RH ENERGYTRANS, LLC — Warning Letter

12024049WL_Warning Letter_06182024_(23-263966)_text.pdf, page 1Official PDFWARNING LETTER OVERNIGHT EXPRESS DELIVERY June 18, 2024 Mr. Kyle Rhoades Chief Operating Officer RH Energytrans, LLC 558 West 6th Street Eerie, Pennsylvania 16507 CPF 1-2024-049-WL Dear Mr. Rhoades: From October 31, 2023 to November 2, 2023, 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 (RH energytrans) pipelines in Pennsylvania and Ohio. 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. § 192.161 Supports and anchors. (c) Each support or anchor on an exposed pipeline must be made of durable, noncombustible material and must be designed and installed as follows: RH Energytrans failed to construct each support or anchor on an exposed pipeline out of durable, noncombustible material in accordance with § 192.161(c). During the field inspection on October 31, 2023, the PHMSA inspector observed wooden shims being utilized as pipe support at North Kingsville Delivery in Ohio. In addition, during the field inspection on November 1, 2023, the PHMSA inspector observed wooden skids being used as support for a valve connected to a pipe at Meadville Compressor Station in Pennsylvania.#

12024049WL_Warning Letter_06182024_(23-263966)_text.pdf, page 2Therefore, RH energytrans failed to comply with the requirements of § 192.161(c). Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $266,015 per violation per day the violation persists, up to a maximum of $2,660,135 for a related series of violations. For violation occurring on or after January 6, 2023 and before December 28, 2023, the maximum penalty may not exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related series of violations. For violation occurring on or after March 21, 2022 and before January 6, 2023, the maximum penalty may not exceed $239,142 per violation per day the violation persists, up to a maximum of $2,391,142 for a related series of violations. For violation occurring on or after May 3, 2021 and before March 21, 2022, the maximum penalty may not exceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related series of violations. For violation occurring on or after January 11, 2021 and before May 3, 2021, the maximum penalty may not 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. 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 identified in this letter. Failure to do so will 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 1-2024-049-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, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration#