# EQUITRANS MIDSTREAM CORPORATION — Safety Order

- **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:** Not available
- **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.

Official case documents:

12022080NOPSO_Closure Letter_02132026_(22-259271).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022080NOPSO/12022080NOPSO_Closure%20Letter_02132026_(22-259271).pdf

12022080NOPSO_Closure Letter_02132026_(22-259271)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022080NOPSO/12022080NOPSO_Closure%20Letter_02132026_(22-259271)_text.pdf

12022080NOPSO_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

12022080NOPSO_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

12022080NOPSO_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

12022080NOPSO_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

12022080NOPSO_Consent Agreement and Order_05262023_(22-259271)_text.pdf

May 26, 2023
VIA ELECTRONIC MAIL TO: rcooper@equitransmidstream.com
Robert Cooper
Senior Vice President, Construction Services
Equitrans Midstream Corporation
2200 Energy Drive
Canonsburg, PA 15317
CPF No. 1-2022-080-NOPSO
Dear Mr. Cooper:
Enclosed please find a Consent Order incorporating the terms of the Consent Agreement between
the Pipeline and Hazardous Materials Safety Administration (PHMSA) and Equitrans Midstream
Corporation, which was executed on May 25, 2023. Service of the Consent Order and Consent
Agreement by electronic mail is deemed effective upon the date of transmission and
acknowledgement of receipt, or as otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosures: Consent Order and Consent Agreement
cc: Mr. Robert Burrough, Director, Eastern Region, Office of Pipeline Safety, PHMSA
Mr. Matthew Eggerding, Deputy General Counsel, Environmental and Regulatory
Affairs, Equitrans Midstream Corporation, meggerding@equitransmidstream.com
Ms. Brianne Kurdock, Outside Counsel for Equitrans Midstream Corporation,
bkurdock@babstcalland.com
CONFIRMATION OF RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
)
In the Matter of )
)
Equitrans Midstream Corporation, ) CPF No. 1-2022-080-NOPSO
)
Respondent. )
____________________________________)
CONSENT ORDER
By letter dated December 29, 2022, the Pipeline and Hazardous Materials Safety Administration
(PHMSA), Office of Pipeline Safety (OPS), issued a Notice of Proposed Safety Order (Notice) to
Equitrans Midstream Corporation (Equitrans or Respondent).
In accordance with 49 C.F.R. § 190.239, the Notice alleged that conditions exist on
Respondent’s Rager Mountain Storage Facility, an interstate underground natural gas storage
facility, that pose an integrity risk to public safety, property, or the environment. The Notice also
proposed that Respondent take certain corrective measures to remedy the alleged conditions and
ensure that the public, property, and the environment are protected from the potential risk.
In response to the Notice, Respondent requested an informal consultation, whereupon the parties
engaged in good-faith settlement discussions that have resulted in the Consent Agreement
attached to this Consent Order that settles all of the allegations in the Notice.
Accordingly, the Consent Agreement is hereby approved and incorporated by reference into this
Consent Order. The Respondent is hereby ordered to comply with the terms of the Consent
Agreement, effective immediately.
Pursuant to 49 U.S.C. § 60101, et seq., failure to comply with this Consent Order may result in
the assessment of civil penalties as set forth in 49 U.S.C. § 60122 and 49 C.F.R. § 190.223, or in
referral to the Attorney General for appropriate relief in a district court of the United States.
The terms and conditions of this Consent Order are effective upon service in accordance with
49 C.F.R. § 190.5.
May 26, 2023
______________________________ ______________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, DC 20590
)
In the Matter of )
)
Equitrans Midstream Corporation, ) CPF No. 1-2022-080-NOPSO
)
Respondent. )
)
CONSENT AGREEMENT
On December 29, 2022, the Pipeline and Hazardous Materials Safety Administration (PHMSA),
Office of Pipeline Safety, Eastern Region issued a Notice of Proposed Safety Order (Notice) to
Equitrans Midstream Corporation (Equitrans or Respondent). The Notice was issued after a
reportable incident occurred on November 6, 2022, at Respondent’s Rager Mountain Storage
Facility, an interstate underground natural gas storage facility (the Facility). The Facility includes
ten operating storage wells and two observation wells, and is connected via pipeline segments to
interstate gas transmission pipelines.
On November 6, 2022, Equitrans was notified that Well 2244 at the Facility was unintentionally
venting natural gas to the atmosphere. Equitrans’s contractor, CUDD Pressure Control, Inc.
(CUDD), responded to the scene. CUDD made multiple attempts to stop the venting by flooding
the well with fresh and brine water. On November 17, 2022, CUDD temporarily stopped the
venting by flooding the well. On November 18, 2022, gas began flowing from the annulus. CUDD
re-initiated dynamic kill activities and attempted to set a bridge plug. On November 19, 2022,
CUDD set a plug at a depth of 5,875 feet. On November 20, 2022, CUDD set another plug at
5,830 feet and had cement pumped into the well bore.
As a result of a preliminary investigation and in accordance with 49 C.F.R. § 190.239, PHMSA
issued the Notice, which alleged that integrity risks to public safety, property, and the environment
existed at the Facility. PHMSA alleged that at the time the Notice was issued, the cause of the
incident and the later venting of annulus gas from Wells 2248 and 2251 were unknown and it was
not clear whether other leaks were present at the Facility without a root cause analysis. The Notice
proposed that Respondent take certain corrective measures, including retaining a third-party expert
to conduct a root cause analysis, to remedy the alleged conditions and ensure that the public,
property, and the environment are protected from the alleged integrity risks.
On January 16, 2023, Equitrans responded to the Notice requesting an informal consultation,
whereupon PHMSA and Respondent (the Parties) engaged in good-faith settlement discussions.
Informal consultations were held virtually between February 16, 2023, and March 30, 2023. As a



result of the informal consultations, the Parties agreed that settlement of this proceeding will avoid
further administrative proceedings or litigation of the Notice and that entry into this Consent
Agreement (Agreement) is the most appropriate means of resolving the issues raised in the Notice.
Therefore, without adjudication of any issue of fact or law, and upon consent and agreement of the
Parties, PHMSA and Equitrans agree to the terms and conditions set forth in this Agreement.
I. General Provisions
1. Respondent acknowledges that as the operator of the Facility, an interstate underground
natural gas storage facility, Respondent is subject to the jurisdiction of the Federal pipeline safety
laws, 49 U.S.C. § 60101, et seq., and the regulations and administrative orders issued thereunder.
For purposes of this Agreement, Respondent acknowledges that it received proper notice of
PHMSA's action in this proceeding and that the Notice states claims upon which relief may be
granted pursuant to 49 U.S.C. 60101, et seq., and the regulations and orders issued thereunder.
2. Respondent agrees, for the purposes of this Agreement, to address the alleged integrity
risks identified in the Notice by completing the actions specified in Section II of this Agreement
(Corrective Measures) and to abide by the terms of this Agreement. This Agreement does not
constitute a finding of violation of any Federal law or regulation and may not be used in any civil
or administrative proceeding of any kind as evidence or proof of any fact, fault, or liability, or as
evidence of the violation of any law, rule, regulations, or requirement, except in a proceeding to
enforce the provisions in the Agreement.
3. After Respondent returns this signed Agreement to PHMSA, an agency representative will
present it to the Associate Administrator for Pipeline Safety recommending that the Associate
Administrator adopt the terms of this Agreement by issuing an administrative order (Consent
Order) incorporating the terms of this Agreement. The terms of this Agreement constitute an offer
of settlement until accepted by the Associate Administrator. Once accepted, the Associate
Administrator will issue a Consent Order incorporating the terms of the Agreement.
4. Respondent consents to the issuance of a Consent Order that is consistent with this
Agreement, and hereby waives any further procedural requirements with respect to its issuance.
Respondent waives all rights to contest the adequacy of notice, or the validity of the Consent Order
or this Agreement, including all rights to administrative or judicial hearings or appeals in this case,
except as set forth herein.
5. This Agreement shall apply to and be binding upon PHMSA, and upon Respondent, its
officers, directors, and employees, and its successors, assigns, or other entities or persons
otherwise bound by law. Respondent agrees to provide a copy of this Agreement and any
incorporated work plans and schedules to all of Respondent’s officers, employees, and agents
whose duties might reasonably include compliance with this Agreement.
6. For all transfers of ownership or operating responsibility of the Facility, Respondent will
provide a copy of this Agreement to the prospective transferee at least 30 days prior to such transfer
and provide written notice of the transfer within 30 days after the transfer to the PHMSA Eastern
Region Director.



7. This Agreement constitutes the final, complete and exclusive agreement and understanding
between the Parties with respect to the settlement embodied in this Agreement. The Parties
acknowledge that there are no representations, agreements or understandings relating to settlement
other than those expressly contained in this Agreement, except that the terms of this Agreement
may be construed by reference to the Notice.
8. Nothing in this Agreement affects or relieves Respondent of its responsibility to comply
with all applicable requirements of the Federal pipeline safety laws, 49 U.S.C. § 60101, et seq.,
and the regulations and orders issued thereunder. Nothing in this Agreement alters PHMSA’s right
of access, entry, inspection, and information gathering or PHMSA's authority to bring enforcement
actions against Respondent, pursuant to the Federal pipeline safety laws, the regulations and orders
issued thereunder, or any other provision of Federal or State law.
9. This Agreement does not waive or modify any Federal, State, or local laws or regulations
that are applicable to Respondent's underground natural gas storage facilities. This Agreement is
not a permit, or a modification of any permit, under any Federal, State, or local laws or regulations.
Respondent remains responsible for achieving and maintaining compliance with all applicable
Federal, State, and local laws, regulations and permits.
10. This Agreement does not create rights in, or grant any cause of action to, any third party
not party to this Agreement. The U.S. Department of Transportation is not liable for any injuries
or damages to persons or property arising from acts or omissions of Respondent or its officers,
employees, or agents carrying out the work required by this Agreement. Equitrans agrees to hold
harmless the U.S. Department of Transportation, its officers, employees, agents, and
representatives from any and all causes of action arising from any acts or omissions of Respondent
or its contractors in carrying out any work required by this Agreement.
11. Upon issuance of the Consent Order, the Parties agree to the following terms.
II. Corrective Measures
12. Definitions.
A. The “Director” means the Director, Eastern Region, Office of Pipeline Safety
(OPS), PHMSA.
“Effective Date” means the date the Consent Order was issued.
The “Facility” means Equitrans’s Rager Mountain Storage Facility.
D. The “Incident” means the event reported in NRC Report #s 1351880 and 1352149
pursuant to 49 C.F.R. § 191.5, as well as the unexpected presence of annulus gas
from Wells 2248 and 2251, or any other well at the Facility between November 6,
2022, and the Effective Date.
B. C.



13. Root Cause Failure Analysis. Within 90 days of the Effective Date, Respondent must
complete a root cause failure analysis (RCFA) examining the cause of the Incident. The RCFA
must also recommend corrective measures. Respondent must submit the RCFA to the Director.
PHMSA has approved Equitrans’s selection of Blade Energy Partners as the third-party conducting
the RCFA on behalf of Equitrans.
A. The RCFA must document the decision-making process and all factors contributing
to the failures.
B. The RCFA must include an analysis of the recent downhole inspections.
C. The RCFA must analyze and document whether the findings and any lessons
learned are applicable to other locations within the Facility.
14. Remedial Work Plan. Within 60 days after submission of the RCFA, Equitrans must
develop and submit to the Director for approval a written Remedial Work Plan (RWP) that includes
corrective measures. The RWP can be submitted contemporaneous with the RCFA. The
submitted RWP will be based on the relevant information available at that time. Equitrans will
update the RWP with the information required below, as it becomes available, and will periodically
resubmit the RWP to the Director until all required elements are complete. The Director may
approve the RWP elements incrementally. Once approved, the RWP (including elements approved
incrementally) shall become incorporated into this Agreement, including any revisions to the
RWP. The RWP must include:
A. A plan for completing inspections of Wells 2244, 2251, and 2248.
B. A plan to inspect all other wells at the Facility for similar conditions and to
address any additional findings and associated repairs.
C. A plan to address the final disposition of the temporary plugs in Wells 2244,
2251, and 2248.
i. The plan must consider the cause of the Incident, and describe
whether Equitrans will plug and abandon or reactivate Well 2244 for future use.
ii. The plan must consider the cause of annulus gas at Well 2251 and
describe whether Equitrans will plug and abandon or reactivate Well 2251 for future
use.
iii. The plan must consider the cause of annulus gas at Well 2248 and
describe whether Equitrans will plug and abandon or reactivate Well 2248 for future
use.
iv. The plan must include a list of all currently installed plugs at the
Facility and their locations and Equitrans’s plan for their disposition.



D. A plan to complete repairs and/or other corrective measures that may be
needed to address the alleged integrity risks listed in paragraph 3 on page 1 of this
Agreement. This plan must also include provisions for continuing long-term and
periodic testing and integrity verification measures to ensure the ongoing safe
operation of the Facility after injection resumes.
E. Documentation of continuous, real time monitoring of annulus pressures at
the Facility (when the valves are closed).
F. A proposed schedule for completion of the actions required by paragraphs (A),
(B), (C), and (D) of this Item.
G. The results of all inspections described in Paragraphs 14(A) and (B) must
be provided to the Director within 30 days of the inspection or the Effective Date,
whichever is later.
15. Review of Records and Procedures. Equitrans must:
A. Within 30 days of the Effective Date, conduct a review of the construction,
operation, maintenance and integrity management records and procedures for
the Facility, make these records and procedures available for PHMSA’s
inspection electronically or at a mutually acceptable date and location, and
submit the analysis and findings from the records and procedures review to the
Director.
B. Address any findings from the review that require remedial measures and
complete any necessary procedural modifications prior to restarting injection.
Findings that require remedial measures may be identified by either Equitrans
or the Director (within 30 days of submission of the analysis).
16. Assessment of Personnel Training. Within 30 days of the Effective Date, Equitrans must
submit to the Director for review and approval an assessment of the training of operations,
maintenance, and supervisory personnel (to include Equitrans contractors) who perform work at
the Facility. This assessment must be performed by Blade Energy Partners. The Assessment must
include a review of the training of the employees involved in the implementation of all applicable
Emergency Response Plans.
17.Injection Plan. Prior to injecting any gas into the Facility and resuming injection
operations, Equitrans must submit a written Injection Plan to the Director for approval. The
Director may approve the Injection Plan incrementally without approving the entire plan, but
Equitrans cannot begin injecting until the Injection Plan is approved in its entirety. The Injection
Plan must include:
A. The day-light hour schedule to begin the injection into the Facility including a plan
for providing advance communication to local emergency response officials and
the Director before beginning any injection.



B. Documentation that verifies the submission of the obligations in Paragraph 13
(RCFA), Paragraph 14 (RWP), Paragraph 15 (Review of Records and Procedures),
and Paragraph 16 (Assessment of Personnel Training).
C. Documentation of the real-time monitoring results at the Facility (See Paragraph
14(E)).
D. Documentation that Equitrans has implemented the corrective measures from its
RWP necessary to provide a safe storage field operation and well integrity for the
wells to be operated, as determined by the Director.
18. Return to Full Operations. After the Director approves the Injection Plan, Equitrans
may inject gas into the Facility, but the operating pressure must not initially exceed
eighty percent (80%) of the actual operating pressure in effect immediately prior to the
Incident.
A. After reaching 80% of the actual operating pressure in effect at the time of
the Incident, Equitrans must complete a 7-day shut-in test to determine all storage
wells used for injection, withdrawal, and/or observation are not leaking and are
otherwise safe to operate.
B. Equitrans must submit the results of the shut-in test to the Director for
approval prior to resuming operation at the Maximum Allowable Operating Pressure.
19. Monthly Reports. Equitrans must submit monthly reports to the Director that: (1)
describe the progress of the repairs and other long-term remedial actions being undertaken and (2)
provide the results of the inspections required by this Agreement (if not already provided through
compliance with Paragraph 14(G)). The first report is due 30 days from the Effective Date.
20. Extensions of Time. The Director may grant an extension of time for compliance with
any of the terms of the Agreement upon a written request timely submitted demonstrating good
cause for an extension. The Director shall respond in writing to any such request within 30 days.
21. Documentation of the Costs. It is requested but not mandated that Equitrans maintain
documentation of the safety improvement costs associated with fulfilling this Agreement and
submit the total to the Director. It is requested that these costs be reported in two categories: (1)
total cost associated with preparation and revision of plans, procedures, studies, and analyses and
(2) total cost associated with replacement, additions, or other changes to underground natural gas
storage infrastructure.
III. Review and Approval Process
22. With respect to any submission under Section II (Corrective Measures) of this
Agreement that requires the approval of the Director, the Director may: (a) approve, in whole or
in part, the submission, (b) approve the submission on specified, reasonable conditions, (c)



disapprove, in whole or in part, the submission, or (d) any combination of the foregoing. If the
Director approves, approves in part, or approves with conditions, Equitrans will take all action as
approved by the Director, subject to Respondent's right to invoke the dispute resolution procedures
in Section IV. If the Director disapproves all or any portion of the submission, the Director will
provide Equitrans with a written notice of the deficiencies. Respondent will correct all deficiencies
within the time specified by the Director and resubmit it for approval.
IV. Dispute Resolution
23. The Director and Equitrans will informally attempt to resolve any disputes arising under
this Agreement. If Respondent and the Director are unable to informally resolve the dispute within
15 business days, Respondent may request in writing, within 10 days from the 15 business day
deadline, a written determination resolving the dispute from the Associate Administrator. The
Director and counsel for the Eastern Region should be copied on any such request. Along with its
request, Respondent will provide all information that Respondent reasonably believes is relevant
to the dispute. If the request is submitted as provided herein, the Associate Administrator will
issue a final determination in writing. This determination will constitute final agency action. The
existence of a dispute and PHMSA's consideration of matters placed in dispute will not excuse,
toll, or suspend any term or timeframe for completion of any work to be performed under this
Agreement during the pendency of the dispute resolution process except as agreed by the Director
or the Associate Administrator in writing.
V. Enforcement
24. This Agreement is subject to all enforcement authorities available to PHMSA under 49
U.S.C. § 60101, et seq., and 49 C.F.R. Part 190, including administrative civil penalties under 49
U.S.C. § 60122, of up to $257,664 per violation for each day the violation continues and referral
of the case to the Attorney General for judicial enforcement, if PHMSA determines that
Respondent is not complying with the terms of this Agreement in accordance with the
determinations made by the Director, or in accordance with decisions of the Associate
Administrator if resolved pursuant to the Dispute Resolution process herein. All work plans and
associated schedules set forth or referenced in Section II are automatically incorporated into this
Agreement and are enforceable in the same manner.
VI. Recordkeeping and Information Disclosure
25. Unless otherwise required in this Agreement or the pipeline safety regulations, Equitrans
agrees to maintain records demonstrating compliance with all requirements of this Agreement for
a period of at least five years following completion of all work to be performed. For any reports,
plans, or other deliverables required to be submitted to PHMSA pursuant to this Agreement,
Equitrans may assert a claim of business confidentiality or other protections applicable to the
release of information by PHMSA, covering part or all of the information required to be submitted
to PHMSA pursuant to this Agreement in accordance with 49 C.F.R. Part 7. Equitrans must mark
the claim of confidentiality in writing on each page, and include a statement specifying the grounds



for each claim of confidentially. PHMSA determines release of any information submitted
pursuant to this Agreement in accordance with 49 C.F.R. Part 7, the Freedom of Information Act,
5 U.S.C. § 552, DOT and PHMSA policies, and other applicable regulations and Executive Orders.
VII. Effective Date
26. The term "Effective Date," as used herein, is the date on which the Consent Order is
issued by the Associate Administrator incorporating the terms of this Agreement. Unless specified
to the contrary, all deadlines for actions required by this Agreement run from the Effective Date
of the Consent Order. Nothing in this Agreement prevents Equitrans from completing any of the
obligations earlier than the deadlines provided for in this Agreement.
VIII. Modification
27. The terms of this Agreement may be modified by mutual agreement of the Parties. Such
modifications must be in writing and signed by both parties.
IX. Termination
28. This Agreement shall remain in effect until the Corrective Measures set forth in Section
II are satisfied, as determined by the Director.
X. Ratification
29. The Parties' undersigned representatives certify that they are fully authorized to enter
into the terms and conditions of this Agreement and to execute and legally bind such party to this
document.
30. The Parties hereby agree to all conditions and terms of this Agreement.



For Respondent:
___________________________________
Robert Cooper
Senior Vice President, Construction Services
Equitrans Midstream Corporation
___________________________________
Date
For PHMSA:
___________________________________
Robert Burrough
Director, Eastern Region, Office of Pipeline Safety
___________________________________
Date

12022080NOPSO_Notice of Proposed Safety Order_12292022_(22-259271)_text.pdf

VIA ELECTRONIC MAIL TO: cbaker@equitransmidstream.com
December 29, 2022
Clifford Baker
Senior Vice President, Commercial Development & Operations
Equitrans Midstream Corporation
2200 Energy Drive
Canonsburg, PA 15317
CPF 1-2022-080-NOPSO
Dear Mr. Baker:
Enclosed is a Notice of Proposed Safety Order (Notice) issued in the above-referenced case. The
Notice proposes that you take certain measures with respect to your Rager Mountain underground
natural gas storage facility and wells to ensure safety. Your options for responding are set forth in
the Notice. Your receipt of the Notice constitutes service of that document under 49 C.F.R. §
190.5.
We look forward to a successful resolution to ensure pipeline safety. Please direct any questions
on this matter to me at 609-771-7809.
Sincerely,
Robert Burrough, Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
Enclosures: Notice of Proposed Safety Order
49 C.F.R. § 190.239
Cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, Office of
Pipeline Safety <linda.daugherty@dot.gov>
Mr. Jake Lyons, Manager Pipeline Safety and Compliance, Equitrans Midstream
Corporation <jlyons@equitransmidstream.com>
CONFIRMATION OF RECEIPT REQUESTED



DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
EASTERN REGION
WEST TRENTON, NJ 08628
__________________________________________
)
In the Matter of )
)
Equitrans Midstream Corporation, ) CPF No. 1-2022-080-NOPSO
)
Respondent. )
__________________________________________)
NOTICE OF PROPOSED SAFETY ORDER
Background and Purpose
Pursuant to Chapter 601 of title 49, United States Code, the Pipeline and Hazardous Materials
Safety Administration (PHMSA) has initiated an investigation and review of the safety of
Equitrans Midstream Corporation’s (ETRN) Rager Mountain Storage (RMS) Facility after
November 2022 failure incidents resulting in the leak of a large amount of natural gas.
As a result of PHMSA’s preliminary investigation, it appears that a condition or conditions exist
at your RMS Facility that poses a pipeline integrity risk to public safety, property, or the
environment.
Pursuant to 49 U.S.C. § 60117(m), PHMSA issues this Notice of Proposed Safety Order (Notice)
notifying you of the preliminary findings of the investigation, and proposing that you take
measures to ensure that the public, property, and the environment are protected from the potential
risk.
Preliminary Findings
• ETRN owns and operates an interstate natural gas transportation system spanning
several states. ETRN’s system includes the RMS Facility located in Cambria County,
Pennsylvania. The RMS Facility is an underground natural gas storage facility
(UNGSF; see 49 C.F.R. § 192.3) which includes ten operating storage wells and two
observation wells, and is connected via pipeline segments to interstate gas transmission
pipelines. The RMS Facility is an interstate gas pipeline facility subject to the Federal



Pipeline Safety Regulations.
1 This facility is located within a Pennsylvania state park,
in a remote area.
• On November 6, 2022, ETRN was notified that Well 22442 (also known as the George
L. Reade No. 1 Well) at the RMS Facility was unintentionally venting natural gas (the
Incident) to the atmosphere through a 1 5/8-inch vent located on the annulus of the well
at a pressure of approximately 1,300 pounds per square inch gauge (psig).
• ETRN reported the Incident to the National Response Center (NRC) on November 6,
2022.
3 ETRN’s contractor, Wild Well Control, indicated it would be unable to arrive
at the RMS Facility until Tuesday, November 8, 2022. Another contractor, CUDD
Well Services (CUDD), was in the area and responded to the Incident on Monday,
November 7, 2022. Beginning on November 10, 2022, CUDD made multiple attempts
to stop the leak by flooding the well with either fresh water or varying salinities of brine
water. These attempts to stop the leak were unsuccessful.
• On November 19, 2022, CUDD temporarily stopped the leak of gas out of the vent of
Well 2244 by successfully setting a temporary bridge plug in the well bore. This was
CUDD’s second attempt to set a plug to stop the leak. The first attempt failed due to
a mechanical failure. This secondary plug was set at a depth of 5,875 feet and a
tertiary plug was set at 5,830 feet. On November 20, 2022, ETRN had cement
pumped into the well bore.
• ETRN estimates that Well 2244 vented over one billion cubic feet (BCF) of natural
gas to the atmosphere before the leak was halted on November 19, 2022.
• During the Incident, based on PHMSA’s observations at the site, it appears that ETRN
did not review its up-to-date schematics of Well 2244 before attempting to stop the
leak. ETRN and Cudd also did not follow all of the procedures in the facility’s “Storage
Well Emergency Response Plan”. The failure to follow all of the "Storage Well
Emergency Response Plan" procedures may have been a factor contributing to the
delay in stopping the leak. The initial attempt to temporarily plug the well failed due to
the plug being stuck on an obstruction not previously identified by ETRN prior to
initiating repairs.
1 ETRN Underground Natural Gas Storage Facility Annual Report for Calendar Year 2021 (OMB No. 2137-0522)
(submitted Mar. 14, 2022).
2 The production string well tubulars for Well 2244 were constructed in 1965 (1,875 feet) and 1993 (5,950 feet),
respectively. The tubulars from both years were 7-inch, N-80, 26 pounds per square foot, and cemented partially.
The cement is present from the bottom of the well to a depth of 2,940 feet. From the depth of approximately 10 feet
to 2,940 feet, a gel was installed to fill the void. The maximum allowable operating pressure (MAOP) of the
underground natural gas storage facility is 3,200 psig. Gas is stored in well composed of Oriskany sandstone
located at a minimum depth of 7,601 feet to a maximum depth of 8,060 feet, per ETRN’s annual report.
3 NRC Report No. 1351880.



• On November 22, 2022, it was discovered another well in the RMS Facility, Well 2251
(also known as the Peoples Natural Gas No. 1 Well), which previously did not have
any flow out of its annulus, was flowing gas at a rate of seven percent gas in air, which
is above the Lower Explosive Limit (LEL) for natural gas. Well 2251 was temporarily
plugged on December 7, and later an additional well, Well 2248, was also temporarily
plugged after a leak was discovered. These additional events may be an indication that
some of the escaping natural gas that was exposed to the annulus in Well 2244 and
vented to the atmosphere may have leaked to additional formations. This may also
indicate there is an additional casing integrity issue.
• To date, the exact causes of the casing failure in Well 2244 and leaks during the
Incident and at Wells 2251 and 2248, are unknown. It is also presently unknown if
the natural gas leak from Well 2244 has affected other portions of the RMS Facility,
including Wells 2251 and 2248. At present, PHMSA is gathering additional data
regarding the Incident and the leaks at the additional wells and is continuing its
investigation. ETRN has reported that is it not presently injecting natural gas into the
RMS Facility. Further, the Commonwealth of Pennsylvania’s Department of
Environmental Protection has alerted PHMSA to other alleged natural gas leaks and
potential integrity issues within the RMS Facility at present.4
Proposed Issuance of Safety Order
Section 60117(m) of Title 49, United States Code, provides for the issuance of a safety order, after
reasonable notice and the opportunity for a hearing, requiring corrective measures, which may
include physical inspection, testing, repair, or other action, as appropriate. The basis for making
the determination that a pipeline facility, including an underground natural gas storage facility, has
a condition or conditions that pose a pipeline integrity risk to public safety, property, or the
environment is set forth both in the above-referenced statute and 49 C.F.R. § 190.239, a copy of
which is enclosed.
After evaluating the foregoing preliminary findings of fact, and based on: (1) The amount of
natural gas stored in the RMS Facility; (2) The amount of natural gas vented to the atmosphere
during the Incident that was discovered beginning on November 6, 2022; (3) The failed well casing
involved; (4) The hazardous nature to persons and the environment of the product stored and
transported; (5) The operating pressures at this UNGSF; and, (6) The presently unknown aspects
regarding the cause of the three leaks, including whether other leaks are present and if unknown
additional impacts are occurring to the RMS Facility, any injection into affected Well 2244 and
the other wells at the RMS Facility, without a root cause analysis and corresponding corrective
measures, would pose a risk to public safety, property, and the environment.
Accordingly, PHMSA issues this Notice to notify Respondent of the proposed issuance of a safety
order and to propose that Respondent take measures specified herein to address the potential risks.
4 See https://www.ahs.dep.pa.gov/NewsRoomPublic/articleviewer.aspx?id=22235&typeid=1.



Proposed Corrective Measures
Pursuant to 49 U.S.C. § 60117(m) and 49 C.F.R. § 190.239, PHMSA proposes to issue to ETRN
a safety order incorporating the following remedial requirements with respect to the affected
pipeline:
1. Definitions. For the purpose of this Notice the following terms are defined as:
(A) “Director” is the Director, Eastern Region, Office of Pipeline Safety
(OPS), Pipeline and Hazardous Materials Safety Administration
(PHMSA)
(B) “Effective Date” is the date a safety order is issued.
2. Root Cause Failure Analysis. Within 90 days after the Effective Date, ETRN must
complete a root cause failure analysis (RCFA) regarding the cause of the leaks that were
discovered beginning on November 6, 2022 (applicable to the Incident and the two
additional leaks) and submit a final RCFA to the Director.
(A) The RCFA must be facilitated by an independent third-party acceptable
to the Director and must document the decision-making process and all
factors contributing to the failures. ETRN shall submit a proposed third-
party for the Director’s approval within 30 days of the Effective Date.
(B) The final RCFA must include findings and any lessons learned. The
RCFA must also analyze and document whether the findings and any
lessons learned are applicable to other locations within ETRN’s RMS
Facility.
3. Remedial Work Plan. Within 60 days after submitting the RCFA, ETRN must develop
and submit to the Director for approval a written Remedial Work Plan (RWP) that includes
corrective measures. The Director may approve the RWP elements incrementally. Once
approved, the RWP shall become incorporated into the safety order, including any
revisions to the RWP. The RWP must include:
(A) A plan for completing inspections of Wells 2244, 2251, and 2248 within
60 days of the RWP. The results of all inspections, field reviews, and
evaluations must be provided to the Director within 30 days of the
inspections.
(B) A plan to inspect all other wells at the UNGSF for similar conditions
and to address any additional findings/leaks and the repairs.
(C) A plan to address the final disposition of the temporary plugs in Wells
2244 2251, and 2248. The plan must consider the cause of the leaks
and describe whether ETRN will Plug and Abandon (P&A) or reactivate



the wells for future use. The RWP must include a list of all plugs and
their locations and ETRN’s plan as to their disposition.
(D) A plan for the performance of repairs or other corrective measures that
fully remediate the identified risk condition(s) within 30 days of
corrective action. The plan must include provisions for continuing long-
term, periodic testing and integrity verification measures to ensure the
ongoing safe operation of the pipeline considering the results of the
analyses, inspections, and corrective measures undertaken pursuant to
the safety order;
(E) A proposed schedule for completion of the actions required by
paragraphs (A), (B), (C), and (D) of this Item.
4. Review of Records and Procedures. Within 30 days of the Effective Date, ETRN must:
(A) Conduct a review of construction, operating and maintenance (O&M)
and integrity management records, such as Magnetic FluxLeakage
(MFL) logs, Gamma Ray Neutron (GRN) logs, Mechanical Integrity
(MIT), root cause failure analysis of prior failures, and aerial and ground
patrols for the RMS Facility.
(B) Submit the analysis and findings from that review to the Director and
address any findings that require remedial measures to be implemented
prior to restarting injection. ETRN must also amend procedures as
necessary. All procedural modifications must be incorporated into
ETRN’s operations and maintenance procedures manual and submitted
to the Director for approval.
5. Injection Plan. Prior to injecting any gas into the RMS Facility and/or resuming normal
operations, ETRN must first develop and submit a written Injection Plan to the Director
for approval. The Director may approve the Injection Plan incrementally without approving
the entire plan, but ETRN cannot begin injecting until the Injection Plan is approved in its
entirety. Once approved by the Director, the Injection Plan will be incorporated by
reference into the safety order. The Injection Plan must include:
(A) The day-light hour schedule to begin the injection into the RMS Facility,
including a plan for providing ad
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