{"operation":"document","citation":"CPF 120181022M","title":"HONEOYE STORAGE CORP — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-10-29","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181022m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181022m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181022m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120181022M","body":"Notice of Amendment involving HONEOYE STORAGE CORP. PHMSA's enforcement data identifies the cited regulation as 192.12(e). The case was opened on 2018-10-29 and is reported as closed as of 2018-12-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120181022M_Closure Letter_12072018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181022M/120181022M_Closure%20Letter_12072018.pdf\n\n120181022M_Closure Letter_12072018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181022M/120181022M_Closure%20Letter_12072018_text.pdf\n\n120181022M_Notice of Amendment_10292018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181022M/120181022M_Notice%20of%20Amendment_10292018.pdf\n\n120181022M_Notice of Amendment_10292018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181022M/120181022M_Notice%20of%20Amendment_10292018_text.pdf\n\n120181022M_Operator Response to Notice_11272018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181022M/120181022M_Operator%20Response%20to%20Notice_11272018.pdf\n\n120181022M_Closure Letter_12072018_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nDecember 7, 2018\nMr. Scott Warnshouse\nGeneral Manager Operations\nHoneoye Storage Corp.\n4511 Egypt Road\nCanandaigua, NY 14424\nCPF 1-2018-1022M\nDear Mr. Warnshouse:\nFrom June 19-21, 2018, a representative from the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site\npipeline safety inspection of Honeoye Storage Corp. (Honeoye) procedures at Honeoye\nUnderground Natural Gas Storage field in Ontario County, New York.\nAs a result of the inspection, Honeoye was issued a Notice of Amendment on October 29, 2018,\nwhich proposed amendments of your procedures.\nHoneoye submitted its amended procedures on November 27, 2018. My staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n120181022M_Notice of Amendment_10292018_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nOctober 29, 2018\nMr. Scott Warnshouse\nGeneral Manager Operations\nHoneoye Storage Corp.\n4511 Egypt Road\nCanandaigua, NY 14424\nCPF 1-2018-1022M\nDear Mr. Warnshouse:\nFrom June 19 to 21, 2018, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nHoneoye Storage Corp. (Honeoye) procedures and records for the Honeoye Underground Natural\nGas Storage field in Ontario County, New York.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nHoneoye’s plans or procedures, as described below:\n1. § 192.12 Underground natural gas storage facilities.\n(e) Operators of underground gas storage facilities must establish and follow written\nprocedures for operations, maintenance, and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171, as required under this section,\nincluding the effective dates as applicable, and incorporate such procedures into their\nwritten procedures for operations, maintenance, and emergencies established\npursuant to §192.605.\nHoneoye’s procedures for operations, maintenance and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171 were inadequate. Specifically, Honeoye’s\nprocedures do not define an annular pressure threshold to determine if additional evaluation is\nrequired in accordance with API RP 1171, Section 9.3.2.\n\n\n\nCPF 1-2018-1022M\n2. § 192.12 Underground natural gas storage facilities.\n(e) Operators of underground gas storage facilities must establish and follow written\nprocedures for operations, maintenance, and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171, as required under this section,\nincluding the effective dates as applicable, and incorporate such procedures into their\nwritten procedures for operations, maintenance, and emergencies established\npursuant to §192.605.\nHoneoye’s procedures for operations, maintenance and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171 were inadequate. Specifically, Honeoye does not\nhave a procedure to verify all applicable staff receive training in the use of the emergency\npreparedness/response plan in accordance with API RP 1171, Section 10.6.2.\n3. § 192.12 Underground natural gas storage facilities.\n(e) Operators of underground gas storage facilities must establish and follow written\nprocedures for operations, maintenance, and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171, as required under this section,\nincluding the effective dates as applicable, and incorporate such procedures into their\nwritten procedures for operations, maintenance, and emergencies established\npursuant to §192.605.\nHoneoye’s procedures for operations, maintenance and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171 were inadequate. Specifically, Honeoye does not\nhave a procedure to measure the effectiveness of operator familiarity with emergency plans and\nprocedures and periodic testing of the effectiveness of the plan in accordance with API RP 1171,\nSection 11.4.2.\n4. § 192.12 Underground natural gas storage facilities.\n(e) Operators of underground gas storage facilities must establish and follow written\nprocedures for operations, maintenance, and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171, as required under this section,\nincluding the effective dates as applicable, and incorporate such procedures into their\nwritten procedures for operations, maintenance, and emergencies established\npursuant to §192.605.\nHoneoye’s procedures for operations, maintenance and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171 were inadequate. Specifically, Honeoye does not\nhave a procedure for the joining of API and ANSI flanges as observed in the field portion of the\ninspection, in accordance with API RP 1171 Section 11.2.1.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\n120181022M_Notice of Amendment_10292018_text Page 2 of 3\n\n\n\nCPF 1-2018-1022M\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 90 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Honeoye maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please refer\nto CPF 1-2018-1022M and, for each document you submit, please provide a copy in electronic\nformat whenever possible.\nPlease note, the address for the PHMSA Eastern Region, Office of Pipeline Safety, has changed:\nPHMSA, Eastern Region, Office of Pipeline Safety\n840 Bear Tavern Road, Suite 300\nWest Trenton, NJ 08628\nPlease make a note of this new information in your records. If you have any questions, please\ncontact us at 609-771-7800.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120181022M_Notice of Amendment_10292018_text Page 3 of 3","truncated":false,"body_characters":9193}