# IROQUOIS GAS CORP — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 120121026
- **title:** IROQUOIS GAS CORP — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2012-12-18
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 192.491(c), 192.707(a)(2).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-120121026.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-120121026.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-120121026
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120121026
**body:**

Notice of Probable Violation involving IROQUOIS GAS CORP. PHMSA's enforcement data identifies the cited regulations as 192.491(c),  192.707(a)(2). The case was opened on 2012-12-18 and is reported as closed as of 2013-09-30. Proposed civil penalty: $8,700. Assessed civil penalty: $8,700. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120121026_Closure Letter_09302013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120121026/120121026_Closure%20Letter_09302013.pdf

120121026_Closure Letter_09302013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120121026/120121026_Closure%20Letter_09302013_text.pdf

120121026_Final Order_05282013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120121026/120121026_Final%20Order_05282013.pdf

120121026_Final Order_05282013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120121026/120121026_Final%20Order_05282013_text.pdf

120121026_NOPV PCP PCO_12182012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120121026/120121026_NOPV%20PCP%20PCO_12182012_text.pdf

120121026_NOPV-PCP-PCO_12182012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120121026/120121026_NOPV-PCP-PCO_12182012.pdf

120121026_Operator_Response_and_Request_for_Time_Extension_01162013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120121026/120121026_Operator_Response_and_Request_for_Time_Extension_01162013.pdf

120121026_Closure Letter_09302013_text.pdf

U.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

U.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



1-2012-1026
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



1-2012-1026
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



1-2012-1026
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

May 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



U.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).



2
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.



3
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.



4
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

e
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



1-2012-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



l-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



t-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.
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