{"operation":"document","citation":"CPF 120141001","title":"NEW YORK STATE ELECTRIC & GAS CORP — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-01-02","effective_on":null,"summary":"CLOSED notice of probable violation citing 192.491(c), 192.709.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120141001.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120141001.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120141001","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120141001","body":"Notice of Probable Violation involving NEW YORK STATE ELECTRIC & GAS CORP. PHMSA's enforcement data identifies the cited regulations as 192.491(c),  192.709. The case was opened on 2014-01-02 and is reported as closed as of 2015-04-07. Proposed civil penalty: $20,000. Assessed civil penalty: $10,000. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120141001_Closure Letter_04072015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120141001/120141001_Closure%20Letter_04072015.pdf\n\n120141001_Closure Letter_04072015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120141001/120141001_Closure%20Letter_04072015_text.pdf\n\n120141001_Final Order_09102014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120141001/120141001_Final%20Order_09102014.pdf\n\n120141001_Final Order_09102014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120141001/120141001_Final%20Order_09102014_text.pdf\n\n120141001_NOPV PCP PCO_01022014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120141001/120141001_NOPV%20PCP%20PCO_01022014.pdf\n\n120141001_NOPV PCP PCO_01022014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120141001/120141001_NOPV%20PCP%20PCO_01022014_text.pdf\n\n120141001_Operator Response_01312014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120141001/120141001_Operator%20Response_01312014.pdf\n\n120141001_NOPV PCP PCO_01022014_text.pdf\n\nU.S. Department Of Transportation Pipeline and 609.989.2171\nHazardous Materials\nSafety Administration\n820 Bear Tavern Road, Suite 103\nWest Trenton, NJ 08628\nNOTICE OF PROBABLE VIOLATION\nPROPOSED CIVIL PENALTY\nand\nPROPOSED COMPLIANCE ORDER\nEXPRESS OVERNIGHT MAIL\nJanuary 2, 2014\nMr. Barry Cigich, VP Operations\nCrestwood Midstream LLC.\nTwo Brush Creek Blvd., Suite 200\nKansas City, MO 64112\nCPF 1-2014-1001\nDear Mr. Cigich:\nBetween October 15 and November 7, 2012, inspectors from the New York State Department of Public\nService (NYSDPS), acting as agents for the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the Arlington Storage Company, LLC\n(ASC) Seneca Lake Storage facilities in Watkins Glen, NY.\nAs a result of the inspection, it appears that you have committed probable violations of the Pipeline Safety\nRegulations, Title 49, Code of Federal Regulations. The items inspected and the probable violations are:\n1. § 192.709 Transmission lines: Record keeping.\nEach operator shall maintain the following records for transmission lines for the periods specified:\n(c) A record of each patrol, survey, inspection, and test required by subparts L and M of this part\nmust be retained for at least 5 years or until the next patrol, survey, inspection, or test is completed,\nwhichever is longer.\nASC failed to maintain a record of each patrol, survey, inspection, and test required by subparts L and M of\nthis part. Specifically, ASC could not produce any documents or capacity test reviews or calculations as\nrequired by §192.743(a) for any of the relief devices on the Seneca Storage and Seneca West Pipeline\nfacilities.\n2. § 192.491 Corrosion control records.\n(c) Each operator shall maintain a record of each test, survey, or inspection required by this subpart in\nsufficient detail to demonstrate the adequacy of corrosion control measures or that a corrosive\ncondition does not exist. These records must be retained for at least 5 years, except that records\nrelated to §§ 192.465 (a) and (e) and 192.475(b) must be retained for as long as the pipeline remains in\nservice.\nASC failed to maintain a record of each test, survey, or inspection required by this subpart in sufficient detail\nto demonstrate the adequacy of corrosion control measures or that a corrosive condition does not exist.\n\n\n\n1-2014-1001\nSpecifically, ASC failed to document the required internal corrosion check upon removal of a section of 16-\ninch pipe from the Seneca West Pipeline during tie-in of “Project 415: Interconnection with Millennium\nPipeline” in 2012, as required by §192.475(b).\nProposed Civil Penalty\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per\nviolation per day the violation persists up to a maximum of $2,000,000 for a related series of violations. For\nviolations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per violation\nper day, with a maximum penalty not to exceed $1,000,000 for a related series of violations. The\nCompliance Officer has reviewed the circumstances and supporting documentation involved in the above\nprobable violations and has recommended that you be preliminarily assessed a civil penalty of $20,000 as\nfollows:\nItem number PENALTY\n1 $10,000\n2 $10,000\nProposed Compliance Order\nWith respect to items 1 and 2 pursuant to 49 United States Code § 60118, the Pipeline and Hazardous\nMaterials Safety Administration proposes to issue a Compliance Order to Arlington Storage Company, LLC.\nPlease refer to the Proposed Compliance Order, which is enclosed and made a part of this Notice.\nResponse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. All material you\nsubmit in response to this enforcement action may be made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions you believe\nqualify for confidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond within 30 days of receipt of\nthis Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the\nAssociate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to\nyou and to issue a Final Order.\nPlease submit all correspondence in this matter to Byron Coy, PE, Director, PHMSA Eastern Region, 820\nBear Tavern Road, Suite 103, W. Trenton, NJ 08628. Please refer to CPF 1-2014-1001 on each document\nyou submit and please, whenever possible, provide a signed PDF copy in electronic format. Smaller files\nmay be emailed to Byron.Coy@dot.gov. Larger files should be sent on a CD accompanied by the original\npaper copy to the Eastern Region Office.\nAdditionally, if you choose to respond to this (or any other case), please ensure that any response letter\npertains solely to one CPF case number.\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nCc: Kevin Speicher NYSDPS\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Compliance Proceedings\n120141001_NOPV_PCP_PCO_01022014 Page 2 of 3\n\n\n\n1-2014-1001\nPROPOSED COMPLIANCE ORDER\nPursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) proposes to issue to Arlington Storage Company, LLC (ASC) a Compliance Order incorporating\nthe following remedial requirements to ensure the compliance of ASC with the pipeline safety regulations:\n1. 2. 3. 4. In regard to Item Number 1 of the Notice pertaining to ASC not providing records to verify\nsizing of relief valves at the Seneca Lake Storage facilities, ASC must perform relief\ncapacity analysis on all associated devices that do not have adequate records, and make any\nchanges, if necessary, to establish adequate capacity.\nIn regard to Item Number 2 of the Notice pertaining to ASC not documenting the required\ninternal corrosion checks on a section of 16-inch pipe removed from service,\na. ASC must perform an internal inspection in the vicinity of the project noted in Item\nNumber 2, either by temporarily removing a component such as a valve, or spool piece,\na meter, a flanged section, or cutting out a section for inspection.\nb. Any new segment of pipe that is used to restore the inspection area would have to meet\nrecords and MAOP requirements.\nc. ASC must modify their Internal Corrosion Control Procedure 906 to provide detailed\nguidance for documenting an internal corrosion inspection when no corrosion is found.\nASC shall have 120 days from the receipt of a Final Order to complete the requirements for\nItem Number 1 and Item Number 2 of the Notice.\nIt is requested (not mandated) that ASC maintain documentation of the safety improvement\ncosts associated with fulfilling this Compliance Order and submit the total to Byron Coy,\nPE, Director, Eastern Region, Pipeline and Hazardous Materials Safety Administration. It is\nrequested that these costs be reported in two categories: 1) total cost associated with\npreparation/revision of plans, procedures, studies and analyses, and 2) total cost associated\nwith replacements, additions and other changes to pipeline infrastructure.\n120141001_NOPV_PCP_PCO_01022014 Page 3 of 3\n\n120141001_Final Order_09102014_text.pdf\n\nSEPTEMBER 10, 2014\nMr. Robert G. Phillips\nChairman, President and Chief Executive Officer\nCrestwood Midstream GP, LLC\nTwo Brush Creek Boulevard, Suite 200\nKansas City, MO 64112\nRe: CPF No. 1-2014-1001\nDear Mr. Phillips:\nEnclosed please find the Final Order issued in the above-referenced case. It withdraws one of\nthe allegations of violation, makes one other finding of violation, assesses a reduced civil penalty\nof $10,000, and specifies actions that need to be taken by your subsidiary, Arlington Storage\nCompany, LLC, to comply with the pipeline safety regulations. The penalty payment terms are\nset forth in the Final Order. When the civil penalty has been paid and the terms of the\ncompliance order completed, as determined by the Director, Eastern Region, this enforcement\naction will be closed. Service of the Final Order by certified mail is deemed effective upon the\ndate of mailing, or as otherwise provided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. Byron E. Coy, P.E., Director, Eastern Region, OPS\nMr. Matthew Norton, Director of PSM and Pipeline Compliance, Crestwood Midstream\nGP, 801 Cherry Street, Suite 3800 – Unit 20, Fort Worth, Texas 76135\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________________\n)\nIn the Matter of )\n)\nArlington Storage Company, LLC, ) CPF No. 1-2014-1001\na subsidiary of Crestwood Midstream GP, LLC, )\n)\nRespondent. )\n____________________________________________)\nFINAL ORDER\nBetween October 15 and November 7, 2012, pursuant to 49 U.S.C. § 60117, inspectors from the\nNew York State Department of Public Service (NYSDPS), acting as agents for the Pipeline and\nHazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),\nconducted an on-site pipeline safety inspection of the facilities and records of Arlington Storage\nCompany, LLC (ASC or Respondent), at the company’s Seneca Lake storage facilities in\nWatkins Glen, New York. This facility is operated by ASC, a subsidiary of Crestwood\nMidstream GP, LLC, and includes an 18.6-mile, 16-inch diameter welded pipeline system and a\ncavern with a storage capacity of 2.1 billion cubic feet of active working gas.1\nAs a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Respondent,\nby letter dated January 2, 2014, a Notice of Probable Violation, Proposed Civil Penalty, and\nProposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice\nproposed finding that ASC had committed two violations of 49 C.F.R. Part 192 and proposed\nassessing a civil penalty of $20,000 for the alleged violations. The Notice also proposed\nordering Respondent to take certain measures to correct the alleged violations.\nASC responded to the Notice by letter dated January 31, 2014 (Response). The company\ncontested one allegation, offered additional information in response to the Notice, and requested\nthat the proposed civil penalty be eliminated.\nRespondent did not request a hearing and therefore has waived its right to one.\n1 http://ceqpinvestor.crestwoodlp.com/phoenix.zhtml?c=132026&p=irol-newsArticle&ID=1585221&highlight=\n(last accessed July 14, 2014); Pipeline Safety Violation Report (Violation Report), dated January 2, 2014 (on file\nwith PHMSA), at 1.\n\n\n\n2\nFINDING OF VIOLATION\nIn its Response, ASC did not contest the allegation in the Notice that it violated 49 C.F.R.\n§ 192.709, as follows:\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.709, which states, in\nrelevant part:\n§ 192.709 Transmission lines: Record keeping.\nEach operator shall maintain the following records for transmission\nlines for the periods specified:\n(a) …\n(c) A record of each patrol, survey, inspection, and test required by\nsubparts L and M of this part must be retained for at least 5 years or\nuntil the next patrol, survey, inspection, or test is completed,\nwhichever is longer.\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.709 by failing to maintain a record\nof each patrol, survey, inspection, and test required by Subparts L and M of 49 C.F.R. Part 192.\nSpecifically, the Notice alleged that ASC could not produce any documents or capacity test\nreviews or calculations, as required by § 192.743(a), for any of the relief devices on the Seneca\nStorage and Seneca West Pipeline facilities.\nRespondent did not contest this allegation of violation. Accordingly, based upon a review of all\nof the evidence, I find that Respondent violated 49 C.F.R. § 192.709 by failing to maintain a\nrecord of each patrol, survey, inspection, and test required by Subparts L and M of 49 C.F.R.\nPart 192.\nThis finding of violation will be considered a prior offense in any subsequent enforcement action\ntaken against Respondent.\nItem 2: The Notice alleged that Respondent violated 49 C.F.R. § 192.491(c), which states:\n§ 192.491 Corrosion control records.\n(a) …\n(c) Each operator shall maintain a record of each test, survey, or\ninspection required by this subpart in sufficient detail to demonstrate the\nadequacy of corrosion control measures or that a corrosive condition does\nnot exist. These records must be retained for at least 5 years, except that\nrecords related to §§ 192.465(a) and 192.475(b) must be retained for as\nlong as the pipeline remains in service.\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.491(c) by failing to maintain a\nrecord of each test, survey, or inspection required by this subpart in sufficient detail to\ndemonstrate the adequacy of corrosion control measures or that a corrosive condition does not\nexist. Specifically, the Notice alleged that ASC failed to document the internal corrosion\n\n\n\n3\ninspection required under 49 C.F.R. § 192.495(b) when the company removed a section of 16-\ninch pipe from the Seneca West Pipeline during tie-in of “Project 415: Interconnection with\nMillennium Pipeline” in 2012.\nIn its Response, ASC challenged the allegation that it failed to document the internal corrosion\ninspection and requested that the proposed civil penalty and compliance order requirement\nassociated with this Item be eliminated. ASC contended that NYSDPS did not request a record\nof the internal corrosion inspection. Also, ASC argued that an internal corrosion inspection was\nindeed conducted at the time of the tie-in project and was recorded on an “Information Report”\nform dated April 17, 2012. ASC indicated that this “Information Report,” which was attached to\nthe Response, had been available at the time of the PHMSA inspection.\nThe NYSDPS disputed ASC’s statement that NYDPS did not ask for the internal corrosion\ninspection records, stating that it did indeed request the records both during and after the\ninspection. Additionally, Section 3.2 of Arlington Storage Procedure 907 states: “[W]henever\nany pipe is removed from a pipeline for any reason, inspect the internal surface for evidence of\ncorrosion. If internal corrosion is found: Investigate the adjacent pipe to determine the extent of\ninternal corrosion and document on O&M Form OM200-02 Pipeline Examination Report. . . .”2\nThere are several problems with the documentation provided by ASC in its Response. First, the\n“Information Report” is not the same record as the “Form OM200-2 Pipe Examination Report”\nrequired by Arlington Storage Procedure 906 and does not reference said procedure. Second,\nthe “Information Report” has “Form S-10 02-08-2002” at the bottom of the page and only\nreferences procedures numbered 301, 303, 304, and 508 at the top of the page but not procedure\n906. Finally, the “Information Report” has no description indicating it was to be used for\nrecording an internal corrosion inspection, but instead was used for recording external surface\ncorrosion if a pipeline were exposed.\nNevertheless, after considering all of the evidence, I find that the information therein is sufficient\nto show that an internal corrosion inspection did indeed occur. The “Information Report”\nprovided by ASC states expressly: “No corrosion detected internally!” and is dated and signed by\nthe inspector. Under the circumstances, I am willing to accept this as proof that ASC did\nmaintain an adequate record of an internal corrosion inspection for the section of pipe in\nquestion.\nBased upon the foregoing, I withdraw Item 2.\nASSESSMENT OF PENALTY\nUnder 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed\n$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any\n2 Violation Report, Exhibit A-01.\n\n\n\n4\nrelated series of violations.3 In determining the amount of a civil penalty under 49 U.S.C.\n§ 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature,\ncircumstances, and gravity of the violation, including adverse impact on the environment; the\ndegree of Respondent’s culpability; the history of Respondent’s prior offenses; and any effect\nthat the penalty may have on its ability to continue doing business; and the good faith of\nRespondent in attempting to comply with the pipeline safety regulations. In addition, I may\nconsider the economic benefit gained from the violation without any reduction because of\nsubsequent damages, and such other matters as justice may require. The Notice proposed a total\ncivil penalty of $20,000 for the violations cited above.\nItem 1: The Notice proposed a civil penalty of $10,000 for Respondent’s violation of 49 C.F.R.\n§ 192.709, for failing to maintain a record of each patrol, survey, inspection, and test required by\nsubparts L and M of Part 192. ASC did not contest this allegation, but did request that the\nproposed civil penalty be reduced or waived. In its Response, ASC indicated that it completed a\nrelief capacity analysis on all associated relief devices following the inspection.\nRespondent stated that the post-inspection analysis indicated all pressure-relief devices had\nsufficient capacity; no device required resetting or physical change. Respondent believed that\nthe proposed penalty should be reduced despite the company’s failure to maintain records of a\ncapacity test. The company argued that its ability to easily conduct a capacity test demonstrated\nthe adequacy of both the original design and ASC’s on-going annual device relief testing\nprogram. Respondent argued in its Response that the relief capacity analysis performed after the\nNYSDPS inspection warrants a penalty reduction. I disagree. The fact that Respondent reacted\nto the NYSDPS inspection by conducting an analysis does not warrant a penalty reduction, as it\nis Respondent’s responsibility to ensure it has all the necessary records available at all times.\nRespondent must maintain all necessary records regardless of whether its relief valves, or other\nequipment, are adequate. The regulation specifically requires operators to maintain records for a\ncertain amount of time. Accordingly, having reviewed the record and considered the assessment\ncriteria, I assess Respondent a civil penalty of $10,000 for violation of 49 C.F.R. § 192.709.\nItem 2: The Notice proposed a civil penalty of $10,000 for Respondent’s violation of 49 C.F.R.\n§ 192.491(c), for failing to maintain a record of each test, survey, or inspection required by this\nsubpart in sufficient detail to demonstrate the adequacy of corrosion control measures or that a\ncorrosive condition does not exist. Based on the discussion above, I withdraw the proposed\npenalty for violation of 49 C.F.R. § 192.491(c).\nIn summary, having reviewed the record and considered the assessment criteria for Item 1 cited\nabove, I assess Respondent a reduced civil penalty of $10,000.\nPayment of the civil penalty must be made within 20 days of service. Federal regulations\n(49 C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer through the Federal\nReserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed\ninstructions are contained in the enclosure. Questions concerning wire transfers should be\n3 The Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011, Pub. L. No. 112-90, § 2(a)(1), 125 Stat.\n1904, January 3, 2012, increased the civil penalty liability for violating a pipeline safety standard to $200,000 per\nviolation for each day of the violation, up to a maximum of $2,000,000 for any related series of violations.\n\n\n\n5\ndirected to: Financial Operations Division (AMK-325), Federal Aviation Administration, Mike\nMonroney Aeronautical Center, P.O. Box 269039, Oklahoma City, Oklahoma 73125. The\nFinancial Operations Division telephone number is (405) 954-8845.\nFailure to pay the $10,000 civil penalty will result in accrual of interest at the current annual rate\nin accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to\nthose same authorities, a late penalty charge of six percent (6%) per annum will be charged if\npayment is not made within 110 days of service. Furthermore, failure to pay the civil penalty\nmay result in referral of the matter to the Attorney General for appropriate action in a district\ncourt of the United States.\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Item 1 in the Notice for violation of\n49 C.F.R. § 192.709. Under 49 U.S.C. § 60118(a), each person who engages in the\ntransportation of gas or who owns or operates a pipeline facility is required to comply with the\napplicable safety standards established under chapter 601. Pursuant to the authority of 49 U.S.C.\n§ 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following actions to\nensure compliance with the pipeline safety regulations applicable to its operations:\n1. With respect to the violation of § 192.709 (Item 1), Respondent must perform a\nrelief capacity analysis on all associated devices that do not have adequate records\nand make any changes, if necessary, to establish adequate capacity.\n2. Respondent shall have 120 days from the receipt of a Final Order to complete the\nrequirements for Item 1 of the Notice.\n3. It is requested (not mandated) that Respondent maintain documentation of the\nsafety improvement costs associated with fulfilling this Compliance Order and\nsubmit the total to Byron Coy, PE, Director, Eastern Region, Pipeline and\nHazardous Materials Safety Administration. It is requested that these costs be\nreported in two categories: 1) total cost associated with preparation/revision of\nplans, procedures, studies, and analyses; and 2) total cost associated with\nreplacements, additions, and other changes to pipeline infrastructure.\nThe Director may grant an extension of time to comply with any of the required items upon a\nwritten request timely submitted by the Respondent and demonstrating good cause for an\nextension.\nFailure to comply with this Order may result in the administrative assessment of civil penalties\nnot to exceed $200,000 for each violation for each day the violation continues or in referral to the\nAttorney General for appropriate relief in a district court of the United States.\nUnder 49 C.F.R. § 190.215, Respondent has a right to submit a Petition for Reconsideration of\nthis Final Order. The petition must be sent to: Associate Administrator, Office of Pipeline\n\n\n\n6\nSafety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC\n20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address. PHMSA\nwill accept petitions received no later than 20 days after receipt of service of this Final Order by\nthe Respondent, provided they contain a brief statement of the issue(s) and meet all other\nrequirements of 49 C.F.R. § 190.215. The filing of a petition automatically stays the payment of\nany civil penalty assessed. Unless the Associate Administrator, upon request, grants a stay, all\nother terms and conditions of this Final Order are effective upon service in accordance with\n49 C.F.R. § 190.5.\n___________________________________ __________________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n120141001_Closure Letter_04072015_text.pdf\n\nU.S. Department Of Transportation Pipeline and 609.989.2171\nHazardous Materials\nSafety Administration\n820 Bear Tavern Road, Suite 103\nWest Trenton, NJ 08628\nOVERNIGHT EXPRESS DELIVERY\nApril 7, 2015\nMs. Miranda Jones, VP ESR\nCrestwood Midstream GP, LLC\n801 Cherry St, Suite 3800, Unit 20\nFort Worth TX, 76102\nCPF 1-2014-1001\nDear Ms. Jones:\nOn September 10, 2014, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued to Arlington Storage Company, LLC (Arlington Storage), a subsidiary of Crestwood\nMidstream GP, LLC, a Final Order in the above-referenced case. This Order included a\nCompliance Order and Civil Penalty assessment. Based on our review of the documentation\nArlington Storage provided, and confirmation of payment of the civil penalty, it has been\ndetermined that Arlington Storage has complied with the terms of this Order.\nAccordingly, this case is now closed and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nCc: Mr. Kevin Speicher, NYSDPS","truncated":false,"body_characters":26584}