{"operation":"document","citation":"CPF 120186001","title":"COLUMBIA MIDSTREAM GROUP, LLC — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-01-05","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.402(a), 195.403(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120186001.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120186001.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120186001","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120186001","body":"Notice of Probable Violation involving COLUMBIA MIDSTREAM GROUP, LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.403(c). The case was opened on 2018-01-05 and is reported as closed as of 2018-07-31. Proposed civil penalty: $20,700. Assessed civil penalty: $20,700. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120186001_Closure Letter_07312018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120186001/120186001_Closure%20Letter_07312018.pdf\n\n120186001_Closure Letter_07312018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120186001/120186001_Closure%20Letter_07312018_text.pdf\n\n120186001_Final Order_06152018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120186001/120186001_Final%20Order_06152018.pdf\n\n120186001_Final Order_06152018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120186001/120186001_Final%20Order_06152018_text.pdf\n\n120186001_NOPV PCP PCO_01052018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120186001/120186001_NOPV%20PCP%20PCO_01052018.pdf\n\n120186001_NOPV PCP PCO_01052018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120186001/120186001_NOPV%20PCP%20PCO_01052018_text.pdf\n\n120186001_NOPV PCP PCO_01052018_text.pdf\n\nNOTICE OF PROBABLE VIOLATION\nPROPOSED CIVIL PENALTY\nand\nPROPOSED COMPLIANCE ORDER\nOVERNIGHT EXPRESS DELIVERY\nJanuary 5, 2018\nMr. Stanley Chapman III\nPresident, US Gas Pipelines\nColumbia Midstream Group, LLC\n700 Louisiana Street, Suite 700\nHouston, TX 77002\nCPF 1-2018-6001\nDear Mr. Chapman:\nFrom April 24 – 28, 2017, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.) inspected the procedures and records of Columbia Midstream Group, LLC,\na subsidiary of TransCanada (TransCanada), at its pipeline facility located in Leetonia, Ohio.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violation(s) are:\n1. § 195.402(a) Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall be\nreviewed at intervals not exceeding 15 months, but at least once each calendar year,\nand appropriate changes made as necessary to insure that the manual is effective.\nThis manual shall be prepared before initial operations of a pipeline system\ncommence, and appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\n\n\n\nCPF 1-2018-6001\nTransCanada failed to follow its procedural manual for operations, maintenance and\nemergencies. Specifically, TransCanada failed to follow its abnormal operating conditions\n(AOC) procedure, pursuant to § 195.402(d)(5), by failing to document the required\neffectiveness review.\nSection 195.402(d)(5) states:\n“(d) Abnormal operation. The manual required by paragraph (a) of this section must include\nprocedures for the following to provide safety when operating design limits have been\nexceeded;\n(5) Periodically reviewing the response of operator personnel to determine the effectiveness of\nthe procedures controlling abnormal operation and taking corrective action where deficiencies\nare found.”\nDuring the inspection, the PHMSA inspector reviewed TransCanada’s (Procedure) “Abnormal\nOperations Plan for Liquid Pipelines”, dated 9/19/16, and prior versions dated 7/1/15 and\n5/2014. The 2015 and 2016 Procedure versions, Section 5 stated, “Twice per calendar year,\nthe Manager of Engineering Services – System Integrity (or designee) will review an Abnormal\nOperations report from the Company’s work management system to determine the Company’s\neffectiveness in controlling Abnormal Operations. Document the review in the Company’s\nwork management system using Procedure 220.005.004 – Abnormal Operations Review.\nWhen deficiencies are found, corrective actions will be initiated.” Similarly, Section 3.1.7 of\nthe 2014 version of the procedures stated, “Twice per calendar year, the Manager of\nEngineering Services (or designee) will review an Abnormal Operations report from the\nCompany’s work management system to determine the Company’s effectiveness in controlling\nAbnormal Operations. Document this review in the Company’s work management system\nusing Company Specification - Abnormal Operation Conditions Report. When deficiencies are\nfound, take corrective action.”\nThe PHMSA inspector requested AOC records and AOC effectiveness records for the 2014 –\n2017 timeframe. TransCanada provided the following (4) records:\n Columbia Midstream 2014 AOC 1\n Columbia Midstream 2015 AOC 4\n Columbia Midstream 2016 AOC 3\n Columbia Midstream 2017 AOC 2\nTransCanada failed to provide any record of AOC effectiveness review for 2014-2017.\nAdditionally, the records TransCanada provided failed to include the following, but not limited\nto:\n Documentation of AOC effectiveness review\n Corrective actions taken\n Signature or approval by supervisor\n Date of AOC closure\n120186001_NOPV PCP PCO_01052018_text Page 2 of 5\n\n\n\nCPF 1-2018-6001\nThe PHMSA inspector re-requested the AOC effectiveness records for the 2014-2017\ntimeframe. TransCanada stated, “The effectiveness review is conducted through root cause and\ndiscussion with the operations team, but this is not documented.”\nTherefore, TransCanada failed to follow its AOC procedure for periodically reviewing the\nresponse of operator personnel to determine the effectiveness of the procedure, per the\nrequirements of § 195.402(d)(5).\n2. § 195.403 Emergency Response Training.\n(c) Each operator shall require and verify that its supervisors maintain a thorough\nknowledge of that portion of the emergency response procedures established\nunder § 195.402 for which they are responsible to ensure compliance.\nTransCanada failed to require and verify that its supervisors maintained a thorough knowledge\nof the portion of the emergency response procedures established under § 195.402 for which\nthey are responsible to ensure compliance.\nDuring the inspection, the PHMSA inspector requested records of supervisor training for 2015\n– 2016 regarding emergency response procedures. TransCanada was unable to provide any\ndocumentation, training record or response demonstrating that it verified that supervisors\nmaintained a thorough knowledge of the portions of the emergency response procedures for\nwhich they are responsible to ensure compliance.\nThe PHMSA inspector also reviewed TransCanada’s (Procedure), “Emergency Response\nPlan Manual Administration Plan”, dated 12/07/16 and “Liquid Pipeline Emergency Plan”,\ndated 02/16/17 (Procedures). The Procedures did not include details such as:\n Defining Emergency Response supervisor role\n Emergency response supervisor training requirements\n Process for verification of supervisor knowledge\nThe PHMSA inspector asked TransCanada where the applicable information is documented\nand TransCanada was not able to provide a response.\nTherefore, TransCanada failed to provide any data that showed it required and verified that\nsupervisors maintained a thorough knowledge of that portion of the emergency response\nprocedures established under § 195.402 for which they are responsible to ensure compliance.\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. The Compliance Officer has reviewed the circumstances and\nsupporting documentation involved in the above probable violation(s) and has recommended that\nyou be preliminarily assessed a civil penalty of $20,700 as follows:\n120186001_NOPV PCP PCO_01052018_text Page 3 of 5\n\n\n\nCPF 1-2018-6001\nItem number PENALTY\n1 $20,700\nProposed Compliance Order\nWith respect to item number 2 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous\nMaterials Safety Administration proposes to issue a Compliance Order to Columbia Midstream\nGroup, LLC. Please refer to the Proposed Compliance Order, which is enclosed and made a part\nof this Notice.\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\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 allegations 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, NJ 08628. Please refer to CPF 1-2018-\n6001 on each document you submit, and whenever possible provide a signed PDF copy in\nelectronic format. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should\nbe 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\n120186001_NOPV PCP PCO_01052018_text Page 4 of 5\n\n\n\nCPF 1-2018-6001\nPROPOSED COMPLIANCE ORDER\nPursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) proposes to issue to Columbia Midstream Group, LLC (TransCanada)\na Compliance Order incorporating the following remedial requirements to ensure the compliance\nof TransCanada with the pipeline safety regulations:\n1. 2. In regard to Item Number 2 of the Notice pertaining to TransCanada’s failure to\nrequire and verify that its supervisors maintained a thorough knowledge of the\nportion of the emergency response procedures established under § 195.402 for\nwhich they are responsible to ensure compliance, TransCanada shall, within\n60 days of issuance of the Final Order, revise its procedures to include guidance for\nrequiring and verifying supervisor’s knowledge of emergency response procedures\nfor which they are responsible.\nIt is requested (not mandated) that TransCanada maintain documentation of the\nsafety improvement costs associated with fulfilling this Compliance Order and\nsubmit the total to Robert Burrough, Director, Eastern Region, Pipeline and\nHazardous Materials Safety Administration. It is requested that these costs be\nreported in two categories: 1) total cost associated with preparation/revision of\nplans, procedures, studies and analyses, and 2) total cost associated with\nreplacements, additions and other changes to pipeline infrastructure.\n120186001_NOPV PCP PCO_01052018_text Page 5 of 5\n\n120186001_Closure Letter_07312018_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJuly 31, 2018\nMr. Stanley Chapman III\nPresident, US Gas Pipelines\nColumbia Midstream Group, LLC\n700 Louisiana Street, Suite 700\nHouston, TX 77002\nCPF 1-2018-6001\nDear Mr. Chapman:\nOn June 15, 2018, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued\nto Columbia Midstream Group, LLC, a subsidiary of TransCanada (TransCanada) a Final Order\nin the above-referenced case. This Order included a Compliance Order requirement to take\ncorrective actions on your pipeline. Based on our review of the documentation you provided, it\nhas been determined that you have complied with the terms of this Order.\nAccordingly, this case is now closed and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n120186001_Final Order_06152018_text.pdf\n\nJune 15, 2018\nMr. Stanley Chapman, III\nPresident, US Gas Pipelines\nColumbia Midstream Group, LLC\n700 Louisiana Street, Suite 700\nHouston, TX 77002\nRe: CPF No. 1-2018-6001\nDear Mr. Chapman:\nEnclosed please find the Final Order issued in the above-referenced case. It makes two findings\nof violation and assesses a civil penalty of $20,700. This is to acknowledge receipt of payment\nof the full penalty amount, by wire transfer, dated February 21, 2018. When the terms of the\ncompliance order have been completed, as determined by the Director, Eastern Region, this\nenforcement action will be closed. Service of the Final Order by certified mail is effective upon\nthe date of mailing, as provided 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. Russell K. Girling, President & CEO, TransCanada Corporation, 450 – 1 St. SW,\nCalgary, Alberta, Canada T2P 5H1\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 )\nColumbia Midstream Group, LLC, ) CPF No. 1-2018-6001\na subsidiary of TransCanada Corporation, )\n)\n)\n)\nRespondent. )\n_________________________________________ )\nFINAL ORDER\nFrom April 24-28, 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 facilities and records of Columbia\nMidstream Group, LLC (Columbia or Respondent), a subsidiary of TransCanada Corporation\n(TransCanada) in Leetonia, Ohio. Columbia operates a hazardous liquid pipeline transporting\nnatural gas liquids products and running approximately 36 miles from the Hickory Bend\nprocessing plant in Mahoning County, Ohio, to the UEO Buckeye Kensington Plant in\nColumbiana County, Ohio.1\nAs a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Respondent,\nby letter dated January 5, 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 Columbia had violated 49 C.F.R. §§ 195.402(a) and 195.403(c) and\nproposed assessing a civil penalty of $20,700 for the alleged violations. The Notice also\nproposed ordering Respondent to take certain measures to correct the alleged violations.\nRespondent failed to respond within 30 days of receipt of service of the Notice. Under 49 C.F.R.\n§ 190.208(d), such failure to respond constitutes a waiver of Columbia’s right to contest the\nallegations in the Notice and authorizes the Associate Administrator, without further notice, to\nfind facts as alleged in the Notice and to issue this Final Order under § 190.213. Despite such\nwaiver, on February 23, 2018, the Eastern Region, OPS, reached out to Mr. Lee Romack,\nManager of U.S. Regulatory Compliance for Respondent, to confirm the company’s receipt of\nthe Notice. In a phone conversation, Mr. Romack confirmed that the Notice had been received,\nand stated that TransCanada had not intended to contest any of the contents of the Notice.\nRespondent paid the civil penalty of $20,700 by wire transfer dated February 21, 2018.\n1 https://www.transcanada.com/en/operations/natural-gas/columbia-midstream/systems/ (last accessed Mar. 7,\n2018).\n\n\n\nCPF No. 1-2018-6001\nPage 2\nFINDINGS OF VIOLATION\nColumbia did not contest the allegations in the Notice that it violated 49 C.F.R. Part 195, as\nfollows:\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a), which states:\n§ 195.402 Procedural manual for operations, maintenance, and\nemergencies.\n(a) General. Each operator shall prepare and follow for each pipeline\nsystem a manual of written procedures for conducting normal operations and\nmaintenance activities and handling abnormal operations and emergencies.\nThis manual shall be reviewed at intervals not exceeding 15 months, but at\nleast once each calendar year, and appropriate changes made as necessary to\ninsure that the manual is effective. This manual shall be prepared before initial\noperations of a pipeline system commence, and appropriate parts shall be kept\nat locations where operations and maintenance activities are conducted.\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.402(a) by failing to follow its own\nmanual of written procedures for conducting normal operations, maintenance, and handling\nabnormal operations and emergencies. Specifically, the Notice alleged that Columbia failed to\nfollow its abnormal operating conditions (AOC) procedure, pursuant to § 195.402(d)(5), by\nfailing to document the required effectiveness review. During the inspection, Columbia failed to\nprovide PHMSA with any record of an AOC effectiveness review for 2014-2017, despite the\ncompany’s procedures requiring an effectiveness review twice per calendar year. Columbia\nstated: “The effectiveness review is conducted through root cause and discussion with the\noperations team, but this is not documented.”\nRespondent did not contest this allegation of violation. Accordingly, based upon a review of all\nof the evidence, I find that Respondent violated 49 C.F.R. § 195.402(a) failing to follow its own\nmanual of written procedures for conducting normal operations, maintenance and handling\nabnormal operations and emergencies.\nItem 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.403(c), which states:\n§ 195.403 Emergency response training.\n(a) . . . .\n(c) Each operator shall require and verify that its supervisors maintain\na thorough knowledge of that portion of the emergency response procedures\nestablished under §195.402 for which they are responsible to ensure\ncompliance.\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.403(c) by failing to require and\nverify that its supervisors maintained a thorough knowledge of the portion of the emergency\nresponse procedures established under § 195.402 for which they are responsible to ensure\ncompliance. Specifically, the Notice alleged that during the inspection, the PHMSA inspector\n\n\n\nCPF No. 1-2018-6001\nPage 3\nrequested records of supervisor training for 2015-2016 regarding emergency response\nprocedures. Columbia was allegedly unable to provide any documentation, training record, or\nresponse demonstrating that it had verified that supervisors maintained a thorough knowledge of\nthe portions of the emergency response procedures for which they were responsible to ensure\ncompliance. The PHMSA inspector also reviewed Columbia’s Emergency Response Plan\nManual Administration Plan, dated December 7, 2016, and Liquid Pipeline Emergency Plan,\ndated February 16, 2017. The Notice alleged that the procedures did not include details such as:\n(1) defining the emergency response supervisor’s role; (2) the emergency response supervisor’s\ntraining requirements; or (3) the process for verification of a supervisor’s knowledge. The\nPHMSA inspector asked Columbia where the applicable information was documented and\nColumbia was unable to provide a response.\nRespondent did not contest this allegation of violation. Accordingly, based upon a review of all\nof the evidence, I find that Respondent violated 49 C.F.R. § 195.403(c) by failing to require and\nverify that its supervisors maintained a thorough knowledge of the portion of the emergency\nresponse procedures established under § 195.402 for which they are responsible to ensure\ncompliance.\nThese findings of violation will be considered prior offenses in any subsequent enforcement\naction taken against Respondent.\nASSESSMENT OF PENALTY\nUnder 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed\n$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any\nrelated series of violations.2 In determining the amount of a civil penalty under 49 U.S.C.\n§ 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature,\ncircumstances, and gravity of the violation, including adverse impact on the environment; the\ndegree of Respondent’s culpability; the history of Respondent’s prior offenses; the Respondent’s\nability to pay the penalty and any effect that the penalty may have on its ability to continue doing\nbusiness; and the good faith of Respondent in attempting to comply with the pipeline safety\nregulations. In addition, I may consider the economic benefit gained from the violation without\nany reduction because of subsequent damages, and such other matters as justice may require.\nThe Notice proposed a total civil penalty of $20,700 for the violation cited above in Item 1.\nItem 1: The Notice proposed a civil penalty of $20,700 for Respondent’s violation of 49 C.F.R.\n§ 195.402(a), for failing to follow its manual of written procedures for operations, maintenance,\nand emergencies. Columbia neither contested the allegation nor presented any evidence or\nargument justifying elimination of the proposed penalty. Accordingly, having reviewed the\nrecord and considered the assessment criteria for violation of 49 C.F.R. § 195.402(a), I assess\nRespondent a total civil penalty of $20,700, which has already been paid in full by wire transfer\ndated February 21, 2018.\n2 These amounts are adjusted annually for inflation. See, e.g., Pipeline Safety: Inflation Adjustment of Maximum\nCivil Penalties, 82 Fed. Reg. 19325 (April 27, 2017).\n\n\n\nCPF No. 1-2018-6001\nPage 4\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Item 2 in the Notice, for the violation of\n49 C.F.R. § 195.403(c). Under 49 U.S.C. § 60118(a), each person who engages in the\ntransportation of hazardous liquids or who owns or operates a pipeline facility is required to\ncomply with the applicable safety standards established under chapter 601. Pursuant to the\nauthority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the\nfollowing actions to ensure compliance with the pipeline safety regulations applicable to its\noperations:\n1. With respect to the violation of § 195.403(c) (Item 2), Respondent must, within\n60 days of issuance of this Final Order, revise its procedures to include guidance for\nrequiring and verifying supervisors’ knowledge of emergency response procedures\nfor which they are responsible.\nThe Director may grant an extension of time to comply with any of the required items upon a\nwritten request timely submitted by the Respondent and demonstrating good cause for an\nextension.\nIt is requested (not mandated) that Respondent maintain documentation of the safety\nimprovement costs associated with fulfilling this Compliance Order and submit the total to the\nDirector. It is requested that these costs be reported in two categories: (1) total cost associated\nwith preparation/revision of plans, procedures, studies and analyses; and (2) total cost associated\nwith replacements, additions and other changes to pipeline infrastructure.\nFailure to comply with this Order may result in the administrative assessment of civil penalties\nnot to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), for each violation for\neach day the violation continues or in referral to the Attorney General for appropriate relief in a\ndistrict court of the United States.\nThe terms and conditions of this Final Order are effective upon service in accordance with\n49 C.F.R. § 190.5.\nJune 15, 2018\n___________________________________ __________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":25127}