# HONEOYE STORAGE CORP — Notice of Amendment

**Citation:** CPF 120181022M  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2018-10-29

CLOSED notice of amendment citing 192.12(e).

## Document text

Notice of Amendment involving HONEOYE STORAGE CORP. PHMSA's enforcement data identifies the cited regulation as 192.12(e). The case was opened on 2018-10-29 and is reported as closed as of 2018-12-07. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120181022M_Closure Letter_12072018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181022M/120181022M_Closure%20Letter_12072018.pdf

120181022M_Closure Letter_12072018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181022M/120181022M_Closure%20Letter_12072018_text.pdf

120181022M_Notice of Amendment_10292018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181022M/120181022M_Notice%20of%20Amendment_10292018.pdf

120181022M_Notice of Amendment_10292018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181022M/120181022M_Notice%20of%20Amendment_10292018_text.pdf

120181022M_Operator Response to Notice_11272018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181022M/120181022M_Operator%20Response%20to%20Notice_11272018.pdf

120181022M_Closure Letter_12072018_text.pdf

OVERNIGHT EXPRESS DELIVERY
December 7, 2018
Mr. Scott Warnshouse
General Manager Operations
Honeoye Storage Corp.
4511 Egypt Road
Canandaigua, NY 14424
CPF 1-2018-1022M
Dear Mr. Warnshouse:
From June 19-21, 2018, a representative from the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site
pipeline safety inspection of Honeoye Storage Corp. (Honeoye) procedures at Honeoye
Underground Natural Gas Storage field in Ontario County, New York.
As a result of the inspection, Honeoye was issued a Notice of Amendment on October 29, 2018,
which proposed amendments of your procedures.
Honeoye submitted its amended procedures on November 27, 2018. My staff reviewed the
amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment
have been corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration

120181022M_Notice of Amendment_10292018_text.pdf

NOTICE OF AMENDMENT
OVERNIGHT EXPRESS DELIVERY
October 29, 2018
Mr. Scott Warnshouse
General Manager Operations
Honeoye Storage Corp.
4511 Egypt Road
Canandaigua, NY 14424
CPF 1-2018-1022M
Dear Mr. Warnshouse:
From June 19 to 21, 2018, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected
Honeoye Storage Corp. (Honeoye) procedures and records for the Honeoye Underground Natural
Gas Storage field in Ontario County, New York.
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
Honeoye’s plans or procedures, as described below:
1. § 192.12 Underground natural gas storage facilities.
(e) Operators of underground gas storage facilities must establish and follow written
procedures for operations, maintenance, and emergencies implementing the
requirements of API RP 1170 and API RP 1171, as required under this section,
including the effective dates as applicable, and incorporate such procedures into their
written procedures for operations, maintenance, and emergencies established
pursuant to §192.605.
Honeoye’s procedures for operations, maintenance and emergencies implementing the
requirements of API RP 1170 and API RP 1171 were inadequate. Specifically, Honeoye’s
procedures do not define an annular pressure threshold to determine if additional evaluation is
required in accordance with API RP 1171, Section 9.3.2.



CPF 1-2018-1022M
2. § 192.12 Underground natural gas storage facilities.
(e) Operators of underground gas storage facilities must establish and follow written
procedures for operations, maintenance, and emergencies implementing the
requirements of API RP 1170 and API RP 1171, as required under this section,
including the effective dates as applicable, and incorporate such procedures into their
written procedures for operations, maintenance, and emergencies established
pursuant to §192.605.
Honeoye’s procedures for operations, maintenance and emergencies implementing the
requirements of API RP 1170 and API RP 1171 were inadequate. Specifically, Honeoye does not
have a procedure to verify all applicable staff receive training in the use of the emergency
preparedness/response plan in accordance with API RP 1171, Section 10.6.2.
3. § 192.12 Underground natural gas storage facilities.
(e) Operators of underground gas storage facilities must establish and follow written
procedures for operations, maintenance, and emergencies implementing the
requirements of API RP 1170 and API RP 1171, as required under this section,
including the effective dates as applicable, and incorporate such procedures into their
written procedures for operations, maintenance, and emergencies established
pursuant to §192.605.
Honeoye’s procedures for operations, maintenance and emergencies implementing the
requirements of API RP 1170 and API RP 1171 were inadequate. Specifically, Honeoye does not
have a procedure to measure the effectiveness of operator familiarity with emergency plans and
procedures and periodic testing of the effectiveness of the plan in accordance with API RP 1171,
Section 11.4.2.
4. § 192.12 Underground natural gas storage facilities.
(e) Operators of underground gas storage facilities must establish and follow written
procedures for operations, maintenance, and emergencies implementing the
requirements of API RP 1170 and API RP 1171, as required under this section,
including the effective dates as applicable, and incorporate such procedures into their
written procedures for operations, maintenance, and emergencies established
pursuant to §192.605.
Honeoye’s procedures for operations, maintenance and emergencies implementing the
requirements of API RP 1170 and API RP 1171 were inadequate. Specifically, Honeoye does not
have a procedure for the joining of API and ANSI flanges as observed in the field portion of the
inspection, in accordance with API RP 1171 Section 11.2.1.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as
part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance
Proceedings. Please refer to this document and note the response options. Be advised that all
material you submit in response to this enforcement action is subject to being made publicly
available. If you believe that any portion of your responsive material qualifies for confidential
120181022M_Notice of Amendment_10292018_text Page 2 of 3



CPF 1-2018-1022M
treatment under 5 U.S.C. 552(b), along with the complete original document you must provide a
second copy of the document with the portions you believe qualify for confidential treatment
redacted and an explanation of why you believe the redacted information qualifies for confidential
treatment under 5 U.S.C. 552(b).
Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of
receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice
and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice
without further notice to you and to issue an Order Directing Amendment. If your plans or
procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans
or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this
Notice, we propose that you submit your amended procedures to my office within 90 days of
receipt of this Notice. This period may be extended by written request for good cause. Once the
inadequacies identified herein have been addressed in your amended procedures, this enforcement
action will be closed.
It is requested (not mandated) that Honeoye maintain documentation of the safety improvement
costs associated with fulfilling this Notice of Amendment (preparation/revision of plans,
procedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and
Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer
to CPF 1-2018-1022M and, for each document you submit, please provide a copy in electronic
format whenever possible.
Please note, the address for the PHMSA Eastern Region, Office of Pipeline Safety, has changed:
PHMSA, Eastern Region, Office of Pipeline Safety
840 Bear Tavern Road, Suite 300
West Trenton, NJ 08628
Please make a note of this new information in your records. If you have any questions, please
contact us at 609-771-7800.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
120181022M_Notice of Amendment_10292018_text Page 3 of 3

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/120181022M>
- Source ID: `phmsa-enforcement`
- SHA-256: `ea878ea2e842778247b31c8694a6dfa399e70e42e0a457e3cdd940bdef96ffec`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-25T05:04:10.956Z
- Document slug: `phmsa-enforcement-120181022m`

### Source metadata

```json
{
  "cpf": "120181022M",
  "operator": "HONEOYE STORAGE CORP",
  "region": "Eastern",
  "pipelineType": "GAS INTERSTATE ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "192.12(e)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 5,
  "attachments": [
    {
      "name": "120181022M_Closure Letter_12072018.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/120181022M/120181022M_Closure%20Letter_12072018.pdf",
      "bytes": 67059,
      "category": "agency_document"
    },
    {
      "name": "120181022M_Closure Letter_12072018_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/120181022M/120181022M_Closure%20Letter_12072018_text.pdf",
      "bytes": 80979,
      "category": "agency_document"
    },
    {
      "name": "120181022M_Notice of Amendment_10292018.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/120181022M/120181022M_Notice%20of%20Amendment_10292018.pdf",
      "bytes": 277034,
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    {
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      "bytes": 303565,
      "category": "agency_document"
    },
    {
      "name": "120181022M_Operator Response to Notice_11272018.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/120181022M/120181022M_Operator%20Response%20to%20Notice_11272018.pdf",
      "bytes": 691525,
      "category": "party_submission"
    }
  ],
  "extractedAgencyDocumentCount": 2,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "HONEOYE STORAGE CORP"
}
```
