# CENTRAL NEW YORK OIL AND GAS CO LLC — Warning Letter - **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:** Not available - **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. Official case documents: 120151004W_Warning Letter_02262015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151004W/120151004W_Warning%20Letter_02262015.pdf 120151004W_Warning Letter_02262015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151004W/120151004W_Warning%20Letter_02262015_text.pdf 120151004W_Warning Letter_02262015_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 WARNING LETTER EXPRESS OVERNIGHT MAIL February 26, 2015 Miranda Jones Vice President, Environmental Safety and Regulatory Crestwood Midstream Partners LP 801 Cherry Street, Suite 3800, Unit 20 Fort Worth, TX 76102 CPF 1-2015-1004W Dear Ms. Jones: Between October 14-19, 2013 inspectors from the New York State Department of Public Service (NYSDPS), acting as agents for the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the Central New York Oil & Gas Corporation (CNYOG) facilities in Owego, NY. 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 violation(s) are: 1. §192.705 Transmission lines: Patrolling. (b) The frequency of patrols is determined by the size of the line, the operating pressures, the class location, terrain, weather, and other relevant factors, but intervals between patrols may not be longer than prescribed in the following table: Maximum interval between patrols Class location of line At highway and railroad crossings At all other places 1,2 7 1/2 months; but at least twice each calendar year 15 months; but at least once each calendar year 1-2015-1004W CYNOG failed to patrol their Class 1 transmission line at an interval not to exceed 15 months. Specifically, from the period starting in April 2012 and ending in October 2013, CNYOG conducted ground patrols at an interval of approximately 18 months on the following ROWs: 1. South Lateral (Compressor Station to TGP 319) 2. North Lateral (Compressor Station to Millennium Meter) 3. Barnhart (Compressor Station to B-2) 4. Barnhart/Lydell (B-2 to L-5) 5. Widell/Barnhart 12”, 16”, 20” (Compressor Station to 16” X-over, W-6, W-3, W-7) When informed of the finding by the NYSDPS inspector, CYNOG’s responsible person stated that he was only trying to accommodate the land owners land use requirements. He stated that CYNOG utilizes a motor vehicle to conduct the patrols and they did not want to inflict damage to the crops that are grown on most of the Right Of Way involved. CNYOG informed the NYSDPS inspector that in the future the patrols will be conducted in the autumn, as this is the time of year when the ground is generally firm enough for a vehicle patrol and the crops have been harvested. 2. §192.706 Transmission lines: Leakage surveys. Leakage surveys of a transmission line must be conducted at intervals not exceeding 15 months, but at least once each calendar year… CYNOG failed to leak survey their un-odorized Class 1 transmission line at an interval not to exceed 15 months… Specifically, from the period starting in April 2012 and ending in October 2013, CNYOG conducted leak surveys at an interval of approximately 18 months on the following ROWs: 1. South Lateral (Compressor Station to TGP 319) 2. North Lateral (Compressor Station to Millennium Meter) 3. Barnhart (Compressor Station to B-2) 4. Barnhart/Lydell (B-2 to L-5) 5. Widell/Barnhart 12”, 16”, 20” (Compressor Station to 16” X-over, W-6, W-3, W-7) When informed of the finding by the NYSDPS inspector, CYNOG’s responsible person stated that he was only trying to accommodate the land owners land use requirements. He stated that CYNOG utilizes a motor vehicle to conduct the leakage surveys and they did not want to inflict damage to the crops that are grown on most of the Right Of Way. CNYOG informed the NYSDPS inspector that in the future the leak surveys will be conducted in the autumn, as this is the time of year when the ground is generally firm enough for a vehicle patrol and the crops have been harvested. 120151004W_WL_02262015 Page 2 of 3 1-2015-1004W 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. We have reviewed the circumstances and supporting documents involved in this case, and have decided not to conduct additional enforcement action or penalty assessment proceedings at this time. We advise you to correct the item(s) identified in this letter. Failure to do so will result in CNYOG being subject to additional enforcement action. No reply to this letter is required. If you choose to reply, please address your correspondence to: Byron Coy, PE, Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103, W. Trenton, NJ 08628 and please refer to CPF 1-2015-1004W. 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). Additionally, if you choose to respond to this (or any other case), please ensure that any response letter pertains solely to one CPF case number Sincerely, Byron Coy, PE Director, Eastern Pipeline and Hazardous Materials Safety Administration Cc: Kevin Speicher, NYSDPS 120151004W_WL_02262015 Page 3 of 3 - **truncated:** false - **body characters:** 6422