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Document Accession #: 20240510-5087 Filed Date: 05/10/2024

Mountain Valley Pipeline


2200 Energy Drive
Canonsburg, PA 15317
844-MVP-TALK
mail@mountainvalleypipeline.info

May 10, 2024

To whom it may concern –

With the final stages of construction nearing an end, Mountain Valley Pipeline, LLC (Mountain Valley) is focused on
safely completing the remaining work and conducting all required pre-commissioning activities, including all
testing and safety measures that are needed to safely place the Mountain Valley Pipeline (MVP) into service. In an
attempt to derail and continue to delay completion of the project, those opposed to the MVP have been focused
on spreading misinformation and unfounded speculation. Recent allegations by several known project opponents
have been rife with inaccuracies that demand the record be set straight for the benefit of the public. Therefore,
Mountain Valley submits this letter in response to the recent spate of public misinformation about, and
mischaracterizations of, the MVP project and its pre-commissioning activities.

As of April 30, 2024, Mountain Valley had successfully completed hydrostatic testing for 269 miles of the project’s
303-mile route. As a quality assurance measure, this testing is prescribed by the U.S. Pipeline and Hazardous
Materials Safety Administration (PHMSA) and involves the use of water to pressure test the pipe for a specified
time period. Using water, hydrostatic testing exposes all pipeline components to a pressure that exceeds the
maximum allowable operating pressure (MAOP) to ensure all components will operate safely prior to the
introduction of gas into the pipeline.

On Wednesday, May 1, Mountain Valley notified appropriate federal and state agencies of a hydrostatic testing
failure at Milepost 245.95. To be clear – Mountain Valley was following all testing protocols to pressurize the pipe
in a manner that exceeds the project’s MAOP – and the pipe failed the test. The component that failed did so at a
pressure substantially above the MAOP, and the failure occurred prior to the completion of the test. The failure
demonstrates the critical importance of conducting hydrostatic testing to ensure the integrity of the pipeline in
advance of in-service operations. Since that time, Mountain Valley has successfully performed hydrostatic testing
on additional segments, including the repaired segment where the disruption occurred, without incident.

For completeness, Mountain Valley also reported that the failed test resulted in the release of water from the
project’s limit of disturbance (LOD) and caused temporary turbidity in nearby streams. While the water used for
this hydrostatic test was municipal water, Mountain Valley assumed full accountability for the water release and
any environmental disruption. Within less than 24 hours of the disruption, the released water had dissipated and
tributaries had returned to their pre-hydrostatic testing conditions.

Opponents have vigorously, albeit erroneously, claimed that the result of this particular hydrostatic test warrants
safety concerns; however, this single test result demonstrates the exact opposite conclusion. In fact, the result of
this testing failure, along with Mountain Valley’s transparent reporting and remedial action, demonstrate that
process is working as designed and intended. To reiterate, hydrostatic testing is a proof test to ensure all pipeline
components will safely operate at the MAOP prior to introducing gas into the pipeline.

It is important for the public to know that Mountain Valley is committed to the safe and responsible construction
and operation of the MVP project, and hydrostatic testing is one component of a robust inspection and testing
process designed to ensure system integrity. The efforts of project opponents to stretch their narrative in support
of their own agenda does not, and should not, undermine the facts of this situation, nor the confidence in or
integrity of the MVP project.
Document Accession #: 20240510-5087 Filed Date: 05/10/2024

Mountain Valley has undergone an unprecedented level of scrutiny and worked collaboratively and productively
with state and federal agencies to build this project according to rigorous and stringent protocols.
• Since MVP construction resumed in 2023, state and federal agencies and appointed third parties have
conducted more than 7,000 environmental inspections.
• Since July 2023, PHMSA and the Virginia State Corporation Commission (PHMSA’s agent in Virginia) have
conducted more than 80 in-field inspection visits, all of which have been multiple days and many of which
have involved multiple inspectors. PHMSA and the Virginia SCC have also conducted intensive and
ongoing auditing of Mountain Valley’s reports, records, and procedures.
• Overall, since construction began in February 2018, there have been more than 47,800 state, federal, and
third-party environmental inspections and more than 72,000 inspections by MVP’s internal environmental
team.

More than 300,000 miles of interstate and intrastate natural gas transmission pipelines operate every day across
the U.S., safely and reliably transporting natural gas for use in homes, businesses, and power generation.
Mountain Valley will soon be a critical part of that network, providing greater access to affordable energy needed
to power modern life and helping to achieve a lower-carbon energy future.

As the project nears completion, Mountain Valley will continue performing its due diligence, working with state
and federal regulators and complying with all legal and regulatory requirements, including upholding its
obligations to satisfy all requirements of the PHMSA Consent Agreement that are necessary for the MVP to enter
service.

Respectfully,

Todd L. Normane
Senior Vice President and MVP Legal Counsel
Equitrans Midstream Corporation

cc: FERC Docket Nos. CP16-10-000, CP21-57-00


Document Accession #: 20240510-5087 Filed Date: 05/10/2024

Document Content(s)
Public_Letter Hydrotest Disruption Response May 2024 FINAL.pdf............1

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