{"operation":"document","citation":"CPF 120025009","title":"COLONIAL PIPELINE CO — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2002-09-13","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.401(b), 195.402(a), 195.402(d), 195.404(a), 195.410(a), 195.416, 195.416(a), 195.420(b), 195.436.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120025009.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120025009.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120025009","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120025009","body":"Notice of Probable Violation involving COLONIAL PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 195,  195.401(b),  195.402(a),  195.402(d),  195.404(a),  195.410(a),  195.416,  195.416(a),  195.420(b),  195.436. The case was opened on 2002-09-13 and is reported as closed as of 2004-08-12. Proposed civil penalty: $182,500. Assessed civil penalty: $101,000. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120025009_Final Order_12102003.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120025009/120025009_Final%20Order_12102003.pdf\n\n120025009_Final Order_12102003.pdf\n\nt~\nu 5.Depa ~\nof~~\n~~~\n$p8CaI ~ ,..\nAu~~\"~~\n~ s.v.nth 51. S W\nW81h...~. DC 20580\nDEC 1 0 ~\nMr. William D. Scott\nVice President\nColonial Pipeline Company\nP. O. Box 1624\nAlpbaretta, GA 3<XM>9-9934\nRE: CPF No. 1-2002-5009\nDear Mr. Scott:\nEnclosed is the Final Order issued by the Associate Administrator for Pipeline Safety in the\nabove-referenced case. It withdraws one of the allegations of violation, makes findings of violation,\nrequires certain corrective actions and assesses a civil penalty of$1 01 ,000. Your receipt of the Final\nOrder constitutes service of that document under 49 C.F.R.§ 190.5. At such time that the civil\npenalty is paid and the tenDS of the compliance order are completed, as detennined by the Director,\nEastern Region. this enforcement action will be closed.\nSincerely,\n~ 0 ~ ~~\nJames Reynolds\nPipeline Compliance Registry\nOffice of Pipeline Safety\ncc:\nMs. Carole P. Sims, Senior Attorney\nMr. William H. Oute, Director, OPS Eastern Region\n\n\n\nDEPARTMENT OF TRANSPORT A nON\nRESEARCH AND SPECIAL PROGRAMS ADMINISTRA nON\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, DC 20590\nIn tbe Matter or\nC'olonial Pipeline Company.\nRespondent\n)\n)\n)\n)\nCPF No. 1-2002-5009\nnNAL ORDER\nBetwea. January 10.2001 8Ixf November 21.2001 pD'lUmlt to 49 V.S.C. § ~117. ~~~\nof the Eastern ReJion. Office of Pipeline Safay (OPS), a rqnIaJtative of the Commonwealth of\nVirginia State Corporation Commiuion (V A-SCC), and a representative of the State of New York\nPublic Service Commission (NY -PSC) coIxtucted onaite pipeline safety inspections and I~id\nreviews of Respondent . s facilities in Delaware, GeoI'lia. M8ryi8ld. Pennsylvania. New Jersey. New\nY Oft. North Carolina. aDd Virginia. As a result ofdtis investigation. the Director. Eastern Region.\nOPS. issued to Respond5t. by letter dated September 13, 200~ a Notice of Probable Violation,\nProposed Civil Penalty, and Proposed Compliance Order (Notice). In accordance with 49 C.F.R.\n§ 190.207, the Notice proposed finding that RCSpond5t bad committed violations of 49 C.F .R. Part\n19S,p roposed as-.ing a total civil penalty of$ 1 82.S00 for the alleged violations.lrMlpro poIa1 that\nR~xICIJt take certain me8Jra to ~~ the aIJeaeci violations.\nReIpOIKient requested IIxI W8 IfIDted In extension of time to ~xt to the Notice by November\n30.2002. Respondent rapoIlded to the Notice by letter dated, November 27.2002 (Response).\nRespondent contested four of the aIlegationiy off~ infonnation in explanation of the allegations\narxI in mitigation of the proposed penalty and requested a hearing. The hearing wu held on March\n4. 2003 in W ashin gto ~ DC . AfteI' this hearing. RellMJlMteIIt provided addi tiona1 information IIxi a\nclosing Response dated April 3. 2003.\nIn its post hearing submission and at the hearing. Respondent requested to enter into a Consent Older\npursuant to 49 C.F.R. § 190.219. A consent order would not be appropriate in thil matter as there\n8'e findings of violations and the ~tofacivil paIalty. In addition, thisOrd«Iddr~ the\nissues raise by R.apolxlent ~prding the tams of the compliance order.\n\n\n\n2\nFINDINGS OF VIOLATION\n(Uncontested)\nAt the hearing, Respondent\ndid not contest three of the alleged violations in the Notice.\nAccordingly, I find that Respondent violated the following sections of 49 C.F.R. Part 195,.\nmore fully described in the\n49 C.F.R. § 195.402(a) -- failing to prepare and follow a manual of written\nprocedures forcond ucting nonnalopera nons and main~e activities and handling\nabnormal operations and emergencies, as the Main Line Relief Block Valve at the\nWoodbury, NJ facility was found in the open position and not \"locked open\" as\nspecified in Respondent's procedures. The \"working\" field alignment sheets in\nRichmond, V A did not have up-to-date revisions and changes to the Pipeline System\nDesign and Drawings to show five new Main Line Block Valves installed on Line\n#27 in 1999.\n49 C.F.R. § 195.404(a) - failing to maintain cunent records of its pipeline system,\nas the Allentown, NJ facility had a themlal pressure relief valve on a pump casing\ntagged at a pressure of 770 psig but the thcnnal relief valve set pressure recorded in\nthe facility inspection test records listed the set pressure as 800 psig.\n49 C.P.R. § 195.410(a) -- failing to maintain clearly visible line markers with the\ncouect name of the operator and a telephone number (including are code) where the\noperator can be reached at all times. Seventeen pipeline markers at the Craney\nIsland, V A facility did not have the con'ect toll free emergency notification telephone\nnumber on them. At the Mitchell, V A facility eight pipeline marker signs at the road\ncrossing for Highways #40 and Route #649 had fra}oed and peeling Sticker decals\nwith outdated emergency notification telephone numbers.\nThese findings of violation will be considered prior offenses in any subsequent enforcement action\ntaken against Respondent.\n(Contested I\nItem 1 in the Notice alleged that Respondent violated 49 C.F.R. § 195.401 (b) by failing to timely\ncorrect conditions that could adv~ely affect the safe operation of its pipeline system, as Respondent\nhad 12 cathodic protection stations with low pipe-to-soilread ings between the airport at Greensboro,\nNC and the NCN A (Virginia) state line. The low pipe--to-soi1 readings were below Respondent's\nestablished criteria of -O.85Ov. At the time of the inspection, th~ was no indication in the records\nthat any action was taken to correct the low potentials, which existed at one test station from 1998\nto 2000 and at the other eleven test stations during 1999 and 2000.\n\n\n\nf\nIn response to the Notice and at the hearing, Respondent acknowledged the low pipe-to-soil readings.\nHowever, Respondent argued that the condition could not adversely affect the safe operation of the\npipeline system because it had initiated several projects to address low pipe to soil readings in the\nsubject area. Respondent advised that intemalline inspections conducted on Line 03 and 04 in 1995\nand 1997 resulted in the evaluatio~ excavation and repair of external corrosion indications between\nthe Greensboro, NC and the NCN A State line. Respondent further advised that in response to a\nprevious Notice, CPF #27501, it established re-inspection intervals for these line segments based on\nconservative con-osion rate evaluations, which are scheduled for completion in 2003. Respondent\nexplained that its plans to address future low pipe-to-soil condition readings were discussed with the\nOPS Eastern Region in April 2001.\nNevertheless, Respondent does not dispute the violation report indicating that 12 cathodic protection\nstations had low pipe-to-soil readings between the airport at Greensboro, NC and the NCN A State\nline. Although Respondent argued that it had initiated several proj~ts to address low pipe to soil\nreadings in the subject area, OPS presented evidence that at the time of the May 2001 inspection,\nthere was no indication in the records that any action was taken to correct the low potentiaJs. OPS\nevidence included Respondent's Test Report Exceptions for Corrosion Area 3 for Lines 03 and 04,\nwhich provides data from January 1, 1998 to December 21, 2000 showing structme pipe-to-soil\nreadings less than -O.85Ov or casing pipe-to-soil readings less than -O.85Ov. Respondent's Exception\nReport, dated May 29, 200 1, demonstrates the low pipe-to-soil readings.\nConsistent low cathodic protection readings indicate that a pipeline is not receiving adequate\nprotection, a condition that could adversely affect the safe operation of a pipeline system. The risk\nof corrosion on the pipeline significantly increases with inadequate pipe-to-soil potentials and can\nresult in a pipeline failure. Preventive maintenance is critical to safety of the public, environment\nand property. Respondent had 12 cathodic protection stations with low pipe-to-soil readings with\nno indication or documentation of timely corrective action. One station had low readings for three\nconsecutive years and eleven stations had low readings in 1999 and 2000. Accordingly, I find that\nRespondent violated 49 C.F.R. §19S.401(b) by not taking actions to correct the condition within a\nreasonable amount of time.\nItem J in the Notice alleged that Respondent had violated 49 C.F .R. § 195.402( d) when Respondent\nfailed to follow procedures for abnormal operations to provide safety when operating design limits\nwere exceeded. An 'llnscheduled Shutdown Report\" dated February 8, 2000, reported the mcOlTect\nopening of a valve, but did not include an investigation or information to demonstrate that the cause\nof the incident was investigated and corrected. Specifically, \"[t]bc shipper oil manifold selection\npanel was set-up to swing from Motiva to Citgo. When the cut button was pressed, the Old\nDominion manifold valve opened instead of the Citgo valve. Situation was verified, then Citgo\nvalve was opened and pressure released. \" Respondent provided no records to show d1at maintenance\nor repairs were perfonned on the valve or instrumentations and controls, as required by Respondent's\nMaintenance Proj ect Work and Document Management Procedures to demonstrate that the abnonnal\noperation condition had been properly investigated, corrected or documented to prevent a\nrecurrence.\n\n\n\n4\nIn response to the Notice\nandat\nthe hearing, RespoDdent\ncontended that § 19S.4O2(d) is applicable\nto situations and in which\nthe ,--\noperating design limits have been exceeded, but does not apply in this\nparticular instance. R.\nesponden\nt argued that the equipment perfonned exactly as it was designed to\nperfonn, making §\n195.402(d) inapplicable. Respondent further argued that OPS incorrectly\ninterpreted the teml 66operating design limit\" in § 195 .402( d) as 6'nonnal operating design limit..\nduring the bearing. Respondent takes the position that if the regulation was intended to be\ninterpreted as 6~orma1 operating design limit,.. then the ~ would have used the modifier\n\"nonnal... much like it did in § 195.402(d)(1)(ii) when referring to 6'nonnal operating limits.'.\nNevertheless, Respondent advised that it now uses a computerized system, «aperational\nPerformance Information System.', which includes a section for Abnormal Event reports that require\na review and analysis by the Operations Manager and Operations Excellence Coordinator.\nRespondent explained that the new system will track the analysis, trending and follow-up corrective\nactions.\nOPS argued that the allegation of violation refers to the procedures for documentation of personnel\nactions and equipment operation when there is a maffimction. In support of its position, OPS argued\nthat \"operating design Jimits\" are characterized in § 195.402(d)(1)(v) as \"any other malfunction of\na component, deviation from normal operation, or personnel error which could cause a hazard to\npersons or property.\"\nThe proposed violation concerns Respondent's failure to properly investigate, correct and document\nthe unintended valve closure. '\"When the cut button was pressed, the Old Dominion manifold valve\nopened instead of the Citgo valve..' When the cut button was pressed the expectation was that the\nCitgo manifold valve would open. However, an unintended or unexpected valve opened when the\ncut button was pressed, which was unperceived. The valve that would nomlally open and was\nexpected to open failed to do so. This malfunction or deviation ftom the noon resulted in the\ngeneration of an \"Unscheduled Shutdown Report\", which recorded an abnonnal operation. This\nunscheduled or unexpected opening of the incorrect valve suggests that there was nothing nonnal\nabout this occurrence, ergo the report was generated.\nIn s~ the regulations require operators to have and to follow a manual of written procedures for\nconducting Donnal operations and maintenance activities and handling abnonnal operations and\nemergencies. Furthennore, Respondent's Maintenance Project Work and Document Management\nProcedures require personnel to document that the incident had been investigated and that correcti ve\naction was taken to mitigate further occunences. However. no investigation or infonnatioD was\ndocumented to demonstrate that what caused the Old Dominion manifold valve to open instead of\nthe Citgo valve was ever investigated and corrected. Accordingly, I find that Respondent violated\n49 C.F.R. §19S.402(d), as required by §19S.402(a).\nItem 6 in the Notice alleged that Respondent violated 49 C.F.R. § 19S.416(a) by failing to conduct\ntests from 1997 to 200 I on each buri~ in contact with the ground, or submerged pipeline. Eighty-\nnine (89) readings were not recorded for forty-five (45) cathodic protection test stations in New\nJersey, New Yo~ and Maryland\n\n\n\n$\nIn response, Respondent submitted docmnentation regarding its cathodic protection test station\nreadings. Although, Respondent acknowledged that readings were not recorded for some test\nstations, Respondent argued that the number was less than the number stated in the Notice.\nBased upon the documentation submitted by Respondent, OPS has determined that from 1997 to\n2001 a total of 43 readings were not recorded for 29 cathodic protection test stations in New Jersey,\nNew York, and Maryland and not 89 readings for 45 test stations as originally proposed, as more\nfully described in the Table below:\n1- -- -- - Missed/Undocumented-- I\nl_- - - - -- - Cathodic Protection Test StationReidi np: ,.1\nMonitoring critical locations of a pipeline or a structure where the risk of con'OSion is greatest allows\npersonnel to take immediate action against the potential for a pipeline failure. Inspection and testing\nat the required intervals are essential to knowing that the pipeline equipment is being maintained,\nwill function properly and that the integrity of the pipeline system is not compromised. The\nmagnitude of the risk of failure increases when there is a lack of monitoring of a pipeline's condition\nand the efficiency of any mitigation program to reduce or arrest oom>sion. AccordingIYt I find\nRespondent violated 49 C.F.R. §195.416(a)t by failing to record 43 readings for 29 cathodic\nprotection test stations from 1997 to 2001 in New Jersey, New Yo~ and Maryland.\nThese findings of violation will be considered prior offenses in any subsequent enforcement action\ntaken against Respondent.\n\n\n\n~'\nWITHDRAWAL OF ALLEGAnON\nItem 7 in the Notice alleged that Respondent violated 49 C.F .R. § 195.436, by failing to adequately\nsecure its facility from unauthorized entry, as an el~trical service cutoff switch, which is the main\npower supply to the valve site, was located outside the fence. In response, Respondent submitted\ninfonnation to evidence that Virginia Power Company considers the electrical equipment at issue\nto be their equipment and subj~t to their control. The contract language between the Respondent\nand Virginia Power states that Virginia Power \"shall have the right to discontinue the supply of\nelectricity without notice if access is denied.\" As set forth under § 110(08) in Virginia Power's\nInfonnation and Requirements for Electrical Service 1998, \"[t]he company shall have the right of\naccess to the customer'sp remises at all reasonable times for the purpose of reading company meters,\nremoving company property, and for any other proper purpose.\" In furtherance, § 230(02) of that\ndocument provides \"[t]be customer shall provide and maintain a suitable space for the installation\nof the necessary metering apparatus. This space shall be readily accessible and convenient for\nreading, testing, maintaining, and servicing of the meter equipment\". Because this is an unmanned\nlocation, relocation of the switch inside die fence would be considered by Virginia Power to be a\ndenial of access, and creating an el~tric power safety issue. Therefore, security has been addressed\nby having the valve status monitored in die Alpharetta Control Center. Based on this inforntation,\nI am withdrawing this allegation of violation.\nASSESSMENT OF PENAL TV\nThe Notice proposed. $182,500 civil penalty for violation of 49 C.F.R. §§ 195.40 1 (a), 195 .402( a),\n195.402(d), 195.4O4(a). 195.410(a), and 195.416(a). Under 49 U.S.C. § 60122, Respondent is\nsubject to a civil penalty not to exceed $100tOOO per violation for each day of the violation up to a\nmaximum of $1 ,000,000 for any related series of violations.\n49 V.S.C. § 60122 and 49 C.F.R. § 190.225 require that, in detennining the amount of the civil\npenalty, I consider the following criteria: nature, circumstances, and gravity of the violation, degree\nof Respondent's culpability, history of Respondenrs prior offenses, Respondent's ability to pay the\npenalty, good faith by Respondent in attempting to achieve compliance, the effect on Respondent's\nability to continue in business, and such other matters as justice may require.\nThe proposed penalty for Item 1 is S13,<XX> for violation of 49 C.F.R. § 19S.40I(b). Respondent\nfailed to timely correct conditions at 12 cathodic protection stations with low pipe-to-soil readings,\nwhich could adversely affect the safe operation of its pipeline system. Without adequate cathodic\nprotection, corrosion can occur resulting in a pipeline failure. A failme in a line carrying hazardous\nliquids poses a danger to the pub lic and the environment. Respondent bas not provided any evidence\nthat would justify mitigation of the penalty. Accordingly. baving reviewed the record and considered\nthe assessment criteria, I assess Respondent a civil penalty ofS13,OOO.\n\n\n\n7\nThe proposed penalty for Item 2 is $2.000 for violation of49 C.F.R. § 195.402(8). Respondentdid\nnot contest the alleged violation but advised that it had instituted corrective measures and contended\ndtat the proposed civil penalty was excessive. Respondent has not provided any evidence that would\njustify mitigation of the penalty. Accordingly. having reviewed the record and considered the\nassessment criteria. I assess Respondent a civil penalty of $2.000.\nThe proposed penalty for Item 3 is $1,000 for violation of 49 C.F.R. § I 95.402(d). Respondent\nfailed to follow procedures to conduct an investigation or gather information to demonstrate that the\ncause of an incorrect valve opening was investigated, corrected or documented to prevent a\nrecunence. Respondent argued that proposed civil penalty should be withdrawn because the\nequipment perfonned exactly as it was designed to perfonn. making § 195.402( d) inapplicable. The\nunscheduled or unexpected opening of the incorrect valve suggests that there was nothing normal\nabout this occurrence. Respondent did not deny that no infonnation was gathered to demonstrate that\nthe cause of the opening of an incorrect valve was investigated and corrected. Respondent has not\nprovided any evidence that would justify the withdrawal of the propos ed civil penalty. Accordingly,\nhaving reviewed the record and considered the assessment criteria, I assess Respondent a civil\npenalty of$I,OOO.\nThe proposed penalty for Item 4 is 2,000 for violation of 49 C.F .R. § 195.4O4(a). Respondent did\nnot contest the alleged violation but requested that the proposed civil penalty be reduced.\nDocumentation is essential not only to show that the set pressure and test pressure of critical safety\nvalves are accurately maintained but to ensure the safe operation. mainteoance and repair of pipeline\nsystems and components. Without documentation and sound record keeping, it is difficult for an\noperator to ensure that all inspections. testing. calibration. and repair records are accurately\nmaintained. Respondent bas not provided any evidence that would justify mitigation of the civil\npenalty. Accordingly, having reviewed the record and considered the assessment criteria. I assess\nRespondent a civil penalty of $2,000.\nThe proposed penalty for Item 5 is $25,000 forviolationof49 C.F.R. § 195.410(a). Respondentdid\nnot contest the alleged violation but explained that the facility where some of the line markers are\nlocated is a govemment-controlled environment which limits its access to the line markers.\nRespondent further explained that the operator at the facility has Respondent's correct emergency\ntelephone number in its emergency plan. Respondent requested mitigation of the civil penalty\nbecause the scope of the pipeline marker survey is overbroad and should be reduced to a limited\ngeographical area. rather than 5,000 miles.\nBased upon a review of recent inspection and compliance activities, the area Respondent is required\nto survey will be limited to the geographical boundaries of the Richmond District. from Witt Station\nto the south and the Rapidan River to the north. Limiting the geographical area of the survey in no\nway reduces the gravity of the violation. The geographical limitation is merely tailored to\nRespondent's organizational structure. In the event of an emergency, the lack of clearly visible line\nmarkers will interfere with and delay first respondss' efforts to contact the Respondent, which poses\na danger to the public and the environment. Accordingly, having reviewed the record and considered\nthe assessment criteria, I assess Respondent a civil penalty of $25,000.\n\n\n\n8\nThe proposed penalty for Item 6 is $139,500 for violation of 49 C.F.R. § 195.416(a). Respondent\nfailed to conduct tests from 1997 to 200 1 on each buried, in contact with the ground, or submerged\npipeline. The Notice alleged that eighty-nine (89) readings were not recorded for forty-five (45)\ncathodic protection test stations in New Jersey, New York, and Maryland. Respondent\nacknowledged that readings were not recorded for some test stations, but argued that the nmnber was\nless that the Notice alleged. Respondent indicated that many of the missing records were a result of\npoor internal management. Subsequently, Respondent submitted associated records relative to the\nmissing records. Based upon a review of this documentation, OPS has detennined that from 1997\nto 2001 a total of 43 readings were not recorded for 29 cathodic protection test stations. Respondent\nhas provided evidence that would justify mitigation of the civil penalty. After further review of the\nnumber of missed test stations and the number of years the test stations were missed, the OPS\nCompliance Officer computations were recalculated. Accordingly, having reviewed the record and\nconsidered the assessment criteria, I assess Respondent a civil penalty of $58,000.\nAccordingly, having reviewed the record and considered the assessment criteria, I assess Respondent\na total civil penalty of$1 01,000. A detennination bas been made that Respondent bas the ability to\npay this penalty without adversely affecting its ability to continue business.\nPayment of the civil penalty must be made within 20 days of service. Federal regulations\n(49 C.F .R. § 89.21 (b )(3» require this payment be made by wire transfer, through dle Federal Reserve\nCommunications System (Fedwire), to dle account of the U.S. Treasury. Detailed instructions are\ncontained in the enclosure. Questions concerning wire transfers should be directed to: Financial\nOperations Division (AMZ-120), Federal Aviation Administration, Mike Monroney Aeronautical\nCenter, P.O. Box 25082, Oklahoma City, OK 73125; (405) 954-4719.\nFailure to pay the $101 tOOO civil penalty will result in accrual of interest at the current annual rate\nin accordance with 31 U.S.C. § 3717,31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to those\nsame authoritiest a late penalty charge of six percent (6%) per annum will be charged ifpayment is\nnot made within 110 days of service. Fw'dlennorc, failure to pay dle civil penalty may result in\nreferral of the matter to dle Attorney General for appropriate action in a United States District Court.\nThe Notice\n§195.410(a).\n~sed a compliance\norder with respect to Item S for violation of 49 C.F oR.\nUnder 49 U.S.C. § 6O118(a), each person who engages in the transportation of hazardous liquids or\nwho owns or operates a pipeline facility is required to comply widt dte applicable safety standards\nestablished WIder chapter 601. Pursuant to the audtority of 49 U.S.C. § 60118(b) and 49 C.F.R.\n§ 190.217, Respondent is ordered to take the following actions to ensure compliance with the\npipeline safety regulations applicable to its operations. Respondent must -\n\n\n\n9\n1. Survey all its pipeline marker signs on all pipeline~ stations. block valves. stubs,\nlaterals to Roanoke and Norfolk. connecting stubs and delivery lines from the Witt\nStation to the south and the Rapidan River to the north in Virginia, for incorrect\nemergency tel~hone numbers and illegible signs including any fraying or weathered\ndecals/signs and replace them as necessary to ensure that correct active emergency\nnotification telephone numbers are clearly displayed and legjble as required by\n49 C.F.R. §195. 410(a). The principle pipeline numbers are 3, 4. 25. and 27.\nLegible and\n~.~ be posted with\nn urn bers\ntelephone must\nthis Order.\n180 days of receipt of\n2. Submit.\n!i\n1:0\nEastern OPS,\nand/or evidence of completion of these actions to the Director.\n409 31d Street, SW, Suite 300, Washington, DC 20024.\nJ.\nThe Director, OPS, Eastern Region may grant an extension of time for compliance\nwith any of the tenDS ofdris order for good cause. A request for an extension must\nbe in writing.\nFailure to ly with\ncomp\nthis\nFinal Order may result assessment\nin the of civil penalties of up to\n$100,(XK) per violation per day, or in the referral of the case for judicial enforcement.\nUnder 49 C.F.R. § 190.215, Respondent has a right to submit a Petition for Reconsideration of this\nFinal Order. The petition must be received within 20 days of Respondent's receipt of this Final\nOrder and must contain a brief statement of the issue(s). The filing of the petition automatically\nstays the payment of any civil penalty assess ed. All other terms of the order, including any required\ncolTeCtive ~tion, remain in full effect unless the Associate Administrator, upon request, grants a\nstay. The tenns and conditions of this Final Order are effective on receipt.\nDEC 10m3\nfor Pipeline\nI'\\dmlnistrator\nSafety","truncated":false,"body_characters":26724}