{"operation":"document","citation":"CPF 120183005","title":"NIAGARA MOHAWK POWER CORP — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-06-12","effective_on":null,"summary":"CLOSED notice of probable violation citing 193.2635(d).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120183005.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120183005.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120183005","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120183005","body":"Notice of Probable Violation involving NIAGARA MOHAWK POWER CORP. PHMSA's enforcement data identifies the cited regulation as 193.2635(d). The case was opened on 2018-06-12 and is reported as closed as of 2020-02-24. Proposed civil penalty: $46,700. Assessed civil penalty: $0. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120183005_Final Order_02242020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120183005/120183005_Final%20Order_02242020.pdf\n\n120183005_Final Order_02242020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120183005/120183005_Final%20Order_02242020_text.pdf\n\n120183005_Hearing_Scheduled_10092018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120183005/120183005_Hearing_Scheduled_10092018.pdf\n\n120183005_NOPV PCP PCO_06122018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120183005/120183005_NOPV%20PCP%20PCO_06122018.pdf\n\n120183005_NOPV PCP PCO_06122018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120183005/120183005_NOPV%20PCP%20PCO_06122018_text.pdf\n\n120183005_Operator Post Hearing Submission_01112019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120183005/120183005_Operator%20Post%20Hearing%20Submission_01112019.pdf\n\n120183005_Operator Response Notice and Request for Hearing_07102018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120183005/120183005_Operator%20Response%20Notice%20and%20Request%20for%20Hearing_07102018.pdf\n\n120183005_Operator Response to Notice and Request for Hearing_07102018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120183005/120183005_Operator%20Response%20to%20Notice%20and%20Request%20for%20Hearing_07102018.pdf\n\n120183005_Final Order_02242020_text.pdf\n\nFebruary 24, 2020\nMr. John Pettigrew\nChief Executive Officer\nNational Grid, PLC\n1-3 Strand\nLondon WC2N 5EH, United Kingdom\nRe: CPF No. 1-2018-3005\nDear Mr. Pettigrew:\nEnclosed please find the Final Order issued in the above-referenced case. It withdraws the\nallegation in the Notice of Probable Violation issued on June 12, 2018. Accordingly, this case is\nnow closed. Service of the Final Order by certified mail is effective upon the date of mailing as\nprovided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. Robert Burrough, Director, Eastern Region, Office of Pipeline Safety, PHMSA\nMr. Ross Turrini, Senior Vice President, Gas Process and Engineering, National Grid,\nPLC, 40 Sylvan Road, Waltham, Massachusetts 02451\nMr. David C. Lodemore, Esq., Senior Counsel, National Grid, PLC, 40 Sylvan Road,\nWaltham, Massachusetts 02451\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nNiagara Mohawk Power Corporation, ) CPF No. 1-2018-3005\na subsidiary of National Grid, PLC, )\n)\n)\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nFrom August 29-31, 2017, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),\nconducted an on-site pipeline safety inspection of the Providence LNG Plant facilities and\nrecords of Niagara Mohawk Power Corporation (Niagara or Respondent), in Providence, Rhode\nIsland. Niagara is a subsidiary of National Grid, PLC, which engages in the transmission and\ndistribution of gas and electricity in several northeastern states including New York,\nMassachusetts, and Rhode Island. The Providence LNG Plant is a storage and peak shaving\nfacility that began service in 1974 with a tank capacity of 600,000 bbl. of LNG.1\nAs a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Respondent,\nby letter dated June 12, 2018, a Notice of Probable Violation, Proposed Civil Penalty, and\nProposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice\nproposed finding that Niagara had violated 49 C.F.R. § 193.2635(d) and proposed assessing a\ncivil penalty of $46,700 for the alleged violation. The Notice also proposed ordering Respondent\nto take certain measures to correct the alleged violation.\nNiagara responded to the Notice by letter dated July 10, 2018 (Response). Niagara contested the\nallegation and requested a hearing. A hearing was subsequently held on December 12, 2018, in\nWest Trenton, New Jersey before a Presiding Official from PHMSA’s Office of Chief Counsel.\nAt the hearing, Respondent was represented by counsel. Respondent provided additional written\nmaterials prior to the hearing on December 3, 2018 (Pre-hearing submission), and following the\nhearing on January 11, 2019 (Post-hearing submission). The Director submitted a region\nrecommendation on April 8, 2019 (Recommendation), and Respondent submitted a reply to the\nregion recommendation on April 19, 2019 (Reply).\n1 Pipeline Safety Violation Report (Violation Report), (June 12, 2018) (on file with PHMSA), at 1.\n\n\n\nCPF No. 1-2018-3005\nPage 2\nWITHDRAWAL OF ALLEGATION\nThe Notice alleged that Respondent violated 49 C.F.R. Part 193, as follows:\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 193.2635(d), which states:\n§ 193.2635 Monitoring corrosion control.\nCorrosion protection provided as required by this subpart must be\nperiodically monitored to give early recognition of ineffective corrosion\nprotection, including the following, as applicable:\n(a)…\n(d) Each component that is protected from atmospheric corrosion must\nbe inspected at intervals not exceeding 3 years.\nThe Notice alleged that Respondent violated 49 C.F.R. § 193.2635(d) by failing to inspect each\ncomponent that is protected from atmospheric corrosion at intervals not exceeding three years.\nSpecifically, the Notice alleged that Niagara failed to inspect insulated piping for the glycol\nsystem and three insulated vaporizers for atmospheric corrosion at its Providence LNG Plant for\nthe 2014 to 2017 period.\nIn its Response and at the hearing, Niagara contested the allegation. Niagara argued that while\nthe facility piping was generally subject to the three-year atmospheric corrosion inspection\nrequirement, the regulation did not expressly require the piping that was covered by thermal\ninsulation to be inspected. Niagara pointed out that the atmospheric corrosion inspection\nprovisions for natural gas pipelines in 49 CFR Part 192 (§ 192.481) and for hazardous liquid\npipelines in 49 CFR Part 195 (§ 195.583) both expressly require inspecting under thermal\ninsulation, but the cited regulation in Part 193 for LNG facilities does not. Respondent believes\nthis may have been a purposeful omission. Respondent cited United States v. Approximately\n64,695 Pounds of Shark Fins to argue that it was reasonable to presume that PHMSA acted\nintentionally when the agency did not include an express requirement to inspect LNG facility\npiping under insulation in § 193.2635(d).2\nIn response to this argument, OPS explained that Niagara’s comparison of the pipeline\nregulations in Parts 192 and 195 to the LNG facility regulations in Part 193 failed to observe a\nkey distinction. Both §§ 192.481 and 195.583 are distinguishable from § 193.2635 because they\nconcern pipelines that are “exposed to the atmosphere,” whereas § 193.2635 contemplates\ninspection of “each component that is protected from atmospheric corrosion.” OPS argued that\nthis distinction reflects the differences in the types of facilities being regulated. LNG is natural\ngas that has been cooled to a liquid state, at or below -260º F. LNG facility piping is almost\nalways protected with insulation or jacketing to protect the pipe from atmospheric corrosion, to\nprevent heat transfer due to the ambient temperature being hundreds of degrees higher, and to\nprotect the people working in the facility from cryogenic temperatures. In comparison to the\ntreatment of insulation by the Part 192 and 195 code drafters, the Part 193 code drafters would\n2 520 F. 3d 976, 983 (9th Cir. 2008).\n\n\n\nCPF No. 1-2018-3005\nPage 3\nhave been well aware that LNG facility piping was generally insulated requiring removal for\nvisual inspection of the protected piping.3 OPS is correct that it follows from the Part 193\nlanguage that the material to be inspected is the protected material, even if it is underneath\ninsulation or jacketing. Moreover, there is no rationale for the proposition that insulated LNG\npiping should receive lesser inspections than aboveground natural gas and hazardous liquid pipes\nthat are insulated.\nNiagara further argued that it had not received “fair notice” of PHMSA’s application of\n§ 193.2635(d).4 Niagara noted that in contrast to PHMSA’s approach under Parts 192 and 195, it\nmade no compliance guidance on atmospheric corrosion inspections under Part 193 available to\noperators.5 In response, OPS noted that the DC Circuit stated in General Electric Company v.\nUS EPA that where a party argues that an agency is providing notice of interpretation through an\nenforcement action, the relevant question is, “whether the regulated party received, or should\nhave received notice of the agency’s interpretation in the most obvious way of all: by reading the\nregulations.”6\nHaving considered these arguments, I find that PHMSA did provide such notice to LNG\noperators. The regulation states:\n(d) Each component that is protected from atmospheric corrosion must\nbe inspected at intervals not exceeding 3 years.\nComponent is defined by § 193.2007, to include:\n“any part, or system of parts functioning as a unit, including, but not limited\nto, piping, processing equipment, containers, control devices, impounding\nsystems, lighting, security devices, fire control equipment, and\ncommunication equipment, whose integrity or reliability is necessary to\nmaintain safety in controlling, processing, or containing a hazardous fluid.”\nThus, the regulation itself provides fair notice that operators must inspect each component that is\nprotected from atmospheric corrosion at intervals not exceeding three years. Niagara\nacknowledged that its asbestos insulation and aluminum jacketing served as thermal insulation\nand protection against atmospheric corrosion.7 Insulation is not a component protected from\natmospheric corrosion. Rather, insulation protects the component in question from atmospheric\ncorrosion. To comply with § 193.2635(d), an operator must “inspect” the component being\n3 OPS also pointed out that in Shark Fins, the court analyzed subsections within the same regulation, specifically 50\nCFR § 600.1204(b) and (c). Conversely, the LNG regulation § 193.2635 is in a completely different Part of title 49\nfrom the parts dealing with natural gas and hazardous liquid pipelines, Parts 192 and 195.\n4 Post-hearing submission, at 3.\n5 Post-hearing submission, at 6.\n6 53 F. 3d 1324, 1329 (D.C. Cir. 1995).\n7 Pre-hearing submission, at 3.\n\n\n\nCPF No. 1-2018-3005\nPage 4\nprotected. While non-destructive examination methods can be utilized, if visual inspection is the\nmethod of inspecting the exterior surface of a component for atmospheric corrosion, the\nrequirement to inspect these components requires operators to actually look at the condition of\nthe component being protected from atmospheric corrosion which by definition would involve\nvisual inspection of enough of the pipe surface under the insulation to confirm the absence of\natmospheric corrosion. In this case, Niagara was required to visually inspect enough of the\nglycol system piping and the vaporizers that were protected by asbestos insulation and aluminum\njacketing to confirm the absence of atmospheric corrosion.8\nNiagara then argued in the alternative that even if § 193.2635(d) does require the operator of an\nLNG facility to inspect under thermal insulation, certain activities that it conducted at the\nProvidence LNG Plant during the relevant period should be considered to have satisfied any such\nrequirement.9 Niagara explained that the facility had an ongoing program of replacing the\nasbestos insulation with polycarbonate insulation whenever the asbestos insulation was found to\nbe in a deleterious condition. Niagara stated that atmospheric corrosion inspections were\nperformed on the pipe surface exposed by the removal of the old asbestos insulation during this\ninsulation replacement program. During the hearing, Niagara provided photos of portions of the\nglycol system and vaporizers with insulation removed demonstrating that the pipe surface was\ninspected. Niagara further explained that these visual atmospheric corrosion inspections were\nsupplemented with ultrasonic readings of the 8-inch glycol pipe and other sections of piping.10\nOPS conceded that it may be possible to “conduct atmospheric corrosion inspections and achieve\ncompliance with § 193.2635(d) during the performance of other field activities.”11 However,\nOPS maintained that although deteriorated insulation could be a factor to consider for\nprioritizing locations for atmospheric corrosion inspection, none of the 2014, 2015, 2016, or\n2017 asbestos insulation removal locations were identified in Niagara’s records as locations that\ncorresponded to a risk-based assessment of the portions of the glycol lines or vaporizers with the\ngreatest risk of atmospheric corrosion.\nThe issue to be determined in this case is whether the regulation at issue allowed Niagara to\nconduct its atmospheric corrosions in the manner described. Under § 193.2635(d), an LNG\nfacility operator has wide latitude in developing the procedures by which its atmospheric\ncorrosion inspections will be conducted. The regulations permit an operator to determine the\nappropriate manner of inspection for its particular facility so long as the procedures account for\nthe presence of piping that is not visually accessible such as insulated piping. For example,\noperators that utilize visual inspection as the primary method can establish procedures for\n8 In a highly similar case from 2012, for example, PHMSA alleged that Transco, an LNG operator, failed to inspect\nany pipe under the thermal insulation on its steel piping during atmospheric corrosion surveys. The operator was\nfound to have violated § 193.2635(d), ordered to pay a civil penalty of $48,400, and ordered to comply with\ncompliance terms. In the Matter of Transcontinental Gas Pipe Line Company, LLC, CPF No. 1-2012-3002, Final\nOrder, 2012 WL 6892766 (D.O.T., Oct. 26, 2012).\n9 Post-hearing submission, at 8-12.\n10 Reply, at 2.\n11 Region recommendation, at 6.\n\n\n\nCPF No. 1-2018-3005\nPage 5\nremoving select portions of the insulation or clamps or developing a program whereby visual\ninspections occur in predetermined critical inspection locations by creating inspection ports.\nThey can also supplement visual inspections with non-destructive methods such as ultrasonic or\nradiographic testing.\nOPS is correct that Respondent did not utilize a rigorous risk-based approach for planning and\nconducting its atmospheric corrosion inspections on the insulated piping and that its written\nprocedures in this area were not ideal. Respondent correctly pointed out, however, that the\nregulation does not require a risk-based atmospheric corrosion inspection program. Niagara\nreasoned that the areas it did visually inspect where the insulation had deteriorated would tend to\ncorrespond to the higher risk areas for atmospheric corrosion.12 Moreover, in this case the sheer\nextent of Niagara’s insulation replacement program resulted in hundreds of linear feet of the\ninsulation on piping being replaced and hundreds of square feet of insulation on the vaporizers\nbeing replaced during the 2014 to 2017 period. As a result, Respondent may well have inspected\na greater amount of the pipe surface under the insulation at its facility than an operator that has\npre-designated its inspection locations typically inspects. While Niagara would be well advised\nto clarify and enhance its atmospheric corrosion inspection procedures, in this case OPS did not\nestablish that the inspections under the insulation that Respondent did conduct were so\ninadequate that they constituted non-compliance with the minimum requirements in the\nregulation.\nBased upon the foregoing, I hereby order that this allegation be withdrawn.\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to the alleged violation of 49 C.F.R. §\n193.2635(d). Because the allegation has been withdrawn, the compliance terms are also\nwithdrawn.\nThe terms and conditions of this Final Order are effective upon service in accordance with 49\nC.F.R. § 190.5.\nFebruary 24, 2020\n___________________________________ __________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety\n12 Reply, at 4.\n\n120183005_NOPV PCP PCO_06122018_text.pdf\n\nNOTICE OF PROBABLE VIOLATION\nPROPOSED CIVIL PENALTY\nand\nPROPOSED COMPLIANCE ORDER\nOVERNIGHT EXPRESS DELIVERY\nJune 12, 2018\nMr. Ross Turrini\nSVP, Gas Process and Engineering\nNiagara Mohawk Power Corp.\n25 Hub Drive\nMelville, NY 11747\nCPF 1-2018-3005\nDear Mr. Turrini:\nFrom August 29-31, 2017, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety, pursuant to Chapter 601 of 49 United States\nCode (U.S.C.), inspected Niagara Mohawk Power Corporation (Niagara)’s LNG Plant in\nProvidence, Rhode Island. Niagara is a subsidiary of National Grid plc.\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 items inspected\nand the probable violation is:\n1. § 193.2635 Monitoring corrosion control.\n(d) Each component that is protected from atmospheric corrosion must be inspected\nat intervals not exceeding 3 years.\nNiagara failed to inspect each component that is protected from atmospheric corrosion (AC) at\nintervals not exceeding 3 years. Specifically, Niagara failed to conduct effective AC inspections\nfor the insulated glycol system and three insulated vaporizers at its Providence LNG Plant during\nthe timeframe of 2014 to 2017.\n\n\n\nCPF 1-2018-3005\nDuring the inspection, the PHMSA inspector reviewed Niagara’s LNG Plant, Plant Atmospheric\nCorrosion Inspection, 17.PR-M5 Rev 9 (Procedure), and its 2014-2017 records of AC inspections.\nThe PHMSA inspector performed a field review of the LNG Plant and identified insulation barriers\nthat prevented access to the majority of the glycol system and three vaporizers. The glycol system\nconsisted of 1,650 feet of 8-inch pipe. Inspecting these carbon steel components required\nspecialized preparation or expanded effort to access and evaluate them for evidence of AC.\nNiagara’s Procedure failed to provide a pathway for the inspection of carbon steel components\nunder thermal insulation. Further review of the Procedure revealed lack of similar pathways to\naccess and inspect other components with visual barriers, such as, pipe at supports and areas under\ndisbonded coating.\nThe records reviewed demonstrated that Niagara conducted annual AC inspections of its facility.\nThe 2017 records indicated that Niagara did not perform the AC inspections under most of the 8-\ninch glycol system piping and the three vaporizers due to the insulation barriers. The 2014-2016\nNiagara AC inspection records showed inspection results for components under insulation, but\nthere were no records to attest that the insulation had been removed to access and evaluate the\ncarbon steel components. Niagara stated that it had not removed insulation during the AC\ninspections. Niagara’s actions and its procedures present no alternate method to perform the AC\ninspections.\nTherefore, Niagara failed to inspect, at intervals not exceeding 3 years, each component that is\nprotected from atmospheric corrosion, by failing to conduct effective AC inspections of above-\nground components under insulation at its Providence LNG Plant from 2014 to 2017.\nProposed Civil Penalty\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$209,002 per violation per day the violation persists, up to a maximum of $2,090,022 for a related\nseries of violations. For violations occurring prior to November 2, 2015, the maximum penalty\nmay not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000\nfor a related series of violations. Also, for LNG facilities, an additional penalty of not more than\n$76,352 for each violation may be imposed. The Compliance Officer has reviewed the\ncircumstances and supporting documentation involved in the above probable violation and has\nrecommended that you be preliminarily assessed a civil penalty of $46,700 as follows:\nItem number PENALTY\n1 $46,700\nProposed Compliance Order\nWith respect to item number 1, pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous\nMaterials Safety Administration proposes to issue a Compliance Order to Niagara Mohawk Power\nCorp. Please refer to the Proposed Compliance Order, which is enclosed and made a part of this\nNotice.\nResponse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. All material\n120183005_NOPV PCP PCO_06122018_text Page 2 of 4\n\n\n\nCPF 1-2018-3005\nyou submit in response to this enforcement action may be made publicly available. If you believe\nthat any portion of your responsive material qualifies for confidential treatment under 5 U.S.C.\n552(b), along with the complete original document, you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, or request a\nhearing under 49 CFR § 190.211. If you do not respond within 30 days of receipt of this Notice,\nthis constitutes a waiver of your right to contest the allegation in this Notice and authorizes the\nAssociate Administrator for Pipeline Safety to find facts as alleged in this Notice without further\nnotice to you and to issue a Final Order. If you are responding to this Notice, we propose that you\nsubmit your correspondence to my office within 30 days from receipt of this Notice. This period\nmay be extended by written request for good cause.\nPlease submit all correspondence in this matter to Robert Burrough, Director, PHMSA Eastern\nRegion, 820 Bear Tavern Road, Suite 103, West Trenton, New Jersey 08628. Please refer to\nCPF 1-2018-3005 on each document you submit, and whenever possible provide a signed PDF\ncopy in electronic format. Smaller files may be emailed to robert.burrough@dot.gov. Larger files\nshould be sent on a CD accompanied by the original paper copy to the Eastern Region Office.\nAdditionally, if you choose to respond to this (or any other case), please ensure that any response\nletter pertains solely to one CPF case number.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Compliance Proceedings\n120183005_NOPV PCP PCO_06122018_text Page 3 of 4\n\n\n\nCPF 1-2018-3005\nPROPOSED COMPLIANCE ORDER\nPursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) proposes to issue to Niagara Mohawk Power Corp. a Compliance Order\nincorporating the following remedial requirements to ensure the compliance of Niagara Mohawk\nPower Corp. with the pipeline safety regulations:\n1. 2. 3. 4. In regard to Item Number 1 of the Notice pertaining to § 193.2635, Niagara shall\nrevise its procedure for atmospheric corrosion inspection to address insulated\ncomponents, pipe at supports and pipe under disbonded coating. Niagara shall\nprovide PHMSA the revised procedure for review within 90 days of receipt of the\nFinal Order.\nWithin 365 days of PHMSA’s acceptance of the procedure in Number 1 above,\nNiagara must then apply those procedures to conduct effective atmospheric\ncorrosion inspections for all insulated components at Niagara’s Providence LNG\nPlant.\nUpon request, Niagara shall provide records indicating the completion of the\natmospheric corrosion inspections in Number 2 above.\nIt is requested (not mandated) that Niagara Mohawk Power Corp. maintain\ndocumentation of the safety improvement costs associated with fulfilling this\nCompliance Order and submit the total to Robert Burrough, Director, Eastern\nRegion, Pipeline and Hazardous Materials Safety Administration. It is requested\nthat these costs be reported in two categories: 1) total cost associated with\npreparation/revision of plans, procedures, studies and analyses, and 2) total cost\nassociated with replacements, additions and other changes to pipeline\ninfrastructure.\n120183005_NOPV PCP PCO_06122018_text Page 4 of 4","truncated":false,"body_characters":25133}