EQUITRANS MIDSTREAM CORPORATION — Safety Order

12023053NOPSO_Consent Agreement and Order_10032023_(23-264189)_text.pdf, page 1Official PDFOctober 3, 2023 VIA ELECTRONIC MAIL TO: cbaker@equitransmidstream.com Cliff Baker Senior Vice President Commercial Development & Operations Equitrans Midstream Corporation 2200 Energy Drive, Canonsburg, Pennsylvania 15317 CPF No. 1-2023-053-NOPSO Dear Mr. Baker: 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 October 3, 2023. Service of the Consent Order and Consent Agreement by electronic mail is effective upon the date of transmission and acknowledgement of receipt as 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 Enclosure: Order and Consent Agreement cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, Office of Pipeline Safety, PHMSA Mr. Robert Burrough, Director, Eastern Region, Office of Pipeline Safety, PHMSA Mr. Keith Coyle, Esq., Babst Calland, Outside Counsel for Equitrans Midstream Corporation, kcoyle@babstcalland.com CONFIRMATION OF RECEIPT REQUESTED#

12023053NOPSO_Consent Agreement and Order_10032023_(23-264189)_text.pdf, page 2U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 ____________________________________ ) In the Matter of ) ) Equitrans Midstream Corporation, ) CPF No. 1-2023-053-NOPSO ) Respondent. ) ____________________________________) CONSENT ORDER By letter dated August 11, 2023, the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety, issued a Notice of Proposed Safety Order (Notice) to Equitrans Midstream Corporation (Respondent). In accordance with 49 C.F.R. § 190.239, the Notice alleged that conditions exist at Respondent’s Mountain Valley Pipeline in West Virginia and Virginia, 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. October 3, 2023 ___________________________________ __________________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety#

12023053NOPSO_Consent Agreement and Order_10032023_(23-264189)_text.pdf, page 3U.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. 1-2023-053-NOPSO ) Respondent. ) ____________________________________) CONSENT AGREEMENT Pursuant to Chapter 601 of title 49, United States Code, the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), initiated on-site inspections and investigation of Equitrans Midstream Corporation’s (Respondent) Mountain Valley Pipeline (MVP) in West Virginia and Virginia.1 The MVP encompasses the proposed and partially constructed 303-mile natural gas transmission pipeline system in its entirety (Affected Facility). The Affected Facility, an interstate natural gas pipeline (42-inch diameter, coated steel pipe) that has been under construction since 2018, is subject to Federal pipeline safety laws and regulations, including the natural gas pipeline design and construction safety regulations in 49 C.F.R. Part 192. As a result of the investigation, the Director, Eastern Region, OPS (Director), issued to Respondent, by letter dated August 11, 2023, a Notice of Proposed Safety Order (Notice). The Notice alleged that conditions exist on Respondent’s Affected Facility that pose a pipeline 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 alleged integrity risk. On August 12, 2023, Respondent responded to the Notice by timely submitting a request for an informal consultation under 49 C.F.R. § 190.239(b)(2). PHMSA and Respondent (the Parties) held informal consultation meetings beginning on August 14, 2023. As a result of the informal consultation, the Parties agree that settlement of this proceeding by entry into this Consent Agreement (Agreement) is the most appropriate means of resolving the issues raised in the Notice, will avoid further administrative proceedings or litigation, and is in the 1 The MVP is owned by Mountain Valley Pipeline, LLC, Series A (Mountain Valley), a joint venture of several entities. An affiliate of Equitrans Midstream Corporation (OPID 31604) serves as the operator of MVP.#

12023053NOPSO_Consent Agreement and Order_10032023_(23-264189)_text.pdf, page 4public interest. Therefore, pursuant to 49 C.F.R. § 190.239(b)(2), without adjudication of any issue of law or fact, and upon consent and agreement, the Parties agree to the following terms and conditions. I. General Provisions 1. Respondent acknowledges that as the operator of the pipeline facilities subject to the Notice, Respondent and its referenced pipeline facilities are 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 does not admit or deny any of the allegations in the Notice but agrees, for purposes of this Agreement, to complete the actions specified in Section II of this Agreement (Corrective Measures) and to abide by the terms of this Agreement. 3. After Respondent returns this signed Agreement to PHMSA, the Agency’s 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 this Agreement. 4. Respondent consents to the issuance of the Consent Order, 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, except as set forth in the Dispute Resolution provisions set forth herein. 5. This Agreement shall apply to and be binding upon PHMSA and 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 Respondent’s pipeline system referenced herein, Respondent will provide a copy of this Agreement to the prospective transferee at least 30 days prior to such transfer. Respondent will provide written notice of the transfer to the Director no later than 60 days after the transfer occurs. 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.#

12023053NOPSO_Consent Agreement and Order_10032023_(23-264189)_text.pdf, page 58. 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 pipeline systems, including the provisions in the Fiscal Responsibility Act of 2023, Pub. L. No. 118-5, § 324. 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. Respondent 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. 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, regulation, or requirement, except in a proceeding to enforce the provisions of this Agreement. II. Corrective Measures: 12. Measures set forth below. Upon issuance of the Consent Order, Respondent agrees to perform the Corrective 13. Definitions. (A) “Director” means the Director, Eastern Region, OPS; (B) “Effective Date” means the date on which the Consent Order is issued by the Associate Administrator, PHMSA, incorporating the terms of this Agreement; and, (C) “Affected Facility” means the approximately 303-mile MVP pipeline traversing the states of West Virginia and Virginia, commencing at mile post (MP) 0.0 in Wetzel County, West Virginia, and ending at MP 303.0 in Pittsylvania County, Virginia, and includes all associated compressor stations and facilities. (D) “Uninstalled Pipe” means pipe that:#

12023053NOPSO_Consent Agreement and Order_10032023_(23-264189)_text.pdf, page 6(i) is stored on the pipeline right-of-way on or after the Effective Date (including in the Bradley, West Virginia Yard, or at any other location outdoors) and which must be installed to complete the construction of the Affected Facility; and (ii) may have been installed on or after July 1, 2023, for which a deficiency must be corrected under Corrective Measure 17(B)(ii). (E) “KTA” means KTA-Tator, Inc., an independent third-party with expertise and experience in assessing the coating type being utilized on the Affected Facility. 14. Reports/Results. Within 15 days of completing the actions specifically referenced in Corrective Measures 16(A), 17(A), 18(A), 19(A), and by the alternate reporting deadlines specified for Corrective Measure 19(B)-(C), Respondent must provide the written report describing the results of that action to the Director. 15. Remedial Work Plan. Within 30 days of completing the actions specifically referenced in Corrective Measures 16(B)(i), 17(A)-(C), and 18(B)(i), and 19(A)-(D), Respondent must develop and submit a written remedial work plan (Work Plan or RWP) to the Director that includes any necessary corrective measures. The Plan must include provisions to: (A) Remediate any identified safety conditions, including the specific remedial actions described in Corrective Measures 16(B)(ii), 17(A)-(C), 18(B)(ii), and 19 below, and identify the location and type of any necessary remediation activities; (B) Include a proposed timeline for completion of the corrective measures; (C) Revise the Plan as necessary to incorporate new information obtained during the evaluations and associated remedial activities. Respondent must submit any such revisions to the Director for prior approval; (D) Allow the Director to approve Plan elements incrementally. Once approved, the Plan shall become incorporated into the Consent Order; and (E) Implement the Plan as it is approved by the Director, including any revisions to the Plan. Results of actions taken in accordance with the approved Plan must be available for review by PHMSA or its representative. 16. ACVG/DCVG Surveys. (A) Prior to commissioning the Affected Facility, Respondent must: (i) Conduct alternating current voltage gradient (ACVG), direct current voltage gradient (DCVG), or other comparable inspection, testing, or surveys capable of locating and assessing pipeline coating conditions indicative of potential corrosion#

12023053NOPSO_Consent Agreement and Order_10032023_(23-264189)_text.pdf, page 7threats or anomalies, on all installed pipe segments, except for those installed and tested after January 1, 2023; (ii) A minimum of two (2) coating survey assessment classifications for survey calibration must be excavated, classified, and/or remediated per each survey crew per each time a survey is performed for each External Corrosion Direct assessment (ECDA) region. ECDA regions are to be identified in accordance with NACE International Standard Practice 0502-2010, “Pipeline External Corrosion Direct Assessment Methodology,” (NACE SP 0502-2010) Section 3.5 Identification of ECDA Regions. and, (iii) Conduct excavations for each survey as provided in NACE SP 0502-2010, Section 5.3 Guidelines for Determining the Required Number of Direct Examinations. (iv) A variance from the requirements of NACE SP 0502-2010 Sections 3.5 and 5.3, as applicable under 16(A)(ii)-(iii), may be obtained if Respondent submits a request with an adequate explanation and supporting plan in advance to the Director for approval. (B) After completing the ACVG, DCVG, or other comparable inspection, testing, or surveys required under Corrective Measure 16(A), Respondent must: (i) and Provide a written report to the Director pursuant to Corrective Measure 14; (ii) Submit an RWP to the Director pursuant to Corrective Measure 15 for remediating any damaged coating indications found during the assessments that are classified as severe indications with voltage (IR) drop greater than 60 percent for DCVG or 70 dBµV for ACVG, as provided in 49 C.F.R. § 192.461(h), or severe based on NACE SP 0502-2010. (C) Respondent’s plan for conducting the DCVG surveys required under this Corrective Measure is described in Appendix I to this agreement. 17. Coating. (A) Respondent shall: (i) Provide to the Director KTA’s evaluation of the procedures that Respondent is using to assess and remediate any potential damage to the coating for the Uninstalled Pipe, including by performing adhesion tests to evaluate coating performance; (ii) Adopt any changes to the procedures that KTA determines are necessary to ensure the safe installation of Uninstalled Pipe; and#

12023053NOPSO_Consent Agreement and Order_10032023_(23-264189)_text.pdf, page 8(iii) Provide a written report to the Director pursuant to Corrective Measure 14 describing the results of KTA’s evaluation and any changes adopted to the procedures under Corrective Measure 15. (iv) The Director has received the evaluation, written report, and procedures required under Corrective Measure 17(A)(i)-(iii) and approved the procedures that Respondent is using to assess and remediate any potential damage to the coating for the Uninstalled Pipe. (B) After submitting the written report to the Director required under Corrective Measure 17(A), Respondent shall: (i) Require KTA to audit the implementation of the procedures for assessing and remediating any potential damage to the coating for the Uninstalled Pipe at all MVP spreads; (ii) Take any actions that KTA, or the Director after consulting with KTA as the independent third-party, determines are necessary to correct any deficiency in implementing those procedures for any Uninstalled Pipe under the RWP; and (iii) hours. Notify the Director of any such deficiency and corrective actions within 24 (iv) The Director has received and approved Respondent’s plan for auditing the implementation of the procedures for assessing and remediating any potential damage to the coating for the Uninstalled Pipe at all MVP spreads. (C) If KTA determines in conducting the audit that a change to the coating assessment and remediation procedures is necessary to ensure the safe installation of Uninstalled Pipe, Respondent shall immediately adopt the change and include it in the RWP and notify the Director. (D) If KTA is unable for any reason to perform the requirements in Corrective Measures 17(A)-(C), Respondent shall: (i) Immediately notify the Director; and (ii) Within 15 days of notification of the Director, submit an RWP pursuant to Corrective Measure 15 for approval of another independent third-party with expertise and experience in assessing the coating type being utilized on the Affected Facility. Coating assessment and remediation activities must cease upon KTA’s end of performance and until another third party approved by the Director begins coating audit activities.#

12023053NOPSO_Consent Agreement and Order_10032023_(23-264189)_text.pdf, page 9(E) Respondent is authorized to continue assessing and remediating any potential damage to the coating for the Uninstalled Pipe while completing the construction of the Affected Facility, subject to applicable provisions in this Agreement. 18. Cathodic Protection CIS Surveys. (A) Within six months after commissioning, Respondent must assess the effectiveness of the Affected Facility’s permanent CP system via a close interval survey (CIS) to ensure MVP’s CP systems, including AC mitigation or interferences measures, are operating as designed per National Association of Corrosion Engineers (NACE) specified standards. The CIS must be conducted at a maximum 5-foot spacing and with interrupted on/off current to meet the requirements in §§ 192.463 and 192.465. (B) After conducting the CIS, Respondent must: (i) and Provide a written report to the Director pursuant to Corrective Measure 14; (ii) Submit an RWP to the Director pursuant to Corrective Measure 15 for remediating any identified locations as necessary in accordance with 49 C.F.R. Part 192, Subpart I. 19. ILI/Tool Runs. (A) Prior to commissioning of the Affected Facility, Respondent must run a low-resolution caliper tool capable of detecting dents and ovalities and remediate any identified imperfection or damage in accordance with the requirements of 49 C.F.R. § 192.309. Respondent must provide a report to the Director pursuant to Corrective Measure 14 within 15 days of completing the low-resolution caliper tool run. If any segments of pipe are determined to have imperfection or damage that requires remediation, Respondent must submit an RWP to the Director pursuant to Corrective Measure 15 for remediating those segments. (B) Within 90 days of commencing commercial natural gas transportation service on the Affected Facility, Respondent must run a high-resolution inline inspection (ILI) tool consisting of a magnetic flux leakage (MFL) tool with incorporated inertial measurement unit (IMU) and high-resolution caliper/deformation capabilities. After completing the tool run, Respondent must analyze all areas on the Affected Facility to identify locations susceptible to excessive external stresses, including, but not limited, to all sag locations and tie- in welds, and for any corrosion-related or other integrity-related conditions that require remediation under the applicable provisions in Subpart M or Subpart O of#

12023053NOPSO_Consent Agreement and Order_10032023_(23-264189)_text.pdf, page 10Part 192.2 The tools required under this Corrective Measure 19(B) must have the required sensitivity of measurements, and the highest resolution presently available for sensor spacing and sampling rate, and capability of multiple readings per sensor on the mechanical arm/sensor carrier (e.g., capable of additional readings such as “stand-off” at the sensor carrier), with a required sensitivity of measurements that enables repeatability in characterization and prioritization based upon anomaly size. Respondent must provide preliminary and final analysis reports to the Director pursuant to Corrective Measure 14 within 90 and 180 days of completing the tool run. An analysis of areas potentially susceptible to excessive external stresses on the Affected Facility must commence immediately following the Effective Date. (C) Within one year of completing the tool run required under Corrective Measure 19(B), Respondent must run another tool with IMU capabilities. After completing the tool run, Respondent must analyze areas on the Affected Facility susceptible to excessive external stresses, including, but not limited, to all sag locations and tie-in welds. Respondent must provide preliminary and final analysis reports to the Director pursuant to Corrective Measure 14 within 90 and 180 days of completing the tool run. (D) Respondent must perform a comparative strain analysis utilizing the tool run data attained in Corrective Measures 19(B)-(C) to more accurately identify potential areas of strain that may warrant further investigation. If any segments of pipe are determined to be subject to excessive external stress, Respondent must submit an RWP to the Director pursuant to Corrective Measure 15 for remediating those segments. Respondent must consult with appropriate subject matter experts and determine appropriate acceptable action levels for geohazards and other conditions. In the absence of an acceptable action level determination as agreed upon with the Director, the default values of two (2) percent strain for pipe and 0.5 percent strain for girth welds will be utilized. After appropriate determination of the action levels, Respondent shall remediate any identified locations above the specified thresholds as required by the applicable provisions in Subpart M or Subpart O of Part 192. Any other conditions discovered during the tool runs performed under Corrective Measures 19(A)-(C) that are actionable under Part 192 must be remediated as contemplated by the applicable code sections and included in the RWP submitted to the Director pursuant to Corrective Measure 15. 2 The requirements specified in the text of Subpart M or Subpart O of Part 192 on the Effective Date apply under the terms of this paragraph 19, regardless of whether their general applicability to the pipeline industry is presently effective (e.g., PHMSA’s enforcement discretion until February 2024 as to certain Part 192 requirements does not apply under this paragraph 19 requirement to the MVP. See, e.g., LIMITED ENFORCEMENT DISCRETION FOR EXISTING ONSHORE GAS TRANSMISSION PIPELINES REGARDING COMPLIANCE WITH THE RECENTLY ISSUED GAS TRANSMISSION FINAL RULE (87 FR 52224 (AUG. 24, 2022)); available online at: https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2022- 12/PHMSA%20Onshore%20Gas%20Transmission%20Notice%20of%20Limited%20Enforcement%20Discretion.p df.#

12023053NOPSO_Consent Agreement and Order_10032023_(23-264189)_text.pdf, page 11(E) Respondent may submit a request pursuant to Corrective Measure 23 to extend the deadlines for completing the tool runs required under Corrective Measures 19(A)-(C) for good cause, including tool availability concerns. 20. Additional Measures. After receiving and analyzing additional data during this proceeding and implementation of the Corrective Measures described above, the Director may identify other safety measures that need to be taken on the Affected Facility. In that event, the Director will notify the Respondent of any proposed additional measures and, if necessary, may seek to modify this Agreement pursuant to Paragraph 29. 21. Quarterly Reports. Respondent must submit quarterly reports to the Director that: (1) include available data and results of the testing and evaluations required by the Agreement; and (2) describe the progress of the repairs and other remedial actions being undertaken. The first quarterly report shall be due 90 days from the Effective Date. 22. Final Summary Report. A final summary report of work performed on the above items must be submitted to the Director within 30 days of the completion of the last action performed by Respondent that is set forth in this Agreement. 23. 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. 24. Documentation of Costs. It is requested that Respondent 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/revision of plans, procedures, studies, and analyses; and 2) total cost associated with replacements, additions, and other changes to pipeline infrastructure. III. Review and Approval Process: 25. 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, Respondent will take all actions as approved by the Director, subject to Respondent’s right to invoke the dispute resolution procedures with respect to any conditions the Director identifies. If the Director disapproves all or any portion of the submission, the Director will provide Respondent a written notice of the deficiencies, subject to Respondent’s right to invoke the dispute resolution procedures. Respondent will correct all deficiencies within the time specified by the Director and resubmit it for approval. IV. Dispute Resolution:#

12023053NOPSO_Consent Agreement and Order_10032023_(23-264189)_text.pdf, page 1226. The Director and Respondent will informally attempt to resolve any disputes arising under this Agreement, including any decision of the Director under the terms of Section II (Corrective Measures). If Respondent and the Director are unable to informally resolve the dispute within 15 calendar days after the dispute is first raised, in writing, to the Director, Respondent may submit a written request for a determination resolving the dispute from the Associate Administrator for Pipeline Safety, PHMSA. Such request must be made in writing and provided to the Director, counsel for Eastern Region, and to the Associate Administrator for Pipeline Safety, no later than 10 calendar days from the 15-day deadline for informal resolution referenced in this paragraph. Along with its request, Respondent must provide the Associate Administrator with all information Respondent believes is relevant to the dispute. Decisions of the Associate Administrator under this paragraph will constitute final agency action subject to judicial review pursuant to 49 U.S.C. § 60119. 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. V. Enforcement: 27. 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. The maximum civil penalty amounts are adjusted annually for inflation. See 49 C.F.R. § 190.223. 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: 28. Unless otherwise required in this Agreement, Respondent agrees to maintain records demonstrating compliance with all requirements of this Agreement for a period of at least five (5) 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, Respondent 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. Respondent 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. Modification: 29. 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.#

12023053NOPSO_Consent Agreement and Order_10032023_(23-264189)_text.pdf, page 13VIII. Termination: 30. This Agreement will remain in effect until the Corrective Measures in Section II are satisfied, as determined by the Director. The Agreement shall not terminate until the Director confirms, in writing, that the Agreement is terminated in accordance with this paragraph. Nothing in this Agreement prevents Respondent from completing any of the obligations earlier than the deadlines provided for in this Agreement. IX. Ratification: 31. 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. 32. The Parties hereby agree to all findings, conditions, and terms of this Agreement. [Signature Lines on Following Page]#

12023053NOPSO_Consent Agreement and Order_10032023_(23-264189)_text.pdf, page 14For Equitrans Midstream Corporation: ___________________________________ ________________________ Date For PHMSA: ________________________________________ Director, Eastern Region, Office of Pipeline Safety ________________________ Date#

12023053NOPSO_Consent Agreement and Order_10032023_(23-264189)_text.pdf, page 15APPENDIX I: DCVG PLAN Condition 16 of the Agreement requires Respondent to conduct alternating current voltage gradient (ACVG), direct current voltage gradient (DCVG), or other comparable inspection, testing, or surveys capable of locating and assessing pipeline coating conditions indicative of potential corrosion threats or anomalies, on certain pipeline segments prior to commissioning. Respondent has developed a plan for conducting the surveys required by Condition 16, and that plan will require Respondent to conduct a minimum of 14 DCVG surveys of varying lengths. Respondent considered the following technical, logistical, and personnel safety considerations in selecting the DCVG survey segments: • Survey segments of adequate length to provide meaningful data that can be analyzed quickly to determine where excavations for further investigations are required. • Survey segments that predominantly coincide with the existing construction Spread breaks. These Spread breaks also coincide with changes in the topography and similar geologic conditions. • Survey segment breaks where large installation gaps existed prior to 2023 construction activities or at test segment break points. These break points ensure that additional welding will not interfere with the testing or results conducted in those segments. • Survey segments based on the availability of permanent cathodic protection groundbeds to use as the anode source during testing. • Survey sections based on the schedule for completing continuous pipe sections to minimize the number of excavations that need to occur during winter months. Respondent may divide the 14 survey segments described in Table 1 below into smaller sections to facilitate coordination with other ongoing construction activities. If that occurs, Respondent will still conduct the minimum number of excavations required under Condition 16 of the Consent Agreement. Table 1: Description of DCVG Survey Segments Survey Segment # Start (MP) End (MP) Segment Length (miles) Pre- 2023 Pipe (miles) Start of Survey End of Survey 1 0 33.02 33.02 32.38 Start of Line End of Test Section A4 2 33.02 76.19 43.17 41.79 Start of Test Section B1 End of Test Section B3 3 76.19 98.55 22.58 20.26 Start of Test Section C1 End of Test Section C6 4 98.62 118.28 19.66 17.65 Start of Test Section D1 5 119.01 154.43 35.42 32.71 Gauley River Crossing Area Stallworth CS 6 154.45 167.33 12.88 12.56 GAS Gauley River Crossing Area Stallworth CS End of Test Section F1#

12023053NOPSO_Consent Agreement and Order_10032023_(23-264189)_text.pdf, page 167 8 9 10 11 12 13 14 167.33 195.09 27.76 24.6 Start of Test Section F2 201.65 219.55 17.9 14.5 Main Line Valve 24 221.5 234.02 12.52 10.01 Start of Test Section G2 234.38 241.41 7.03 2.18 245.9 253.95 8.05 6.67 GAS I-81 Crossing GAS Bent Mtn Area 253.95 270.9 16.95 13.62 Start of Test Section I1 270.9 289.59 18.69 15.6 Start of Test Section I4 289.59 303.36 14.61 11.25 Start of Test Section I5 End of Test Section F7 End of Test Section G1 CIS I-81 Crossing CIS Bent Mtn Area End of Test Section H6 End of Test Section I3 End of Test Section I4 End of Line#

12023053NOPSO_Notice of Proposed Safety Order_08112023_(23-264189)_text.pdf, page 1Official PDFVIA ELECTRONIC MAIL TO: cbaker@equitransmidstream.com August 11, 2023 Cliff Baker Senior Vice President Commercial Development & Operations Equitrans Midstream Corporation 2200 Energy Drive, Canonsburg, PA 15317 CPF No. 1-2023-053-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 Mountain Valley Pipeline to ensure pipeline 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, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration Enclosures: Notice of Proposed Safety Order 49 C.F.R. § 190.239 Cc: Linda Daugherty, Deputy Associate Administrator for Field Operations, Office of Pipeline Safety <linda.daugherty@dot.gov> Keith Coyle, Esq. Babst Calland <kcoyle@babstcalland.com> CONFIRMATION OF RECEIPT REQUESTED#

12023053NOPSO_Notice of Proposed Safety Order_08112023_(23-264189)_text.pdf, page 2DEPARTMENT 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. 1-2023-053-NOPSO ) Respondent ) ____________________________________) NOTICE OF PROPOSED SAFETY ORDER Background and Purpose This Notice of Proposed Safety Order (NOPSO or Notice) is being issued by the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), under the authority of 49 U.S.C. § 60117. Pursuant to § 60117, PHMSA has initiated an investigation and on-site inspections of the safety of Equitrans Midstream Corporation’s (ETRN) Mountain Valley Pipeline, LLC in West Virginia and Virginia. PHMSA’s ongoing investigation indicates that conditions may exist on ETRN’s Mountain Valley Pipeline (MVP) facilities that pose a pipeline integrity risk to public safety, property, or the environment. The conditions potentially exist on the MVP system and may present immediate risk if the pipeline is commissioned without remediation. 1 Pursuant to 49 U.S.C. § 60117(m), PHMSA is issuing this Notice to notify you of the preliminary findings of the investigation and propose you take measures to ensure that the public, property, and the environment are protected from the potential risks. Preliminary Findings A. General Preliminary Findings • The MVP construction project encompasses the proposed and partially constructed MVP interstate natural gas transmission system in its entirety, which will be comprised of approximately 303 miles of 42-inch diameter coated steel pipe (Affected Facility). The Affected Facility traverses the states of West Virginia and Virginia, commencing at mile 1 See, e.g., In the Matter of Occidental Chemical Corporation, PHMSA CPF No. 4-2011-5009S (June 28, 2011); available online at: https://primis.phmsa.dot.gov/comm/reports/enforce/documents/420115009S/420115009S NOPSO 06282011.pdf.#

12023053NOPSO_Notice of Proposed Safety Order_08112023_(23-264189)_text.pdf, page 3post (MP) 0.0 in Wetzel County, West Virginia, and ending at MP 303.0 in Pittsylvania County, Virginia, at the Transcontinental Gas Pipeline Company’s (Transco) compressor station (CS) 165. The Affected Facility also incorporates construction of three new greenfield compressor stations located in Wetzel, Braxton, and Greenbrier Counties in West Virginia. The MVP mainline will be constructed mainly of 42-inch diameter, ranging from 0.500 to 0.888-inch thickness, X70M, Type SAWL pipe. The pipe was manufactured by Welspun Corporation, Limited. • The Affected Facility is an interstate natural gas pipeline that has been under construction since 2018. The Affected Facility is mostly completed, except for a few miles of pipeline yet to be installed in the Jefferson National Forest in Virginia and numerous water and other crossings. • The Affected Facility is subject to Federal pipeline safety laws and regulations, including the natural gas pipeline design and construction safety regulations in 49 C.F.R. Part 192. PHMSA has conducted pipeline construction safety oversight activities of MVP construction project since 2018. • The MVP construction project has been halted for long periods of time while pipe segments have been buried without cathodic protection (CP) installed, and without other corrosion control processes and inspections at different junctures. 2 • The construction delays have caused the coated steel pipe staged along the Affected Facility right-of-way to be exposed to the elements and ultraviolet (UV) radiation for long periods of time.3 • The Affected Facility traverses karst and mountainous topography, making the pipeline environment susceptible to land movement. • Recent PHMSA inspections of the Affected Facility in West Virginia and Virginia have focused on all construction activity—in particular, pipe coating remediation and installed CP systems. PHMSA has recently observed active CP systems in Spreads A and B of the MVP construction project. CP installation in the remaining spreads are currently being observed to evaluate their efficacy. • During recent inspections of the Affected Facility, PHMSA has observed coating remediation data and the documentation of coating inspections. Some data was being recorded on an outdated form that does not represent current processes and procedures governing such coating remediation work. 2 See January 23, 2020, letter from ETRN to FERC requesting to perform additional supplemental activities, Docket No. CP16-10-000, Accession Number 20200123-5084; available online at: https://elibrary ferc.gov/eLibrary/docinfo?accession number=20200123-5084. 3 Id. See infra note 14.#

12023053NOPSO_Notice of Proposed Safety Order_08112023_(23-264189)_text.pdf, page 4B. • Recent legislative, construction approval, and litigation-related developments unrelated to PHMSA’s safety oversight authorities have taken place, which temporarily allowed ETRN to resume construction activities on the MVP construction project. 4 While those activities were delayed again, 5 recent developments indicate ETRN may imminently complete and commission the Affected Facility. 6 • The identified risk conditions described further below are associated with external corrosion control requirements prescribed under Part 192 (see, e.g., §§ 192.455 and 192.461). This NOPSO is intended to ensure an effective corrosion assessment and control system is carried out. The details associated with each condition are listed below. Cathodic Protection Systems Preliminary Findings • The objective of cathodic protection is to mitigate pipeline corrosion, which can naturally occur once steel pipe is buried. PHMSA requires operators to comply with § 192.455(a)(2) by protecting pipeline facilities from corrosion during construction phases; monitoring for conditions that could pose a threat to the integrity of the pipeline; and remediating identified conditions, if necessary. • ETRN provided PHMSA construction notification for the Affected Facility on January 3, 2018. During the construction and maintenance phases that have taken place since that date, PHMSA has been conducting ongoing safety regulatory compliance activities to ensure compliance with the relevant pipeline safety laws and regulations. Welding began in Spread G on May 25, 2018, with additional construction activities initiating in multiple spreads shortly thereafter. On October 15, 2019, the Federal Energy Regulatory Commission (FERC)—the Federal agency responsible for authorizing gas pipeline construction and operation activities in the U.S.—issued an order entitled “Cessation of Certain Activities” in Docket No. CP16-10-000 (Cessation Order). 7 In the Cessation Order, FERC ordered ETRN to cease all construction activity with the exception of restoration and stabilization. 4 See Section 324 of the Fiscal Responsibility Act of 2023, Pub. L. No. 118-5, 137 Stat. 10 (June 2023). See also June 28, 2023 FERC Order Authorizing All Construction Activities, Docket No. 16-10-000, Accession Number: 20230628-3041, available online at: https://elibrary ferc.gov/eLibrary/filelist?accession number=20230628- 3041&optimized=false. 5 See, e.g., Appalachian Voices v. Dep’t of the Interior, No. 23-1384 (4th Cir.). 6 See Supreme Court of the United States Order Vacating Stays, Mountain Valley Pipeline, LLC v. Wilderness Society, et al. (No. 23A35, July 27, 2023); available online at https://www.supremecourt.gov/orders/courtorders/072723zr_j4ek.pdf. 7 See October 15, 2019, FERC letter Cessation of Certain Activities, Docket No. CP16-10-000, Accession Number: 20191015-3030, available online at: https://elibrary ferc.gov/eLibrary/filelist?accession number=20191015-3030). This followed an October 11, 2019, decision by the United States Court of Appeals for the Fourth Circuit to grant a stay of the November 2017 Biological Opinion and Incidental Take Statement for MVP (Wild Va. v. U.S. Dep’t of the Interior, No. 19-1866 (4th Cir., Oct. 11, 2019)).#

12023053NOPSO_Notice of Proposed Safety Order_08112023_(23-264189)_text.pdf, page 5• When the Cessation Order was issued, MVP project construction was occurring in multiple spreads throughout West Virginia and Virginia. Numerous pipeline segments of 42-inch diameter pipe were installed in non-contiguous fashion, including many incomplete stream crossings. This resulted in numerous pipeline segments that were essentially orphaned from mechanical and electrical connection to MVP’s originally designed corrosion control systems. By the fourth quarter of 2019, approximately 235 miles of pipe had been installed and buried across nine construction spreads (spreads A thru I). • ETRN reviewed CP test station readings along the Affected Facility in late 2019 and early 2020, noting the need for additional monitoring in areas where higher than expected potential readings were observed during initial testing. ETRN reported to PHMSA that the late 2019 and early 2020 readings revealed no areas that required immediate response. • ETRN approached FERC in January of 2020 to address the Cessation Order, seeking permission to perform additional activities, including slip repair and mitigation and the installation of temporary cathodic protection on installed pipe segments. 8 ETRN’s request discussed the potential corrosion concerns for the uncompleted pipeline at that time, noting some segments would have been installed for more than two years prior to the pipeline possibly being placed into operation. • PHMSA, FERC, and ETRN had ongoing discussions thereafter pertinent to adequacy of the CP system on the Affected Facility and mitigation efforts to be pursued in the event right-of-way access and resumption of construction activities were further delayed. Results of those meetings culminated with ETRN providing an MVP “Integrity Update” on July 8, 2020, referencing proactive approaches to CP and corrosion mitigation taken by ETRN both prior to and after FERC’s issuance of the Cessation Order. • Prior to March 2020, a corrosion specialist firm conducted three prior direct current voltage gradient (DCVG9) coatings surveys on all continuous sections of pipe greater than three miles in Spreads A and B. As of July 2020, approximately 38 miles of pipe had undergone a coating survey and ETRN indicated the surveys resulted in coating remediation activities. Results of the surveys indicated that further investigation would be required once construction was resumed. In the interim, ETRN planned to continue surveying coating on pipe segments greater than three miles in length and presently those surveys have continued. • According to ETRN, at present, 14 of 31 permanent ground bed CP systems have been installed on the Affected Facility’s approximately 270 miles of buried pipe, of which ETRN reports three are energized. In the case of pipe segments that are not cathodically protected by the permanent ground bed CP systems, ETRN indicates it has installed 470 temporary CP “groundbed systems that are protecting the pipeline until these segments can 8 See supra note 2. 9 DCVG (direct current voltage gradient) is a survey technique used for assessing the effectiveness of corrosion protection, particularly on buried steel structures.#

12023053NOPSO_Notice of Proposed Safety Order_08112023_(23-264189)_text.pdf, page 6be connected to permanent ground beds after Mountain Valley fills the construction gaps.”10 • During PHMSA’s ongoing inspections of the Affected Facility, PHMSA discussed with ETRN concerns that pipes installed without CP for extended periods of time could corrode. Specifically, PHMSA underscored to ETRN the extent of corrosion that could potentially exist in the absence of an effective CP system and emphasized the uncertainty that develops once buried pipe is without effective CP (see PHMSA Advisory Bulletin (ADB) 03-06).11 PHMSA ADB 03-06 was issued after “the discovery of substantial external corrosion on a newly constructed gas transmission pipeline. The pipeline had been in service a little over two years when this unexpected corrosion was revealed by a high-resolution, inline inspection tool. The pipe wall pitting was consistent with that caused by underground stray electrical current before a cathodic protection system is installed.”12 • PHMSA acknowledges ETRN has taken several measures to address the cathodic protection system deficiencies on the MVP construction project,13 but some buried pipeline was installed without effective CP for periods of at least two years. This necessitates extensive documentation of efforts to prevent corrosion and support the level of effectiveness of the temporary CP systems, and how any potential corrosion has been addressed to ensure compliance with safety standards. • The MVP currently traverses one high consequence area (HCA) in a Class 3 location as defined in Part 192, and will routinely be required to have an ILI tool run with assessments within 10 years of commissioning. At present, ETRN indicated to PHMSA it is considering conducting an in-line inspection (ILI) tool run with assessments in conjunction with commissioning of the pipeline. C. Protective Coating Preliminary Findings • The MVP construction project has been subject to multiple construction delays. These delays have resulted in the fusion bonded epoxy (FBE) coating on much of the pipe left staged on the project right-of-way (ROW) exposed to potential maleffects (solar oxidation) from the sun’s UV radiation.14 FBE coating on pipe is not intended to be left exposed to 10 See June 29, 2023, letter from ETRN to FERC addressing pipeline integrity concerns on MVP, Docket No. 16-10- 000, Accession Number 20230629-5164, available online at https://elibrary ferc.gov/eLibrary/filelist?accession_number=20230629-5164. 11 68 Fed. Reg. 64,189 (Nov. 12, 2003). After discovery of substantial external corrosion on a newly constructed gas transmission pipeline, PHMSA encouraged operators to have qualified corrosion personnel identify, mitigate, and monitor any detrimental stray currents prior to and during construction. 12 Id. 13Supra note 10. 14 See, e.g., January 12, 2018, testimony of ETRN project manager Robert Cooper (Mountain Valley Pipeline, LLC v. Easements, et al., No. 7:17CV492 (W.D. Va.)), “[t]here are some other things that are kind of unique to this project, one of which is the pipeline material. The pipeline is coated with a protective material. It's an epoxy. As it sits in the sun, it ages or oxidizes and actually becomes thinner. And so we have to continue to monitor that and#

12023053NOPSO_Notice of Proposed Safety Order_08112023_(23-264189)_text.pdf, page 7UV radiation for extended periods of time prior to being buried.15 PHMSA is aware that in some instances this exposure to environmental conditions—such as UV radiation and adverse seasonal weather conditions—may have facilitated potential degradation of the FBE coating on the MVP pipe. This degradation may have placed portions of pipe coating below acceptable effective coating thresholds. ETRN’s present activities to test and rehabilitate degraded coating indicate this risk condition exists. • During recent inspections of the Affected Facility, PHMSA observed coating rehabilitation activities and data, and the documentation of such. During an on-site inspection on July 12–13, 2023, in Spreads A and B, PHMSA staff reviewed records of coating analysis on pipe with coating that was determined to not require remediation. This analysis was recorded on the “Holiday Detector Inspection Form.” During the inspection, records for pipe joint #J16009085D were assessed. The assessment was recorded on the Holiday Detector Inspection Form, and the pipe coating was determined to not require remediation. A single millage reading was required to be recorded on the Holiday Detector Inspection Form; however, the process that ETRN has developed and implemented involves three readings on five random locations for a joint of pipe. • PHMSA has discussed the coating-related concerns described above with ETRN throughout the delays in construction and has recently observed coating-related activities along the MVP right-of-way and evaluated ETRN’s applicable procedures. PHMSA understands ETRN has developed a process to assess and remediate potential coating damage, which includes referencing applicable National Association of Corrosion Engineers (NACE) standards and assessing the coating and remediating damage found, potentially by applying additional coating on-site. The proposed corrective measures below would require additional surveys of the pipe coating prior to commissioning and independent third party review of the processes (and implementation of such) ETRN has adopted to analyze and remediate any pipe coating damage, which will help resolve potential integrity concerns. D. Installation Preliminary Findings • During its inspection of MVP Spread C, conducted from August 6–8, 2019, PHMSA observed the placement of pipe within ditches off Mudlick Run Road and Camp Creek Road in West Virginia was not performed in a manner consistent with ETRN’s procedures prescribed by § 192.303. • During the August 2019 PHMSA inspection at Mudlick Run Road, PHMSA observed a 42-inch diameter pipe was placed within a rock-laden trench without adequate support padding and/or backfill material to protect the pipe coating from damage due to protruding rocks and spoils within the trench. PHMSA observed that pipe installed at this location may have been susceptible to stresses and/or damage that could result from movement or settlement that is typical during required post-installation hydrostatic testing. Specifically, inspect it. And prior to it becoming—there's some margin when you coat it, but prior to it becoming too thin to use, you have to protect it from the sun.” Id. at 134. 15 See, e.g., National Association of Pipe Coating Applicators (NAPCA) Bulletin 12-78-04.#

12023053NOPSO_Notice of Proposed Safety Order_08112023_(23-264189)_text.pdf, page 8E. preparation of trench, padding height, and clear spacing requirements between rock and pipe wall were inconsistent with the required minimum stipulated in ETRN’s 10.2 Standard, Sections 9.1, 14.1, 14.2 and 15.3. ETRN’s response to an inquiry by PHMSA noted that the installation was a proposed tie-in location that was incomplete at the time of inspection. ETRN subsequently remediated the identified condition at this location and provided supporting evidence of such to PHMSA. • At Camp Creek Road, PHMSA observed 42-inch diameter pipe being placed within a rock- laden trench inconsistent with ETRN’s construction requirements. Specifically, clear spacing requirements between pipe and rock wall, rock, and/or rock fragments were inconsistent with the required minimum stipulated in ETRN’s 10.2 Standard, Sections 9.1, 14.1, 14.2 and 15.3. PHMSA observed that pipe installed at this location may be susceptible to stresses and/or damage that may incur as a result of movement or settlement that is typical during required post-installation hydrostatic testing. • On April 14, 2020, PHMSA Eastern Region issued a Warning Letter to ETRN under CPF No. 1-2020-1012W.16 The Warning Letter placed ETRN on notice regarding these pipe installation issues for the remainder of the project. PHMSA’s concerns regarding compliance with § 192.319 may be detrimental to pipeline integrity and be identified during future pipe coating surveys and/or ILI caliper tool runs. The full inspections proposed in the Corrective Measures below will ensure areas of potential integrity risk are identified and remediated. Land Movement and Strain Preliminary Findings • The Affected Facility traverses areas of karst topography and steep slopes, making the pipeline environment susceptible to land movement. Land movement has been a causal factor in recent pipeline failures in the general vicinity of the route of the Affected Facility. 17 Further, the Affected Facility axially traverses many steep hillside and valley combinations that require sag bends and tie-in welds. Axial stresses on girth welds in sag- bend and over-bend locations, and areas where tie-in welds may be susceptible to excessive external stress during and/or soon after construction, have also been a causal factor in recent pipeline failures in the general vicinity of the pipeline route.18 PHMSA has issued advisory bulletins due to the prevalence of land movement issues affecting pipeline safety in recent years to recommend operators take certain actions to prevent damage to pipeline 16https://primis.phmsa.dot.gov/comm/reports/enforce/documents/120201012W/120201012W_Warning%20Letter_0 4142020.pdf. A warning letter was issued pursuant to PHMSA’s enforcement guidelines available online here: https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2020- 09/Section%203%20Selection%20of%20Administrative%20Enforcement%20Actions%20%20%289%2015%20202 0%29.pdf. 17 See, e.g., Leach XPress pipeline failure near Moundsville, West Virginia (June 7, 2018); See also PHMSA CPF No. 1-2018-1016S; available online at https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/news/58376/columbia-gas-npso-july-2018.pdf. 18 See, e.g., Enterprise Products ATEX-1 pipeline failure near Follansbee, West Virginia (2015); Energy Transfer, Rover Pipeline hydrotest near Wilbur, West Virginia (2018).#

12023053NOPSO_Notice of Proposed Safety Order_08112023_(23-264189)_text.pdf, page 9facilities caused by earth movement in variable, steep, and rugged terrain, and in terrain varied or subject to changing subsurface geological conditions.19 Such circumstances necessitate close attention to adopting assessment and mitigating measures, especially in light of the extensive attention to land movement and slip mitigation issues that was necessary as part of the MVP pipeline construction processes to date, and ETRN actions taken to address subsidence along the right of way. The sag and ILI assessments in the proposals below will assist in identifying and remediating any related conditions. 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 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 the unique aspects of the MVP construction, including: (1) the amount of time that significant portions of the pipeline were buried in the ground without being in operation or subject to corrosion prevention and inspection requirements, and uncertainty of conditions that could develop or exist on the Affected Facility in the absence of a timely and effective (and adequately documented) corrosion control program; (2) the amount of time the pipe has been exposed to the environment and UV radiation, and the uncertainty of conditions that could develop on the Affected Facility in the absence of adequate coating remediation; (3) the potential existence of integrity issues due to observed installation practices conveyed in previous PHMSA actions;20 (4) the steep topography the project traverses and karst-related land movement risks; (5) the coating evaluation and remediation process issues noted during recent PHMSA observations of on-site activities; as well as the hazardous nature of the product transported to persons and the environment when operations commence and the pressure required for transporting such product, the commissioning and operation of the MVP pipeline without appropriate inspection and corresponding corrective measures first being undertaken would pose a pipeline integrity risk to public safety, property, and the environment. The conditions described above require a comprehensive evaluation to identify and remediate integrity issues, mitigate the risk, and protect public safety, property, and the environment.21 19 See PHMSA advisory bulletins addressing “Potential for Damage to Pipeline Facilities Caused by Earth Movement and Other Geological Hazards”; 84 Fed. Reg. 18,919 (May 2, 2019); 87 Fed. Reg. 33,576 (June 2, 2022). 20 See CPF No. 1-2020-1012W discussed in the Installation Preliminary Findings section above. See also PHMSA CPF No. 1-2021-063-NOA, alleging ETRN had inadequate procedures under 49 C.F.R. § 192.303 as related to coating and remediation-related issues; available online at https://primis.phmsa.dot.gov/comm/reports/enforce/documents/12021063NOA/12021063NOA_Notice%20of%20A mendment_11182021_(20-172495)_text.pdf/. 21 See, e.g., In the Matter of Algonquin Gas Transmission, LLC, PHMSA CPF No. 1-2020-014-CAO (addressing release of 169,000 cubic feet of natural gas that occurred during commissioning activities of a compressor station), available online at https://primis.phmsa.dot.gov/comm/reports/enforce/documents/12020014CAO/12020014CAO_Amended%20Corre ctive%20Action%20Order_10302020_(20-172418).pdf. See also, In the Matter of Kinder Morgan Energy Partners,#

12023053NOPSO_Notice of Proposed Safety Order_08112023_(23-264189)_text.pdf, page 10Accordingly, 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. Proposed Corrective Measures Pursuant to 49 U.S.C. § 60117(m) and 49 C.F.R. § 190.239, PHMSA proposes to issue a safety order to ETRN incorporating the following remedial requirements with respect to the Affected Facility: 1. (A) Definitions. For the purpose of this Notice, the following terms are defined as: “Director” is the Director, Eastern Region, Office of Pipeline Safety (OPS), Pipeline and Hazardous Materials Safety Administration (PHMSA); (B) (C) “Effective Date” is the date a safety order is issued; and “Affected Facility” means the approximately 303-mile MVP pipeline traversing the states of West Virginia and Virginia, commencing at mile post (MP) 0.0 in Wetzel County, West Virginia, and ending at MP 303.0 in Pittsylvania County, Virginia, and includes all associated compressor stations and facilities. 2. Reports/Results. Within 15 days of completion of the required inspection, testing, analysis, and/or surveys in Corrective Measures 4 through 7 below, ETRN must provide the written results of the required inspection, testing, analysis and/or surveys to the Director. 3. Remedial Work Plan. Within 30 days of completion of the required inspection, testing, analysis, and/or surveys in Corrective Measures 4 through 7 below, ETRN must develop and submit a written remedial work plan (Work Plan or RWP) to the Director that includes the necessary corrective measures. The Plan must include provisions to: (A) Remediate any identified safety conditions to include the specific remedial actions described in Corrective Measures 4 through 7 below, including identification of location and type of any necessary remediation activities; (B) (C) (D) Include a proposed timeline for completion of the corrective measures; Revise the Plan as necessary to incorporate new information obtained during the evaluations and associated remedial activities. Submit any such Plan revisions to the Director for prior approval; Accept the Director may approve Plan elements incrementally. Once approved, the Plan shall become incorporated into the Safety Order; and, LP, PHMSA CPF No. 2-2009-1024H (addressing gas pipeline failure that that occurred soon after pipeline construction was completed); available online at https://primis.phmsa.dot.gov/comm/reports/enforce/documents/320091024H/320091024H_CAO_02172010.pdf.#

12023053NOPSO_Notice of Proposed Safety Order_08112023_(23-264189)_text.pdf, page 11(E) Implement the Plan as it is approved by the Director, including any revisions to the Plan. Results of actions taken in accordance with the approved Plan must be available for review by PHMSA or its representative. 4. Prior to commissioning, ETRN must conduct alternating current voltage gradient (ACVG), direct current voltage gradient (DCVG), or other comparable inspection, testing, or surveys capable of locating and assessing pipeline coating conditions indicative of potential corrosion threats or anomalies, on all installed pipe segments except for those installed and tested after January 1, 2023: (A) A minimum of two (2) coating survey assessment classifications for survey calibration must be excavated, classified, and/or remediated per each survey crew per each time a survey is performed; and, (B) Remediate any damaged coating indications found during the assessments required in Condition 2 that are classified as: i. Severe moderate (voltage (IR) drop greater than 60 percent for DCVG or 70 dBµV for ACVG) (i.e., 35% IR and above for DCVG or 50 dBµV and above for ACVG), or; ii. Severe based on NACE International Standard Practice 0502-2010, “Pipeline External Corrosion Direct Assessment Methodology,” (NACE SP 0502-2010). 5. Prior to installation, ETRN must conduct an analysis on all pipe that is intended to be installed on the Affected Facility and that is currently stored on the MVP right-of-way (including in the Bradley, West Virginia Yard, or at any other location outdoors) to assess the level of any potential damage to the coating and to ensure the pipe is safe to be installed: (A) The process used for the analysis must be evaluated by an independent third-party approved by the Director in advance and with expertise and experience in assessing the coating type being utilized on the Affected Facility, and must address and evaluate coating performance to include adhesion tests. The third party shall audit the pipe analysis and remediation processes at all spreads where rehabilitation activities are conducted. The plan to conduct the analysis must also be approved by the Director; and, (B) As part of the RWP, ETRN must provide to the Director for approval a plan to remediate (prior to installation), or to replace with new coated pipe segments, any defective segments with damaged or defective coating identified during the analysis. 6. Within six months after commissioning, ETRN must assess the effectiveness of the Affected Facility’s permanent CP system via a close interval survey (CIS) to ensure MVP’s CP systems, including AC mitigation or interferences measures, are operating as designed per National Association of Corrosion Engineers (NACE) specified standards: (A) The CIS must be conducted at a maximum 5-foot spacing and with interrupted on/off current to meet the requirements in §§ 192.463 and 192.465; and (B) ETRN must remediate any identified locations as necessary.#

12023053NOPSO_Notice of Proposed Safety Order_08112023_(23-264189)_text.pdf, page 127. ILI/Tool Runs. (A) (B) Within 90 days of commissioning of the Affected Facility, ETRN must run a high- resolution caliper/deformation ILI tool with incorporated IMU capability, and analyze areas on the Affected Facility susceptible to excessive external stresses, including, but not limited, to all sag locations and tie-in welds. 22 Any identified imperfection or damage shall be remediated per the requirements of § 192.309 and run data retained for further analysis. The tools under this Corrective Measure 7 must have the highest resolution presently available for sensor spacing and sampling rate, and capability of multiple readings per sensor on the mechanical arm/sensor carrier (e.g., capable of additional readings such as "stand-off" at the sensor carrier), with a required sensitivity of measurements that enables repeatability in characterization and prioritization based upon anomaly size. Preliminary and final analysis reports shall be provided within 90 and 180 days of completion of the tool run, respectively. The analysis of susceptible areas on the Affected Facility must commence immediately following the Effective Date; and, Within one year of the completion of the tool run in 7(A), ETRN shall run a high- resolution ILI tool consisting of a longitudinal magnetic flux leakage (MFL) tool with incorporated IMU and high-resolution caliper/deformation capabilities to assess for and identify potential external and internal corrosion-related or other anomalies. ETRN must perform a comparative stress/strain analysis (tensile and compressive) utilizing the high-resolution deformation/caliper tool run data attained in 7(A) and 7(B) to more accurately identify potential areas of stress that may warrant further investigation. If any segments of pipe are determined to be subject to excessive external stress under this Corrective Measure 7(A)-(B), those segments must be remediated under the RWP. ETRN will consult appropriate subject matter experts and determine appropriate acceptable action levels for geohazards and other conditions, as agreed upon by the Director. In the absence of an acceptable action level determination as agreed upon with the Director, the default values of two (2) percent strain for pipe and 0.5 percent strain for girth welds will be utilized. After appropriate determination of the action levels, any identified locations above the specified thresholds shall be remediated as required under Part 192. 8. 9. After receiving and analyzing additional data during this proceeding and implementation of the Corrective Measures described above, the Director may identify other safety measures that need to be taken on the Affected Facility. In that event, Respondent will be notified of any proposed additional measures and, if necessary, amendments to the RWP or safety order. ETRN must submit quarterly reports to the Director that: (1) include available data and results of the testing and evaluations required by the Safety Order; and (2) describe the 22 PHMSA acknowledges the availability of ILI tools may affect the exact timing of completion of this proposed Corrective Measure 7. Requests for any time extensions based on documented tool availability concerns must be approved by the Director as required under Corrective Measure 11 below.#

12023053NOPSO_Notice of Proposed Safety Order_08112023_(23-264189)_text.pdf, page 13progress of the repairs and other remedial actions being undertaken. The first quarterly report shall be due 90 days from the date of the Safety Order. 10. A final summary report of work performed on the above items must be submitted to the Director within 30 days of the completion of the last action performed by ETRN that is set forth in the Safety Order. 11. The Director may grant an extension of time for compliance with any of the terms of the Safety Order upon a written request, timely submitted, demonstrating good cause for an extension. 12. ETRN may appeal any decision of the Director to the Associate Administrator for Pipeline Safety. Decisions of the Associate Administrator shall be final. 13. It is requested that ETRN maintain documentation of the safety improvement costs associated with fulfilling this Safety Order and submit the total to the Director. It is requested that these costs be reported in two categories: 1) total cost associated with preparation/revision of plans, procedures, studies, and analyses; and 2) total cost associated with replacements, additions, and other changes to pipeline infrastructure. PHMSA believes that the above Corrective Measures will provide a level of safety equivalent to that provided for in Part 192 and will ensure that ETRN performs inspections, testing, and surveys necessary to identify any corrosion and other safety issues that may have taken place during the delayed construction phase, and to ensure the integrity and safety of the pipeline. The actions proposed by this Notice are in addition to and do not waive any requirements that apply to Respondent’s facility under 49 C.F.R. Parts 190 through 199, under any other order issued to Respondent under authority of 49 U.S.C. § 60101 et seq., or under any other provision of Federal or state law. Respondent may appeal any decision of the Director to the Associate Administrator for Pipeline Safety. Decisions of the Associate Administrator shall be final. Response to this Notice In accordance with 49 C.F.R. § 190.239, ETRN has 30 days following receipt of this Notice to submit a written response to the official who issued the Notice. If ETRN does not respond within 30 days, this constitutes a waiver of ETRN’s right to contest this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to ETRN and to issue a safety order. In ETRN’s response, ETRN may notify that official that it intends to comply with the terms of the Notice as proposed, or ETRN may request that an informal consultation be scheduled. (ETRN will also have the opportunity to request an administrative hearing before a safety order is issued.) Informal consultation provides ETRN with the opportunity to explain the circumstances associated with the risk conditions alleged in the notice and, as appropriate, to present a proposal for a work plan or other remedial measures, without prejudice to ETRN’s position in any subsequent hearing.#

12023053NOPSO_Notice of Proposed Safety Order_08112023_(23-264189)_text.pdf, page 14If ETRN and PHMSA agree within 30 days of informal consultation on a plan and schedule for you to address each identified risk condition, we may enter into a written consent agreement (PHMSA would then issue an administrative consent order incorporating the terms of the agreement). If a consent agreement is not reached, or if ETRN has elected not to request informal consultation, ETRN may request an administrative hearing in writing within 30 days following receipt of the Notice or within 10 days following the conclusion of an informal consultation that did not result in a consent agreement, as applicable. Following a hearing, if the Associate Administrator finds the facility to have a condition that poses a pipeline integrity risk to the public, property, or the environment in accordance with § 190.239, the Associate Administrator may issue a final safety order. Be advised that all material ETRN submits in response to this enforcement action is subject to being made publicly available. If ETRN believes that any portion of its responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original document ETRN must also provide a second copy of the document with the portions ETRN believes qualify for confidential treatment redacted and an explanation of why ETRN believes the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b). In ETRN’s correspondence on this matter, please refer to CPF No. 1-2023-053-NOPSO for each document it submits, and please provide a copy in electronic format whenever possible. ___________________________________ __________________ Robert Burrough Date issued Director, Eastern Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration#