EQT

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Asset Safety and Integrity

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Topic Highlights

EQT has always taken steps to invest in the safety and integrity of our operational footprint, but our efforts have increased following the expansion of our asset base — specifically our pipelines, compressor stations, and storage wells — with the Equitrans acquisition. We prioritize using the best asset safety and environmental practices across all aspects of our operations, and we strive to meet or exceed applicable compliance regulations.

  • We combined the best practices and highest standards from EQT and the legacy Equitrans organization to create comprehensive procedures that go beyond regulatory compliance.
  • We implemented a scalable best-in-class enterprise asset management system.
  • We developed a collaborative and effective approach to asset safety and integrity between our Production, Construction, and Midstream teams.

What We Are Doing

GRI 413-2
11.15.3
Operations with significant actual and potential negative impacts on local communities
SASB EM-MD-540a.4
Discussion of management systems used to integrate a culture of safety and emergency preparedness throughout the value chain and throughout project lifecycles
GRI 413-2
SASB EM-MD-540a.4

The functionality and safety of our assets are fundamental to our business values and success. While asset safety and integrity was not reported as a material topic by EQT prior to the Equitrans acquisition, we recognize its importance has grown following the acquisition and increase in the number of our midstream assets. We continue to expand our operational goals to include pipeline safety practices that ensure our employees, contractors, and the local communities where we live and operate are protected.

By applying EQT’s best practices to acquired assets, including Management of Change and Process Safety Management, we have implemented enhanced safety and integrity procedures as well as proactive analytical measures to ensure alignment with federal, state, and industry standards. The integration of midstream and production best practices has delivered substantial additional benefits, particularly concerning asset safety and integrity. By collaborating across departments and between Midstream and Production teams, we are able to collect more data on field issues to identify trends and be more efficient and effective in our maintenance and repair work. We follow current U.S. Department of Transportation (DOT) regulations and industry standards for safe natural gas and liquid pipeline operations. We also adhere to federal U.S. DOT gas and liquid transmission pipeline integrity regulations (49 Code of Federal Regulations [CFR] Part 192, subpart O, and 49 CFR Part 195) and regularly conduct public safety assessments, demonstrating our safety culture.

In 2024, EQT adopted the Operations and Maintenance Plan (O&M Plan) that had been in place at Equitrans. The O&M Plan was updated to comply with the Protecting Our Infrastructure of Pipelines and Enhances Safety (PIPES) Act of 2020, particularly Section 114, which focuses on methane mitigation, and includes processes, procedures, and methods we currently use to eliminate leaks and minimize methane emissions.

Our commitment remains steadfast in protecting workers and communities by proactively managing asset-related incident risks and continuously improving safety practices.

Pipeline Lifecycle Phases

Design

During a pipeline’s design phase, we prioritize compliance with regulations and industry standards for safety, efficiency, and reliability, while optimizing the route to minimize impacts on sensitive areas and local communities.

Construction

During pipeline construction, we prioritize compliance over cost and conduct activity inspections and weld integrity checks to ensure high quality. During the construction process, we work with contractors who meet our high quality, safety, and performance standards which are evaluated through the ISNetworld® (ISN) digital platform on an ongoing basis. We conduct rigorous checks before new assets are approved for service such as hydrostatic pressure tests, pipe geometry inspections, and corrosion protection assessments to confirm fitness for service.

Operations

We take a fully integrated approach to safety through simultaneous operations that include the combined efforts of our Production, Construction, and Midstream teams. This unified approach enhances efficiency and response time, while promoting safety as an organization-wide priority.

Integrity Management

Our Pipeline Integrity and Field Operations teams maintain standard operating procedures, construction records, and oversight of operator qualification and training for employees and contractors. High-consequence areas are identified and managed through our pipeline integrity program to reduce the risk of public or environmental harm.

Storage Well Safety and Integrity

We conduct annual audits and inspections mandated by the Pipeline and Hazardous Materials Safety Administration (PHMSA) and state pipeline safety agencies. During 2024, we conducted additional inspections of Equitrans assets as part of the due diligence process leading up to, and following, the closing of the acquisition. Recent PHMSA audits focused on integrity management programs for underground natural gas storage. We also leveraged our downhole expertise as an upstream operator to complete multiple storage audits, assess the strength of our Storage Integrity Management Plan, address all action items, and implement improvements.

Rager Mountain Storage Facility Incident

The Rager Mountain facility, in Jackson Township, Cambria County, Pennsylvania, has operated as a storage pool since 1971 with a capacity of approximately 11,600 million cubic feet (MMcf) of natural gas. On November 6, 2022, natural gas escaped from a vent on well 2244, causing a temporary suspension of gas flow. There were no injuries or immediate public safety concerns, and venting was resolved on November 19, 2022. Equitrans, the operator of the well at the time of the incident, complied with and completed all required corrective actions outlined in the Department of Environmental Protection’s orders. EQT will continue to work with the respective state and federal agencies as it works to return the field to full operations.

Managing Asset Safety and Integrity

We use a range of risk mitigation strategies as part of our asset management and operations. Since acquiring Equitrans in July 2024, a key component of our management approach has been consolidating our tools and adopting change management practices to meet evolving regulations, including the application of EQT’s Process Safety Management (PSM) program. By aligning our operations with PSM standards, we have strengthened our safety culture and established consistent protocols throughout the organization.

We leverage field data to target high-risk areas and focus our resources on identifying and addressing potential risks. Through our digital work environment, we track and monitor field-level failures and issues, identify and address common failure points in real-time, and mitigate such matters promptly and efficiently.

We have worked extensively to integrate and refine our Standard Operating Procedures. At the end of 2024, we combined the best practices from both organizations to create comprehensive procedures that go beyond regulatory compliance. We have also focused on improving our crisis management and emergency response plans by adopting universally accepted Incident Command System principles.

In addition to strict adherence to all federal regulations, we also mandate non-destructive testing (NDT) on all pipeline welds to meet industry standards, with additional oversight from NDT auditors on large projects. Every welder must hold an EQT Welder Certification, and completed pipelines undergo hydrostatic testing above normal operating pressure to verify the integrity of all components. Importantly, our inspectors verify that our pipeline construction contractors meet qualifications and follow our Design and Construction Manual. In addition, EQT routinely audits inspectors to ensure compliance with company and applicable regulatory requirements.

We continuously evaluate PHMSA’s Mega Rule and will continue to incorporate changes in inspections, along with other actions. The Mega Rule aims to improve pipeline safety and better prepare emergency responders for incidents by:

  • Intensifying risk assessment and maximum allowable operating pressure (MAOP) requirements;
  • Expanding regulations to include gathering lines and other previously non-regulated lines; and
  • Increasing reporting requirements and safety regulations.

As part of our integration with Equitrans, we enhanced our understanding of MAOP requirements and integrated this knowledge into our processes, which positioned us for continuous improvement. We conducted supplemental investigations and performed confirmation digs for MAOP verification in compliance with the Mega Rule requirements. We also revisited our construction standards to align with industry-leading safety protocols and operational efficiency, updating plans and processes to better align with the Mega Rule. While many of our practices were already closely aligned with the new provisions, we continue to implement all Mega Rule requirements by their respective due dates.

Physical Asset Security

We recognize the importance of security to ensure safety and business continuity, particularly for our pipeline assets, compressor facilities, and project sites. As outlined in the company’s security guidelines, we are committed to providing a safe and secure environment for all employees, customers, suppliers, vendors, and guests. These guidelines, available for employee access and reference in our digital work environment, are intended to create a consistent approach to protect people, assets, and information while mitigating risks to EQT.

Our Approach to Asset Security

From both a safety and business continuity perspective, we must use stringent security measures for all our pipeline assets and project sites. We work closely with the U.S. Transportation Security Administration to ensure our enterprise abides by all federal security regulations and directives.

Asset and Operations Security, Training, and Standards

Our security guards receive thorough security training, including site-specific hazard identification. Our training program covers pipeline security, crisis response, sabotage detection, and protest management. We protect assets with fences, locks, electronic monitoring, and 24-hour surveillance. The security at construction sites is deployed according to risk level, with 24-hour guards or camera systems for high-risk sites. Additionally, we track protests and evaluate security risks on an ongoing basis. Security personnel “observe and report” and assist with evacuations when needed, with armed guards deployed only in select cases.

 


How We Are Doing

GRI 2-27
Compliance with laws and regulations
GRI 2-27

Managing Compliance

SASB EM-MD-520a.1
Total amount of monetary losses as a result of legal proceedings associated with pipeline and storage regulations
SASB EM-MD-540a.1
(1) Number of reportable pipeline incidents, (2) percentage significant
SASB EM-MD-520a.1
SASB EM-MD-540a.1

In alignment with our commitment to compliance, we prioritize transparency with local, state, and federal authorities. We continuously monitor emerging regulations and permit requirements that may impact our operations and actively submit comments on proposed regulations when appropriate, either as a company or through industry trade groups.

We believe it is equally important to be transparent when we fall short of our expectations, especially regarding asset safety and integrity. We take this responsibility seriously, responding to agency notifications and documenting our due diligence to maintain our commitment to compliance with federal and state regulations. The types of enforcement actions include Notices of Violation (NOVs), Notices of Amendment (NOAs), Notices of Proposed Safety Order, and warning letters from state utility commissions and PHMSA.

As shown in the table below, we continue to be the subject of scheduled agency audits. It is important to note that all agency audits are not equal and can range in duration from a few days to several weeks — with operators potentially receiving multiple citations in a single audit, depending upon the type of deficiencies identified. Additionally, as newly implemented regulations continue to mature, it is not uncommon to receive citations of lesser severity (i.e., warning letters or NOAs). These types of enforcement are typically non-punitive in nature and are utilized by the agencies to create awareness and provide an opportunity for the operator to update policies, plans, and procedures to more accurately align with regulations.

All audit interactions with agencies are followed by formal documentation of written findings and improvement opportunities prior to the issuance of any potential enforcement action. EQT is committed to establishing best practices and driving down enforcement actions. We continue to welcome these opportunities for continuous improvement. As we are disclosing asset safety actions and reportable incidents for the first time in this report, data prior to 2024 is not being disclosed.

Asset Safety Actions[1]
Metric 2024

Scheduled Agency Audits[2]

7

Enforcement Actions [3]

2

Total Monetary Losses from Legal Proceedings Associated with Federal Pipeline and Storage Regulations[4]

0

Managing Releases

SASB EM-MD-540a.1
(1) Number of reportable pipeline incidents, (2) percentage significant
SASB EM-MD-540a.2
Percentage of (1) natural gas and (2) hazardous liquid pipelines inspected
SASB EM-MD-540a.1
SASB EM-MD-540a.2

Our mitigation procedures and measurements are designed to ensure safety in the event of a spill or leak related to one of our assets. If a leak is detected on an asset, we work diligently to detect the location of the leak, take immediate action to make repairs, and quickly remediate any damage. Our teams conduct regular inspections of our pipelines to ensure their integrity. In 2024, approximately 29% of our regulated transmission pipelines, which are legacy Equitrans Assets, were inspected per 49 CFR 192 Subpart O requirements for High Consequence Areas. Furthermore, EQT routinely inspects additional miles of non-jurisdictional pipelines, which are not regulated by the DOT. If any areas of concern are identified during inspections, we take immediate action to maintain the integrity of the asset and ensure regulatory compliance.

When an incident occurs, we properly report all releases in line with state and federal regulations. The following table summarizes our reported incidents for pipeline and storage assets for 2024.

Releases Due to Incidents[5]
 Metric 2024

Number of Reportable Releases[6]

0

Volume of Reportable Releases (MCF)[7]

0

Percentage of Reportable Releases that were Significant Incidents[8]

0

MCF: Thousands of cubic feet


Governance

[1] The table includes scheduled agency audits and enforcement actions related to pipeline and storage assets from PHMSA and state utility commissions for January 1–December 31, 2024, for legacy EQT assets and July 22–December 31, 2024, for legacy Equitrans assets.

[2] Agency audits are reported for the year the audit occurred.

[3] Enforcement actions are reported in the year the official agency letter is received; the potential non-compliance may have occurred in a prior year.

[4] Based on the metrics for SASB requirement EM-MD-520a.1.

[5] Includes reportable natural gas incidents for the PHMSA or state utility commission regulated legacy Equitrans Assets from the time of acquisition (July 22, 2024) through the end of 2024 and natural gas and liquid incidents for the PHMSA or state utility commission regulated EQT assets for calendar year 2024. Details regarding a reportable incident that occurred immediately prior to Equitrans acquisition are not included in this table. On July 4, 2024, a reportable release occurred due to a leaking check valve where approximately 7,771 MCF of gas was released through a blowdown stack.

[6] Reportable incidents and releases are defined based on the U.S. DOT requirements in 49 CFR 191.3.

[7] Reportable incidents and releases are defined based on the U.S. DOT requirements in 49 CFR 191.3.

[8] Based on the definition of SASB requirement EM-MD-540a.1, an incident is considered significant if it resulted in fatality or injury requiring in-patient hospitalization; total costs exceeding jurisdictionally defined property damage thresholds for pipeline incident/accident reporting in local currency; highly volatile liquid releases of 5 barrels or more or other liquid releases of 50 barrels or more; or liquid releases resulting in an unintentional fire or explosion.

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