# RH ENERGYTRANS, LLC — Warning Letter

- **operation:** document
- **citation:** CPF 12021009WL
- **title:** RH ENERGYTRANS, LLC — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2021-03-05
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 191.29(b).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-12021009wl.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-12021009wl.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-12021009wl
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/12021009WL
**body:**

Warning Letter involving RH ENERGYTRANS, LLC. PHMSA's enforcement data identifies the cited regulation as 191.29(b). The case was opened on 2021-03-05 and is reported as closed as of 2021-03-05. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

12021009WL_Warning Letter_03052021_(21-201281).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021009WL/12021009WL_Warning%20Letter_03052021_(21-201281).pdf

12021009WL_Warning Letter_03052021_(21-201281)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021009WL/12021009WL_Warning%20Letter_03052021_(21-201281)_text.pdf

12021009WL_Warning Letter_03052021_(21-201281)_text.pdf

WARNING LETTER
VIA ELECTRONIC MAIL TO: krhoades@rhenergytrans.com
March 5, 2021
Mr. Kyle Rhoades
Chief Operating Officer
RH Energytrans, LLC
558 West 6th Street
Erie, Pennsylvania 16507
CPF 1-2021-009-WL
Dear Mr. Rhoades:
On December 10, 2020, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected
RH Energytrans, LLC’s compliance with the National Pipeline Mapping System (NPMS)
submittal requirement for calendar year 2019.
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 inspected and
the probable violation is:
1. §191.29 National Pipeline Mapping System.
(a) …
(b) The information required in paragraph (a) of this section must
be submitted each year, on or before March 15, representing assets as
of December 31 of the previous year. If no changes have occurred since
the previous year's submission, the operator must comply with the
guidance provided in the NPMS Operator Standards manual available
at www.npms.phmsa.dot.gov or contact the PHMSA Geographic
Information Systems Manager at (202) 366-4595.
RH Energytrans, LLC failed to submit information required in paragraph (a) of § 191.29, on or
before March 15, representing its assets as of December 31 of the previous year. Specifically, RH



CPF 1-2021-009-WL
Energytrans, LLC failed to submit to PHMSA 1) Geospatial data, attributes, metadata and
transmittal letter appropriate for use in the National Pipeline Mapping System; 2) the name of and
address for the operator; and 3) the name and contact information of a pipeline company employee,
to be displayed on a public Web site, who will serve as a contact for questions from the general
public about the operator's NPMS data for its assets as of December 31, 2019, by the due date of
March 15, 2020.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for a related
series of violations. For violation occurring on or after July 31, 2019 and before January 11, 2021,
the maximum penalty may not 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.
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 complete an accurate and acceptable calendar year 2020 NPMS submittal
for all of the gas transmission pipelines in your calendar year 2020 Annual Report on or before
March 15, 2021. Failure to do so may result in RH Energytrans, LLC being subject to additional
enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 1-2021-009-WL. 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).
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
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