"SALTVILLE GAS STORAGE COMPANY, L.L.C."

Incident Narrative

"ON NOVEMBER 25TH, 2023, AT 10:45 A.M. ET, SALTVILLE GAS STORAGE COMPANY, LLC (""SALTVILLE GAS"" OR THE ""COMPANY"") RECEIVED A CALL FROM A LANDOWNER REPORTING A HISSING SOUND EMANATING FROM HIS PRIVATE WATER WELL. THIS WAS THE EARLIEST INDICATION THAT SALTVILLE GAS HAD OF A GAS RELEASE POTENTIALLY RELATED TO ITS STORAGE FIELD, WHICH IS WHY IT IS IDENTIFIED AS THE INCIDENT DATE/TIME IN A4 AND THE DATE/TIME THAT A ""FAILURE"" WAS IDENTIFIED IN A13 OF THIS REPORT. THE COMPANY'S INVESTIGATION IS ONGOING, HOWEVER, AND IT HAS NOT YET IDENTIFIED AN EQUIPMENT OR OTHER FAILURE AS A CONTRIBUTING FACTOR TO THIS EVENT. SALTVILLE GAS TOOK PROMPT ACTION TO INVESTIGATE THE NOVEMBER 25, 2023, NOTIFICATION FROM THE LANDOWNER, AS WELL AS THE LANDOWNER'S NOVEMBER 26, 2023, REPORT OF INTERMITTENT BUBBLING AT COVE CREEK. THE COMPANY DID NOT CONFIRM THAT THE STORAGE FIELD WAS LIKELY THE SOURCE OF THE GAS UNTIL JANUARY 30, 2024, THE DATE AN INCIDENT WAS REPORTED TO THE NATIONAL RESPONSE CENTER (NRC) IN ACCORDANCE WITH PHMSA REPORTING CRITERIA. ON NOVEMBER 26, 2023, OPERATIONS PERSONNEL BEGAN AN EARLY WITHDRAWAL FROM THE UNDERGROUND STORAGE FIELD TO REDUCE THE PRESSURE IN THE FIELD, A DAY EARLIER THAN WITHDRAWAL HAD PREVIOUSLY BEEN PLANNED. IN THE SUCCEEDING WEEKS, SALTVILLE GAS CLOSELY MONITORED FIELD PRESSURE AND ANY EVIDENCE OF GAS AT THE LANDOWNER'S PROPERTY, AND IT GATHERED AND ANALYZED GAS SAMPLES FROM THE LANDOWNER'S WATER WELL TO CONFIRM THE RELEASE SOURCE. ON JANUARY 30TH, 2024, A GAS SAMPLE ANALYSIS REPORT CONFIRMED THAT THE GAS DISCOVERED IN THE LANDOWNER'S WATER WELL LIKELY ORIGINATED FROM THE STORAGE FIELD. AT THAT TIME, SALTVILLE GAS DEEMED THE EVENT SIGNIFICANT WITHIN THE MEANING OF THE PHMSA ""INCIDENT"" DEFINITION (SEE 49 CFR 191.3(3)) EVEN THOUGH IT DID NOT MEET THE OTHER INCIDENT CRITERIA UNDER 49 CFR 191.3(1) OR (2). THEREFORE, ON JANUARY 30TH, 2024, AT 9:59 A.M. ET, SALTVILLE STORAGE NOTIFIED NRC. SUPPLEMENTAL 07/16/2025 ON APRIL 22, 2024, SALTVILLE GAS CONDUCTED NITROGEN PRESSURE TESTS ON STORAGE WELLS EH-87, EH-90 AND EH-93. RESULTS FROM THESE TESTS WERE NOT AVAILABLE IN TIME TO BE INCLUDED IN THE INITIAL 30-DAY INCIDENT REPORT SUBMITTED ON FEBRUARY 28TH. BOTH WELLS EH-87 AND EH-90 WERE ABLE TO MAINTAIN PRESSURE FOR THE DURATION OF THE TESTING PERIOD, INDICATING EACH WELLS' PRODUCTION CASING WAS INTACT. HOWEVER, INITIAL TEST PRESSURES AT WELL EH-93 WOULD NOT STABILIZE, AND PRESSURE DROPPED OFF STEADILY, INDICATING THAT EH-93'S PRODUCTION CASING WAS COMMUNICATING WITH SUBSURFACE. (PLEASE NOTE THAT SINCE DECEMBER 10, 2023, EH-93 HAS BEEN ISOLATED BY DOWNHOLE TEMPORARY PLUGS). ON APRIL 7, 2025, SALTVILLE GAS COMPLETED ALL PLUG AND ABANDONMENT WORK ON WELL EH-93. THE AFFECTED CASING WAS REMOVED AND SENT TO A THIRD-PARTY LABORATORY FOR ANALYSIS. THIRD-PARTY METALLURGICAL TEST RESULTS CONFIRMED THAT THE THROUGH-WALL DEFECT WAS PRIMARILY CAUSED BY MICROBIOLOGICALLY INFLUENCED EXTERNAL CORROSION."