HONEOYE STORAGE CORP — Notice of Amendment

party submissionOfficial PDF120181022M_Operator Response to Notice_11272018.pdf#

120181022M_Closure Letter_12072018_text.pdf, page 1Official PDFOVERNIGHT EXPRESS DELIVERY December 7, 2018 Mr. Scott Warnshouse General Manager Operations Honeoye Storage Corp. 4511 Egypt Road Canandaigua, NY 14424 CPF 1-2018-1022M Dear Mr. Warnshouse: From June 19-21, 2018, a representative from the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site pipeline safety inspection of Honeoye Storage Corp. (Honeoye) procedures at Honeoye Underground Natural Gas Storage field in Ontario County, New York. As a result of the inspection, Honeoye was issued a Notice of Amendment on October 29, 2018, which proposed amendments of your procedures. Honeoye submitted its amended procedures on November 27, 2018. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration#

120181022M_Notice of Amendment_10292018_text.pdf, page 1Official PDFNOTICE OF AMENDMENT OVERNIGHT EXPRESS DELIVERY October 29, 2018 Mr. Scott Warnshouse General Manager Operations Honeoye Storage Corp. 4511 Egypt Road Canandaigua, NY 14424 CPF 1-2018-1022M Dear Mr. Warnshouse: From June 19 to 21, 2018, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Honeoye Storage Corp. (Honeoye) procedures and records for the Honeoye Underground Natural Gas Storage field in Ontario County, New York. On the basis of the inspection, PHMSA has identified the apparent inadequacies found within Honeoye’s plans or procedures, as described below: 1. § 192.12 Underground natural gas storage facilities. (e) Operators of underground gas storage facilities must establish and follow written procedures for operations, maintenance, and emergencies implementing the requirements of API RP 1170 and API RP 1171, as required under this section, including the effective dates as applicable, and incorporate such procedures into their written procedures for operations, maintenance, and emergencies established pursuant to §192.605. Honeoye’s procedures for operations, maintenance and emergencies implementing the requirements of API RP 1170 and API RP 1171 were inadequate. Specifically, Honeoye’s procedures do not define an annular pressure threshold to determine if additional evaluation is required in accordance with API RP 1171, Section 9.3.2.#

120181022M_Notice of Amendment_10292018_text.pdf, page 2CPF 1-2018-1022M 2. § 192.12 Underground natural gas storage facilities. (e) Operators of underground gas storage facilities must establish and follow written procedures for operations, maintenance, and emergencies implementing the requirements of API RP 1170 and API RP 1171, as required under this section, including the effective dates as applicable, and incorporate such procedures into their written procedures for operations, maintenance, and emergencies established pursuant to §192.605. Honeoye’s procedures for operations, maintenance and emergencies implementing the requirements of API RP 1170 and API RP 1171 were inadequate. Specifically, Honeoye does not have a procedure to verify all applicable staff receive training in the use of the emergency preparedness/response plan in accordance with API RP 1171, Section 10.6.2. 3. § 192.12 Underground natural gas storage facilities. (e) Operators of underground gas storage facilities must establish and follow written procedures for operations, maintenance, and emergencies implementing the requirements of API RP 1170 and API RP 1171, as required under this section, including the effective dates as applicable, and incorporate such procedures into their written procedures for operations, maintenance, and emergencies established pursuant to §192.605. Honeoye’s procedures for operations, maintenance and emergencies implementing the requirements of API RP 1170 and API RP 1171 were inadequate. Specifically, Honeoye does not have a procedure to measure the effectiveness of operator familiarity with emergency plans and procedures and periodic testing of the effectiveness of the plan in accordance with API RP 1171, Section 11.4.2. 4. § 192.12 Underground natural gas storage facilities. (e) Operators of underground gas storage facilities must establish and follow written procedures for operations, maintenance, and emergencies implementing the requirements of API RP 1170 and API RP 1171, as required under this section, including the effective dates as applicable, and incorporate such procedures into their written procedures for operations, maintenance, and emergencies established pursuant to §192.605. Honeoye’s procedures for operations, maintenance and emergencies implementing the requirements of API RP 1170 and API RP 1171 were inadequate. Specifically, Honeoye does not have a procedure for the joining of API and ANSI flanges as observed in the field portion of the inspection, in accordance with API RP 1171 Section 11.2.1. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings. Please refer to this document and note the response options. 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 120181022M_Notice of Amendment_10292018_text Page 2 of 3#

120181022M_Notice of Amendment_10292018_text.pdf, page 3CPF 1-2018-1022M 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). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 90 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that Honeoye maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 1-2018-1022M and, for each document you submit, please provide a copy in electronic format whenever possible. Please note, the address for the PHMSA Eastern Region, Office of Pipeline Safety, has changed: PHMSA, Eastern Region, Office of Pipeline Safety 840 Bear Tavern Road, Suite 300 West Trenton, NJ 08628 Please make a note of this new information in your records. If you have any questions, please contact us at 609-771-7800. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings 120181022M_Notice of Amendment_10292018_text Page 3 of 3#