{"operation":"document","citation":"CPF 12024039NOPV","title":"EQT PRODUCTION — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-11-06","effective_on":null,"summary":"CLOSED notice of probable violation citing 192.605(a), 192.605(b)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024039nopv.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024039nopv.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024039nopv","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12024039NOPV","body":"Notice of Probable Violation involving EQT PRODUCTION. PHMSA's enforcement data identifies the cited regulations as 192.605(a),  192.605(b)(1). The case was opened on 2024-11-06 and is reported as closed as of 2026-02-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12024039NOPV_Closure Letter_02102026_(23-276594).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024039NOPV/12024039NOPV_Closure%20Letter_02102026_(23-276594).pdf\n\n12024039NOPV_Closure Letter_02102026_(23-276594)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024039NOPV/12024039NOPV_Closure%20Letter_02102026_(23-276594)_text.pdf\n\n12024039NOPV_Final Order_09262025_(23-276594).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024039NOPV/12024039NOPV_Final%20Order_09262025_(23-276594).pdf\n\n12024039NOPV_Final Order_09262025_(23-276594)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024039NOPV/12024039NOPV_Final%20Order_09262025_(23-276594)_text.pdf\n\n12024039NOPV_Operator Response to Notice_01132025_(23-276594).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024039NOPV/12024039NOPV_Operator%20Response%20to%20Notice_01132025_(23-276594).pdf\n\n12024039NOPV_PCO_11062024_(23-276594).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024039NOPV/12024039NOPV_PCO_11062024_(23-276594).pdf\n\n12024039NOPV_PCO_11062024_(23-276594)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024039NOPV/12024039NOPV_PCO_11062024_(23-276594)_text.pdf\n\n12024039NOPV_Final Order_09262025_(23-276594)_text.pdf\n\nSeptember 26, 2025\nVIA ELECTRONIC MAIL TO: justin.trettel@eqt.com\nMr. Justin Trettel\nVice President\nEQT Production Company\n2200 Energy Drive\nCanonsburg, Pennsylvania 15317\nRe: CPF No. 1-2024-039-NOPV\nDear Mr. Trettel:\nEnclosed please find the Final Order issued in the above-referenced case. It makes two findings\nof violation and specifies actions that need to be taken by EQT Production Company to comply\nwith the pipeline safety regulations. When the terms of the compliance order are completed, as\ndetermined by the Director, Eastern Region, this enforcement action will be closed. Service of\nthe Final Order by e-mail is effective upon the date of transmission and acknowledgement of\nreceipt as provided under 49 CFR § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nLinda Daugherty\nActing Associate Administrator\nfor Pipeline Safety\ncc: Robert Burrough, Director, Eastern Region, Office of Pipeline Safety, PHMSA\nJacob Lyons, EQT Production Company, jacob.lyons@eqt.com;\nRobert Pichardo, EQT Production Company, robert.pichardo@eqt.com;\nBrianne Kurdock, Counsel for EQT Production Company, BKurdock@babstcalland.com\nCONFIRMATION OF RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\n)\nIn the Matter of )\n)\nEQT Production Company ) CPF No. 1-2024-039-NOPV\n)\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nFrom October 31, 2022 through March 27, 2023, pursuant to 49 U.S.C. § 60117, a representative\nof the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline\nSafety (OPS), conducted an on-site pipeline safety inspection of the procedures and records of\nEQT Production Company (EQT or Respondent), in Canonsburg, Pennsylvania.\nAs a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Respondent,\nby letter dated November 6, 2024, a Notice of Probable Violation and Proposed Compliance Order\n(Notice). In accordance with 49 CFR § 190.207, the Notice proposed finding that EQT had\ncommitted two violations of 49 CFR Part 192 and proposed ordering Respondent to take certain\nmeasures to correct the alleged violations.\nEQT responded to the Notice by letter dated January 13, 2025 (Response). Respondent contested\none of the violations and offered additional information in response to the Notice. Respondent did\nnot request a hearing and therefore has waived its right to one.\nFINDINGS OF VIOLATION\nThe Notice alleged that Respondent violated 49 CFR Part 192, as follows:\nItem 1: The Notice alleged that Respondent violated 49 CFR § 192.605(a), which states:\n§ 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a\nmanual of written procedures for conducting operations and maintenance\nactivities and for emergency response. For transmission lines, the manual\nmust also include procedures for handling abnormal operations. This\n\n\n\n2\nmanual must be reviewed and updated by the operator at intervals not\nexceeding 15 months, but at least once each calendar year. This manual\nmust be prepared before operations of a pipeline system commence.\nAppropriate parts of the manual must be kept at locations where operations\nand maintenance activities are conducted.\nThe Notice alleged that Respondent violated 49 CFR § 195.605(a) by failing to follow its manual\nof written procedures for conducting operations and maintenance activities and for emergency\nresponse. Specifically, the Notice alleged that EQT failed to follow Section 14 of its Integrity\nManagement Plan (IMP), Revised 10/15/22, titled “MCA Identification and Assessment (192.3),”\nwhich required identification of Moderate Consequence Areas (MCAs) and other pipeline\nsegments subject to § 192.710. The Notice alleged that in three instances, EQT’s GIS mapping of\nMCA locations failed to appropriately identify the boundaries of identified MCAs due to new\nconstruction within the potential impact radius (PIR) of the segment.\nEQT did not contest this allegation of violation. In its Response, EQT stated that it reviewed\nSection 14 of its IMP and discussed internally how to avoid the issue in the future. In addition,\nEQT stated that it would conduct retraining of certain personnel to ensure the correct identification\nof MCA boundaries.\nAccordingly, based upon a review of all of the evidence, I find that Respondent violated 49 CFR\n§ 192.605(a) by failing to follow Section 14 of its Integrity Management Plan (IMP), Revised\n10/15/22, titled “MCA Identification and Assessment (192.3),” which required identification of\nModerate Consequence Areas (MCAs) and other pipeline segments subject to § 192.710.\nItem 2: The Notice alleged that Respondent violated 49 CFR § 192.605(b)(1), which states:\n§ 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) . . . .\n(b) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following, if\napplicable, to provide safety during maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in accordance\nwith each of the requirements of this subpart and subpart M of this part.\nThe Notice alleged that Respondent violated 49 CFR § 192.605(b)(1) by failing to have procedures\nfor operating, maintaining, and repairing the pipeline in accordance with each of the requirements\nof Subparts L and M. Specifically, the Notice alleged that EQT’s manual of written procedures\nfailed to incorporate the requirements of § 192.712 of Subpart M of Part 192, including sections\naddressing applicability (§ 192.712(a)), analysis of corrosion metal loss (§ 192.712(b)), analysis\nof cracks and crack-like defects (§ 192.712(d)), data analysis (§ 192.712(e)), review of analysis\nconducted (§ 192.712(f)), and documentation and retention of applicable records (§ 192.712(g)).\nThe Notice alleged that EQT’s Operations and Maintenance Manual (O&M Manual) Revision 15\n(10/17/2022) omitted these material components of § 192.712.\nIn its Response, EQT stated that with respect to cracks and crack-like defects (§ 192.712(d)), EQT\n\n\n\n3\ndiscussed this issue during the inspection and pointed out that it had not experienced susceptibility\nto cracking, has had no history of stress corrosion cracking (SCC) or cyclic loading, and if a crack\nwere to be discovered, EQT would treat all cracks and crack-like defects as an immediate repair.\nEQT stated that because all cracks would be treated as an immediate repair condition, there was\nno need for a comprehensive procedure for crack evaluation. EQT noted, however, that in an effort\nto resolve the issue, it added a cross-reference to its IMP in its operations and maintenance\nprocedure and made other revisions.\nEQT contended that its procedure requiring cracks and crack-like defects to be removed or repaired\nwas more conservative than the regulatory requirement and therefore it did not violate\n§ 192.605(b)(1). EQT requested this item be withdrawn, or in the alternative, converted to a\nwarning item based on its good faith effort to implement the regulation. While EQT provided\ninformation regarding evaluation of cracks and crack-like defects (§ 192.712(d)), EQT did not\ncontest or otherwise respond to the allegations in the Notice that the manual was missing\nprocedures required under § 192.712(a), (b), (e), (f), and (g).\nSection 192.605(a) requires each pipeline operator to prepare a manual of written procedures for\noperating and maintaining the pipeline and for emergency response. Procedures the manual “must\ninclude” under § 192.605(b)(1) include “operating, maintaining, and repairing the pipeline in\naccordance with each of the requirements of . . . subpart M” of Part 192. Within subpart M, §\n192.712 provides that “operators of onshore steel transmission pipelines must analyze anomalies\nor defects to determine the predicted failure pressure at the location of the anomaly or defect, and\nthe remaining life of the pipeline segment.” The regulation specifies the substantive requirement\nand applicability (§ 192.712(a)) and the analysis required for different types of anomalies,\nincluding corrosion metal loss (§ 192.712(b)), dents and mechanical damage (§ 192.712(c)), and\ncracks and crack-like defects (§ 192.712(d)). An operator’s manual must include procedures\nrequiring analysis for each of these anomaly types, plus additional provisions addressing data\nanalysis, reviews, and record retention (§ 192.712(e), (f), and (g), respectively), among other\nrequirements.\nHaving reviewed the record, I find Respondent’s manual of written procedures did not have\nprovisions required by § 192.712. Specifically, Respondent did not contest the allegations in the\nNotice that the manual was missing procedures required under § 192.712(a), (b), (e), (f), and (g).\nFailure to include these procedures constitutes a violation of § 192.605(b)(1). EQT’s procedure\ntreating cracks and crack-like defects as immediate repairs does not, on its own, warrant\nwithdrawing the alleged violation in its entirety because the manual was missing other procedures\nas well. In addition, PHMSA recognizes Respondent has revised its procedures to remediate the\nnoncompliance. The revisions render it unnecessary for PHMSA to order compliance, as discussed\nbelow, but do not warrant withdrawing the violation or reducing to a warning because the\nremediation was conducted after the noncompliance was identified during the PHMSA\ninspection.1\n1 See In the Matter of Oasis Midstream Partners, LP, 2020 WL 6870720, at *3 (Oasis's actions in addressing these\ntraining deficiencies are welcomed by PHMSA, but such after-the-fact conduct does not provide a basis to absolve\nOasis of its acknowledged violations, nor does it warrant reducing the violation to something less); In the Matter of\nColonial Pipeline Company, 2010 WL 6518285, at *6 (“I am not persuaded in this case that non-compliant test survey\nfrequencies could somehow be ‘corrected’ after the fact or that such efforts demonstrate “good faith” in attempting to\n\n\n\n4\nAccordingly, based upon a review of all of the evidence, I find that Respondent violated 49 CFR\n§ 192.605(b)(1) by failing to have procedures for maintaining the pipeline in accordance with\nSubpart M, specifically the omission of procedures addressing § 192.712.\nThese findings of violation will be considered prior offenses in any subsequent enforcement\naction taken against Respondent.\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Items 1 and 2 in the Notice for violations\nof 49 CFR §§ 192.605(a) and 192.605(b)(1), respectively. Under 49 U.S.C. § 60118(a), each\nperson who engages in the transportation of gas or who owns or operates a pipeline facility is\nrequired to comply with the applicable safety standards established under chapter 601. The\nDirector has indicated that Respondent has taken the following actions to address one of the cited\nviolations:\nWith respect to the violation of § 192.605(b)(1) (Item 2), EQT stated in its Response that it had\nadded a cross-reference to its IMP in its O&M procedure and provided a copy of its revised\nprocedure.\nIn a recommendation for final action submitted pursuant to § 190.209(b)(7), the Director indicated\nthat the revised O&M manual satisfied the requirements of the proposed compliance term in the\nNotice. Accordingly, I find that compliance has been achieved with respect to Item 2. Therefore,\nthe compliance terms proposed in the Notice for Item 2 are not included in this Order.\nAs for the remaining compliance term, pursuant to the authority of 49 U.S.C. § 60118(b) and 49\nCFR § 190.217, Respondent is ordered to take the following actions to ensure compliance with\nthe pipeline safety regulations applicable to its operations:\n1. With respect to the violation of § 192.605(a) (Item 1), EQT must evaluate all aerial\nimagery platforms, software, processes, training, and methods of communication\namongst work groups associated with the identification of MCAs to determine why\nexisting structure and roadway MCAs were not properly identified or extended. Upon\ncompletion of the review, EQT must submit their findings, to include cause for the\nomissions and update their current “Assessment Schedule” required under § 192.710\nwith all MCAs included. Newly identified MCAs resulting from compliance with this\nCompliance Order must be noted within the updated assessment schedule which shall\nbe submitted to the Eastern Region Director for review no later than 90 days from\nreceipt of this Final Order.\nThe Director may grant an extension of time to comply with any of the required items upon a\nwritten request timely submitted by the Respondent and demonstrating good cause for an\nextension.\nachieve compliance”).\n\n\n\n5\nPHMSA requests that Respondent maintain documentation of the safety improvement costs\nassociated with fulfilling this Compliance Order and submit the total to the Director. It is requested\nthat these costs be reported in two categories: (1) total cost associated with preparation/revision of\nplans, procedures, studies and analyses; and (2) total cost associated with replacements, additions\nand other changes to pipeline infrastructure.\nFailure to comply with this Order may result in administrative assessment of civil penalties\nexceeding $200,000, as adjusted for inflation (see 49 CFR § 190.223 for adjusted amounts), for\neach violation for each day the violation continues or in referral to the Attorney General for\nappropriate relief in a district court of the United States.\nUnder 49 CFR § 190.243, Respondent may submit a Petition for Reconsideration of this Final\nOrder to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey\nAvenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of\nChief Counsel, PHMSA, at the same address. The written petition must be received no later than\n20 days after receipt of the Final Order by Respondent. Any petition submitted must contain a\nstatement of the issue(s) and meet all other requirements of 49 CFR § 190.243. The filing of a\npetition automatically stays the payment of any civil penalty assessed. The other terms of the\norder, including corrective action, remain in effect unless the Associate Administrator, upon\nrequest, grants a stay. The terms and conditions of this Final Order are effective upon service in\naccordance with 49 CFR § 190.5.\n___________________________________ __________________________\nLinda Daugherty Date Issued\nActing Associate Administrator\nfor Pipeline Safety\n\n12024039NOPV_Closure Letter_02102026_(23-276594)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials\nSafety Administration\n840 Bear Tavern Road, Suite 300\nWest Trenton, NJ 08628\n609.771.7800\nVIA ELECTRONIC MAIL TO: justin.trettel@eqt.com\nFebruary 10, 2026\nJustin Trettel\nVice President, Midstream\nEQT Production Company\n2200 Energy Drive\nCanonsburg, Pennsylvania 15317\nRE: CPF 1-2024-039-NOPV\nDear Mr. Trettel:\nOn September 26, 2025, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued a Final Order to EQT Production Company (EQT) in the above-referenced case. This Order\nincluded a Compliance Order. Based on our review of the documentation you provided, it has been\ndetermined that you have complied with the terms of this Order.\nAccordingly, this case is now closed and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":17353}