{"operation":"document","citation":"CPF 120141005W","title":"IROQUOIS GAS CORP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-04-16","effective_on":null,"summary":"CLOSED warning letter citing 192.465(a), 192.465(d).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120141005w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120141005w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120141005w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120141005W","body":"Warning Letter involving IROQUOIS GAS CORP. PHMSA's enforcement data identifies the cited regulations as 192.465(a),  192.465(d). The case was opened on 2014-04-16 and is reported as closed as of 2014-04-16. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120141005W_Warning Letter_04162014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120141005W/120141005W_Warning%20Letter_04162014.pdf\n\n120141005W_Warning Letter_04162014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120141005W/120141005W_Warning%20Letter_04162014_text.pdf\n\n120141005W_Warning Letter_04162014_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\nWARNING LETTER\nOVERNIGHT EXPRESS MAIL\nApril 16, 2014\nJeffrey Bruner\nPresident\nIroquois Gas Corporation\nOne Corporate Drive, Suite 600\nShelton, CT 06484\nCPF 1-2014-1005W\nDear Mr. Bruner:\nFrom March 5 to May 4, 2012, inspectors from the New York State Department of Public Service\n(NYSDPS) and the Connecticut Department of Energy and Environmental Protection, acting as agents for\nthe Pipeline and Hazardous Materials Safety Administration (PHMSA), and representatives of the\nPipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),\npursuant to Chapter 601 of 49 United States Code conducted an integrated inspection of Iroquois Gas\nCorporation’s (Iroquois) assets in Connecticut and New York.\nAs a result of the inspection, it appears that you have committed a probable violation of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations. The item inspected and the probable violation\nis:\n1. §192.465 External corrosion control: Monitoring.\n(a) Each pipeline that is under cathodic protection must be tested at least once each calendar\nyear, but with intervals not exceeding 15 months, to determine whether the cathodic protection\nmeets the requirements of §192.463. . .\n(d) Each operator shall take prompt remedial action to correct any deficiencies indicated by\nthe monitoring.\nIroquois failed to take prompt remedial action to correct deficiencies indicated by its external corrosion\ncontrol monitoring (annual cathodic protection survey).\nDuring the inspection, PHMSA inspectors reviewed the annual cathodic protection survey records for the\nSouthern New York area from valve MLV-34 to valve MLV-35. The PHMSA inspectors observed that\nthree locations along the pipeline indicated low cathodic protection (CP) under the requirement of\n§192.463. Iroquois’ pipe-to-soil voltages were less negative than -0.85 volts for more than one inspection\ninterval, as shown below.\n\n\n\n1-2014-1005W\nValve Sgmt\nCode and Pipe\nStation Number Location\nDescription\nInspection Date\nand Time\nStructure P/S\n(Volts)\nStructure IRF\n(Volts)\nMLV-34-PL 81+94 D/S Fort S Rd 1 4/26/2011 -0.649 -0.303\n4/3/2012 -0.654 -0.214\nValve Sgmt\nCode and Pipe\nStation Number Location\nDescription\nInspection Date\nand Time\nStructure P/S\n(Volts)\nStructure IRF\n(Volts)\nMLV-35-PL 173+65 U/S Vet’s Hwy\n4/25/2011 -0.645 -0.312\n1\n4/2/2012 -0.672 -0.290\nValve Sgmt\nCode and Pipe\nStation Number Location\nDescription\nInspection Date\nand Time\nStructure P/S\n(Volts)\nStructure IRF\n(Volts)\nMLV-35-PL 173+51 D/S Vets Hwy 4/25/2011 -0.636 -0.290\n4/2/2012 -0.573 -0.234\nAdditionally, Iroquois had low CP readings in the Connecticut area at locations between valve MLV-31\nand valve MLV-32 from 2010 to 2012.\nIroquois could not produce any records of any remedial work that was done to correct these deficiencies.\nTherefore, Iroquois did not take prompt remedial action.\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.\nFor violations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per\nviolation per day, with a maximum penalty not to exceed $1,000,000 for a related series of violations.\nWe have reviewed the circumstances and supporting documents involved in this case, and have decided\nnot to conduct additional enforcement action or penalty assessment proceedings at this time. We advise\nyou to correct the items identified in this letter. Failure to do so will result in Iroquois being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, please address your correspondence to: Byron\nCoy, PE, Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103, W. Trenton, NJ 08628\nand please refer to CPF 1-2014-1005W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete\noriginal document you must provide a second copy of the document with the portions you believe qualify\nfor confidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b).\nAdditionally, if you choose to reply to this (or any other case), please ensure that any response letter\npertains solely to one CPF case number.\nSincerely,\nByron Coy, P.E.\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\ncc: Mr. Kevin Speicher, NYSDPS\nMr. Karl Baker, Connecticut Department of Energy and Environmental Protection","truncated":false,"body_characters":5570}