{"operation":"document","citation":"CPF 12024049WL","title":"RH ENERGYTRANS, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-06-18","effective_on":null,"summary":"CLOSED warning letter citing 192.161(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024049wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024049wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024049wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12024049WL","body":"Warning Letter involving RH ENERGYTRANS, LLC. PHMSA's enforcement data identifies the cited regulation as 192.161(c). The case was opened on 2024-06-18 and is reported as closed as of 2024-06-18. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12024049WL_Warning Letter_06182024_(23-263966).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024049WL/12024049WL_Warning%20Letter_06182024_(23-263966).pdf\n\n12024049WL_Warning Letter_06182024_(23-263966)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024049WL/12024049WL_Warning%20Letter_06182024_(23-263966)_text.pdf\n\n12024049WL_Warning Letter_06182024_(23-263966)_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nJune 18, 2024\nMr. Kyle Rhoades\nChief Operating Officer\nRH Energytrans, LLC\n558 West 6th Street\nEerie, Pennsylvania 16507\nCPF 1-2024-049-WL\nDear Mr. Rhoades:\nFrom October 31, 2023 to November 2, 2023, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) inspected RH Energytrans, LLC’s (RH energytrans) pipelines in Pennsylvania and Ohio.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and\nthe probable violation is:\n1. § 192.161 Supports and anchors.\n(c) Each support or anchor on an exposed pipeline must be made of\ndurable, noncombustible material and must be designed and installed\nas follows:\nRH Energytrans failed to construct each support or anchor on an exposed pipeline out of durable,\nnoncombustible material in accordance with § 192.161(c).\nDuring the field inspection on October 31, 2023, the PHMSA inspector observed wooden shims\nbeing utilized as pipe support at North Kingsville Delivery in Ohio. In addition, during the field\ninspection on November 1, 2023, the PHMSA inspector observed wooden skids being used as\nsupport for a valve connected to a pipe at Meadville Compressor Station in Pennsylvania.\n\n\n\nTherefore, RH energytrans failed to comply with the requirements of § 192.161(c).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$266,015 per violation per day the violation persists, up to a maximum of $2,660,135 for a related\nseries of violations. For violation occurring on or after January 6, 2023 and before December 28,\n2023, the maximum penalty may not exceed $257,664 per violation per day the violation persists,\nup to a maximum of $2,576,627 for a related series of violations. For violation occurring on or\nafter March 21, 2022 and before January 6, 2023, the maximum penalty may not exceed $239,142\nper violation per day the violation persists, up to a maximum of $2,391,142 for a related series of\nviolations. For violation occurring on or after May 3, 2021 and before March 21, 2022, the\nmaximum penalty may not exceed $225,134 per violation per day the violation persists, up to a\nmaximum of $2,251,334 for a related series of violations. For violation occurring on or after\nJanuary 11, 2021 and before May 3, 2021, the maximum penalty may not exceed $222,504 per\nviolation per day the violation persists, up to a maximum of $2,225,034 for a related series of\nviolations. For violation occurring on or after July 31, 2019 and before January 11, 2021, the\nmaximum penalty may not exceed $218,647 per violation per day the violation persists, up to a\nmaximum 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.\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 identified in this letter. Failure to do so will result in RH\nEnergytrans, LLC 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 1-2024-049-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, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":4915}