CENTRAL NEW YORK OIL AND GAS CO LLC — Notice of Amendment

case documentOfficial PDF120111008M_NOA_05232011.pdf#

case documentOfficial PDF120111008M_NOA_05232011_text.pdf#

party submissionOfficial PDF120111008M_Operator Response to NOA_06152011.pdf#

120111008M_Closure Letter_04192012_text.pdf, page 1Official PDFU.S. Department 820 Bear Tavern Road, Suite 103 Of Transportation West Trenton, NJ 08628 Pipeline and 609.989.2171 Hazardous Materials Safety Administration EXPRESS OVERNIGHT MAIL April 19, 2012 Mr. Barry Cigich Vice President Operations and Engineering Inergy Midstream, LP Two Brush Creek Boulevard, Suite 200 Kansas City, MO 64112 CPF 1-2011-1008M Dear Mr. Cigich: On September 15, 2008, an inspector from the New York State Department of Public Service (NYSDPS), acting as agents for the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Central New York Oil & Gas (CNYOG) pipeline facilities in Owego, NY. As a result of the inspection, CNYOG was issued an NOA on May 23, 2011. The NOA required CNYOG to amend certain procedures in its written operations and maintenance (O&M) manual. On June 15, 2011, PHMSA received CNYOG’s existing procedures in response to the referenced NOA, which CNYOG believed addressed the NOA. Based on our review, we determined the existing procedures are still inadequate; specifically, CNYOG did not adequately address atmospheric corrosion monitoring requirements in the existing O&M procedures, or in the CNYOG form to be completed when atmospheric corrosion is discovered. As a result of our review, CNYOG was issued a Region response for information letter on December 28, 2011, notifying CNYOG that the existing procedures PHMSA received on June 15, 2011, are still inadequate. On February 13, 2012, PHMSA received via e-mail CNYOG amended procedures in a response dated January 25, 2012. On March 1, 2012, a member of my staff sent Mr. John Shaffer of CNYOG an e-mail that provided PHMSA public guidance information indicating that the amended CNYOG procedures appeared to still be inadequate; specifically, CNYOG did not adequately address atmospheric#

120111008M_Closure Letter_04192012_text.pdf, page 2corrosion monitoring requirements as required in §192.481(c): “If atmospheric corrosion is found during an inspection, the operator must provide protection against the corrosion as required by §192.479 (c).” The CNYOG amended procedures appeared not to comply with the actions required by §192.479 (c) by excluding adequate atmospheric corrosion protection at soil- to-air interfaces. On March 26, 2012, PHMSA received CNYOG amended procedures in a response dated March 23, 2012. 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, Byron E. Coy, P.E. Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Cc: Mr. Kevin Speicher, NYS DPS#