EQT PRODUCTION — Notice of Probable Violation

party submissionOfficial PDF12024039NOPV_Operator Response to Notice_01132025_(23-276594).pdf#

case documentOfficial PDF12024039NOPV_PCO_11062024_(23-276594).pdf#

case documentOfficial PDF12024039NOPV_PCO_11062024_(23-276594)_text.pdf#

12024039NOPV_Final Order_09262025_(23-276594)_text.pdf, page 1Official PDFSeptember 26, 2025 VIA ELECTRONIC MAIL TO: justin.trettel@eqt.com Mr. Justin Trettel Vice President EQT Production Company 2200 Energy Drive Canonsburg, Pennsylvania 15317 Re: CPF No. 1-2024-039-NOPV Dear Mr. Trettel: Enclosed please find the Final Order issued in the above-referenced case. It makes two findings of violation and specifies actions that need to be taken by EQT Production Company to comply with the pipeline safety regulations. When the terms of the compliance order are completed, as determined by the Director, Eastern Region, this enforcement action will be closed. Service of the Final Order by e-mail is effective upon the date of transmission and acknowledgement of receipt as provided under 49 CFR § 190.5. Thank you for your cooperation in this matter. Sincerely, Linda Daugherty Acting Associate Administrator for Pipeline Safety cc: Robert Burrough, Director, Eastern Region, Office of Pipeline Safety, PHMSA Jacob Lyons, EQT Production Company, jacob.lyons@eqt.com; Robert Pichardo, EQT Production Company, robert.pichardo@eqt.com; Brianne Kurdock, Counsel for EQT Production Company, BKurdock@babstcalland.com CONFIRMATION OF RECEIPT REQUESTED#

12024039NOPV_Final Order_09262025_(23-276594)_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 ) ) EQT Production Company ) CPF No. 1-2024-039-NOPV ) ) Respondent. ) ____________________________________) FINAL ORDER From October 31, 2022 through March 27, 2023, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), conducted an on-site pipeline safety inspection of the procedures and records of EQT Production Company (EQT or Respondent), in Canonsburg, Pennsylvania. As a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Respondent, by letter dated November 6, 2024, a Notice of Probable Violation and Proposed Compliance Order (Notice). In accordance with 49 CFR § 190.207, the Notice proposed finding that EQT had committed two violations of 49 CFR Part 192 and proposed ordering Respondent to take certain measures to correct the alleged violations. EQT responded to the Notice by letter dated January 13, 2025 (Response). Respondent contested one of the violations and offered additional information in response to the Notice. Respondent did not request a hearing and therefore has waived its right to one. FINDINGS OF VIOLATION The Notice alleged that Respondent violated 49 CFR Part 192, as follows: Item 1: The Notice alleged that Respondent violated 49 CFR § 192.605(a), which states: § 192.605 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. For transmission lines, the manual must also include procedures for handling abnormal operations. This#

12024039NOPV_Final Order_09262025_(23-276594)_text.pdf, page 32 manual must be reviewed and updated by the operator at intervals not exceeding 15 months, but at least once each calendar year. This manual must be prepared before operations of a pipeline system commence. Appropriate parts of the manual must be kept at locations where operations and maintenance activities are conducted. The Notice alleged that Respondent violated 49 CFR § 195.605(a) by failing to follow its manual of written procedures for conducting operations and maintenance activities and for emergency response. Specifically, the Notice alleged that EQT failed to follow Section 14 of its Integrity Management Plan (IMP), Revised 10/15/22, titled “MCA Identification and Assessment (192.3),” which required identification of Moderate Consequence Areas (MCAs) and other pipeline segments subject to § 192.710. The Notice alleged that in three instances, EQT’s GIS mapping of MCA locations failed to appropriately identify the boundaries of identified MCAs due to new construction within the potential impact radius (PIR) of the segment. EQT did not contest this allegation of violation. In its Response, EQT stated that it reviewed Section 14 of its IMP and discussed internally how to avoid the issue in the future. In addition, EQT stated that it would conduct retraining of certain personnel to ensure the correct identification of MCA boundaries. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 CFR § 192.605(a) by failing to follow Section 14 of its Integrity Management Plan (IMP), Revised 10/15/22, titled “MCA Identification and Assessment (192.3),” which required identification of Moderate Consequence Areas (MCAs) and other pipeline segments subject to § 192.710. Item 2: The Notice alleged that Respondent violated 49 CFR § 192.605(b)(1), which states: § 192.605 Procedural manual for operations, maintenance, and emergencies. (a) . . . . (b) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following, if applicable, to provide safety during maintenance and operations. (1) Operating, maintaining, and repairing the pipeline in accordance with each of the requirements of this subpart and subpart M of this part. The Notice alleged that Respondent violated 49 CFR § 192.605(b)(1) by failing to have procedures for operating, maintaining, and repairing the pipeline in accordance with each of the requirements of Subparts L and M. Specifically, the Notice alleged that EQT’s manual of written procedures failed to incorporate the requirements of § 192.712 of Subpart M of Part 192, including sections addressing applicability (§ 192.712(a)), analysis of corrosion metal loss (§ 192.712(b)), analysis of cracks and crack-like defects (§ 192.712(d)), data analysis (§ 192.712(e)), review of analysis conducted (§ 192.712(f)), and documentation and retention of applicable records (§ 192.712(g)). The Notice alleged that EQT’s Operations and Maintenance Manual (O&M Manual) Revision 15 (10/17/2022) omitted these material components of § 192.712. In its Response, EQT stated that with respect to cracks and crack-like defects (§ 192.712(d)), EQT#

12024039NOPV_Final Order_09262025_(23-276594)_text.pdf, page 43 discussed this issue during the inspection and pointed out that it had not experienced susceptibility to cracking, has had no history of stress corrosion cracking (SCC) or cyclic loading, and if a crack were to be discovered, EQT would treat all cracks and crack-like defects as an immediate repair. EQT stated that because all cracks would be treated as an immediate repair condition, there was no need for a comprehensive procedure for crack evaluation. EQT noted, however, that in an effort to resolve the issue, it added a cross-reference to its IMP in its operations and maintenance procedure and made other revisions. EQT contended that its procedure requiring cracks and crack-like defects to be removed or repaired was more conservative than the regulatory requirement and therefore it did not violate § 192.605(b)(1). EQT requested this item be withdrawn, or in the alternative, converted to a warning item based on its good faith effort to implement the regulation. While EQT provided information regarding evaluation of cracks and crack-like defects (§ 192.712(d)), EQT did not contest or otherwise respond to the allegations in the Notice that the manual was missing procedures required under § 192.712(a), (b), (e), (f), and (g). Section 192.605(a) requires each pipeline operator to prepare a manual of written procedures for operating and maintaining the pipeline and for emergency response. Procedures the manual “must include” under § 192.605(b)(1) include “operating, maintaining, and repairing the pipeline in accordance with each of the requirements of . . . subpart M” of Part 192. Within subpart M, § 192.712 provides that “operators of onshore steel transmission pipelines must analyze anomalies or defects to determine the predicted failure pressure at the location of the anomaly or defect, and the remaining life of the pipeline segment.” The regulation specifies the substantive requirement and applicability (§ 192.712(a)) and the analysis required for different types of anomalies, including corrosion metal loss (§ 192.712(b)), dents and mechanical damage (§ 192.712(c)), and cracks and crack-like defects (§ 192.712(d)). An operator’s manual must include procedures requiring analysis for each of these anomaly types, plus additional provisions addressing data analysis, reviews, and record retention (§ 192.712(e), (f), and (g), respectively), among other requirements. Having reviewed the record, I find Respondent’s manual of written procedures did not have provisions required by § 192.712. Specifically, Respondent did not contest the allegations in the Notice that the manual was missing procedures required under § 192.712(a), (b), (e), (f), and (g). Failure to include these procedures constitutes a violation of § 192.605(b)(1). EQT’s procedure treating cracks and crack-like defects as immediate repairs does not, on its own, warrant withdrawing the alleged violation in its entirety because the manual was missing other procedures as well. In addition, PHMSA recognizes Respondent has revised its procedures to remediate the noncompliance. The revisions render it unnecessary for PHMSA to order compliance, as discussed below, but do not warrant withdrawing the violation or reducing to a warning because the remediation was conducted after the noncompliance was identified during the PHMSA inspection.1 1 See In the Matter of Oasis Midstream Partners, LP, 2020 WL 6870720, at *3 (Oasis's actions in addressing these training deficiencies are welcomed by PHMSA, but such after-the-fact conduct does not provide a basis to absolve Oasis of its acknowledged violations, nor does it warrant reducing the violation to something less); In the Matter of Colonial Pipeline Company, 2010 WL 6518285, at *6 (“I am not persuaded in this case that non-compliant test survey frequencies could somehow be ‘corrected’ after the fact or that such efforts demonstrate “good faith” in attempting to#

12024039NOPV_Final Order_09262025_(23-276594)_text.pdf, page 54 Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 CFR § 192.605(b)(1) by failing to have procedures for maintaining the pipeline in accordance with Subpart M, specifically the omission of procedures addressing § 192.712. These findings of violation will be considered prior offenses in any subsequent enforcement action taken against Respondent. COMPLIANCE ORDER The Notice proposed a compliance order with respect to Items 1 and 2 in the Notice for violations of 49 CFR §§ 192.605(a) and 192.605(b)(1), respectively. Under 49 U.S.C. § 60118(a), each person who engages in the transportation of gas or who owns or operates a pipeline facility is required to comply with the applicable safety standards established under chapter 601. The Director has indicated that Respondent has taken the following actions to address one of the cited violations: With respect to the violation of § 192.605(b)(1) (Item 2), EQT stated in its Response that it had added a cross-reference to its IMP in its O&M procedure and provided a copy of its revised procedure. In a recommendation for final action submitted pursuant to § 190.209(b)(7), the Director indicated that the revised O&M manual satisfied the requirements of the proposed compliance term in the Notice. Accordingly, I find that compliance has been achieved with respect to Item 2. Therefore, the compliance terms proposed in the Notice for Item 2 are not included in this Order. As for the remaining compliance term, pursuant to the authority of 49 U.S.C. § 60118(b) and 49 CFR § 190.217, Respondent is ordered to take the following actions to ensure compliance with the pipeline safety regulations applicable to its operations: 1. With respect to the violation of § 192.605(a) (Item 1), EQT must evaluate all aerial imagery platforms, software, processes, training, and methods of communication amongst work groups associated with the identification of MCAs to determine why existing structure and roadway MCAs were not properly identified or extended. Upon completion of the review, EQT must submit their findings, to include cause for the omissions and update their current “Assessment Schedule” required under § 192.710 with all MCAs included. Newly identified MCAs resulting from compliance with this Compliance Order must be noted within the updated assessment schedule which shall be submitted to the Eastern Region Director for review no later than 90 days from receipt of this Final Order. The Director may grant an extension of time to comply with any of the required items upon a written request timely submitted by the Respondent and demonstrating good cause for an extension. achieve compliance”).#

12024039NOPV_Final Order_09262025_(23-276594)_text.pdf, page 65 PHMSA requests that Respondent maintain documentation of the safety improvement costs associated with fulfilling this Compliance 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. Failure to comply with this Order may result in administrative assessment of civil penalties exceeding $200,000, as adjusted for inflation (see 49 CFR § 190.223 for adjusted amounts), for each violation for each day the violation continues or in referral to the Attorney General for appropriate relief in a district court of the United States. Under 49 CFR § 190.243, Respondent may submit a Petition for Reconsideration of this Final Order to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address. The written petition must be received no later than 20 days after receipt of the Final Order by Respondent. Any petition submitted must contain a statement of the issue(s) and meet all other requirements of 49 CFR § 190.243. The filing of a petition automatically stays the payment of any civil penalty assessed. The other terms of the order, including corrective action, remain in effect unless the Associate Administrator, upon request, grants a stay. The terms and conditions of this Final Order are effective upon service in accordance with 49 CFR § 190.5. ___________________________________ __________________________ Linda Daugherty Date Issued Acting Associate Administrator for Pipeline Safety#

12024039NOPV_Closure Letter_02102026_(23-276594)_text.pdf, page 1Official PDFU.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 840 Bear Tavern Road, Suite 300 West Trenton, NJ 08628 609.771.7800 VIA ELECTRONIC MAIL TO: justin.trettel@eqt.com February 10, 2026 Justin Trettel Vice President, Midstream EQT Production Company 2200 Energy Drive Canonsburg, Pennsylvania 15317 RE: CPF 1-2024-039-NOPV Dear Mr. Trettel: On September 26, 2025, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a Final Order to EQT Production Company (EQT) in the above-referenced case. This Order included a Compliance Order. Based on our review of the documentation you provided, it has been determined that you have complied with the terms of this Order. Accordingly, this case is now closed and no further action is contemplated with respect to the matters involved in this case. Thank you for your cooperation in this matter. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration#