{"operation":"document","citation":"CPF 12026049NOA","title":"WYCKOFF GAS STORAGE COMPANY, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2026-06-30","effective_on":null,"summary":"OPEN notice of amendment citing 191.23(a), 191.5(a), 192.13(d), 192.199, 192.225(a), 192.225(b), 192.3, 192.303, 192.465(d), 192.481(a), 192.485(a), 192.485(b), 192.485(c), 192.605(a), 192.605(b)(5), 192.605(c), 192.605(c)(4), 192.605(d), 192.613(a), 192.613(b), 192.613(c), 192.614(a), 192.615(a)(3), 192.617(a), 192.619(a)(1), 192.619(a)(2), 192.631(c)(3), 192.706, 192.710(a)(1), 192.710(a)(2), 192.714(d)(1), 192.717(b)(2), 192.739(a), 192.745(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026049noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026049noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026049noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12026049NOA","body":"Notice of Amendment involving WYCKOFF GAS STORAGE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulations as 191.23(a),  191.5(a),  192.13(d),  192.199,  192.225(a),  192.225(b),  192.3,  192.303,  192.465(d),  192.481(a),  192.485(a),  192.485(b),  192.485(c),  192.605(a),  192.605(b)(5),  192.605(c),  192.605(c)(4),  192.605(d),  192.613(a),  192.613(b),  192.613(c),  192.614(a),  192.615(a)(3),  192.617(a),  192.619(a)(1),  192.619(a)(2),  192.631(c)(3),  192.706,  192.710(a)(1),  192.710(a)(2),  192.714(d)(1),  192.717(b)(2),  192.739(a),  192.745(a). The case was opened on 2026-06-30 and is reported as open. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12026049NOA_Notice of Amendment_06302026_(25-329592).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026049NOA/12026049NOA_Notice%20of%20Amendment_06302026_(25-329592).pdf\n\n12026049NOA_Notice of Amendment_06302026_(25-329592)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026049NOA/12026049NOA_Notice%20of%20Amendment_06302026_(25-329592)_text.pdf\n\n12026049NOA_Notice of Amendment_06302026_(25-329592)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials\nSafety Administration\n840 Bear Tavern Road, Suite 300\nWest Trenton, New Jersey 08628\n609.771.7800\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: CharlesL@KFOC.net\nJune 30, 2026\nMr. Don Millican\nVice President/CFO\nWyckoff Gas Storage Company, LLC\n6733 S. Yale Avenue\nTulsa, Oklahoma 74136\nCPF 1-2026-049-NOA\nDear Mr. Millican:\nFrom April 8 2025 through August 7, 2025, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\nconducted an inspection of Wyckoff Gas Storage Company, LLC’s (Wyckoff) procedures,\nrecords, and facilities in Greenwood, New York.\nAs a result of the inspection, PHMSA has identified apparent inadequacies within Wyckoff’s plans\nor procedures. The items inspected and the inadequacies are described below:\n1. § 191.23 Reporting safety-related conditions.\n(a) Except as provided in paragraph (b) of this section, each operator shall\nreport in accordance with § 191.25 the existence of any of the following\nsafety-related conditions involving facilities in service:\nWyckoff’s written procedures were inadequate to ensure safe operation of a pipeline facility.\nSpecifically, Wyckoff’s Operations and Maintenance Manual (Jan. 2022) (“O&M Plan”) failed\nto include adequate procedures for reporting safety related conditions in accordance with\n§ 191.23(a).\nDuring the inspection, PHMSA’s inspector reviewed Wyckoff's O&M Plan. Section P191.23,\n\"Reporting Safety Related Conditions\" failed to assign a responsible party for reporting safety-\nrelated conditions.\n\n\n\nCPF 1-2026-049-NOA\nTherefore, PHMSA proposes to require that Wyckoff revise its O&M Plan to identify a party\nresponsible for reporting safety-related conditions.\n2. § 191.5 Immediate notice of certain incidents.\n(a) At the earliest practicable moment following discovery, but no later\nthan one hour after confirmed discovery, each operator must give notice in\naccordance with paragraph (b) of this section of each incident as defined in\n§ 191.3.\nWyckoff’s written procedures were inadequate to ensure safe operation of a pipeline facility.\nSpecifically, Wyckoff’s O&M Plan failed to include adequate procedures for reporting incidents\nat the earliest practicable moment following discovery, but no later than one hour after confirmed\ndiscovery in accordance with § 191.5(a).\nWyckoff’s O&M Plan, Section P-191.5, “Incident Notification, Reporting and Investigation”\ninstructs personnel to give notice of a reportable incident at the earliest practicable moment, but\nfails to instruct personnel that this must be performed no later than one hour after confirmed\ndiscovery.\nTherefore, PHMSA proposes to require that Wyckoff revise its procedures to include adequate\nprocedures for reporting incidents at the earliest practicable moment following discovery, but no\nlater than one hour after confirmed discovery in accordance with § 191.5(a).\n3. § 192.13 What general requirements apply to pipelines regulated under this part?\n(a) . . . .\n(d) Each operator of an onshore gas transmission pipeline must evaluate\nand mitigate, as necessary, significant changes that pose a risk to safety or\nthe environment through a management of change process. Each operator of\nan onshore gas transmission pipeline must develop and follow a management\nof change process, as outlined in ASME B31.8S, section 11 (incorporated by\nreference, see § 192.7), that addresses technical, design, physical,\nenvironmental, procedural, operational, maintenance, and organizational\nchanges to the pipeline or processes, whether permanent or temporary. A\nmanagement of change process must include the following: reason for\nchange, authority for approving changes, analysis of implications, acquisition\nof required work permits, documentation, communication of change to\naffected parties, time limitations, and qualification of staff. For pipeline\nsegments other than those covered in subpart O of this part, this\nmanagement of change process must be implemented by February 26, 2024.\nThe requirements of this paragraph (d) do not apply to gas gathering\npipelines. Operators may request an extension of up to 1 year by submitting\na notification to PHMSA at least 90 days before February 26, 2024, in\naccordance with § 192.18. The notification must include a reasonable and\ntechnically justified basis, an up-to-date plan for completing all actions\nPage 2 of 19\n\n\n\nCPF 1-2026-049-NOA\nrequired by this section, the reason for the requested extension, current\nsafety or mitigation status of the pipeline segment, the proposed completion\ndate, and any needed temporary safety measures to mitigate the impact on\nsafety.\nWyckoff’s written procedures were inadequate to ensure safe operation of a pipeline facility.\nSpecifically, Wyckoff’s O&M Plan failed to include a procedure for management of change\nprocesses in accordance with § 192.13(d).\nTherefore, PHMSA proposes to require that Wyckoff revise its procedures to include a\nmanagement of change process in accordance with § 192.13(d).\n4. § 192.225 Welding procedures.\n(a) Welding must be performed by a qualified welder or welding operator\nin accordance with welding procedures qualified under section 5 (except for\nNote 2 in section 5.4.2.2), section 12, Appendix A or Appendix B of API Std\n1104 (incorporated by reference, see § 192.7), or section IX of the ASME\nBoiler and Pressure Vessel Code (ASME BPVC) (incorporated by reference,\nsee § 192.7) to produce welds meeting the requirements of this subpart. The\nquality of the test welds used to qualify welding procedures must be\ndetermined by destructive testing in accordance with the applicable welding\nstandard(s).\n(b) Each welding procedure must be recorded in detail, including the\nresults of the qualifying tests. This record must be retained and followed\nwhenever the procedure is used.\nWyckoff’s written procedures were inadequate to ensure safe operation of its pipeline facility.\nSpecifically, Wyckoff’s O&M Plan failed to include detailed welding procedures and the\napplicable welding standard in accordance with § 192.225.\nWyckoff’s O&M Plan Section P-192.225, “Pipeline Welding,” while referencing API 1104 and\nASME Boiler and Pressure Vessel Code (BPVC) Section IX, failed to incorporate the specific\nrequirements of those standards, and failed to include detailed welding procedures which provide\nthe specific parameters for welding made pursuant to the procedure.\nTherefore, PHMSA proposes to require that Wyckoff revise its procedures to include detailed\nwelding procedures and the applicable welding standard in accordance with § 192.225.\n5. § 192.3 Definitions.\nModerate consequence area means:\n(1) An onshore area that is within a potential impact circle, as defined in\n§ 192.903, containing either:\n(i) Five or more buildings intended for human occupancy; or\n(ii) Any portion of the paved surface, including shoulders, of a designated\ninterstate, other freeway, or expressway, as well as any other principal\narterial roadway with 4 or more lanes, as defined in the Federal Highway\nPage 3 of 19\n\n\n\nCPF 1-2026-049-NOA\nAdministration's Highway Functional Classification Concepts, Criteria and\nProcedures, Section 3.1 (see:\nhttps://www.fhwa.dot.gov/planning/processes/statewide/related/highway_fun\nctional_classifications/fcauab.pdf, and that does not meet the definition of\nhigh consequence area, as defined in § 192.903.\n(2) The length of the moderate consequence area extends axially along the\nlength of the pipeline from the outermost edge of the first potential impact\ncircle containing either 5 or more buildings intended for human occupancy;\nor any portion of the paved surface, including shoulders, of any designated\ninterstate, freeway, or expressway, as well as any other principal arterial\nroadway with 4 or more lanes, to the outermost edge of the last contiguous\npotential impact circle that contains either 5 or more buildings intended for\nhuman occupancy, or any portion of the paved surface, including shoulders,\nof any designated interstate, freeway, or expressway, as well as any other\nprincipal arterial roadway with 4 or more lanes\n§ 192.710 Transmission lines: Assessments outside of high consequence areas.\n(a) Applicability: This section applies to onshore steel transmission\npipeline segments with a maximum allowable operating pressure of greater\nthan or equal to 30% of the specified minimum yield strength and are\nlocated in:\n(1) A Class 3 or Class 4 location; or\n(2) A moderate consequence area as defined in § 192.3, if the pipeline\nsegment can accommodate inspection by means of an instrumented inline\ninspection tool (i.e., “smart pig”).\nWyckoff’s written procedures were inadequate to ensure safe operation of a pipeline facility.\nSpecifically, Wyckoff’s procedures failed to include a procedure for defining and identifying\nModerate Consequence Areas (MCAs) in accordance with §§192.3 and 192.710(a)(2).\nTherefore, PHMSA proposes to require that Wyckoff revise its procedures to include a procedure\nfor defining and identifying Moderate Consequence Areas (MCAs) in accordance with §§192.3\nand 192.710(a)(2).\n6. § 192.303 Compliance with specifications or standards.\nEach transmission line or main must be constructed in accordance with\ncomprehensive written specifications or standards that are consistent with\nthis part.\n§ 192.199 Requirements for design of pressure relief and limiting devices.\nExcept for rupture discs, each pressure relief or pressure limiting device\nmust:\n(a) Be constructed of materials such that the operation of the device will\nnot be impaired by corrosion;\n(b) Have valves and valve seats that are designed not to stick in a position\nthat will make the device inoperative;\nPage 4 of 19\n\n\n\nCPF 1-2026-049-NOA\n(c) Be designed and installed so that it can be readily operated to\ndetermine if the valve is free, can be tested to determine the pressure at\nwhich it will operate, and can be tested for leakage when in the closed\nposition;\n(d) Have support made of noncombustible material;\n(e) Have discharge stacks, vents, or outlet ports designed to prevent\naccumulation of water, ice, or snow, located where gas can be discharged into\nthe atmosphere without undue hazard;\n(f) Be designed and installed so that the size of the openings, pipe, and\nfittings located between the system to be protected and the pressure relieving\ndevice, and the size of the vent line, are adequate to prevent hammering of\nthe valve and to prevent impairment of relief capacity;\n(g) Where installed at a district regulator station to protect a pipeline\nsystem from overpressuring, be designed and installed to prevent any single\nincident such as an explosion in a vault or damage by a vehicle from affecting\nthe operation of both the overpressure protective device and the district\nregulator; and\n(h) Except for a valve that will isolate the system under protection from\nits source of pressure, be designed to prevent unauthorized operation of any\nstop valve that will make the pressure relief valve or pressure limiting device\ninoperative.\nWyckoff’s written procedures were inadequate to ensure safe operation of a pipeline facility.\nSpecifically, Wyckoff’s written procedures failed to include requirements for design of pressure\nrelief and limiting devices in accordance with §§ 192.303 and 192.199.\nTherefore, PHMSA proposes to require that Wycoff revise its procedures to include requirements\nfor design of pressure relief and limiting devices in accordance with §§ 192.303 and 192.199.\n7. § 192.465 External corrosion control: Monitoring and remediation.\n(a) . . . .\n(d) Each operator must promptly correct any deficiencies indicated by\nthe inspection and testing required by paragraphs (a) through (c) of this\nsection. For onshore gas transmission pipelines, each operator must develop\na remedial action plan and apply for any necessary permits within 6 months\nof completing the inspection or testing that identified the deficiency.\nRemedial action must be completed promptly, but no later than the earliest\nof the following: prior to the next inspection or test interval required by this\nsection; within 1 year, not to exceed 15 months, of the inspection or test that\nidentified the deficiency; or as soon as practicable, not to exceed 6 months,\nafter obtaining any necessary permits.\nWyckoff’s written procedures were inadequate to ensure safe operation of a pipeline facility.\nSpecifically, Wyckoff’s O&M Plan failed to include a procedure for remedial action plans in\naccordance with § 192.465(d).\nPage 5 of 19\n\n\n\nCPF 1-2026-049-NOA\nWyckoff’s O&M Plan, Section P-192.455, \"External Corrosion Control\" states in relevant part:\n“Remedial Action\nWhen cathodic protection levels are discovered to be below established criteria\nlevels, take remedial action to restore cathodic protection to acceptable levels.\nConsider the particular problem affecting pipeline integrity in completing the\nremedial action. Any remedial action necessary to facilitate the effective\napplication of corrosion control must not extend 15 months beyond discovery.\nIf the remaining pipe wall thickness is less that that required to substantiate the\nMAOP of the pipeline, one of the following will be done:\n1. Pipeline segment replaced.\n2. MAOP reduced based on actual remaining wall thickness.\n3. Pipe repaired according to Procedure P-192.711: Pipeline Repair\nProcedures.\nThe remaining strength of the correct pipe will be determined using ASME B-\n31G or RESTRENG, as long as the corroded sections do not penetrate the pipe\nwall.”\nSection P-192.455 failed to require application for any necessary permits within 6 months, and\nfailed to require that remedial action be completed no later than the earliest of the following: prior\nto the next inspection or test interval required by this section; within 1 year, not to exceed 15\nmonths, of the inspection or test that identified the deficiency; or as soon as practicable, not to\nexceed 6 months, after obtaining any necessary permits.\nTherefore, PHMSA proposes to require that Wyckoff revise its procedures to require application\nfor any necessary permits within 6 months, and to require that remedial action be completed no\nlater than the earliest of the following: prior to the next inspection or test interval required by this\nsection; within 1 year, not to exceed 15 months, of the inspection or test that identified the\ndeficiency; or as soon as practicable, not to exceed 6 months, after obtaining any necessary permits.\n8. § 192.481 Atmospheric corrosion control: Monitoring.\n(a) Each operator must inspect and evaluate each pipeline or portion of the\npipeline that is exposed to the atmosphere for evidence of atmospheric\ncorrosion, as follows:\nPipeline type: Then the frequency of inspection is:\n(1) Onshore other than a\nService Line\nAt least once every 3 calendar years, but with intervals\nnot exceeding 39 months.\n(2) Onshore Service Line At least once every 5 calendar years, but with intervals\nnot exceeding 63 months, except as provided in\nparagraph (d) of this section.\n(3) Offshore At least once each calendar year, but with intervals not\nexceeding 15 months.\nPage 6 of 19\n\n\n\nCPF 1-2026-049-NOA\nWyckoff’s written procedures were inadequate to ensure safe operation of a pipeline facility.\nSpecifically, Wyckoff’s O&M Plan failed to include adequate procedures for inspection and\nevaluation of each pipeline or portion of the pipeline that is exposed to the atmosphere for evidence\nof atmospheric corrosion in accordance with § 192.481(a)(1).\nWyckoff’s O&M Plan, Section P-192.479, “Protection Against Atmospheric Corrosion” contains\nguidance for the grading of the atmospheric corrosion on above ground pipelines with three\nconditions: good, fair and poor. Section P-192.479 requires the completion of a companion form,\nForm F-192.481, only upon discovery of a poor condition. However, operators must maintain a\nrecord of each inspection required by Subpart I in sufficient detail to demonstrate the adequacy of\ncorrosion control measures or that a corrosive condition does not exist for at least 5 years in\naccordance with § 192.491(c).\nIn addition, Form F-192.481 does not contain adequate guidance for personnel to appropriately\ngrade poor, fair or good conditions, and contains additional grading information not noted or\nexplained in Section P-192.479. The form also has no clear space to indicate which facility was\ninspected with either a milepost, station number, or location name.\nTherefore, PHMSA proposes to require that Wyckoff revise its procedures to include adequate\nprocedures for inspection and evaluation of each pipeline or portion of the pipeline that is exposed\nto the atmosphere for evidence of atmospheric corrosion in accordance with § 192.481(a)(1).\n9. § 192.485 Remedial measures: Transmission lines.\n(a) General corrosion. Each segment of transmission line with general\ncorrosion and with a remaining wall thickness less than that required for the\nMAOP of the pipeline must be replaced or the operating pressure reduced\ncommensurate with the strength of the pipe based on actual remaining wall\nthickness. However, corroded pipe may be repaired by a method that reliable\nengineering tests and analyses show can permanently restore the\nserviceability of the pipe. Corrosion pitting so closely grouped as to affect the\noverall strength of the pipe is considered general corrosion for the purpose of\nthis paragraph.\n(b) Localized corrosion pitting. Each segment of transmission line pipe\nwith localized corrosion pitting to a degree where leakage might result must\nbe replaced or repaired, or the operating pressure must be reduced\ncommensurate with the strength of the pipe, based on the actual remaining\nwall thickness in the pits.\n(c) Calculating remaining strength. Under paragraphs (a) and (b) of this\nsection, the strength of pipe based on actual remaining wall thickness must be\ndetermined and documented in accordance with § 192.712.\nWyckoff’s written procedures were inadequate to ensure safe operation of a pipeline facility.\nSpecifically, Wyckoff’s O&M Plan failed to include adequate procedures for repair or replacement\nof transmission lines with general corrosion and a remaining wall thickness less than that required\nfor the MAOP of the pipeline in accordance with § 192.485.\nPage 7 of 19\n\n\n\nCPF 1-2026-049-NOA\nWyckoff’s O&M Plan, Section P192.711, “Pipeline Repair Procedures” failed to include adequate\nprocedures for evaluation of pipeline anomalies or damage such as determining remaining wall\nstrength, evaluation of cracks, and evaluation of dents. The section addresses evaluation of\nanomalies or damage in (4) sub-sections: Corrosion, Dents, Gouges, and Other Defects. The\nCorrosion subsection fails to include instructions or requirements for measuring corrosion depth.\nThe Dent subsection fails to include procedure to determine strain levels. The Other Defects\nsubsection contains no procedure for evaluation of cracks or crack like anomalies, and instead\ncontains only information about types of defects and reporting requirements.\nWyckoff indicated to PHMSA personnel that, if evaluation were necessary, a third party would be\nconsulted for determining the condition severity and appropriate repair. However, without its own\nstandards or requirements in place, Wyckoff’s procedures fail to ensure that such evaluation would\noccur in accordance with the requirements of § 192.485.\nTherefore, PHMSA proposes to require that Wyckoff revise its procedures to include adequate\nprocedures for evaluation of pipeline anomalies or damage.\n10. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) . . . .\n(c) Abnormal operation. For transmission lines, the manual required by\nparagraph (a) of this section must include procedures for the following to\nprovide safety when operating design limits have been exceeded:\n(1) Responding to, investigating, and correcting the cause of:\n(i) Unintended closure of valves or shutdowns;\n(ii) Increase or decrease in pressure or flow rate outside normal operating\nlimits;\n(iii) Loss of communications;\n(iv) Operation of any safety device; and\n(v) Any other foreseeable malfunction of a component, deviation from\nnormal operation, or personnel error, which may result in a hazard to\npersons or property.\n(2) Checking variations from normal operation after abnormal operation\nhas ended at sufficient critical locations in the system to determine continued\nintegrity and safe operation.\n(3) Notifying responsible operator personnel when notice of an abnormal\noperation is received.\n(4) Periodically reviewing the response of operator personnel to\ndetermine the effectiveness of the procedures controlling abnormal operation\nand taking corrective action where deficiencies are found.\n(5) The requirements of this paragraph (c) do not apply to natural gas\ndistribution operators that are operating transmission lines in connection\nwith their distribution system.\nPage 8 of 19\n\n\n\nCPF 1-2026-049-NOA\nWyckoff’s written procedures were inadequate to ensure safe operation of a pipeline facility.\nSpecifically, Wyckoff’s O&M Plan failed to include adequate procedures for responding to,\ninvestigating, and correcting the cause of abnormal operations in accordance with § 192.605(c).\nWyckoff's O&M Plan, Section P-192.605(c), “Handling Abnormal Operations\" contains\nreferences to hazardous liquid pipeline asset types such as pumps and product batches, even though\nWyckoff operates a gas transmission pipeline. In addition, Section P-192.605(c) failed to include\nadequate guidance for checking variations from normal operation after abnormal operation has\nended at sufficient critical locations in the system to determine continued integrity and safe\noperation in accordance with § 192.605(c)(2).\nTherefore, PHMSA proposes to require that Wyckoff revise its written procedures to include\ndetailed procedures for safety when operating design limits have been exceeded, specifically\naddressing § 192.605(c) and (c)(2).\n11. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a\nmanual of written procedures for conducting operations and maintenance\nactivities and for emergency response. For transmission lines, the manual\nmust also include procedures for handling abnormal operations. This manual\nmust be reviewed and updated by the operator at intervals not exceeding 15\nmonths, but at least once each calendar year. This manual must be prepared\nbefore operations of a pipeline system commence. Appropriate parts of the\nmanual must be kept at locations where operations and maintenance activities\nare conducted.\nWyckoff’s written procedures were inadequate to ensure safe operation of a pipeline facility.\nSpecifically, Wyckoff’s O&M Plan failed to adequately include a procedure to review its O&M\nPlan at intervals not exceeding 15 months, but at least once each calendar year, in accordance with\n§ 192.605(a).\nWyckoff's O&M Plan, Section P-192.605(a), “Operations & Maintenance,” includes in relevant\npart:\n“1. Have personnel who are knowledgeable in pipeline operations and\nmaintenance review the Operations & Maintenance Manual. This review is\naccomplished through the following activities:\na. Reviewing the manual itself, including all procedures and forms used;\nb. Reviewing other Wyckoff Gas Storage manuals referenced in this manual;”\nSection P-192.605(a) failed to adequately define roles and responsibilities for the review process,\nsuch as which personnel are responsible for each section of the O&M Plan and other manuals. In\naddition, it failed to adequately define which manuals outside of the O&M Plan require an annual\nreview, such as its Emergency Response Plan, OQ Plan, or CRM Plan.\nTherefore, PHMSA proposes to require that Wyckoff revise its procedures to define roles and\nPage 9 of 19\n\n\n\nCPF 1-2026-049-NOA\nresponsibilities for the review process, such as which personnel are responsible for each section of\nthe O&M Plan and other manuals, and define which manuals outside of the O&M Plan require an\nannual review.\n12. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) . . . .\n(b) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following, if\napplicable, to provide safety during maintenance and operations.\n(1) . . . .\n(5) Starting up and shutting down any part of the pipeline in a manner\ndesigned to assure operation within the MAOP limits prescribed by this part,\nplus the build-up allowed for operation of pressure-limiting and control\ndevices.\nWyckoff’s written procedures were inadequate to ensure safe operation of a pipeline facility.\nSpecifically, Wyckoff’s O&M Plan failed to include adequate procedures for starting up and\nshutting down any part of the pipeline in a manner designed to assure operation within the\nmaximum allowable operating pressure (MAOP) limits in accordance with § 192.605(b)(5).\nTherefore, PHMSA proposes that Wyckoff revise its procedures to include adequate procedures\nfor starting up and shutting down any part of the pipeline in a manner designed to assure operation\nwithin the maximum allowable operating pressure (MAOP) limits.\n13. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) . . . .\n(c) Abnormal operation. For transmission lines, the manual required by\nparagraph (a) of this section must include procedures for the following to\nprovide safety when operating design limits have been exceeded:\n(1) . . . .\n(4) Periodically reviewing the response of operator personnel to determine\nthe effectiveness of the procedures controlling abnormal operation and taking\ncorrective action where deficiencies are found.\nWyckoff’s written procedures were inadequate to ensure safe operation of a pipeline facility.\nSpecifically, Wyckoff’s O&M Plan failed to include adequate procedures for periodically\nreviewing the response of operator personnel to determine the effectiveness of the procedures\ncontrolling abnormal operation and taking corrective action where deficiencies are found, in\naccordance with § 192.605(c)(4).\nTherefore, PHMSA proposes to require that Wyckoff revise its procedures to include adequate\nprocedures for periodically reviewing the response of operator personnel to determine the\neffectiveness of the procedures controlling abnormal operation and taking corrective action where\ndeficiencies are found.\nPage 10 of 19\n\n\n\nCPF 1-2026-049-NOA\n14. § 192.613 Continuing surveillance.\n(a) Each operator shall have a procedure for continuing surveillance of its\nfacilities to determine and take appropriate action concerning changes in\nclass location, failures, leakage history, corrosion, substantial changes in\ncathodic protection requirements, and other unusual operating and\nmaintenance conditions.\n(b) If a segment of pipeline is determined to be in unsatisfactory condition\nbut no immediate hazard exists, the operator shall initiate a program to\nrecondition or phase out the segment involved, or, if the segment cannot be\nreconditioned or phased out, reduce the maximum allowable operating\npressure in accordance with § 192.619 (a) and (b).\n(c) Following an extreme weather event or natural disaster that has the\nlikelihood of damage to pipeline facilities by the scouring or movement of the\nsoil surrounding the pipeline or movement of the pipeline, such as a named\ntropical storm or hurricane; a flood that exceeds the river, shoreline, or\ncreek high-water banks in the area of the pipeline; a landslide in the area of\nthe pipeline; or an earthquake in the area of the pipeline, an operator must\ninspect all potentially affected onshore transmission pipeline facilities to\ndetect conditions that could adversely affect the safe operation of that\npipeline.\nWyckoff’s written procedures were inadequate to ensure safe operation of a pipeline facility.\nSpecifically, Wycoff’s O&M Plan failed to include adequate procedures for continuing\nsurveillance in accordance with each requirement of § 192.613.\nWyckoff’s O&M Plan, Section P-162.613, “Continuing Surveillance\" failed to address each of the\nrequirements of § 192.613. First, Section P-192.613 failed to include adequate procedures to\ndetermine and take appropriate action concerning changes in class location, failures, leakage\nhistory, corrosion, substantial changes in cathodic protection requirements, and other unusual\noperating and maintenance conditions. Instead, it states only that responsibility for these\ndeterminations are distributed throughout the company.\nSecond, Section P-192.613 states in relevant part:\n\"If a segment of the pipe is determined to be in unsatisfactory condition, but without\nimmediate hazards existing, the operator will develop and initiate a program to\nrecondition or phase out the segment involved, or if this is not possible, reduce the\nmaximum allowable operating pressure in accordance with 49 CFR 192.619(a) and\n(b).\"\nHowever, it fails to designate responsibility for remediation or identify a necessary repair,\nabandonment, or pressure reduction procedure.\nThird, Section P-192.613 failed to provide for procedures for actions following an extreme weather\nevent or natural disaster that has the likelihood of damage to pipeline facilities, in accordance with\n§ 192.613(c).\nPage 11 of 19\n\n\n\nCPF 1-2026-049-NOA\nTherefore, PHMSA proposes to require that Wyckoff revise its procedures to include adequate\nprocedures for continuing surveillance in accordance with each requirement of § 192.613.\n15. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) . . . .\n(d) Safety-related condition reports. The manual required by paragraph\n(a) of this section must include instructions enabling personnel who perform\noperation and maintenance activities to recognize conditions that potentially\nmay be safety-related conditions that are subject to the reporting\nrequirements of § 191.23 of this subchapter.\nWyckoff’s written procedures were inadequate to ensure safe operation of a pipeline facility.\nSpecifically, Wyckoff’s O&M Plan failed to include adequate instructions enabling personnel who\nperform operation and maintenance activities to recognize conditions that potentially may be\nsafety-related conditions that are subject to the reporting requirements of Section 191.23, in\naccordance with § 192.605(d).\nTherefore, PHMSA proposes to require that Wyckoff revise its procedures to include adequate\ninstructions enabling personnel who perform operation and maintenance activities to recognize\nconditions that potentially may be safety-related conditions that are subject to the reporting\nrequirements of Section 191.23.\n16. § 192.614 Damage prevention program.\n(a) Except as provided in paragraphs (d) and (e) of this section, each\noperator of a buried pipeline must carry out, in accordance with this section,\na written program to prevent damage to that pipeline from excavation\nactivities. For the purposes of this section, the term “excavation activities”\nincludes excavation, blasting, boring, tunneling, backfilling, the removal of\naboveground structures by either explosive or mechanical means, and other\nearthmoving operations.\nWyckoff ‘s written procedures were inadequate to ensure safe operation of a pipeline facility.\nSpecifically, Wyckoff’s O&M Plan failed to include adequate procedures for damage prevention\nin accordance with § 192.614(a).\nWyckoff’s O&M Plan, Section P-192.614, “Damage Prevention Program,” outlines the general\nrequirements for a damage prevention program without providing adequate detail for roles and\nresponsibilities of relevant personnel. In addition, Section P-192.614 fails to specify which one-\ncall system it participates in, and fails to define responsibilities for how one-calls are received,\nwhat systems are checked, and which personnel are responsible for following up on one-calls.\nTherefore, PHMSA proposes to require that Wyckoff revise its procedures to include adequate\nprocedures for damage prevention in accordance with § 192.614(a).\nPage 12 of 19\n\n\n\nCPF 1-2026-049-NOA\n17. § 192.615 Emergency plans.\n(a) Each operator shall establish written procedures to minimize the\nhazard resulting from a gas pipeline emergency. At a minimum, the\nprocedures must provide for the following:\n(1) . . . .\n(3) Prompt and effective response to a notice of each type of emergency,\nincluding the following:\n(i) Gas detected inside or near a building.\n(ii) Fire located near or directly involving a pipeline facility.\n(iii) Explosion occurring near or directly involving a pipeline facility.\n(iv) Natural disaster.\nWyckoff’s procedures for emergencies were inadequate to ensure safe operation of a pipeline\nfacility. Specifically, Wyckoff’s Emergency Response Plan (Aug. 2022) (“Emergency Plan”)\nfailed to provide for prompt and effective response to each type of emergency in accordance with\n§ 192.615(a)(3).\nWyckoff’s Emergency Plan, Section A2, “Response Actions” fails to provide procedures for a\nprompt and effective response to gas detection inside or near a building.\nTherefore, PHMSA proposes to require that Wyckoff revise its Emergency Plan to provide\nprocedures for a prompt and effective response to gas detection inside or near a building.\n18. § 192.617 Investigation of failures and incidents.\n(a) Post-failure and incident procedures. Each operator must establish\nand follow procedures for investigating and analyzing failures and incidents\nas defined in § 191.3, including sending the failed pipe, component, or\nequipment for laboratory testing or examination, where appropriate, for the\npurpose of determining the causes and contributing factor(s) of the failure or\nincident and minimizing the possibility of a recurrence.\nWyckoff’s written procedures were inadequate to ensure safe operation of a pipeline facility.\nSpecifically, Wyckoff’s O&M Plan failed to include adequate procedures for investigation of\nfailures and incidents in accordance with § 192.617(a).\nWyckoff's O&M Plan, Section P-192.617, “Investigating and Analyzing Incidents and Failures,\"\nfails to contain procedures for establishing a chain of custody for sending the failed pipe,\ncomponent, or equipment for laboratory testing or examination, where appropriate, for the purpose\nof determining the causes and contributing factor(s) of the failure or incident and minimizing the\npossibility of a recurrence.\nTherefore, PHMSA proposes to require that Wyckoff revise its procedures to include procedures\nfor establishing a chain of custody for sending the failed pipe, component, or equipment for\nlaboratory testing or examination, where appropriate, for the purpose of determining the causes\nand contributing factor(s) of the failure or incident and minimizing the possibility of a recurrence.\nPage 13 of 19\n\n\n\nCPF 1-2026-049-NOA\n19. § 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 (MAOP)\ndetermined under paragraph (c), (d), or (e) of this section, or the lowest of\nthe following:\n(1) The design pressure of the weakest element in the segment,\ndetermined in accordance with subparts C and D of this part. However, for\nsteel pipe in pipelines being converted under § 192.14 or uprated under\nsubpart K of this part, if any variable necessary to determine the design\npressure under the design formula (§ 192.105) is unknown, one of the\nfollowing pressures is to be used as design pressure:\n(i) Eighty percent of the first test pressure that produces yield\nundersection N5 of Appendix N of ASME B31.8 (incorporated by reference,\nsee § 192.7), reduced by the appropriate factor in paragraph (a)(2)(ii) of this\nsection; or\n(ii) If the pipe is 123⁄4 inches (324 mm) or less in outside diameter and is\nnot tested to yield under this paragraph, 200 p.s.i. (1379 kPa).\n(2) The pressure obtained by dividing the pressure to which the pipeline\nsegment was tested after construction as follows:\n(i) For plastic pipe in all locations, the test pressure is divided by a factor\nof 1.5.\n(ii) For steel pipe operated at 100 psi (689 kPa) gage or more, the test\npressure is divided by a factor determined in accordance with the Table 1 to\nparagraph (a)(2)(ii):\nWyckoff’s written procedures were inadequate to ensure safe operation of a pipeline facility.\nSpecifically, Wycoff’s O&M Plan failed to include adequate procedures for determination of\nmaximum allowable operating pressure (MAOP) in accordance with § 192.619(a).\nWyckoff's O&M Plan, Section P-162.619, \"MAOP Determination\" identifies Form F-192.619 to\ncalculate pipeline MAOP by segment. Section P-192.619 failed to specify where the records for\nmaterial strength and pressure tests will be stored such that the calculation form values can be\nverified, and fails to provide for tying the segment forms into system wide MAOP. Form F-\n192.619 failed to include identifiers such as milepost or line number regarding the pipeline\nsegment for which MAOP is being calculated, and failed to provide guidance on the appropriate\nfactors to be used for class location.\nTherefore, PHMSA proposes to require that Wyckoff revise its procedures to include adequate\nprocedures for determination of maximum allowable operating pressure (MAOP) in accordance\nwith § 192.619(a).\n20. § 192.631 Control room management.\n(a) . . . .\n(c) Provide adequate information. Each operator must provide its\ncontrollers with the information, tools, processes and procedures necessary\nPage 14 of 19\n\n\n\nCPF 1-2026-049-NOA\nfor the controllers to carry out the roles and responsibilities the operator has\ndefined by performing each of the following:\n(1) . . . .\n(3) Test and verify an internal communication plan to provide adequate\nmeans for manual operation of the pipeline safely, at least once each calendar\nyear, but at intervals not to exceed 15 months;\nWyckoff’s written procedures were inadequate to ensure safe operation of a pipeline facility.\nSpecifically, Wyckoff’s Control Room Management Plan (Aug. 2024) (“CRM Plan”) failed to\ninclude detailed procedures to test and verify an internal communication plan to provide adequate\nmeans for manual operation of the pipeline safely, at least once each calendar year, but at intervals\nnot to exceed 15 months, in accordance with § 192.631(c)(3).\nWyckoff's CRM Plan, Section B, \"Roles and Responsibilities” stated in relevant part:\n“Upon discovery of loss of communications between SCADA and equipment, the\ncontroller will contact the supervisor, and then proceed with manual shut down of\nsystem. (Process found in CRM, section C). A reference to identify loss of\ncommunication can be found in Wyckoff’s O&M 192.605 (c).”\nWyckoff’s CRM Plan only provides for manual operation","truncated":true,"body_characters":52015}