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

- **operation:** document
- **citation:** CPF 120111008M
- **title:** CENTRAL NEW YORK OIL AND GAS CO LLC — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2011-05-23
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 192.605(b)(2).
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-120111008m.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-120111008m
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120111008M
**body:**

Notice of Amendment involving CENTRAL NEW YORK OIL AND GAS CO LLC. PHMSA's enforcement data identifies the cited regulation as 192.605(b)(2). The case was opened on 2011-05-23 and is reported as closed as of 2012-04-19. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120111008M_Closure Letter_04192012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120111008M/120111008M_Closure%20Letter_04192012.pdf

120111008M_Closure Letter_04192012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120111008M/120111008M_Closure%20Letter_04192012_text.pdf

120111008M_NOA_05232011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120111008M/120111008M_NOA_05232011.pdf

120111008M_NOA_05232011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120111008M/120111008M_NOA_05232011_text.pdf

120111008M_Operator Response to NOA_06152011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120111008M/120111008M_Operator%20Response%20to%20NOA_06152011.pdf

120111008M_Closure Letter_04192012_text.pdf

U.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



corrosion 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
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