# HUNT REFINING CO — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 220055002
- **title:** HUNT REFINING CO — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2005-03-21
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.52.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-220055002.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-220055002.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-220055002
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/220055002
**body:**

Notice of Probable Violation involving HUNT REFINING CO. PHMSA's enforcement data identifies the cited regulation as 195.52. The case was opened on 2005-03-21 and is reported as closed as of 2006-06-08. Proposed civil penalty: $5,000. Assessed civil penalty: $5,000. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220055002_Final Order_11152005.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220055002/220055002_Final%20Order_11152005.pdf

220055002_final order_11152005_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220055002/220055002_final%20order_11152005_text.pdf

Final Order Hunt Refining Company CPF No 2-2005-5002.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220055002/Final%20Order%20Hunt%20Refining%20Company%20CPF%20No%202-2005-5002.pdf

220055002_final order_11152005_text.pdf

U. s. Department
of Transportation
Pipeline and
Hazardous ttttaterlats Safety
Administration
400 Seventh Street, S. W.
Washington, D. C. 20590
NOV 15 2005
Mr. David Carroll
Vice President and General Counsel
Hunt Refining Company
100 Town Center Blvd.
Suite 300
,
Tuscaloosa, AL 35406-1829
RE: CPF No. 2-2005-5002
Dear Mr. Carroll:
Enclosed is the Final Order issued by the Associate Administrator for Pipeline Safety in
the above-referenced case. It makes a finding of violation and assesses a civil penalty of $5, 000.
The penalty payment terms are set forth in the Final Order. This enforcement action closes
automatically upon payment. Your receipt of the Final Order constitutes service of that document
under 49 C. F. R. It 190. 5.
Sincerely,
James Reynolds
Pipeline Compliance Registry
Office of Pipeline Safety
Enclosure
cc: Ms. Linda Daugherty, Director, OPS Southern Region
CERTIFIED MAIL - RETURN RECEIPT RE UESTED
RECEIVES NOV 2 2 2005



DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D. C. 20590
In the Matter of
Hunt Refining Company,
Respondent.
CPF No. 2-2005-5002
FINAL ORDER
On December 28, 2004, pursuant to 49 U. S. C. tj 60117, a representative of the Southern Region,
Office of Pipeline Safety (OPS) initiated an investigation of Respondent's report of an incident
involving its 6-inch petroleum pipeline in Tuscaloosa, Alabama. As a result of the investigation, the
Director, Southern Region, OPS, issued to Respondent, by letter dated March 21, 2005, a Notice of
Probable Violation and Proposed Civil Penalty (Notice). In accordance with 49 C. F. R. $ 190. 207,
the Notice proposed finding that Respondent violated 49 C. F. R. $ 195. 52 and proposed assessing
a civil penalty of $5, 000 for the alleged violation.
In a letter dated March 29, 2005, Respondent submitted a Response to the Notice(Response).
Respondent contested the allegation of violation, offered information to explain the allegation,
requested that the proposed civil penalty be eliminated, and requested a hearing. A hearing was held
via telephone conference on May 4, 2005.
FIND NGS OF VIOLATION
The Notice alleged that Respondent violated 49 C. F. R. )195. 52 by not giving telephonic notification
to the National Response Center (NRC), at the earliest practicable moment, following discovery of
the incident that occurred on December 27, 2004. The incident involved a release of 300 barrels of
No. 2-D fuel on Respondent's 6-inch petroleum pipeline three miles southwest of the Hunt Oil
Refinery in Tuscaloosa, Alabama. In response to a phone call from an adjacent property owner,
Respondent arrived at the incident site at approximately 3:15 p. m on December 27, 2004 CST.
According to the NRC and the Alabama Public Service Commission pipeline safety office,
Respondent did not give the NRC telephonic notification of the incident until 10:20 a. m. EST on
December 28, 2005, approximately 18 hours after discovery of the incident.
In response, Respondent conceded that it received notice from an adjacent property owner of a leak
in the area of its 6-inch product pipeline on December 27, 2004, at approximately 2:30 p. m. CST and
arrived at approximately 3:35 p. m. Respondent advised that upon arrival it observed bubbles



coming from water which covered the area of the pipeline right-of-way. Due to recent rains, there
was a great deal of water covering the area and it was not possible to tell the extent of the release.
Respondent immediately shutdown the pipeline and began an evaluation of a wooded area.
Respondent explained that it also recognized that there was standing water and that any additional
rainfall might cause any product to migrate. Respondent further advised that it took a sample from
the nearest stream to confirm that no product had reached the stream. Respondent placed a boom
at the stream, approximately 'r4 mile away, because of the standing rainwater. Respondent then
mobilized its vacuum truck to suction up the tdsible liquid, which appeared to be rainwater. This
was done just before the sun set at 4:51 p. m. on December 27, 2004,
Respondent determined, based upon its initial evaluation, that it was not a reportable incident under
49 C F R. tj19552 because there was no death or personal injuryrequiring hospitalization; there was
no fire or explosion; it did not appear tha& the property damage including clean up cost would meet
$50, 000; there was no pollution of any stream and it did not appear significant.
Respondent argued that notification was made as soon as practicable, at 9:20 a. m. on December 28,
2004, when it made a determination that the incident was reportable under 49 C. F. R. $195. 52(a)(3).
Respondent contented it was not until morning that it became apparent that the spill area was larger
than originally observed and that it provided timely notification. Concern was expressed by
Respondent as to whether the incident was the result of third party excavator damage. The cause of
the concern was the liquid located in the area on the side of an excavation company and pine tree
nursery. Respondent also expressed concern about the impact of reporting the incident on December
27, 2004, which could have been premature because of incomplete information.
OPS opined that the nature of 49 C. F. R. fl195. 52 is two-fold, early warning and investigatory.
Telephone notification to the NRC is an early warning for OPS, its State partner, and the National
Transportation Safety Board (NTSB) to decide whether or not the federal government needs to
investigate the incident for compliance and safety factors. OPS argued that notification must be
made as soon as practicable so that an evaluation can be made to determined whether continued
operation of the pipeline will endanger or further endanger the public, property or the environment,
OPS posed that it is important that OPS arrive at the site when the evidence is still present at the site,
the evidence is fresh and before the evidence is disturbed. OPS further argued that advisory bulletins
have been issued to owners and operators of gas distribution, gas transmission, and hazardous liquid
pipelines systems, and liquified natural gas facilities to ensure that telephonic reports of incidents
to the NRC are prompt and at the earliest practicable moment following discovery. The bulletins
also clarify the term incident, earliest practicable moment and discuss telephonic reports made when
early information is incomplete. OPS also advised that Respondent is permitted to contact the NRC
later to withdraw a report.
Pre-enforcement efforts such as advisorv bulletins.
, agency interpretations and 49 C. F. R. (190. 11
provide notice and enable Respondent to identify with certainty the standards with which OPS
expects operators to comply. 49 C. F. R. (190. 11 provides for informal guidance and interpretive
assistance about compliance with pipeline safety regulations, 49 C. F. R. Parts 190-199.



If Respondent needs clarification, information on, and advice about compliance with pipeline safety
regulations, then Respondent should take advantage of 49 C. F. R. II190. 11 to resolve ambiguities.
In furtherance, the issuance of advisory bulletins of "Required Notification of National Response
Center" basically addresses Respondent's concerns. ' The advisory bulletin recognizes that
telephonic reports are often made when the information on an incident is incomplete. The bulletin
also makes it clear that OPS expects an operator to provide update information during the emergency
response phase, as new information changes the understanding of the nature, cause, and severity of
the incident. OPS understands that some hazardous liquid operators do not provide an estimated
release amount when reporting an incident to the NRC. While the estimated spill size should be
initially reported, OPS also recognizes that there may be difficulty in estimating spill amounts,
especially if the release is underground or into water. An operator that provides update information
to the NRC should tell the NRC representative if a previous report was filed for the incident and
provide the NRC Report Number of the original telephonic.
Respondent's reservations or concerns about the reporting requirements do not negate the fact that
a violation occurred. During its initial arrival at approximately 3:35 p. m.
, Respondent could have
taken advantage of 49 C. F. R. )190. 11 for informal guidance and interpretive assistance about
compliance withpipeline safetyregulations. PHMSA, OPS, has established awebsite on the Internet
and a telephone line at OPS headquarters where operators can obtain information on and advice
about compliance. The website and phone line (202-366-0918) are staffed by OPS personnel from
9: 00 a. m. through 5: 00 p. m.
,
Eastern time, Monday through Friday, except Federal holidays. Even
if Respondent was concerned about prematurely reporting the incident or an inaccurate spill estimate,
Respondent could have made the telephonic report and filed an additional report during the
emergency response phase if the circumstances and/or estimates changed. Respondent could have
called the NRC to provide updated information to document the latest information. Respondent has
not shown any circumstance that justifies the failure to report to the NRC in a timely manner.
Accordingly, I find Respondent violated 49 C F R. II 19552 by failing to give telephonic notification
to the National Response Center, at the earliest practicable moment, following discovery of an
incident.
This finding of violation will be considered a prior offense in any subsequent enforcement action
taken against Respondent.
ASSESSMENT OF PENALTY
Under 49 U. S. C. II 60122, Respondent is subject to a civil penalty not to exceed $100, 000 per
violation for each day of the violation up to a maximum of $1, 000, 000 for any related series of
violations. The Notice proposed a $5, 000 civil penalty for violation of 49 C. F. R. II 195. 52.
67 FR 67060 (2002); 67 FR 67061 (2002).



49 U. S. C. ) 60122 and 49 C. F. R. $ 190. 225 require that, in determining the amount of the civil
penalty, I consider the following criteria: nature, circumstances, and gravity of the violation, degree
of Respondent's culpability, history of Respondent's prior offenses, Respondent's ability to pay the
penalty, good faith by Respondent in attempting to achieve compliance, the effect on Respondent's
ability to continue in business, and such other matters as justice may require.
The Notice proposed a civil penalty of $5, 000, as Respondent failed to give telephonic notification
to the National Response Center (NRC), at the earliest practicable moment, following discovery of
an incident on December 27, 2004. In response to the Notice and in support of its position,
Respondent argued its initial evaluation suggested that it was not a reportable incident under 49
C. F. R. )195. 52. However, Respondent conceded that the property damage including clean up cost
would meet $50, 000. On April 15, 1991 and September 6, 2002, Notices were issued by the
Department of Transportation, OPS, reiterating that telephonic notification should be made within
one to two hours after discovery. OPS's ability to take corrective action and/or mitigate potential
safetyproblems is severely hampered byuntimelytelephonic notification of an incident. Respondent
has not shown any circumstance that would have prevented or justified it not taking prompt action
to give telephonic notification to the NRC. Accordingly, having reviewed the record and considered
the assessment criteria, I assess Respondent a civil penalty of $5, 000, for violation of 49 C. F. R.
)195. 52.
Payment of the civil penalty must be made within 20 days of service. Payment may be made by
sending a certified check or money order (containing the CPF Number for this case) payable to
"U. S, Department of Transportation" to the Federal Aviation Administration, Mike Monroney
Aeronautical Center, Financial Operations Division (AMZ-120), P. O. Box 25770, Oklahoma City,
OK 73125.
Federal regulations (49 C. F. R. ) 89. 21(b)(3)) also permit this payment to be made by wire transfer,
through the Federal Reserve Communications System (Fedwire), to the account of the U. S. Treasury.
Detailed instructions are contained in the enclosure. Questions concerning wire transfers should be
directed to: Financial Operations Division (AMZ-120), Federal Aviation Administration, Mike
Monroney Aeronautical Center, P. O. Box 25082, Oklahoma City, OK 73125; (405) 954-4719.
Failure to pay the $5, 000 civil penalty will result in accrual of interest at the current annual rate in
accordance with 31 U. S. C. tj 3717, 31 C. F. R. tj 901. 9 and 49 C. F. R. tj 89. 23. Pursuant to those same
authorities, a late penalty charge of six percent (6%) per annum will be charged if payment is not
made within 110 days of service. Furthermore, failure to pay the civil penalty may result in referral
of the matter to the Attorney General for appropriate action in an United States District Court.
Under 49 C. F. R. ( 190. 215, Respondent has a right to petition for reconsideration of this Fina!
Order. The petition must be received within 20 days of Respondent's receipt of this Final Order and
must contain a brief statement of the issue(s). The filing of a petition automatically stays the
payment of any civil penalty assessed. All other terms of the order, including any required corrective
action, shall remain in full effect unless the Associate Administrator, upon written request, grants



a stay. The terms and conditions of this Final Order are effective upon receipt.
NOV 15 2005
Date Issued
Brawl
y A late Administrator
for Pipeline Safety

Final Order Hunt Refining Company CPF No 2-2005-5002.pdf

U.S. Department
of Transportation
Pipeline and
Hazardous Materials Safety
Administration
400 Seventh Street, S.W.
Washington, D.C. 20590
NOV 1 5 3105
Mr. David Carroll
Vice President and General Counsel
Hunt Refining Company
100 Town Center Blvd., Suite 300
Tuscaloosa, AL 35406-1 829
RE: CPF NO. 2-2005-5002
Dear Mr. Carroll:
Enclosed is the Final Order issued by the Associate Administrator for Pipeline Safety in
the above-referenced case. It makes a finding of violation and assesses a civil penalty of $5,000.
The penalty payment terms are set forth in the Final Order. This enforcement action closes
automatically upon payment. Your receipt of the Final Order constitutes service of that document
under 49 C.F.R. 9 190.5.
Sincerely,
James Reynolds
Pipeline Compliance Registry
Office of Pipeline Safety
Enclosure
cc: Ms. Linda Daugherty, Director, OPS Southern Region
CERTIFIED MAIL - RETURN RECEIPT REOUESTED



DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
In the Matter of 1
Hunt Refining Company, 1
1 CPF NO. 2-2005-5002
Respondent.
FINAL ORDER
On December 28,2004, pursuant to 49 U.S.C. 8 601 17, a representative of the Southern Region,
Office of Pipeline Safety (OPS) initiated an investigation of Respondent's report of an incident
involving its 6-inch petroleum pipeline in Tuscaloosa, Alabama. As a result of the investigation, the
Director, Southern Region, OPS, issued to Respondent, by letter dated March 2 1,2005, a Notice of
Probable Violation and Proposed Civil Penalty (Notice). In accordance with 49 C.F.R. § 190.207,
the Notice proposed finding that Respondent violated 49 C.F.R. 5 195.52 and proposed assessing
a civil penalty of $5,000 for the alleged violation.
In a letter dated March 29, 2005, Respondent submitted a Response to the Notice(Response).
Respondent contested the allegation of violation, offered information to explain the allegation,
requested that the proposed civil penalty be eliminated, and requested a hearing. A hearing was held
via telephone conference on May 4,2005.
FINDINGS OF VIOLATION
The Notice alleged that Respondent violated 49 C.F.R. $195.52 by not giving telephonic notification
to the National Response Center (NRC), at the earliest practicable moment, following discovery of
the incident that occurred on December 27,2004. The incident involved a release of 300 barrels of
No.2-D fuel on Respondent's 6-inch petroleum pipeline three miles southwest of the Hunt Oil
Refinery in Tuscaloosa, Alabama. In response to a phone call from an adjacent property owner,
Respondent arrived at the incident site at approximately 3:15 p.m on December 27, 2004 CST.
According to the NRC and the Alabama Public Service Commission pipeline safety office,
Respondent did not give the NRC telephonic notification of the incident until 10:20 a.m. EST on
December 28, 2005, approximately 18 hours after discovery of the incident.
In response, Respondent conceded that it received notice from an adjacent property owner of a leak
in the area of its 6-inch product pipeline on December 27,2004, at approximately 2:30 p.m. CST and
arrived at approximately 3:35 p.m. Respondent advised that upon arrival it observed bubbles



coming from water which covered the area of the pipeline right-of-way. Due to recent rains, there
was a great deal of water covering the area and it was not possible to tell the extent of the release.
Respondent immediately shutdown the pipeline and began an evaluation of a wooded area.
Respondent explained that it also recognized that there was standing water and that any additional
rainfall might cause any product to migrate. Respondent further advised that it took a sample from
the nearest stream to confirm that no product had reached the stream. Respondent placed a boom
at the stream, approximately '/4 mile away, because of the standing rainwater. Respondent then
mobilized its vacuum truck to suction up the visible liquid, which appeared to be rainwater. This
was done just before the sun set at 4:5 1 p.m. on December 27,2004.
Respondent determined, based upon its initial evaluation, that it was not a reportable incident under
49 C.F.R. $195.52 because there was no death or personal injury requiring hospitalization; there was
no fire or explosion; it did not appear that the property damage including clean up cost would meet
$50,000; there was no pollution of any stream and it did not appear significant.
Respondent argued that notification was made as soon as practicable, at 9:20 a.m. on December 28,
2004, when it made a determination that the incident was reportable under 49 C.F.R. $ 195.52(a)(3).
Respondent contented it was not until morning that it became apparent that the spill area was larger
than originally observed and that it provided timely notification. Concern was expressed by
Respondent as to whether the incident was the result of third party excavator damage. The cause of
the concern was the liquid located in the area on the side of an excavation company and pine tree
nursery. Respondent also expressed concern about the impact of reporting the incident on December
27,2004, which could have been premature because of incomplete information.
OPS opined that the nature of 49 C.F.R. 4195.52 is two-fold, early warning and investigatory.
Telephone notification to the NRC is an early warning for OPS, its State partner, and the National
Transportation Safety Board (NTSB) to decide whether or not the federal government needs to
investigate the incident for compliance and safety factors. OPS argued that notification must be
made as soon as practicable so that an evaluation can be made to determined whether continued
operation of the pipeline will endanger or further endanger the public, property or the environment.
OPS posed that it is important that OPS arrive at the site when the evidence is still present at the site,
the evidence is fresh and before the evidence is disturbed. OPS further argued that advisory bulletins
have been issued to owners and operators of gas distribution, gas transmission, and hazardous liquid
pipelines systems, and liquified natural gas facilities to ensure that telephonic reports of incidents
to the NRC are prompt and at the earliest practicable moment following discovery. The bulletins
also clarify the term incident, earliest practicable moment and discuss telephonic reports made when
early information is incomplete. OPS also advised that Respondent is permitted to contact the NRC
later to withdraw a report.
Pre-eaf~rcement effmtc such as advisory bulletins, agency interpretations and 49 C.F.R. fj 190.1 1
provide notice and enable Respondent to identify with certainty the standards with which OPS
expects operators to comply. 49 C.F.R. 5190.1 1 provides for informal guidance and interpretive
assistance about compliance with pipeline safety regulations, 49 C.F.R. Parts 190-199.



If Respondent needs clarification, information on, and advice about compliance with pipeline safety
regulations, then Respondent should take advantage of 49 C.F.R. § 190.1 1 to resolve ambiguities.
In furtherance, the issuance of advisory bulletins of "Required Notification of National Response
Center" basically addresses Respondent's concerns.' The advisory bulletin recognizes that
telephonic reports are often made when the information on an incident is incomplete. The bulletin
also makes it clear that OPS expects an operator to provide update information during the emergency
response phase, as new information changes the understanding of the nature, cause, and severity of
the incident. OPS understands that some hazardous liquid operators do not provide an estimated
release amount when reporting an incident to the NRC. While the estimated spill size should be
initially reported, OPS also recognizes that there may be difficulty in estimating spill amounts,
especially if the release is underground or into water. An operator that provides update information
to the NRC should tell the NRC representative if a previous report was filed for the incident and
provide the NRC Report Number of the original telephonic.
Respondent's reservations or concerns about the reporting requirements do not negate the fact that
a violation occurred. During its initial arrival at approximately 3:35 p.m., Respondent could have
taken advantage of 49 C.F.R. §190.11 for informal guidance and interpretive assistance about
compliance with pipeline safetyregulations. PHMSA, OPS, has established awebsite on the Internet
and a telephone line at OPS headquarters where operators can obtain information on and advice
about compliance. The website and phone line (202-366-0918) are staffed by OPS personnel from
9:00 a.m. through 5:00 p.m., Eastern time, Monday through Friday, except Federal holidays. Even
if Respondent was concerned about prematurelyreporting the incident or an inaccurate spill estimate,
Respondent could have made the telephonic report and filed an additional report during the
emergency response phase if the circumstances andlor estimates changed. Respondent could have
called the NRC to provide updated information to document the latest information. Respondent has
not shown any circumstance that justifies the failure to report to the NRC in a timely manner.
Accordingly, I find Respondent violated 49 C.F.R. 5 195.52 by failing to give telephonic notification
to the National Response Center, at the earliest practicable moment, following discovery of an
incident.
This finding of violation will be considered a prior offense in any subsequent enforcement action
taken against Respondent.
ASSESSMENT OF PENALTY
Under 49 U.S.C. 60122, Respondent is subject to a civil penalty not to exceed $100,000 per
violation for each day of the violation up to a maximum of $1,000,000 for any related series of
violations. The Notice proposed a $5,000 civil penalty for violation of 49 C.F.R. 9 195 S2.



49 U.S.C. $ 60122 and 49 C.F.R. $ 190.225 require that, in determining the amount of the civil
penalty, I consider the following criteria: nature, circumstances, and gravity of the violation, degree
of Respondent's culpability, history of Respondent's prior offenses, Respondent's ability to pay the
penalty, good faith by Respondent in attempting to achieve compliance, the effect on Respondent's
ability to continue in business, and such other matters as justice may require.
The Notice proposed a civil penalty of $5,000, as Respondent failed to give telephonic notification
to the National Response Center (NRC), at the earliest practicable moment, following discovery of
an incident on December 27, 2004. In response to the Notice and in support of its position,
Respondent argued its initial evaluation suggested that it was not a reportable incident under 49
C.F.R. 9195.52. However, Respondent conceded that the property damage including clean up cost
would meet $50,000. On April 15, 1991 and September 6, 2002, Notices were issued by the
Department of Transportation, OPS, reiterating that telephonic notification should be made within
one to two hours after discovery. OPS's ability to take corrective action andlor mitigate potential
safety problems is severely hampered by untimely telephonic notification of an incident. Respondent
has not shown any circumstance that would have prevented or justified it not taking prompt action
to give telephonic notification to the NRC. Accordingly, having reviewed the record and considered
the assessment criteria, I assess Respondent a civil penalty of $5,000, for violation of 49 C.F.R.
5195.52.
Payment of the civil penalty must be made within 20 days of service. Payment may be made by
sending a certified check or money order (containing the CPF Number for this case) payable to
"U.S. Department of Transportation" to the Federal Aviation Administration, Mike Monroney
Aeronautical Center, Financial Operations Division (AMZ-120), P.O. Box 25770, Oklahoma City,
OK 73125.
Federal regulations (49 C.F.R. $ 89.21(b)(3)) also permit this payment to be made by wire transfer,
through the Federal Reserve Communications System (Fedwire), to the account ofthe U.S. Treasury.
Detailed instructions are contained in the enclosure. Questions concerning wire transfers should be
directed to: Financial Operations Division (AMZ-120), Federal Aviation Administration, Mike
Monroney Aeronautical Center, P.O. Box 25082, Oklahoma City, OK 73125; (405) 954-4719.
Failure to pay the $5,000 civil penalty will result in accrual of interest at the current annual rate in
accordance with 3 1 U.S.C. $ 3717,3 1 C.F.R. 9 901.9 and49 C.F.R. 9 89.23. Pursuant to those same
authorities, a late penalty charge of six percent (6%) per annum will be charged if payment is not
made within 1 10 days of service. Furthermore, failure to pay the civil penalty may result in referral
of the matter to the Attorney General for appropriate action in an United States District Court.
Under 49 C.F.R. $ 190.215, Respondent has a right to petition for reconsideration of this Final
Order. The petition must be received within 20 days of Respondent's receipt of this Final Order and
must contain a brief statement of the issue(s). The filing of a petition automatically stays the
payment of any civil penalty assessed. All other terms of the order, including any required corrective
action, shall remain in full effect unless the Associate Administrator, upon written request, grants



a stay. The terms and conditions of this Final Order are effective upon receipt.
NOV 1 5
Date Issued
' for Pipeline Safety
- **truncated:** false
- **body characters:** 28297