{"operation":"document","citation":"CPF 12021010WL","title":"HONEOYE STORAGE CORP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-03-05","effective_on":null,"summary":"CLOSED warning letter citing 192.201(a)(2)(i), 192.619(a), 192.705(b), 192.709(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021010wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021010wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021010wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12021010WL","body":"Warning Letter involving HONEOYE STORAGE CORP. PHMSA's enforcement data identifies the cited regulations as 192.201(a)(2)(i),  192.619(a),  192.705(b),  192.709(c). 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.\n\nOfficial case documents:\n\n12021010WL_Warning Letter_03052021_(20-177166).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021010WL/12021010WL_Warning%20Letter_03052021_(20-177166).pdf\n\n12021010WL_Warning Letter_03052021_(20-177166)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021010WL/12021010WL_Warning%20Letter_03052021_(20-177166)_text.pdf\n\n12021010WL_Warning Letter_03052021_(20-177166)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: carnavosp@conedtransmission.com\nMarch 5, 2021\nPeter Carnavos\nPresident\nHoneoye Storage Corp\n4 Irving Place\nNew York, NY 10003\nCPF 1-2021-010-WL\nDear Peter Carnavos:\nOn May 26, 2020 to August 14, 2020, an inspector from the New York Department of Public\nService (NY DPS), acting as Agent for the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nHoneoye Storage Corp’s (HSC) Compression Station and pipe in Ontario county New York.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. 192.201 Required capacity of pressure relieving and limiting stations.\n(a) Each pressure relief station or pressure limiting station or group\nof those stations installed to protect a pipeline must have enough\ncapacity, and must be set to operate, to insure the following:\n(1) …\n(2) In pipelines other than a low pressure distribution system:\n(i) If the maximum allowable operating pressure is 60 p.s.i. (414\nkPa) gage or more, the pressure may not exceed the maximum\nallowable operating pressure plus 10 percent, or the pressure that\nproduces a hoop stress of 75 percent of SMYS, whichever is lower.\n\n\n\nCPF 1-2021-010-WL\nHSC failed to have each pressure relief device set to operate at a pressure that would not exceed\nthe maximum allowable operating pressure plus 10 percent (%), or the pressure that produces a\nhoop stress of 75% of SMYS, whichever is lower. Specifically, HSC failed to set the RV-1 relief\ndevice to relieve within the 1,030 psig maximum allowable operating pressure (MAOP) limit plus\n10% during the 2017 inspection and test of RV-1.\nDuring the inspection, the NY DPS inspector reviewed HSC’s relief device inspection and test\nrecords for 2016-2020. The Relief Valve Testing records indicated that RV-1 high pressure relief\nvalve was found at 1,148 psig and left at 1,135 psig on 10/17/2017. These pressures exceeded the\nMAOP plus 10% of 1,133 psi.\nAdditionally, the Relief Valve Testing records indicated that RV-1 high pressure relief valve was\nfound at 1,135 psig and left at 1,133 on 10/24/2016. Setting a pressure relief device at MAOP plus\n10% (1,133 psig) could result in over pressurization as pressure drop between the pressure relief\nvalve to the regulator is not accounted for. A pressure relief valve begins to open at the set pressure\nplus any backpressure and kickoff pressure, and continues to open before it begins to relieve fully\nopen. This results in an accumulation of overpressure above the set pressure due to the pressure\ndrop. Therefore, setting a pressure relief device at MAOP plus 10% does not ensure pressure will\nnot exceed the MAOP plus 10%.\nTherefore, HSC failed to set the RV-1 pressure relief station to operate at a pressure that will not\nexceed MAOP plus 10% in accordance with § 192.201(a)(2)(i).\n2. §192.619 Maximum allowable operating pressure: Steel or plastic pipelines.\n(a) No person may operate a segment of steel or plastic pipeline at a\npressure that exceeds a maximum allowable operating pressure\n(MAOP) determined under paragraph (c), (d), or (e) of this section, or\nthe lowest of the following:\nHSC failed to determine the maximum allowable operating pressure (MAOP) for steel pipeline\nsegments in accordance with § 192.619. Specifically, HSC records failed to substantiate the\nestablished MAOP of its pipelines pursuant to § 192.619(a).\nDuring the inspection, the NY DPS inspector reviewed HSC’s historical pipe segment\nsummary. The records indicated the established MAOP of 1,030 psig for the segments listed\nbelow. However, the pressure obtained by dividing the pressure to which the segment was tested\nafter construction by 1.1, as per § 192.619(a)(2)(ii)1, was lower than the established MAOP.\n Elm Tree Rd. West, Section 4: Test pressure 1,130 psig / 1.1 = 1,027 psig\n Route 64 West, Section 6: Test pressure 1,130 psig / 1.1 = 1,027 psig.\n Hopkins Rd. to Hickox Rd., Section 11: Test pressure 1,129 psig / 1.1 = 1,026 psig\n Hopkins Rd. to Hickox Rd., Section 12: Test pressure 1,129 psig / 1.1 = 1,026 psig\nTherefore, HSC failed to establish a MAOP for its steel pipeline segments that did not exceed the\nlowest applicable pressure determined in accordance with § 192.619(a).\n12021010WL_Warning Letter_03052021_(20-177166)_text Page 2 of 5\n\n\n\nCPF 1-2021-010-WL\n3. §192.705 - Transmission lines: Patrolling.\n(a) …\n(b) The frequency of patrols is determined by the size of the line, the\noperating pressures, the class location, terrain, weather, and other\nrelevant factors, but intervals between patrols may not be longer than\nprescribed in the following table:\nMaximum interval between patrols\nClass location of\nline At highway and railroad crossings At all other places\n1, 2 71∕2 months; but at least twice each\ncalendar year\n15 months; but at least once each\ncalendar year.\n3 41∕2 months; but at least four times each\ncalendar year\n71∕2 months; but at least twice each\ncalendar year.\n4 41∕2 months; but at least four times each\ncalendar year\n41∕2 months; but at least four times each\ncalendar year.\nHSC failed to patrol transmission pipeline highway and railroad crossings at an interval not longer\nthan 7 ½-months, but at least twice each calendar year. Specifically, HSC exceeded the 7-½ month\nmaximum interval for 13 highway and railroad crossings in Class 1 and 2 locations along its TGP\nto HSC Compressor Station transmission pipeline between 2018 and 2019.\nDuring the inspection, the NY DPS inspector reviewed HSC’s Road Crossing Inspection records\nfor 2016-2020. The records indicated that the 13 highway and railroad crossings from TGP to\nHSC Compressor Station were patrolled on 10/23/18, and not again until 9/14/19, which exceeded\nthe 7 ½-month maximum interval for Class 1 and 2 locations by 97 days.\nTherefore, HSC failed to patrol its transmission pipeline’s highway and railroad crossings at 7 ½-\nmonth intervals in accordance with § 192.705(b).\n4. §192.709 - Transmission lines: Record keeping.\n(c) A record of each patrol, survey, inspection, and test required by\nsubparts L and M of this part must be retained for at least 5 years or\nuntil the next patrol, survey, inspection, or test is completed, whichever\nis longer.\nEach operator shall maintain the following records for transmission\nlines for the periods specified:\nHSC failed to maintain a record of each patrol, survey, inspection, and test required by subparts L\nand M of Part 192 for at least 5 years or until the next inspection or test is completed, whichever\nis longer. Specifically, HSC failed to maintain records demonstrating that two (2) compressor\nstation pressure relieving devices were inspected and tested in accordance with § 192.739(a)2, as\nrequired by § 192.731(a)3, during 2015 and 2016.\n12021010WL_Warning Letter_03052021_(20-177166)_text Page 3 of 5\n\n\n\nCPF 1-2021-010-WL\nSection 192.731(a) requires that each pressure limiting station, relief device (except rupture discs)\nand pressure regulating station and its equipment be inspected and tested in accordance with\n§ 192.739(a) at intervals not exceeding 15 months, but at least once each calendar year.\nDuring the inspection, the NY DPS inspector reviewed HSCs compressor station relief device\ninspection and test records for 2015-2019. The records indicated that the RV-9 compressor station\nrelief device was inspected and tested on 10/25/16, 10/17/17, 11/05/18, and 11/05/19, but there\nwas no 2015 inspection and test record. The records also indicated that the RV-24 compressor\nstation relief device was inspected and tested on 8/20/15, 10/17/17, 11/06/18, and 11/04/19, but\nthere was no 2016 inspection and test record.\nTherefore, HSC failed in 2 instances to maintain a record of each inspection and test for the RV-9\ncompressor station relief device and for the RV-24 compressor station relief device, as required\nby § 192.709(c).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for a related\nseries of violations. For violation occurring on or after July 31, 2019 and before January 11, 2021,\nthe maximum penalty may not exceed $218,647 per violation per day the violation persists, up to\na maximum of $2,186,465 for a related series of violations. For violation occurring on or after\nNovember 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per\nviolation per day, with a maximum penalty not to exceed $2,132,679. For violation occurring on\nor after November 2, 2015 and before November 27, 2018, the maximum penalty may not exceed\n$209,002 per violation per day, with a maximum penalty not to exceed $2,090,022.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the item(s) identified in this letter. Failure to do so will result in\nHoneoye Gas Storage Corp being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2021-010-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n1 §192.619 Maximum allowable operating pressure: Steel or plastic pipelines.\n12021010WL_Warning Letter_03052021_(20-177166)_text Page 4 of 5\n\n\n\nCPF 1-2021-010-WL\n(a) No person may operate a segment of steel or plastic pipeline at a pressure that exceeds a\nmaximum allowable operating pressure (MAOP) determined under paragraph (c), (d), or (e) of\nthis section, or the lowest of the following:\n(1) …\n(2) The pressure obtained by dividing the pressure to which the pipeline segment was tested after\nconstruction as follows:\n(i) …\n(ii) For steel pipe operated at 100 psi (689 kPa) gage or more, the test pressure is divided by a\nfactor determined in accordance with the Table 1 to paragraph (a)(2)(ii):\nTABLE 1 TO PARAGRAPH (a)(2)(ii)\nFactors,1 segment—\nClass location\nInstalled\nbefore\n(Nov. 12, 1970)\nInstalled\nafter\n(Nov. 11, 1970)\nand before\nJuly 1, 2020\nInstalled\non or after\nJuly 1, 2020\nConverted\nunder §192.14\n1 1.1 1.1 1.25 1.25\n2 1.25 1.25 1.25 1.25\n3 1.4 1.5 1.5 1.5\n4 1.4 1.5 1.5 1.5\n2 §192.739 Pressure limiting and regulating stations: Inspection and testing.\n(a) Each pressure limiting station, relief device (except rupture discs), and pressure regulating station\nand its equipment must be subjected at intervals not exceeding 15 months, but at least once each\ncalendar year, to inspections and tests to determine that it is-\n(1) In good mechanical condition;\n(2) Adequate from the standpoint of capacity and reliability of operation for the service in which it\nis employed;\n(3) Except as provided in paragraph (b) of this section, set to control or relieve at the correct pressure\nconsistent with the pressure limits of §192.201(a); and\n(4) Properly installed and protected from dirt, liquids, or other conditions that might prevent proper\noperation.\n3 §192.731 Compressor stations: Inspection and testing of relief devices.\n(a) Except for rupture discs, each pressure relieving device in a compressor station must be inspected\nand tested in accordance with §§192.739 and 192.743, and must be operated periodically to\ndetermine that it opens at the correct set pressure.\n12021010WL_Warning Letter_03052021_(20-177166)_text Page 5 of 5","truncated":false,"body_characters":12907}