions that pose a pipeline integrity risk to public safety, property, or the\nenvironment is set forth both in the above-referenced statute and 49 C.F.R. § 190.239, a copy of\nwhich is enclosed.\nAfter evaluating the foregoing preliminary findings of fact, and based on: (1) The amount of\nnatural gas stored in the RMS Facility; (2) The amount of natural gas vented to the atmosphere\nduring the Incident that was discovered beginning on November 6, 2022; (3) The failed well casing\ninvolved; (4) The hazardous nature to persons and the environment of the product stored and\ntransported; (5) The operating pressures at this UNGSF; and, (6) The presently unknown aspects\nregarding the cause of the three leaks, including whether other leaks are present and if unknown\nadditional impacts are occurring to the RMS Facility, any injection into affected Well 2244 and\nthe other wells at the RMS Facility, without a root cause analysis and corresponding corrective\nmeasures, would pose a risk to public safety, property, and the environment.\nAccordingly, PHMSA issues this Notice to notify Respondent of the proposed issuance of a safety\norder and to propose that Respondent take measures specified herein to address the potential risks.\n4 See https://www.ahs.dep.pa.gov/NewsRoomPublic/articleviewer.aspx?id=22235&typeid=1.\n\n\n\nProposed Corrective Measures\nPursuant to 49 U.S.C. § 60117(m) and 49 C.F.R. § 190.239, PHMSA proposes to issue to ETRN\na safety order incorporating the following remedial requirements with respect to the affected\npipeline:\n1. Definitions. For the purpose of this Notice the following terms are defined as:\n(A) “Director” is the Director, Eastern Region, Office of Pipeline Safety\n(OPS), Pipeline and Hazardous Materials Safety Administration\n(PHMSA)\n(B) “Effective Date” is the date a safety order is issued.\n2. Root Cause Failure Analysis. Within 90 days after the Effective Date, ETRN must\ncomplete a root cause failure analysis (RCFA) regarding the cause of the leaks that were\ndiscovered beginning on November 6, 2022 (applicable to the Incident and the two\nadditional leaks) and submit a final RCFA to the Director.\n(A) The RCFA must be facilitated by an independent third-party acceptable\nto the Director and must document the decision-making process and all\nfactors contributing to the failures. ETRN shall submit a proposed third-\nparty for the Director’s approval within 30 days of the Effective Date.\n(B) The final RCFA must include findings and any lessons learned. The\nRCFA must also analyze and document whether the findings and any\nlessons learned are applicable to other locations within ETRN’s RMS\nFacility.\n3. Remedial Work Plan. Within 60 days after submitting the RCFA, ETRN must develop\nand submit to the Director for approval a written Remedial Work Plan (RWP) that includes\ncorrective measures. The Director may approve the RWP elements incrementally. Once\napproved, the RWP shall become incorporated into the safety order, including any\nrevisions to the RWP. The RWP must include:\n(A) A plan for completing inspections of Wells 2244, 2251, and 2248 within\n60 days of the RWP. The results of all inspections, field reviews, and\nevaluations must be provided to the Director within 30 days of the\ninspections.\n(B) A plan to inspect all other wells at the UNGSF for similar conditions\nand to address any additional findings/leaks and the repairs.\n(C) A plan to address the final disposition of the temporary plugs in Wells\n2244 2251, and 2248. The plan must consider the cause of the leaks\nand describe whether ETRN will Plug and Abandon (P&A) or reactivate\n\n\n\nthe wells for future use. The RWP must include a list of all plugs and\ntheir locations and ETRN’s plan as to their disposition.\n(D) A plan for the performance of repairs or other corrective measures that\nfully remediate the identified risk condition(s) within 30 days of\ncorrective action. The plan must include provisions for continuing long-\nterm, periodic testing and integrity verification measures to ensure the\nongoing safe operation of the pipeline considering the results of the\nanalyses, inspections, and corrective measures undertaken pursuant to\nthe safety order;\n(E) A proposed schedule for completion of the actions required by\nparagraphs (A), (B), (C), and (D) of this Item.\n4. Review of Records and Procedures. Within 30 days of the Effective Date, ETRN must:\n(A) Conduct a review of construction, operating and maintenance (O&M)\nand integrity management records, such as Magnetic FluxLeakage\n(MFL) logs, Gamma Ray Neutron (GRN) logs, Mechanical Integrity\n(MIT), root cause failure analysis of prior failures, and aerial and ground\npatrols for the RMS Facility.\n(B) Submit the analysis and findings from that review to the Director and\naddress any findings that require remedial measures to be implemented\nprior to restarting injection. ETRN must also amend procedures as\nnecessary. All procedural modifications must be incorporated into\nETRN’s operations and maintenance procedures manual and submitted\nto the Director for approval.\n5. Injection Plan. Prior to injecting any gas into the RMS Facility and/or resuming normal\noperations, ETRN must first develop and submit a written Injection Plan to the Director\nfor approval. The Director may approve the Injection Plan incrementally without approving\nthe entire plan, but ETRN cannot begin injecting until the Injection Plan is approved in its\nentirety. Once approved by the Director, the Injection Plan will be incorporated by\nreference into the safety order. The Injection Plan must include:\n(A) The day-light hour schedule to begin the injection into the RMS Facility,\nincluding a plan for providing ad","truncated":true,"body_characters":48253}