# PGPIPELINE, LLC. — Warning Letter

- **operation:** document
- **citation:** CPF 120191019W
- **title:** PGPIPELINE, LLC. — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2019-09-26
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.935(d)(3).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-120191019w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-120191019w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-120191019w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120191019W
**body:**

Warning Letter involving PGPIPELINE, LLC.. PHMSA's enforcement data identifies the cited regulation as 192.935(d)(3). The case was opened on 2019-09-26 and is reported as closed as of 2019-09-26. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120191019W_Operator Response to Notice_10232019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191019W/120191019W_Operator%20Response%20to%20Notice_10232019.pdf

120191019W_Warning Letter_09262019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191019W/120191019W_Warning%20Letter_09262019.pdf

120191019W_Warning Letter_09262019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191019W/120191019W_Warning%20Letter_09262019_text.pdf

120191019W_Warning Letter_09262019_text.pdf

WARNING LETTER
OVERNIGHT EXPRESS DELIVERY
September 26, 2019
Mr. Steve Newell
Director of Finance
Zeeland Farm Services, Inc.
2525 84th Ave
Zeeland, MI 49464
CPF 1-2019-1019W
Dear Mr. Newell:
From January 23, 2019 – July 11, 2019, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),
performed an integrated inspection of PGPipeline, LLC’s (PGPipeline) pipeline system in
Clearfield, Pennsylvania. PGPipeline is a second-tier subsidiary of Zeeland Farm Services, Inc.
As a result of the inspection, it is alleged that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item(s) inspected
and the probable violation(s) are:
1. § 192.935 What additional preventive and mitigative measures must an operator
take?
(d) Pipelines operating below 30% SMYS. An operator of a transmission pipeline
operating below 30% SMYS located in a high consequence area must follow the
requirements in paragraphs (d)(1) and (d)(2) of this section. An operator of a
transmission pipeline operating below 30% SMYS located in a Class 3 or Class 4 area
but not in a high consequence area must follow the requirements in paragraphs (d)(1),
(d)(2) and (d)(3) of this section.
…



CPF 1-2019-1019W
(3) Perform semi-annual leak surveys (quarterly for unprotected pipelines or
cathodically protected pipe where electrical surveys are impractical)
PGPipeline failed to perform semi-annual leak surveys on its Clearfield County, PA transmission
pipeline (CC pipeline) during 2018, as required by § 192.935(d)(3).
PGPipeline’s CC pipeline is a transmission line operating below 30% SMYS in a Class 3 location,
with sections not in a high consequence area. During the inspection, the PHMSA inspector
reviewed PGPipeline’s procedure and associated 2018 leak survey records for this pipeline. The
records demonstrated that PGPipeline only conducted one leak survey of the CC pipeline during
calendar year 2018.
Therefore, PGPipeline failed to perform semi-annual leak surveys on its CC pipeline during 2018,
as required by § 192.935(d)(3).
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related
series of violations. For violation occurring on or after November 27, 2018 and before July 31,
2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum
penalty not to exceed $2,132,679. For violation occurring on or after November 2, 2015 and before
November 27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a
maximum penalty not to exceed $2,090,022. For violations occurring prior to November 2, 2015,
the maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty
not to exceed $2,000,000 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 PGPipeline, LLC being subject to
additional enforcement action.
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).
No reply to this letter is required. If you choose to reply, please submit all correspondence in this
matter to Robert Burrough, Director, PHMSA Eastern Region, 840 Bear Tavern Road, Suite 300,
West Trenton, NJ 08628. Please refer to CPF 1-2019-1019W on each document you submit, and
whenever possible provide a signed PDF copy in electronic format. Smaller files may be emailed
to robert.burrough@dot.gov. Larger files should be sent on USB flash drive accompanied by the
original paper copy to the Eastern Region Office.
120191019W_Warning Letter_09262019_text Page 2 of 3



CPF 1-2019-1019W
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
120191019W_Warning Letter_09262019_text Page 3 of 3
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