IROQUOIS GAS CORP — Notice of Probable Violation

party submissionOfficial PDF120121026_Operator_Response_and_Request_for_Time_Extension_01162013.pdf#

120121026_Closure Letter_09302013_text.pdf, page 1Official PDFU.S. Department Of Transportation Pipeline and 609.989.2171 Hazardous Materials Safety Administration 820 Bear Tavern Road, Suite 103 West Trenton, NJ 08628 OVERNIGHT EXPRESS MAIL September 30, 2013 Mr. Jeffrey A. Bruner, President Iroquois Pipeline Operating Company One Corporate Drive, Suite 600 Shelton, CT 06484 CPF 1-2012-1026 Dear Mr. Bruner: On May 28, 2013, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to Iroquois Pipeline Operating Company a Final Order in the above-referenced case. This Order included a Compliance Order and Civil Penalty assessment. Based on our review of the documentation you provided, and confirmation of payment of the civil penalty, it has been determined that you have complied with the terms of this Order. Accordingly, this case is now closed and no further action is contemplated with respect to the matters involved in this case. Thank you for your cooperation in this matter. Sincerely, Byron Coy, PE Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Cc: Kevin Speicher, NYSDPS#

120121026_NOPV PCP PCO_12182012_text.pdf, page 1Official PDFU.S. Department Of Transportation Pipeline and 609.989.2171 Hazardous Materials Safety Administration 820 Bear Tavern Road, Suite 103 West Trenton, NJ 08628 NOTICE OF PROBABLE VIOLATION PROPOSED CIVIL PENALTY and PROPOSED COMPLIANCE ORDER UPS OVERNIGHT DELIVERY December 18, 2012 Mr. E.J. Holm, President Iroquois Pipeline Operating Company One Corporate Drive, Suite 600 Shelton, CT 06484 CPF 1-2012-1026 Dear Mr. Holm: Between July 11 and July 15, 2011, State Inspectors from the New York State Department of Public Service (NYSDPS), acting as Agent for the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your pipeline facilities in the Overland operating district of NY State, and records in Shelton, CT. As a result of the inspection, it appears that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable violations are: 1. § 192.491 Corrosion control records (c) Each operator shall maintain a record of each test, survey, or inspection required by this subpart in sufficient detail to demonstrate the adequacy of corrosion control measures or that a corrosive condition does not exist. These records must be retained for at least 5 years, except that records related to §§192.465 (a) and (e) and 192.475(b) must be retained for as long as the pipeline remains in service. The operator could not produce a record of an inspection for internal corrosion as required by 192.475(b). In December of 2010, Iroquois Pipeline Operating Company (IPOC) completed a meter replacement project at their New Bremen metering station. The work involved removal of a 4-inch turbine meter and#

120121026_NOPV PCP PCO_12182012_text.pdf, page 21-2012-1026 installation of a Dresser Series 7M1480 Roots meter. To accommodate installation of the new meter, the company had to remove a short section of 4-inch piping. During the audit conducted the week of July 11, 2011, staff requested documentation of an internal inspection for the New Bremen meter replacement project. IPOC staff maintained that the inspection was done, but they did not have an internal inspection record on file. 2. § 192.707 Line markers for mains and transmission lines. (a) Buried pipelines. Except as provided in paragraph (b) of this section, a line marker must be placed and maintained as close as practical over each buried main and transmission line: (2) Wherever necessary to identify the location of the transmission line or main to reduce the possibility of damage or interference. The operator failed to properly install and maintain line markers for each transmission line wherever necessary to identify the location of the transmission line or main to reduce the possibility of damage or interference. On 7/14/2011 and 7/15/2011, NYSDPS staff performed a field audit along the pipeline from the St. Lawrence River crossing to the Mohawk River Crossing. During this field audit, staff walked and drove sections of the pipeline and noted the operator did not have pipeline markers in adequate quantity or placement so that the route of the pipeline could be accurately discerned from any point on or adjacent to the pipeline right-of-way. There is at least one bend or turn along each of the pipeline sections denoted below. The areas inspected by NYSDPS staff include the following: a. From milepost MP 0 at the St. Lawrence River to the Crossing of State Route 37 (approximately b. c. d. 1 mile). From milepost MP 37.25 to MP 38.25. From milepost MP 76 to MP 76.75. There was only 1 line marker along this entire length of ROW and it was obscured by large growth vegetation. NYSDPS staff observed no line markers in the ROW near MP 149, MP 150 and MP 150.5. NYSDPS staff took photographs of their observations along the pipeline. Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a related series of violations. For violations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a related series of violations. The Compliance Officer has reviewed the circumstances and supporting documentation involved in the above probable violation(s) and has recommended that you be preliminarily assessed a civil penalty of $8,700 as follows: Item number PENALTY 1 $ 8,700 120121026_NOPV_PCP_PCO_12182012 Page 2 of 4#

120121026_NOPV PCP PCO_12182012_text.pdf, page 31-2012-1026 Proposed Compliance Order With respect to item 2 pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration proposes to issue a Compliance Order to IPOC. Please refer to the Proposed Compliance Order, which is enclosed and made a part of this Notice. Response to this Notice 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 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). 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 a Final Order. Please submit all correspondence in this matter to Byron Coy, PE, Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103, W. Trenton, NJ 08628. Please refer to CPF 1-2012-1026 on each document you submit, and please, whenever possible, provide a signed PDF copy in electronic format. Smaller files may be emailed to Byron.Coy@dot.gov. Larger files should be sent on a CD accompanied by the original paper copy to the Eastern Region Office. Sincerely, Byron E. Coy, P.E. Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Enclosures: Proposed Compliance Order Response Options for Pipeline Operators in Compliance Proceedings Cc: Mr. Kevin Speicher, NYSDPS 120121026_NOPV_PCP_PCO_12182012 Page 3 of 4#

120121026_NOPV PCP PCO_12182012_text.pdf, page 41-2012-1026 PROPOSED COMPLIANCE ORDER Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposes to issue to Iroquois Pipeline Operating Company (IPOC) a Compliance Order incorporating the following remedial requirements to ensure the compliance of IPOC with the pipeline safety regulations: 1. In regard to Item Number 2 of the Notice pertaining to the failure to properly install and maintain pipeline line markers along the pipeline from the St. Lawrence River Crossing to the Mohawk River Crossing, IPOC must install pipeline markers in adequate quantity and placement so that the route of the pipeline, especially at changes in direction, can be accurately discerned from any point along the pipeline right-of-way (ROW). 2. IPOC must submit documentation that demonstrates it has completed the installation of the pipeline line markers along the pipeline from the St. Lawrence River Crossing to the Mohawk River Crossing, as noted in item #1 above, within 90 days of receipt of the Final Order. 3 It is requested (not mandated) that IPOC maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to Byron E. Coy, P.E., Director, Eastern Region, Pipeline and Hazardous Materials Safety Administration. It is requested that these costs be reported in two categories: 1) total cost associated with preparation/revision of plans, procedures, studies and analyses, and 2) total cost associated with replacements, additions and other changes to pipeline infrastructure. 120121026_NOPV_PCP_PCO_12182012 Page 4 of 4#

120121026_Final Order_05282013_text.pdf, page 1Official PDFMay 28, 2013 Mr. Jeffrey A. Bruner President Iroquois Pipeline Operating Company One Corporate Drive, Suite 600 Shelton, CT 06484 Re: CPF No. 1-2012-1026 Dear Mr. Bruner: Enclosed please find the Final Order issued in the above-referenced case. It makes findings of violation, assesses a civil penalty of $8,700, and specifies actions that need to be taken by Iroquois Pipeline Operating Company to comply with the pipeline safety regulations. This is to acknowledge receipt of payment of the full penalty amount, by wire transfer dated February 7, 2013. When the terms of the Compliance Order are completed, as determined by the Director, Eastern Region, this enforcement action will be closed. Service of the Final Order by certified mail is deemed effective upon the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5. Thank you for your cooperation in this matter. Sincerely, Jeffrey D. Wiese Associate Administrator for Pipeline Safety Enclosure cc: Mr. Byron Coy, Director, Eastern Region, OPS Mr. Alan Mayberry, Deputy Associate Administrator for Field Operations, OPS CERTIFIED MAIL - RETURN RECEIPT REQUESTED#

120121026_Final Order_05282013_text.pdf, page 2U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 ____________________________________ In the Matter of ) Iroquois Pipeline Operating Company, ) ) ) ) Respondent. ) ____________________________________) CPF No. 1-2012-1026 FINAL ORDER Between July 11, and July 15, 2012, State Inspectors from the New York State Department of Public Service (NYSDPS), acting as Agent for 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 the facilities and a records review of Iroquois Pipeline Operating Company (Iroquois or Respondent) in New York and Western Connecticut. Iroquois is a wholly owned subsidiary of Iroquois Gas Transmission System, LP. Iroquois operates a 416-mile natural gas pipeline extending through New York and Western Connecticut.1 As a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Respondent, by letter dated December 18, 2012, a Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Iroquois had violated 49 C.F.R. §§ 192.491(c) and 192.707(a) and proposed assessing a civil penalty of $8,700 for one of the alleged violations. The Notice also proposed ordering Respondent to take certain measures to correct an alleged violation. Iroquois responded to the Notice by letter dated January 16, 2013 (Response). The company did not contest the allegations of violation and paid the proposed civil penalty of $8,700, as provided in 49 C.F.R. § 190.227. Payment of the penalty authorizes PHMSA to make findings of violation as to those items which Iroquois has paid. The findings are made with prejudice to Respondent. FINDINGS OF VIOLATION In its Response, Iroquois did not contest the allegations in the Notice that it violated 49 C.F.R. Part 192, as follows: 1 See http://www.iroquois.com/environmental-gas.asp, (last accessed on May 2, 2013).#

120121026_Final Order_05282013_text.pdf, page 32 Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.491(c), which states in relevant part: § 192.491 Corrosion control records. (a)…. (c) Each operator shall maintain a record of each test, survey, or inspection required by this subpart in sufficient detail to demonstrate the adequacy of corrosion control measures or that a corrosive condition does not exist. These records must be retained for at least 5 years, except that records related to §§192.465 (a) and (e) and 192.475(b) must be retained for as long as the pipeline remains in service. The Notice alleged that Respondent violated 49 C.F.R. § 192.491(c) by failing to maintain and provide a record of an inspection for internal corrosion. Specifically, the Notice alleged that Iroquois failed to maintain a record of inspecting the internal surface of removed pipe for corrosion during the installation of a Dresser Series 7M1480 Roots meter and the removal of a short section of 4-inch pipe, on July 22, 2011, for the New Bremen meter replacement project. Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 192.491 by failing to maintain an internal inspection record for corrosion during the installation of a Dresser Series 7M1480 Roots meter and the removal of a short section of 4-inch pipe for the New Bremen meter replacement project. Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 192.707(a), which states in relevant part: § 192.707 Line markers for mains and transmission lines. (a) Buried Pipelines. Except as provided in paragraph (b) of this section, a line marker must be placed and maintained as close as practical over each buried main and transmission line: (1) …. (2) Wherever necessary to identify the location of the transmission line or main to reduce the possibility of damage or interference. The Notice alleged that Respondent violated 49 C.F.R. § 192.707(a) by failing to install and maintain markers for each transmission line wherever necessary to identify the location of the transmission line or main to reduce the possibility of damage or interference. Specifically, the Notice alleged that Iroquois did not have pipeline markers in adequate quantity or placement so that the location of the pipeline from the St. Lawrence River Crossing to the Mohawk River Crossing could be accurately discerned. Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 192.707 by failing to have pipeline markers in adequate quantity or placement so that the location of the pipeline from the St. Lawrence River Crossing to the Mohawk River Crossing could be accurately discerned.#

120121026_Final Order_05282013_text.pdf, page 43 These findings of violation will be considered prior offenses in any subsequent enforcement action taken against Respondent. ASSESSMENT OF PENALTY Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed $100,000 per violation for each day of the violation, up to a maximum of $1,000,000 for any related series of violations. In determining the amount of a civil penalty under 49 U.S.C. § 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature, circumstances, and gravity of the violation, including adverse impact on the environment; the degree of Respondent’s culpability; the history of Respondent’s prior offenses; the Respondent’s ability to pay the penalty and any effect that the penalty may have on its ability to continue doing business; and the good faith of Respondent in attempting to comply with the pipeline safety regulations. In addition, I may consider the economic benefit gained from the violation without any reduction because of subsequent damages, and such other matters as justice may require. The Notice proposed a total civil penalty of $8,700 for the violations cited above. Item 1: The Notice proposed a civil penalty of $8,700 for Respondent’s violation of 49 C.F.R. § 192.491, for failing to maintain an internal inspection record for corrosion during the installation of a Dresser Series 7M1480 Roots meter and the removal of a short section of 4-inch pipe, on July 22, 2011, for the New Bremen meter replacement project. Iroquois paid the proposed penalty, which authorizes PHMSA to make a finding of violation, with prejudice, regarding this item. Accordingly, having reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of $8,700 for violation of 49 C.F.R. §192.491. In summary, having reviewed the record and considered the assessment criteria for each of the Items cited above, I assess Respondent a total civil penalty of $8,700, which has been paid in full by Iroquois. COMPLIANCE ORDER The Notice proposed a Compliance Order with respect to Item 2 in the Notice for the violation of 49 C.F.R. §192. Under 49 U.S.C. § 60118(a), each person who engages in the transportation of gas or who owns or operates a pipeline facility is required to comply with the applicable safety standards established under chapter 601. Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following actions to ensure compliance with the pipeline safety regulations applicable to its operations: 1. With respect to the violation of § 192.707 (Item 2), Respondent must install and maintain pipeline markers along the pipeline from the St. Lawrence River Crossing to the Mohawk River Crossing in adequate quantity and placement so that the route of the pipeline, especially changes in direction, can be accurately discerned to reduce the possibility of damage or interference.#

120121026_Final Order_05282013_text.pdf, page 54 2. Respondent must submit documentation that demonstrates it has completed the installation of the pipeline markers, as noted in item #1 above, within 90 days of receipt of the Final Order. 3. It is requested (not mandated) that Respondent maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to Byron Coy, P.E., Director, Eastern Region, Pipeline and Hazardous Materials Safety Administration. It is requested that these costs be reported in two categories: 1) total cost associated with preparation/revision of plans, procedures, studies and analyses; and 2) total cost associated with replacements, additions and other changes to pipeline infrastructure. The Director may grant an extension of time to comply with any of the required items upon a written request timely submitted by the Respondent and demonstrating good cause for an extension. Failure to comply with this Order may result in the administrative assessment of civil penalties not to exceed $100,000 for each violation for each day the violation continues or in referral to the Attorney General for appropriate relief in a district court of the United States. The terms and conditions of this Final Order are effective upon service in accordance with 49 C.F.R. § 190.5. ___________________________________ __________________________ Jeffrey D. Wiese Date Issued Associate Administrator for Pipeline Safety#

120121026_NOPV-PCP-PCO_12182012.pdf, page 1Official PDFe U.S. Department Of Transoortation Pipeline aid Hazardous Materials Safety Administration 82o BearTavem Road, Suite lo3 West Trenton, NJ 08628 6099.9E9.2r7r NOTICE OF PROBABLE VIOLATION PROPOSED CIVI PENALTY and PROPOSED COMPLIANCE ORDER UPS OVERNIGHT DELIVERY December 18,2012 Mr. E.J. Holm, President lroquois Pipeline Opcrating Company One Corporate Drive, Suite 600 Shelton, CT 06484 cPF r-2012-1026 Dcar Mr. Holm: Between July I I and July 15, 201I, State Inspectors from the Ncw York State Department of Public Service Q',trYSDPS), acting as Agent for the Pipeline and Hazardous Materials Safcty Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your pipeline facilities in the Overland opcrating district ofNY State, and records in Shelton, CT. As a result ofthe inspection, it appears that you have committed probable violations ofthe Pipelinc Safety Rcgulations, Title 49, Code of Federal Regulations. The items inspected and the probablc violations are: f. $ 192.491 Corrosion control records (c) Each operator shall maintain a record ofeach test, survey, or inspection required by this subpart in sulficient detail to demonstrate the adequacy of corrosion control measures or that a corrosive condition does not exist. These records must be retained for at least 5 years, except that records related to 55192.465 (a) and (e) and 192.475(b) must be retained lbr as long as the pipeline remains in service. The operator could not producc a rccord ofan inspection for intemal corrosion as requircd by 192.47 5(b). In December of 2010, Iroquois Pipelinc Opcrating Company (IPOC) completed a meter replaccment project at their New Bremen mctering station. The work involved removal ofa 4-inch turbine meter and#

120121026_NOPV-PCP-PCO_12182012.pdf, page 21-2012-t026 installation of a Dresser Series 7M1480 Roots meter. To accommodate installation of the new meter, the company had to remove a short section of4-inch piping. During the audit conducted the week of July 11, 201l, staff requested documentation of an intemal inspection for thc Ncw Bremen meter replacement project. IPOC staffmaintained that the inspection was done, but they did not have an intcmal inspection record on file. 2. S 192.707 Line markers for mains and transmission lines. (a) Buried pipelines. Except as provided in paragraph (b) of this section, a line marker must be placed and maintained as close as practical over each buried main and transmission line: (2) Wherever necessary to identify the location ofthe transmission line or main to reduce the possibility of damage or interference. The operator failed to properly install and maintain linc markers for each transmission line wherevcr necessa.ry to identify the location ofthe transmission line or main to reduce the possibility ofdamage or interference. On 7/14/2011 and 711512011, NYSDPS staff performed a field audit along the pipelinc fiom the St. Lawrence River crossing to the Mohawk River Crossing. During this field audit, staff walked and drove sections ofthe pipeline and noted the operator did not have pipeline markers in adequate quantity or placement so that the route of the pipeline could be accurately discemed fiom any point on or adjacent to the pipeline right-of-way. There is at least one bend or tum along each of the pipeline sections denoted below. The areas inspected by NYSDPS staff include the following: a. From milepost MP 0 at the St. Lawrence Rivcr to the Crossing of State Route 37 (approximately I mile). b. From milepostMP 37 .25 to MP 38.25. c. From milepost MP 76 to MP 76.75. There was only I line marker along this entire length of ROW and it was obscured by large growth vegetation. d. NYSDPS staff observed no line markers in the ROW near MP 149, MP 150 and MP 150.5. NYSDPS stafftook photographs oftheir observations along the pipelinc. Under 49 United States Code, $ 60122, you are subject to a civil penalty not to exceed $200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a related series of violations. For violations occurring prior to January 4,2012, thc maximum penalty may not exceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a related series of violations. Thc Compliance Officer has reviewcd the circumstances and supporting documcntation involvcd in the above probable violation(s) and has recommended that you bc preliminarily assessed a civil penalty of $8,700 as follows: Item number I PENALTY $ 8,700 t20t2t026 NoPV PCP PCO 12182012 Page 2 of 4#

120121026_NOPV-PCP-PCO_12182012.pdf, page 3l-2012-1026 Prooosed Comoliance Order With respect to item 2 pursuant to 49 United States Code $ 601 18, the Pipeline and Hazardous Materials Safety Adrninistration proposes to issuc a Compliance Order to IPOC. Please refcr to the Proposed Compliance Order, which is enclosed and made a part of this Notice. Resoonse to this Notice Enclosed as part of this Notice is a document entitled Response Options Jbr 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 poiion ofyour responsive material qualifies for confidential 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 qualif! 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). 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 thc Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without firrther notice to you and to issue a Final Order. Please submit all correspondence in this matter to Byron Coy, PE, Director, PHMSA Eastem Region, 820 Bear Tavem Road. Suite 103, W. Trenton, NJ 08628. Pleasc refer to CPF 1-2012-1026 on cach document you submit, and plcase, whencver possible, provide a signed PDF copy in electronic format. Smaller files may be emailed to Btron.Coyaa)dot.gov. Larger files should be sent on a CD accompanied by the original paper copy to the Eastern Region Office. Sincerely, O .^" ,/ i ^-. l'TIt*- L ( w1 tl t t- By.o$ E. Coy, P.E. Director, Eastem Region Pipeline and Hazardous Materials Safety Administration Enclosures: Proposed Compliance Order Response Options for Pipeline Operators in Compliance Proceedings Cc: Mr. Kevin Speicher. NYSDPS 120121026 NoPV PCO 12182012 Page 3 of4#

120121026_NOPV-PCP-PCO_12182012.pdf, page 4t-20t2-1026 PROPOSED COMPLIANCE ORDER Pursuant to 49 United States code $ 60118, the Pipeline and Hazardous Materials safety 4dministratio^n (PHJv{SA) proposes to issue to Iroquois Pipeline Operating Company (IPOC) ; C^omplijnce. Order .incorporating the following remedial r6quirements to 6nsure ihe compliance - of IPOC with the pipeline safety regulations: 1. In re_gard to Item Number 2 of the Notice pertaining to the failure to properly install and maintain pipeline line markers along ihe pipeline from - the Si. Lawrence River Crossing to the Mohawk River Crossing, IPOC must install pipeline markers in adequate quantity and placement so that the route of the pipeline, especially at changes in direction, can be accurately discemed from any point along the pipeline righrof-way (ROW). 2. IPOC must submit documentation that demonstrates it has completed the installation of the pipeline line markers along the pipeline from the St. Lawrence River Crossing to the Mohawk River Crossing, as noted in item #l above, within 90 days ofreceipt ofthe Final Order. 3 It is requested (not mandated) that IPOC maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to Byron E. Coy, P.E., Director, Eastem Region, Pipeline and Hazardous Materials Safety Administration. It is requested that these costs be reported in two categories: 1) total cost associated with preparation/revision of plans, procedures, studies and analyses, and 2) total cost associated with replacements, additions and other changes to pipeline infrastructure. t20t21026 NOPV PCP PCO 12182012 Page 4 of 4#