{"operation":"document","citation":"CPF 120151004W","title":"CENTRAL NEW YORK OIL AND GAS CO LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-02-26","effective_on":null,"summary":"CLOSED warning letter citing 192.705(b), 192.706.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120151004w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120151004w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120151004w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120151004W","body":"Warning Letter involving CENTRAL NEW YORK OIL AND GAS CO LLC. PHMSA's enforcement data identifies the cited regulations as 192.705(b),  192.706. The case was opened on 2015-02-26 and is reported as closed as of 2015-02-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120151004W_Warning Letter_02262015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151004W/120151004W_Warning%20Letter_02262015.pdf\n\n120151004W_Warning Letter_02262015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151004W/120151004W_Warning%20Letter_02262015_text.pdf\n\n120151004W_Warning Letter_02262015_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\nEXPRESS OVERNIGHT MAIL\nFebruary 26, 2015\nMiranda Jones\nVice President, Environmental Safety and Regulatory\nCrestwood Midstream Partners LP\n801 Cherry Street, Suite 3800, Unit 20\nFort Worth, TX 76102\nCPF 1-2015-1004W\nDear Ms. Jones:\nBetween October 14-19, 2013 inspectors from the New York State Department of Public Service\n(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 Central New York Oil\n& Gas Corporation (CNYOG) facilities in Owego, NY.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violation(s) are:\n1. §192.705 Transmission lines: Patrolling.\n(b) The frequency of patrols is determined by the size of the line, the operating pressures,\nthe class location, terrain, weather, and other relevant factors, but intervals between\npatrols may not be longer than prescribed in the following table:\nMaximum interval between patrols\nClass\nlocation of\nline\nAt highway and railroad\ncrossings\nAt all other places\n1,2 7 1/2 months; but at least twice\neach calendar year\n15 months; but at least\nonce each calendar year\n\n\n\n1-2015-1004W\nCYNOG failed to patrol their Class 1 transmission line at an interval not to exceed 15 months.\nSpecifically, from the period starting in April 2012 and ending in October 2013, CNYOG\nconducted ground patrols at an interval of approximately 18 months on the following ROWs:\n1. South Lateral (Compressor Station to TGP 319)\n2. North Lateral (Compressor Station to Millennium Meter)\n3. Barnhart (Compressor Station to B-2)\n4. Barnhart/Lydell (B-2 to L-5)\n5. Widell/Barnhart 12”, 16”, 20” (Compressor Station to 16” X-over, W-6, W-3, W-7)\nWhen informed of the finding by the NYSDPS inspector, CYNOG’s responsible person stated\nthat he was only trying to accommodate the land owners land use requirements. He stated that\nCYNOG utilizes a motor vehicle to conduct the patrols and they did not want to inflict damage\nto the crops that are grown on most of the Right Of Way involved.\nCNYOG informed the NYSDPS inspector that in the future the patrols will be conducted in the\nautumn, as this is the time of year when the ground is generally firm enough for a vehicle patrol\nand the crops have been harvested.\n2. §192.706 Transmission lines: Leakage surveys.\nLeakage surveys of a transmission line must be conducted at intervals not exceeding 15\nmonths, but at least once each calendar year…\nCYNOG failed to leak survey their un-odorized Class 1 transmission line at an interval not to\nexceed 15 months…\nSpecifically, from the period starting in April 2012 and ending in October 2013, CNYOG\nconducted leak surveys at an interval of approximately 18 months on the following ROWs:\n1. South Lateral (Compressor Station to TGP 319)\n2. North Lateral (Compressor Station to Millennium Meter)\n3. Barnhart (Compressor Station to B-2)\n4. Barnhart/Lydell (B-2 to L-5)\n5. Widell/Barnhart 12”, 16”, 20” (Compressor Station to 16” X-over, W-6, W-3, W-7)\nWhen informed of the finding by the NYSDPS inspector, CYNOG’s responsible person stated\nthat he was only trying to accommodate the land owners land use requirements. He stated that\nCYNOG utilizes a motor vehicle to conduct the leakage surveys and they did not want to inflict\ndamage to the crops that are grown on most of the Right Of Way.\nCNYOG informed the NYSDPS inspector that in the future the leak surveys will be conducted in\nthe autumn, as this is the time of year when the ground is generally firm enough for a vehicle\npatrol and the crops have been harvested.\n120151004W_WL_02262015 Page 2 of 3\n\n\n\n1-2015-1004W\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this letter.\nFailure to do so will result in CNYOG being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, please address your correspondence to:\nByron Coy, PE, Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103, W.\nTrenton, NJ 08628 and please refer to CPF 1-2015-1004W. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 5 U.S.C. 552(b).\nAdditionally, if you choose to respond to this (or any other case), please ensure that any response\nletter pertains solely to one CPF case number\nSincerely,\nByron Coy, PE\nDirector, Eastern\nPipeline and Hazardous Materials Safety Administration\nCc: Kevin Speicher, NYSDPS\n120151004W_WL_02262015 Page 3 of 3","truncated":false,"body_characters":6422}