{"operation":"document","citation":"CPF 12025033NOPV","title":"EQUITRANS MIDSTREAM CORPORATION — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2025-10-17","effective_on":null,"summary":"OPEN notice of probable violation citing 192.12(b)(2), 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025033nopv.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025033nopv.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025033nopv","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12025033NOPV","body":"Notice of Probable Violation involving EQUITRANS MIDSTREAM CORPORATION. PHMSA's enforcement data identifies the cited regulations as 192.12(b)(2),  192.12(c). The case was opened on 2025-10-17 and is reported as open. Proposed civil penalty: $939,900. Assessed civil penalty: $466,550. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12025033NOPV_Consent Agreement and Order_04212026_(22-259271).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025033NOPV/12025033NOPV_Consent%20Agreement%20and%20Order_04212026_(22-259271).pdf\n\n12025033NOPV_Consent Agreement and Order_04212026_(22-259271)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025033NOPV/12025033NOPV_Consent%20Agreement%20and%20Order_04212026_(22-259271)_text.pdf\n\n12025033NOPV_Operator Response to Notice and Request Informal Meeting and Request for Hearing and Statement of Issues and Request for Case File_11172025_(22-259271).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025033NOPV/12025033NOPV_Operator%20Response%20to%20Notice%20and%20Request%20Informal%20Meeting%20and%20Request%20for%20Hearing%20and%20Statement%20of%20Issues%20and%20Request%20for%20Case%20File_11172025_(22-259271).pdf\n\n12025033NOPV_Operator Withdrawal of Hearing Request_04212026_(22-259271).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025033NOPV/12025033NOPV_Operator%20Withdrawal%20of%20Hearing%20Request_04212026_(22-259271).pdf\n\n12025033NOPV_PCP_10172025_(22-259271).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025033NOPV/12025033NOPV_PCP_10172025_(22-259271).pdf\n\n12025033NOPV_PCP_10172025_(22-259271)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025033NOPV/12025033NOPV_PCP_10172025_(22-259271)_text.pdf\n\n12025033NOPV_PHC Hearing Scheduled_12152025_(22-259271).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025033NOPV/12025033NOPV_PHC%20Hearing%20Scheduled_12152025_(22-259271).pdf\n\n12025033NOPV_PHC Hearing Scheduled_12152025_(22-259271)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025033NOPV/12025033NOPV_PHC%20Hearing%20Scheduled_12152025_(22-259271)_text.pdf\n\n12025033NOPV_PHC Hearing Scheduled_12152025_(22-259271)_text.pdf\n\n1200 New Jersey Avenue, SE\nU.S. Department Washington, DC 20590\nof Transportation\nPipeline and\nHazardous Materials\nSafety Administration\nDecember 15, 2025\nVIA EMAIL TO: BKurdock@babstcalland.com, Ian.Curry@dot.gov et al.\nMs. Brianne Kurdock, Esq.\nCounsel for EQT Production Company\nBabst Calland\n505 9th Street, NW, Ste. 602\nWashington, DC 20004\nMr. Ian Curry, Esq.\nCounsel for the Agency\nPipeline and Hazardous Materials Safety Administration (PHMSA)\n1200 New Jersey Ave., S.E.\nWashington, DC 20590\nRe: PHMSA CPF No.: 1-2025-033-NOPV, EQT, Notice of Hearing and Order\nRegarding Prehearing Statement\nDear Ms. Kurdock and Mr. Curry,\nIn accordance with 49 C.F.R. § 190.211, a hearing will be held regarding the Notice of\nProbable Violation and Proposed Civil Penalty issued by PHMSA in the above\nreferenced case. The hearing will take place on April 22, 2026, beginning at 9:30\na.m. Eastern Time. The hearing will be held at DOT Headquarters:\n1200 New Jersey Ave, S.E.\nWashington, DC\n20590\nAdditional instructions for accessing the DOT Headquarters building will be provided\nlater.\nEach party is directed to submit to the presiding official and the other party by email a\npre-hearing statement, due no later than April 8, 2026, including the following\ninformation:\n1. A statement of facts\n\n\n\nPage 2\n2. A list of all agreed upon facts\n3. Defenses and arguments\n4. A witness list including a description and anticipated length of each witness’\nanticipated testimony. The description must be sufficient to show how the\nanticipated testimony may prove or disprove a fact significant to the case.\n5. A copy of all exhibits with an index identifying the documents. All exhibits must\nbe marked for identification in the lower right corner of each page. Documents\nalready in the case file need not be included.\nThe parties must confer regarding item 2 above. Failure to submit items 4 and 5 above\nmay result in disallowance of that evidence at the hearing. The parties may supplement\ntheir hearing exhibits or witness list with fair notice to the other party and the presiding\nofficial.\nA brief pre-hearing conference may be held 7-10 days prior to the hearing if the\npresiding official deems it appropriate.\nThe presiding official strongly recommends that a court reporter transcribe the hearing.\nIf Respondent elects to transcribe the hearing, Respondent should notify the presiding\nofficial (with copy to the other party) as soon as practicable.\nThe Agency is required to be represented by counsel for these proceedings.\nRegards,\nDolores Francis\nPresiding Official\n\n12025033NOPV_Consent Agreement and Order_04212026_(22-259271)_text.pdf\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Avenue, S.E.\nWashington, D.C. 20590\nApril 21, 2026\nVIA EMAIL TO: justin.trettel@eqt.com\nJustin Trettel\nVice President\nEQT Production Company\n2200 Energy Drive\nCanonsburg, Pennsylvania 15317\nCPF No. 1-2025-033-NOPV\nDear Mr. Trettel:\nEnclosed please find a Consent Order incorporating the terms of the Consent Agreement between\nthe Pipeline and Hazardous Materials Safety Administration (PHMSA) and EQT Production\nCompany, which was executed on April 14, 2026. Service of the Consent Order and Consent\nAgreement by electronic mail is deemed effective upon the date of transmission and\nacknowledgement of receipt, or as otherwise provided under 49 CFR § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nLinda Daugherty\nActing Associate Administrator\nfor Pipeline Safety\nEnclosure: Consent Order and Consent Agreement\ncc: Robert Burrough, Region Director, Eastern Region, Office of Pipeline Safety, PHMSA\nBrianne Kurdock, Counsel for EQT, Babst Calland, 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____________________________________\nIn the Matter of )\nEQT Production Company, ) CPF No. 1-2025-033-NOPV\n)\n)\n)\nRespondent. )\n____________________________________)\nCONSENT ORDER\nBy letter dated October 17, 2025, pursuant to 49 CFR § 190.207, the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), Eastern Region,\nissued a Notice of Probable Violation and Proposed Civil Penalty (Notice) to EQT Production\nCompany (EQT or Respondent).\nEQT responded to the Notice by letter dated November 17, 2025 (Response). Respondent\ncontested the alleged violations and the proposed civil penalties, and requested a hearing. EQT\nalso requested to meet informally with PHMSA to discuss the matters raised in the Response.\nRespondent and PHMSA (the Parties) subsequently met on December 16, 2025, and on several\noccasions thereafter. As a result of those discussions, the Parties have agreed to a Consent\nAgreement by which PHMSA makes two findings of violations. Respondent will pay a reduced\ncivil penalty in the amount of $466,550, and Respondent will complete certain compliance\nactions.\nAccordingly, the Consent Agreement is hereby approved and incorporated by reference into this\nConsent Order issued pursuant to 49 CFR § 190.219. EQT is hereby ordered to comply with the\nterms of the Consent Agreement pursuant to its terms. Pursuant to 49 U.S.C. § 60101, et seq.,\nfailure to comply with this Consent Order may result in the assessment of civil penalties as set\nforth in 49 U.S.C. § 60122 and 49 CFR § 190.223, or in referral to the Attorney General for\nappropriate relief in a district court of the United States.\nThe terms and conditions of this Consent Order are effective upon service in accordance with\n49 CFR § 190.5.\n______________________ ______________________\nLinda Daugherty Date Issued\nActing Associate Administrator\nfor Pipeline Safety\n\n\n\nDocusign Envelope ID: E3F06378-CA57-483A-8591-E2B3C17FA557 CPF No. 1-2025-033-NOPV\nPage 1\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nEQT Production Company, )\n)\n)\n)\nRespondent. )\n____________________________________)\nCPF No. 1-2025-033-NOPV\nCONSENT AGREEMENT\nFrom November 9, 2022, through March 3, 2025, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter\n601 of Title 49, United States Code (U.S.C.), investigated a substantial release of natural gas at\nthe Rager Mountain Underground Natural Gas Storage Field (Rager Mt. UNGSF), operated by\nEQT Production Company (EQT)1 in Jackson Township, Cambria County, Pennsylvania. The\nRager Mt. UNGSF includes ten operating storage wells and two observation wells and is\nconnected via pipeline segments to interstate gas transmission pipelines.\nAs a result of the investigation, the Director, Eastern Region, OPS (Director), issued to\nRespondent, by letter dated October 17, 2025, a Notice of Probable Violation and Proposed Civil\nPenalty (Notice), which also included a warning item pursuant to 49 CFR § 190.205. In\naccordance with 49 CFR § 190.207, the Notice proposed finding that EQT committed two\nviolations of 49 CFR Part 192 and proposed a civil penalty of $939,900.\nEQT responded to the Notice by letter dated November 17, 2025 (Response). Respondent\ncontested the alleged violations and the proposed civil penalty, and requested a hearing. EQT\nalso requested to meet informally with PHMSA to discuss the matters raised in its Response.\nPHMSA and Respondent (the Parties) subsequently met to discuss the issues raised in the\nResponses. As a result of those discussions and as explained in more detail below, the Parties\nhave agreed to a Consent Agreement (Agreement) by which PHMSA makes two findings of\nviolations. Respondent will pay a reduced civil penalty in the amount of $466,550, and\nRespondent will complete certain compliance actions.\n1 At the time of the incident, Equitrans Midstream Corporation (OPID 31604) operated the Rager Mt. UNGSF. The\nfacility is now operated by EQT Production Company (OPID 39491).\n\n\n\nDocusign Envelope ID: E3F06378-CA57-483A-8591-E2B3C17FA557 CPF No. 1-2025-033-NOPV\nPage 2\nHaving agreed that settlement of this proceeding will avoid further administrative proceedings or\nlitigation and will serve the public interest by promoting safety and protection of the\nenvironment, pursuant to 49 U.S.C. § 60101, et seq. and 49 CFR Part 190, and upon consent and\nagreement, the Parties hereby agree as follows:\nI. General Provisions:\n1. Respondent acknowledges that as the operator of the pipeline facilities subject to\nthe Notice, Respondent and its referenced pipeline facilities are subject to the jurisdiction of the\nFederal pipeline safety laws, 49 U.S.C. § 60101, et seq., and the regulations and administrative\norders issued thereunder. For purposes of this Agreement, Respondent acknowledges that it\nreceived proper notice of PHMSA’s action in these proceedings and that the Notice states a\nclaim upon which relief may be granted pursuant to 49 U.S.C. § 60101, et seq., and the\nregulations and orders issued thereunder.\n2. After Respondent returns this signed Agreement to PHMSA, the Agency’s\nrepresentative will present it to the Associate Administrator for Pipeline Safety, recommending\nthat the Associate Administrator adopt the terms of this Agreement by issuing an administrative\norder (Consent Order) incorporating the terms of this Agreement. The terms of this Agreement\nconstitute an offer of settlement until accepted by the Associate Administrator. Once accepted, the\nAssociate Administrator will issue a Consent Order incorporating the terms of this Agreement.\n3. Respondent consents to the issuance of the Consent Order, and hereby waives any\nfurther procedural requirements with respect to its issuance. Respondent waives all rights to\ncontest the adequacy of the Notice, or the validity of the Consent Order or this Agreement,\nincluding all rights to administrative or judicial hearings or appeals, except for the Dispute\nResolution provisions set forth herein. Respondent agrees to withdraw its request for an\nadministrative hearing regarding the Notice upon receipt of the Consent Order.\n4. This Agreement shall apply to and be binding upon PHMSA and Respondent, its\nofficers, directors, and employees, and their successors, assigns, or other entities or persons\notherwise bound by law. Respondent agrees to provide a copy of this Agreement and any\nincorporated work plans and schedules to all of Respondent’s officers, employees, and agents\nwhose duties might reasonably include compliance with this Agreement.\n5. This Agreement constitutes the final, complete and exclusive agreement and\nunderstanding between the Parties with respect to the settlement embodied in this Agreement.\nThe Parties acknowledge that there are no representations, agreements or understandings relating\nto settlement other than those expressly contained in this Agreement, except that the terms of this\nAgreement may be construed by reference to the Notice.\n6. Nothing in this Agreement affects or relieves Respondent of its responsibility to\ncomply with all applicable requirements of the Federal pipeline safety laws, 49 U.S.C. § 60101,\net seq., and the regulations and orders issued thereunder. Nothing in this Agreement alters\nPHMSA’s right of access, entry, inspection, and information gathering or PHMSA’s authority to\n\n\n\nDocusign Envelope ID: E3F06378-CA57-483A-8591-E2B3C17FA557 CPF No. 1-2025-033-NOPV\nPage 3\nbring enforcement actions against Respondent pursuant to the Federal pipeline safety laws, the\nregulations and orders issued thereunder, or any other provision of Federal or State law.\n7. For all transfers of ownership or operating responsibility of Respondent’s pipeline\nsystem referenced herein, Respondent will provide a copy of this Agreement to the prospective\ntransferee at least 30 days prior to such transfer. Respondent will provide written notice of the\ntransfer to the Director no later than 60 days after the transfer occurs.\n8. This Agreement does not waive or modify any Federal, State, or local laws or\nregulations that are applicable to Respondent’s pipeline systems. This Agreement is not a permit,\nor a modification of any permit, under any Federal, State, or local laws or regulations.\nRespondent remains responsible for achieving and maintaining compliance with all applicable\nFederal, State, and local laws, regulations and permits.\n9. This Agreement does not create rights in, or grant any cause of action to, any third\nparty not party to this Agreement. The U.S. Department of Transportation is not liable for any\ninjuries or damages to persons or property arising from acts or omissions of Respondent or its\nofficers, employees, or agents carrying out the work required by this Agreement. Respondent\nagrees to hold harmless the U.S. Department of Transportation, its officers, employees, agents,\nand representatives from any and all causes of action arising from any acts or omissions of\nRespondent or its contractors in carrying out any work required by this Agreement.\n10. Except as set forth herein, this Agreement does not constitute a finding of\nviolation of any other federal law or regulation and may not be used in any civil proceeding of\nany kind as evidence or proof of any fact, fault or liability, or as evidence of a violation of any\nlaw, rule, regulation, or requirement, except in a proceeding to enforce the provisions of this\nAgreement or in future PHMSA enforcement actions.\nII. Findings of Violation:\n11. Item 1 - 49 CFR § 192.12(b)(2): The Notice alleged that EQT failed to follow\nsection 8, Risk Management for Gas Storage Operations, in American Petroleum Institute\nRecommended Practice 1171 (2015) (API RP 1171) (incorporated by reference, see section\n192.7).2 Specifically, the Notice alleged that 1) EQT failed to use available information\nregarding operational characteristics, such as individual well deliverability, and previous\nintegrity issues with top joint casing corrosion at the Rager Mt. UNGSF, including at Well 2244,\nto determine susceptibility to threat and hazard-related events and to assess threat and hazard\ninteraction in accordance with section 8.3.2 in API RP 1171 and 2) EQT failed to evaluate the\npotential threat and hazard of top joint casing corrosion impacting Rager Mt.\ni. EQT asserted in its Response that it did not receive any indication that an integrity\nissue with top joint casing corrosion existed at Well 2244 prior to the incident.\n2 Section 192.7(b)(11) has since been updated to incorporate a new version of API RP 1171: API Recommended\nPractice 1171, Functional Integrity of Natural Gas Storage in Depleted Hydrocarbon Reservoirs and Aquifer\nReservoirs, 2nd edition, November 2022, including Errata 1, September 2023 (API RP 1171).\n\n\n\nDocusign Envelope ID: E3F06378-CA57-483A-8591-E2B3C17FA557 CPF No. 1-2025-033-NOPV\nPage 4\nDuring the informal meeting, EQT provided information that prior to the incident\nit had submitted numerous requests to the previous operator seeking additional\ndata on the Rager Mt. wells and when it did not receive the requested information\nfrom the previous operator, it accelerated its risk ranking on the Rager Mt. wells.\nEQT logged the wells at the Rager Mt. facility prior to the incident and the data\nprovided by the vendor did not indicate a top joint casing corrosion issue.\nii. For purposes of settlement, EQT does not contest this allegation of violation. As\nsuch, PHMSA finds a violation of 49 CFR § 192.12(b)(2).\n12. Item 2 - 49 CFR § 192.12(c): The Notice alleged that EQT failed to follow its\nmanual of written procedures for emergency preparedness and response activities. Specifically,\nthe Notice alleged that EQT failed to follow its Storage Well Emergency Response Plan, Rev-2\n(Jan. 24, 2022) by failing to design and implement a dynamic kill or other special kill procedures\nto overbalance and gain control of the well no later than seven days after the incident, or by\nNovember 12, 2022. For purposes of settlement, EQT does not contest this allegation of\nviolation. As such, PHMSA finds a violation of 49 CFR § 192.12(c).\n13. Each Item in Section II will be considered by PHMSA as a prior offense in any\nfuture PHMSA enforcement action taken against Respondent.\nIII. Warning Item:\n14. Item 3 - 49 CFR § 192.12(c): The Notice alleged that EQT failed to maintain\nrecords necessary to administer its procedures in accordance with section 192.12(c). Specifically,\nthe Notice alleged that EQT failed to maintain records required by its Storage Well Emergency\nResponse Plan, Rev-2 (Jan. 24, 2022), such as well control incident data sheets, and records from\nmeetings during the November 2022 reportable incident with attendance and action items. This\nItem was brought as a warning and does not constitute a finding of violation. EQT accepts the\nwarning as alleged.\nIV. Civil Penalty:\n15. Item 1: The Notice proposed assessing a civil penalty in the amount of $483,800\nfor Item 1. EQT requested that the proposed civil penalty be reduced or withdrawn to reflect the\nefforts EQT took prior to the incident, including accelerating the risk ranking. PHMSA agrees\nthat a reduction to the proposed civil penalty is appropriate after considering other matters that\njustice may require. Accordingly, PHMSA reduces the civil penalty to $120,950.\n16. Item 2: The Notice proposed assessing a civil penalty in the amount of $456,100\nfor Item 2. EQT requested that the proposed civil penalty be reduced to reflect, among other things,\nthat there was only one instance of a violation and its duration was shorter than alleged. PHMSA\nagrees that a reduction to the proposed civil penalty is appropriate after adjusting for the duration\nand instances of violation. Accordingly, PHMSA reduces the civil penalty to $345,600.\n\n\n\nDocusign Envelope ID: E3F06378-CA57-483A-8591-E2B3C17FA557 CPF No. 1-2025-033-NOPV\nPage 5\n17. Respondent will pay a total reduced civil penalty in the amount of $466,550,\npursuant to the payment instructions at 49 CFR § 190.227(a), to be paid in full no later than 20\ndays from the Effective Date of this Agreement.\nV. Compliance Terms:\n18. Item 1: The Notice did not include a proposed compliance order, but as a result\nof informal discussions, and in order to resolve any ongoing concerns at the Rager Mt. UNGSF,\nEQT agrees to complete the following actions:\ni. Update the risk procedure to include top joint threat interaction including casing\nthinning and Class 4 feature interaction within the top 30 feet;\nii. Revise the emergency response procedures to include all lessons learned from the\n2022 incident;\niii. Create a well gel evaluation and gelling criteria procedure;\niv. Develop a surveillance logging evaluation and criteria procedure;\nv. Add vent systems to all annuli with an inert gas blanket at Rager;\nvi. Add pressure transmitters to all annuli at Rager Mt. UNGSF for remote\nmonitoring;\nvii. Conduct a downhole assessment at Rager Mt. UNGSF during calendar year 2027\nand provide the results to the Director;\nviii. Use additional logging technology at EQT’s storage facilities when logging\nassessments are conducted in 2027; and\nix. Conduct a lessons learned presentation before the American Gas Association’s\nUnderground Natural Gas Storage Committee no later than spring 2027 and\nprovide a copy of the presentation to the Director.\nx. EQT has completed Corrective Measures (i)-(vi) in advance of the execution of\nthis Consent Agreement, and documentation has been reviewed by the Director.\nEQT agrees to complete Corrective Measures (vii)-(ix) and provide\ndocumentation of completion to the Director by December 31, 2027.\nVI. Enforcement:\n19. This Agreement is subject to all enforcement authorities available to PHMSA\nunder 49 U.S.C. § 60101, et seq., and 49 CFR Part 190, including administrative civil penalties\nunder 49 U.S.C. § 60122, of up to $272,926 per violation for each day the violation continues and\nreferral of the case to the Attorney General for judicial enforcement, if PHMSA determines that\nRespondent is not complying with the terms of this Agreement in accordance with the\ndeterminations made by the Director, or in accordance with decisions of the Associate\nAdministrator if resolved pursuant to the Dispute Resolution process herein. The maximum civil\npenalty amounts are adjusted annually for inflation. See 49 CFR § 190.223. All work plans and\nassociated schedules set forth or referenced in Section V (Compliance Terms) are automatically\nincorporated into this Agreement and are enforceable in the same manner.\nVII. Review and Approval Process:\n\n\n\nDocusign Envelope ID: E3F06378-CA57-483A-8591-E2B3C17FA557 CPF No. 1-2025-033-NOPV\nPage 6\n20. With respect to any submission under Section V (Compliance Terms) of this\nAgreement that requires the approval of the Director, the Director may: (a) approve, in whole or\nin part, the submission; (b) approve the submission on specified, reasonable conditions; (c)\ndisapprove, in whole or in part, the submission; or (d) any combination of the foregoing. If the\nDirector approves, approves in part, or approves with conditions, Respondent will take all\nactions as approved by the Director, subject to Respondent’s right to invoke the dispute\nresolution procedures with respect to any conditions the Director identifies. If the Director\ndisapproves all or any portion of the submission, the Director will provide Respondent a written\nnotice of the deficiencies. Respondent will correct all deficiencies within the time specified by\nthe Director and resubmit it for approval.\nVIII. Dispute Resolution:\n21. The Director and Respondent will informally attempt to resolve any disputes\narising under this Agreement, including any decision of the Director under the terms of Sections\nV (Compliance Terms) and VII (Review and Approval Process). If Respondent and the Director\nare unable to informally resolve the dispute within 15 calendar days after the dispute is first\nraised, in writing, to the Director, Respondent may submit a written request for a determination\nresolving the dispute from the Associate Administrator. Such request must be made in writing\nand provided to the Director, counsel for the Eastern Region, and to the Associate Administrator,\nno later than 10 calendar days from the 15-day deadline for informal resolution referenced in this\nparagraph. Along with its request, Respondent must provide the Associate Administrator with all\ninformation Respondent believes is relevant to the dispute. Decisions of the Associate\nAdministrator under this paragraph will constitute final agency action. The existence of a dispute\nand PHMSA’s consideration of matters placed in dispute will not excuse, toll, or suspend any\nterm or timeframe for completion of any work to be performed under this Agreement during the\npendency of the dispute resolution process.\nIX. Effective Date:\n22. The term “Effective Date,” as used herein, is the date on which the Consent Order\nis issued by the Associate Administrator incorporating the terms of this Agreement.\nX. Recordkeeping and Information Disclosure:\n23. Unless otherwise required in this Agreement, Respondent agrees to maintain\nrecords demonstrating compliance with all requirements of this Agreement for a period of\nat least five (5) years following completion of all work to be performed, unless a longer\nperiod of time is required pursuant to 49 CFR Parts 190-199. For any reports, plans, or other\ndeliverables required to be submitted to PHMSA pursuant to this Agreement, Respondent\nmay assert a claim of business confidentiality or other protections applicable to the\nrelease of information by PHMSA, covering part or all of the information required to be\nsubmitted to PHMSA pursuant to this Agreement in accordance with 49 CFR Part 7.\nRespondent must mark the claim of confidentiality in writing on each page, and include a\nstatement specifying the grounds for each claim of confidentiality. PHMSA determines release\n\n\n\nDocusign Envelope ID: E3F06378-CA57-483A-8591-E2B3C17FA557 CPF No. 1-2025-033-NOPV\nPage 7\nof any information submitted pursuant to this Agreement in accordance with 49 CFR Part 7, the\nFreedom of Information Act, 5 U.S.C. § 552, DOT and PHMSA policies, and other applicable\nregulations and Executive Orders.\nXI. Modification:\n24. The terms of this Agreement may be modified by mutual agreement of the Parties.\nSuch modifications must be in writing and signed by both parties.\nXII. Termination:\n25. This Agreement will remain in effect until the Civil Penalty in Section IV is paid\nin full and the Compliance Terms in Section V are satisfied, as determined by the Director. The\nAgreement shall not terminate until the Director confirms, in writing, that the Agreement is\nterminated in accordance with this paragraph. Nothing in this Agreement prevents Respondent\nfrom completing any of the obligations earlier than the deadlines provided for in this Agreement.\nXIII. Ratification:\n26. The Parties’ undersigned representatives certify that they are fully authorized to\nenter into the terms and conditions of this Agreement and to execute and legally bind such party\nto this document.\n27. The Parties hereby agree to all findings, conditions, and terms of this Agreement.\nFor EQT Production Company:\n___________________________________\nJustin Trettel, Vice President\n________________________\nDate\nFor PHMSA:\n________________________________________\nDirector, Eastern Region, Office of Pipeline Safety\n________________________\nDate","truncated":false,"body_characters":27809}