{"operation":"document","citation":"CPF 12026050WL","title":"WYCKOFF GAS STORAGE COMPANY, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2026-06-30","effective_on":null,"summary":"CLOSED warning letter citing 192.13(d), 192.631(c)(3), 192.736(c), 192.739(a), 192.743(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026050wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026050wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026050wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12026050WL","body":"Warning Letter involving WYCKOFF GAS STORAGE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulations as 192.13(d),  192.631(c)(3),  192.736(c),  192.739(a),  192.743(c). The case was opened on 2026-06-30 and is reported as closed as of 2026-06-30. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12026050WL_Warning Letter_06302026_(25-329592).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026050WL/12026050WL_Warning%20Letter_06302026_(25-329592).pdf\n\n12026050WL_Warning Letter_06302026_(25-329592)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026050WL/12026050WL_Warning%20Letter_06302026_(25-329592)_text.pdf\n\n12026050WL_Warning Letter_06302026_(25-329592)_text.pdf\n\n901 Locust Street, Suite 480\nKansas City, MO 64106\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nWARNING LETTER\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 1-2026-050-WL\nDear Mr. Millican:\nFrom April 8, 2025 through August 7, 2025, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA),1 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, it is alleged that WGS has committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. § 192.13 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 the\nenvironment through a management of change process. Each operator of an\nonshore gas transmission pipeline must develop and follow a management of\nchange 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\n1 For this inspection, the representatives were inspectors for the New York Department of Public Service (NY DPS)\nacting as an interstate agent pursuant to 49 U.S.C. 60117(a)(2).\n\n\n\nCPF 1-2026-050-WL\nmanagement of change process must include the following: reason for change,\nauthority for approving changes, analysis of implications, acquisition of\nrequired work permits, documentation, communication of change to affected\nparties, time limitations, and qualification of staff. For pipeline segments other\nthan those covered in subpart O of this part, this management of change\nprocess must be implemented by February 26, 2024. The requirements of this\nparagraph (d) do not apply to gas gathering pipelines. Operators may request\nan extension of up to 1 year by submitting a notification to PHMSA at least 90\ndays before February 26, 2024, in accordance with § 192.18. The notification\nmust include a reasonable and technically justified basis, an up-to-date plan\nfor completing all actions required by this section, the reason for the requested\nextension, current safety or mitigation status of the pipeline segment, the\nproposed completion date, and any needed temporary safety measures to\nmitigate the impact on safety.\nWyckoff failed to evaluate and mitigate, as necessary, significant changes that pose a risk to safety\nor the environment through a management of change process in accordance with § 192.13(d).\nSpecifically, Wyckoff failed to develop and follow a management of change process, as outlined\nin ASME B31.8S, section 11, and implement the process by February 26, 2024.\nDuring the inspection, the NY DPS inspector requested records related to management of change\nfor 2024. Wyckoff failed to provide any records and stated that it did not have a procedure or\nformal records for management of change.\nTherefore, Wyckoff failed to evaluate and mitigate, as necessary, significant changes that pose a\nrisk to safety or the environment through a management of change process in accordance with\n§ 192.13(d).\n2. § 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 for\nthe 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 failed to test and verify an internal communication plan to provide adequate means for\nmanual operation of the pipeline safely, at least once each calendar year, but at intervals not to\nexceed 15 months in accordance with § 192.631(c)(3). Specifically, Wyckoff failed to test and\nverify an internal communication plan for calendar years 2022, 2023, and 2024.\nPage 2 of 5\n\n\n\nCPF 1-2026-050-WL\nDuring the inspection, the NY DPS inspector requested records documenting testing and\nverification of its internal communication plan spanning the period 2022 through 2024. Wyckoff\nfailed to provide any records and stated that testing and verification was not performed during this\ntime period.\nTherefore, Wyckoff failed 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).\n3. § 192.736 Compressor stations: Gas detection.\n(a) . . . .\n(c) Each gas detection and alarm system required by this section must be\nmaintained to function properly. The maintenance must include performance\ntests.\nWyckoff failed to properly maintain and conduct performance tests on each of its gas detection\nand alarm systems in accordance with § 192.736(c). Specifically, Wyckoff failed to conduct\nperformance tests on three gas detectors and failed to maintain adequate records of tests on six gas\ndetectors for the period spanning calendar years 2022 through 2024.\nDuring the inspection, the NY DPS inspector reviewed gas detection and alarm inspection records\nfor the period spanning calendar years 2022 through 2024. These records did not include\nperformance tests of three gas detectors (GDT-0500AA, GDT-0500AB, and GDT-0500CB). In\naddition, Wyckoff failed to provide records of performance tests of six gas detectors (GDT-\n0500AA, GDT-0500AB, GDT-0500BA, GDT-0500BB, GDT-0500CA, and GDT-0500CB).\nTherefore, failed to properly maintain and conduct performance tests on each of its gas detection\nand alarm systems in accordance with § 192.736(c).\n4. § 192.739 Pressure limiting and regulating stations: Inspection and testing.\n(a) Each pressure limiting station, relief device (except rupture\ndiscs), and pressure regulating station and its equipment must be\nsubjected at intervals not exceeding 15 months, but at least once each\ncalendar year, to inspections and tests to determine that it is— . . . .\nWyckoff failed to inspect and test pressure regulating equipment at intervals not exceeding 15\nmonths, but at least once each calendar year in accordance with § 192.739(a). Specifically,\nWyckoff failed to inspect four fuel gas line regulators located at Wyckoff Compressor Station\nbetween 2022 and 2024.\nDuring the inspection, the NY DPS inspector reviewed inspection and test records for the time\nperiod spanning 2022 to 2024. Wyckoff failed to provide any records that four compressor fuel\ngas line regulators were inspected and tested. Wyckoff indicated that the regulators were not\nPage 3 of 5\n\n\n\nCPF 1-2026-050-WL\ninspected and tested, and stated that its understanding was that fuel gas regulators did not require\ninspection.\nTherefore, Wyckoff failed to inspect and test pressure regulating equipment at intervals not\nexceeding 15 months, but at least once each calendar year in accordance with § 192.739(a).\n5. § 192.743 Pressure limiting and regulating stations: Capacity of relief devices.\n(a) Pressure relief devices at pressure limiting stations and pressure\nregulating stations must have sufficient capacity to protect the facilities to\nwhich they are connected. Except as provided in § 192.739(b), the capacity must\nbe consistent with the pressure limits of § 192.201(a). This capacity must be\ndetermined at intervals not exceeding 15 months, but at least once each\ncalendar year, by testing the devices in place or by review and calculations. . . .\n(b) . . . .\n(c) If a relief device is of insufficient capacity, a new or additional device\nmust be installed to provide the capacity required by paragraph (a) of this\nsection.\nWyckoff failed to install a new or additional pressure relief device to provide the capacity required\nby section 192.743(a) when a relief device was at insufficient capacity in accordance with §\n192.743(c). Specifically, Wyckoff failed to install a new or additional device to provide adequate\ncapacity, or adjustments made to limit the required capacity, regarding two relief devices that were\nof insufficient capacity.\nDuring the inspection, the NY DPS inspector reviewed PSV verifications records for the time\nperiod spanning calendar years 2022 to 2025. Those records indicated that two relief devices (PSV-\n1308 and PSV-1304) were of insufficient capacity. However, Wyckoff failed to install a new or\nadditional device to provide adequate capacity, or adjust to limit the required capacity.\nTherefore, Wyckoff failed to install a new or additional pressure relief device to provide the\ncapacity required by section 192.743(a) when a relief device was at insufficient capacity in\naccordance with § 192.743(c).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a related\nseries of violations. For violation occurring on or after December 28, 2023 and before December\n30, 2024 the maximum penalty may not exceed $266,015 per violation per day the violation\npersists, up to a maximum of $2,660,135 for a related series of violations. For violation occurring\non or after January 6, 2023 and before December 28, 2023 the maximum penalty may not exceed\n$257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related\nseries of violations. For violation occurring on or after March 21, 2022 and before January 6, 2023\nthe maximum penalty may not exceed $239,142 per violation per day the violation persists, up to\nPage 4 of 5\n\n\n\nCPF 1-2026-050-WL\na maximum of $2,391,142 for a related series of violations. For violation occurring on or after\nMay 3, 2021 and before March 21, 2022 the maximum penalty may not exceed $225,134 per\nviolation per day the violation persists, up to a maximum of $2,251,334 for a related series of\nviolations. For violation occurring on or after January 11, 2021 and before May 3, 2021 the\nmaximum penalty may not exceed $222,504 per violation per day the violation persists, up to a\nmaximum of $2,225,034 for a related series of violations. For violation occurring on or after July\n31, 2019 and before January 11, 2021 the maximum penalty may not exceed $218,647 per violation\nper day the violation persists, up to a maximum of $2,186,465 for a related series of violations.\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 items identified in this letter. Failure to do so will result in WGS\nbeing subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2026-050-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\ncc: Aaron Daniels, EHS Manager, WGS, aarond@kfoc.net\nAndrew Hutton, SR. HGS Representative, WGS, huttona@kfoc.net\nPage 5 of 5","truncated":false,"body_characters":12917}