Our Approach to Pipeline Safety and Integrity
At Equitrans, the functionality and safety of our pipelines is crucial to our business values and success. The primary goal of our pipeline safety practices is to protect our employees, contractors, and the local communities where we live and operate. Our pipelines are operated, maintained, and repaired in accordance with current U.S. Department of Transportation (DOT) regulations and industry standards for safe pipeline operations, including the American Society of Mechanical Engineers’ Gas Transmission and Distribution Piping Systems Standard and the American Petroleum Institute’s Recommended Practices 80 for Onshore Gas Gathering Lines. We adhere to federal gas transmission pipeline integrity regulations (DOT 192, subpart O) and regularly complete public safety assessments, such as pipeline encroachment and leak surveys, confirmation excavations, and materials testing to ensure asset integrity on both high-pressure gathering and transmission assets. As we strive to exceed regulations, these supplemental assessments, while not always required by federal or state government agencies on non-jurisdictional assets, are an important part of our safety culture.
Additionally, a congressional methane mandate was issued to the Pipeline and Hazardous Materials Safety Administration (PHMSA) in 2021 to require pipeline operators to update policies, plans, and procedures to include mechanisms and work procedures that document how methane is being mitigated across our system. This industrywide requirement is above and beyond the rules set forth by traditional environmental regulators.
Equitrans is committed to working with our agencies to embed our environmentally conscious practices into pipeline safety documentation. In 2021, we proactively invested approximately $3.1 million in related pipeline safety initiatives and $1.59 million in corrosion prevention activities. The 2021 compliance budget was increased by approximately $500,000 due to the incorporation of storage integrity management. In addition to traditional in-line inspection and corrosion activities, the budget now accounts for an accelerated well-logging schedule, risk management of storage wells, additional PHMSA audits and inspections, and well remediation costs.
As a result of our continued commitment to meeting and exceeding compliance requirements, we strive to manage the risk and probability of a serious pipeline or storage incident to better protect our workers and local communities. Additionally, we have developed our own detailed internal safety procedures for pipeline design, construction, operation, and maintenance. During these lifecycle phases, we proactively integrate preventive measures to enhance the safety of our employees, contractors, and community members.
Lifecycle Phases
Design
During a pipeline’s design phase, we take every opportunity to embed safety practices. This process starts with extensively evaluating applicable federal, state, and local regulations and then adapting the design components and procedures to meet those regulations. When designing, we also ensure the pipeline and its supporting infrastructure are consistent with industry standards and best practices for asset safety, efficiency, and reliability.
We also incorporate external factors in the design phase, as the pipeline itself is not our sole focus. Equitrans proactively optimizes a pipeline’s route to avoid, wherever possible, sensitive environmental and cultural areas, as well as unforeseen impacts to local communities.
Construction
Throughout a pipeline’s construction, it is critical that we make every effort to confirm that the pipeline is properly constructed and installed in accordance with our high compliance standards. To do this, we inspect all activities both during construction and upon completion to verify the safety and integrity of the pipeline and to ensure proper installation procedures were utilized. One crucial aspect of this inspection process is the examination of welds to confirm their integrity before the pipeline is operational.
Last, before a pipeline is approved and placed into service, we extensively assess the asset to confirm its fitness for service. We test by using regulatorily accepted integrity checks prior to the introduction of gas into the pipeline, including hydrostatic pressure tests and pipe geometry inspections (e.g., pigging) to check for dents and ovality. When applicable, cathodic protection and voltage gradient surveys are also utilized to confirm the effectiveness of corrosion protection systems.
Operations
Equitrans’ priority is maintaining pipeline safety and functionality throughout its entire operation. To ensure this, we monitor pipelines and supporting assets while operating to detect any pipe shifts or potential disturbances. Employees in our state-of-the-art Gas Control Center control, monitor, and analyze our pipelines’ natural gas flow 24 hours a day, seven days a week. The Center enables us to quickly identify and respond to any potential issues that may arise, and resolve those issues as soon and as safely as possible.
Equitrans mitigates the risk of corrosion on a pipeline through industry-standard cathodic protection system maintenance, which applies impressed electrical current to the pipeline to inhibit corrosion on our assets. This is accomplished by installing sacrificial anodes and ground beds along the pipeline route, which are designed to corrode at known rates, in lieu of the pipeline. Other corrosion prevention strategies we deploy include routine sampling to quickly identify if corrosion is occurring, as well as flow controls to limit excessive gas velocities within the pipeline, which can often contribute to erosion of the pipe.
Our landslide management program outlines landslide inspection frequency and response time following weather-related events to help ensure that pipeline integrity concerns are discovered and addressed in a timely manner. Equitrans’ engineering team monitors rainfall data and freeze/thaw cycles in our operating areas to ensure adequate pipeline inspections are being conducted to determine impacts of known slides on our pipeline systems. Semi-annually, Equitrans conducts light detection and ranging (LiDAR) data collection on the majority of our pipeline systems to determine any new slides that may have occurred on the pipeline rights-of-way (ROW). Additionally, for any pipeline that is suspected to have been subject to movement, we perform a strain analysis and develop a monitoring plan, which may include baseline surveys, staking, and subsequent drone monitoring to track any shifting of the pipe.
Another important strategy we leverage to evaluate pipeline safety is maintaining pipeline right-of-way (ROW). In addition to routine, on-the-ground safety inspections, it is important to keep the ROW open and clear to easily conduct aerial safety patrols using helicopters and drones. When our Gas Control Center or inspections teams identify a safety or maintenance concern, we act swiftly to remediate it. Our internal operations and maintenance program teams work together to promptly mitigate and resolve any issues to ensure the integrity and longevity of our operational assets.
Integrity Management
The preparation for and mitigation of a potential pipeline issue are vital to ensuring operations are safe, and we have strategies in place to execute this plan. Equitrans’ compliance, corrosion, and technical training departments (pipeline integrity) and field operations team’s primary responsibilities focus on managing pipeline integrity. The groups evaluate and maintain standard operating policies, procedures, and pipeline construction records. The pipeline integrity department and field operations team oversee the Operator Qualification Program and other relevant trainings for employees and contractors, which empower workers to identify and mitigate potential pipeline integrity risks.
Additionally, the groups utilize industry-accepted formulas on pipeline characteristics to identify high-consequence areas that have a potential to affect local populations, buildings, and land near the pipeline route. The teams also utilize a GIS-based (Geographic Information System) risk model to implement strategies to improve the health of the system. Equitrans’ pipeline integrity group also evaluates corrosion, participates in government audits, performs internal audits, and reviews pressure tests when applicable.
To fulfill specific regulatory obligations by government agencies, Equitrans conducts annual audits and inspections required by PHMSA and state pipeline safety agencies. In recent years, PHMSA has conducted focused audits on Storage Integrity Management programs due to prior industry incidents. These very intense, detailed audits emphasize both public safety and environmental impacts of storage methane release. Under PHMSA’s direction, Equitrans conducted numerous storage audits from 2018 through 2021 to gauge the strength of our Storage Integrity Management Plan (SIMP) and its adherence to published code. In 2021, the Integrity Team addressed all cited deficiencies to improve the SIMP, and instituted the following enhancements to storage operations:
- Mitigation of risk by changing the frequencies of well surveillance logging from every 15 years to every seven years
- Utilization of Remote Terminal Units on storage wells for 24-hour monitoring by Gas Control
- Development and implementation of storage-specific procedures to standardize storage maintenance and operations activities across the Company
- Dedicating personnel trained specifically for storage operations
To date, Equitrans has remediated all known bare steel transmission pipelines with coated steel pipe to increase integrity and reduce incident risks. Bare steel lacks a protective coating, making the steel more sensitive to environmental impacts, such as corrosion, and requires constant maintenance and assessments to ensure the pipelines remain in good working order. Coated steel has a protective outer layer which makes the pipe more durable, while also requiring less maintenance and increasing cost effectiveness over the long term.
Pipeline Security
Ensuring the safety and integrity of our pipelines also requires that we stay informed of security-related risks and act diligently to reduce these risks as well as any potential dangers. We safeguard our assets through meticulous security planning and on-site strategies including fences, building locks, electronic monitoring, and continuous surveillance. For more information, see the Security and Cybersecurity section of this report.
Slip Prevention Plan
Slips occur when land shifts from a stable to an unstable condition, which could potentially affect the integrity of our pipe. An unstable condition is caused by environmental disturbances, such as soil erosion or excessive rainfall or snowmelt, loosening the soil either underground or on top of our pipelines. Prior to commencing construction, Equitrans analyzes the proposed pipeline site with ground and aerial surveys, historical landslide mapping, and soil maps to identify landslide-prone soils — all of which help to minimize the risk of slippage and environment disturbance.
Once in the operational phase, we utilize ground surveys, drones, GIS, and data analysis to monitor soil movement and identify pipeline slips, and our compliance team conducts aerial surveys bi-annually. Engineering teams identify areas where slip risks occur along our pipelines and notifies our compliance and operations teams of the risk severity. If a site is determined to have a high risk of slippage, our engineering team will conduct on-site surveys and, when necessary, implement measures to ensure our pipelines remain stable.
Managing Releases
Our mitigation procedures and measurements are designed to ensure safety in the event of a pipeline spill or leak. If a pipeline spill or leak occurs, we work diligently to quickly detect its location, take action to repair it, and remediate any damage.
Our pipeline integrity team conducts regular inspections of our pipelines to ensure their integrity and identify any potential spills and leaks. In 2021, 16.4% of our natural gas transmission pipelines were inspected per 49 CFR 192 Subpart O requirements for High Consequence Areas (HCA). Further, Equitrans routinely inspects additional miles of non-jurisdictional pipelines, which are not regulated by the DOT, with industry-leading technologies to reduce the overall risk to our communities, stakeholders, and employees. If any areas of concern are identified during inspections, we take immediate action to make repairs and enhancements to maintain integrity of the asset and ensure regulatory compliance.
When a leak occurs, Equitrans properly reports all releases in line with state and federal regulations. We track all releases that occur and gather data to identify any trends and long-term items of concern that could require technical solutions from our engineering team.
|
Natural Gas Incidents1
|
2019
|
20204
|
2021
|
|
Number of Reportable Incidents2
|
2
|
0
|
0
|
|
Volume of Reportable Releases (MCF)2
|
19,900
|
0
|
0
|
|
Percentage Reportable Incidents That Were Significant3
|
0%
|
0%
|
0%
|
Equitrans regularly evaluates our processes to limit leaks and releases from our operations. We look for areas to improve and learn from past projects to better mitigate the risk of future leaks. We track data for all leaks and releases at each of our stations and along all of our pipeline assets, and our operations team periodically reviews our data to identify patterns and implement solutions to mitigate and avoid future impacts. This process involves a proactive and regimented aerial and foot patrol program following U.S. DOT guidelines.
Managing Compliance
In alignment with our commitment to meet or exceed compliance regulations, it is our goal to always be transparent when interacting with local, state, and federal authorities. We routinely track and evaluate all emerging and changing regulations and permit requirements that may impact Equitrans’ business and operations. Where appropriate, we actively submit comments based on our evaluations of proposed regulations, as a Company or through the industry trade groups of which we are members.
Equitrans believes it is equally important to be transparent when we do not live up to our expectations, and especially so when we fall short of federal, state, or local requirements for pipeline safety and integrity, and environmental compliance. As a responsible company, Equitrans responds to all agency notifications to keep a record of our due diligence and commitment to compliance. As an additional means of responsibility and to ensure transparency, in early 2021 we implemented our Notices of Violation (NOV) Tracker to publicly disclose Equitrans’ formal notices of non-compliance and violations. The tracker, which is routinely updated and published on the Sustainability page of our website, summarizes our compliance data and allows us to be measured not just by the words we use, but by the actions we take. The NOV Tracker includes Pipeline Safety Enforcement Actions, which include NOVs, Notices of Amendment and Warning Letters from state utility commissions and the DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA).
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., Letter of Concern, Warning Letter, or Notice of Amendment). These types of enforcements are typically non-punitive in nature and are utilized by the agencies to create an awareness and opportunity for the operator to update policies, plans, and procedures to more accurately align with regulations.
As shown in the table below, there has been a steady increase in the number of scheduled audits, which is a direct correlation to the increase in enforcement actions. The post-audit interaction between agencies and operators is also changing, with the process now including formal documentation of written findings and improvement opportunities prior to the issuance of an enforcement action. Our pipeline integrity and compliance department strives to achieve zero enforcement actions by any agency and welcomes these opportunities for continuous improvement.
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Pipeline Safety Actions1
|
2019
|
2020
|
2021
|
|
Scheduled Agency Audits
|
4
|
9
|
18
|
|
Enforcement Actions
|
0
|
2
|
3
|
|
Penalties Paid Associated With Enforcement Actions
|
$0
|
$0
|
$0
|
|
Total Monetary Losses From Legal Proceedings Associated With Federal Pipeline and Storage Regulations
|
$0
|
$0
|
$0 |
Maintaining Pipeline Safety and Integrity
Equitrans utilizes a range of risk mitigation strategies as part of our pipeline asset management operations. In addition to strict adherence to all federal regulations, we require that non-destructive tests (NDT) be performed on all pipeline welds to ensure they meet industry requirements for acceptability. On large projects, we hire NDT auditors as supplemental oversight for additional review and verification. Every welder performing work on our pipelines must hold an Equitrans welder certification to ensure welding follows our procedures and best practices. Completed pipelines are hydrostatically tested significantly above the normal operating pressure to ensure integrity of all components. Data logging software is utilized to record critical data points during testing; this information is reviewed by our engineering team to verify testing meets all specifications and requirements. In 2021, Equitrans installed eight remote terminal devices at our storage facilities to enhance our real-time data gathering capabilities. These electronic devices send hardware data to our operational control systems every three to five minutes.
Additionally, our inspectors verify that contractors building our pipelines have qualified workers who follow our Design and Construction Manual and other procedures. While many of our inspectors possess industry-recognized certifications for their crafts, Equitrans’ inspectors are required to complete in-house training on our Company’s specifications to ensure pipeline construction meets both our standards, as well as those of the federal government. These training modules educate inspectors on Equitrans’ best practices and required procedures for pipeline inspections. In addition to focused training efforts, inspectors are routinely audited in the field to ensure projects are being completed following Company and applicable regulatory requirements.
In 2021, Equitrans continued evaluating the requirements of PHMSA’s Mega Rule and began to incorporate changes in inspections, along with other actions, to prepare for the additional provisions as outlined in the Rule. Through three main elements, the Mega Rule was designed to improve pipeline safety and better prepare emergency responders for incidents by:
- Intensifying risk assessment and maximum allowable operating pressure requirements
- Expanding integrity management program regulations to gathering lines and other previously non-regulated lines
- Increasing reporting requirements and safety regulations
