{"operation":"document","citation":"CPF 320035015","title":"FARMLAND INDUSTRIES INC — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2003-05-27","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.402(a), 195.402(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320035015.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320035015.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320035015","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320035015","body":"Notice of Probable Violation involving FARMLAND INDUSTRIES INC. PHMSA's enforcement data identifies the cited regulations as 195.402(a), 195.402(c). The case was opened on 2003-05-27 and is reported as closed as of 2005-11-29. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320035015_Amended Final Order_11292005.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320035015/320035015_Amended%20Final%20Order_11292005.pdf\n\n320035015_Final Order_03042005.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320035015/320035015_Final%20Order_03042005.pdf\n\ncpf_320035015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320035015/cpf_320035015.pdf\n\nLLC Amendment to the Final Order CPF No 3-2003-5015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320035015/LLC%20Amendment%20to%20the%20Final%20Order%20CPF%20No%203-2003-5015.pdf\n\n320035015_Final Order_03042005.pdf\n\n)\n?}\nU.S.Deportment\nof Tronsportotion\nReseorch qnd\nSpeciolPrcgroms\nAdministrotion\n400 $eventh\nS r . S W\nWashington.\nD C 20590\nI\nMAR - 4 2AA5\nMr. Keith D. Osbom\nExecutive Vice President and Refinery General Manager\nCo ffeyville Resourc es Crude Transportation, LLC\nNorth and Linden Streets\nCoffeyville,Ks 67337\nRe: CPF No. -q-2003-5015\nDear Mr. Osborn:\nEnclosed is the Final Order issued bv the Associate Administrator for above-referenced case. It makes findings of violation and specifies actions to\nwith the pipeline safety regulations. When the terms of the Compliance Order determined bythe Director, Central Region, this enforcement action will be c this Final Order constitutes service of that document under 49 C.F.R. $ 190.5.\nSincerely,\n\\, t'n\n$w,o v L__\nJames Reynolds\nPipeline Compliance Registry\nOffice of Pipeline Safety\nline Safety in the\ntaken to comply\ncompleted, as\n. Your receipt of\nEnclosure\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\n\n\n\nDEPARTMENT OF TRANSPORTATION\nRESEARCH AND SPECIAL PROGRAMS ADMINISTRATI\nOFFICE OF PIPELINE SAFETY\nWASHINGTON. DC 20590\nIn the Matter of\nCoffeyville Resources\nCrude Transportation, LLC,\nRespondent.\nCPF No. 3-\n)\nFINAL ORDER\nOn March 3-6,2003,pursuant to 49 U.S.C. $ 60117, representatives ofthe Office o\n(OpS) conducted an on-site pipeline safety inspection in Bartlesville, Oklahoma\nand maintenance procedures for certain hazardous liquid pipeline facilities local\nCoffeyville and Wichita, Kansas then operated byFarmland Industries. As a result\nthe Director, Central Region, OPS, by letter dated May 27,2003, issued to Farn\nNotice of Probable Violation and Proposed Compliance Order (Notice). ln\n49 C.F.R. 5 Ig0.207 ,the Notice proposed finding that Farmland Industries had\nof 49 C.F.R. Part 195 by failing to adequately establish and follow written\nmaintenance, and emergencies. The Notice also proposed that Farmland\nmeasures to correct the alleged violations.\nBy letter dated lune 27 ,20A3 ,Farmland Industries initially responded to the Notir\nFarmland acknowledged inadequacies in the written procedures and proposed a\nrevising its procedurai manual to address the inadequacies. On November 19,\nthe revised procedural manual and reviewed it to determine whether all of the i\nthe Notice were addressed. By letter dated February 3,2004, the Director, Cen\ninformed Farmland's vice President of Petroleum Operations that after tevir\nmanual, the Director had determined that the revisions did not address all 0f the t\nin the Notice, and that some of these revisions had introduced additional inadeqt\n3, 2004, Coffeyville Resources Crude Transportation, LLC succeeded Farmland\noperator of the subject pipeline facilities (as used in this order, \"Respondent\" r(\nIndustries and/or coffeyvitte Resources crude Transportation, LLC)' By letter d\nzl} ,Respondent submitted further responsive materials including a binder cor\nrevised operations anti mainienailce nianiial. Respondent also prot\"ided a ti\nconducting the employee training associated with implementing the revised mar\ndid not request aheanng, and therefore has waived its right to one'\nPipeline Safety\nf the operations\nin the areas of\nthe inspection,\nitted violations\nfor operations,\ntake certain\nIn its response,\nschedule for\nOPS received\n,\nies cited in\nl Region, OPS,\ning the revised\nies. On March\nbrs to Farmland\nining a further\ne schedule for\nal. Respondent\n\n\n\n:\nFINDINGS OF VIOLATION\nIn its responses, Respondent did not contest the alleged violations in the Notice. Accordingly, I find\nthat Respondent violated the following sections of 49 C.F.R. Part 195, as more fully described in the\nNotice:\n49 C.F.R. § 195.402(a) - failing to adequately prepare and follow a manual of written\nprocedures for conducting normal operations and maintenance activities and handling\nabnormal operations and emergencies in accordance with the applicable requirements;\n49 C.F.R. § 195.402(c) - failing to include procedures for conducting pipeline maintenance\nand repairs in accordance with the applicable requirements.\nThese findings of violation will be considered prior offenses in any subsequent enforcement action\ntaken against Respondent.\nCOMPLIANCE ORDER\nThe Notice proposed a Compliance Order with respect to the above referenced violations of\n§§ 195.402(a) and 195.402(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 comply\nwith the applicable safety standards established under Chapter 601. Pursuant to the authority of\n49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following actions\nto ensure compliance with the pipeline safety regulations applicable to its operations. Within 30\ndays following receipt of this order, Respondent must:\nAmend the written procedures to include:\n(A) Procedures for mapping pipeline facilities located in areas where emergency response\ncould be required in the event of a release or other safety-related incident, and procedures for\nminimizing the likelihood of accidental ignition of vapors in these facilities, in accordance\nwith § 195.402(c)(4) and (c)(11);\n(B) Procedures for analyzing failures to determine their causes and to identify measures to\nprevent reoccurrences in accordance with § 195.402(c)(5) and (c)(6);\n©) Procedures for establishing and maintaining liaison with fire, police, and other public\nofficials in accordance with § 195.402(c)(12);\n(D) Procedures for the abandonment of pipeline facilities in accordance with\n§195.402(c)(10);\n(E) Procedures for addressing the hazardous accumulation of vapors in a trench in\naccordance with § 195.402(c)(14);\n\n\n\n2. 3.\n^\nL+.\n5.\n6.\n8. 9.\n10.\n11.\nt.L.\nAmend the written procedures to include procedures for the review of in the emergency response training program, procedures for identifying changes to the emergency response training program to ensure its e\nprocedures for ensuringthat supervisors maintain a thorough knowledge\nperformance\nimplementing\nbctiveness, and\nf the emergency\nresponse procedures forwhich they are responsible, in accordance with $ 1 .403(b) and (c);\nAmend the written procedures to include procedures for repairing pipeli\nwith $ 195.422;\naccordance\nAmend the written procedures to include procedures for moving or\naccordance with $ 195.424(a);\nlines in\nAmend the written procedures to include procedures for safely opening\nreceivers in accordance with 5 195.426;\nlaunchers and\nAmend the written procedures to include procedures for the placement of igns near pump\nstations and breakout tanks including guidance on the content of the signs i\naccordance with\n5 r95.434;\nAmend the written procedures to include procedures for providing securi\nunauthorized entry of pump station and breakout tank areas in accordanc\nand preventing\nwith $ 195.436;\nAmend the written procedures for the damage prevention program to inc notifying potential excavators of the existence of pipeline facilities aI\nresponding to notifications of intended excavation activity including det\nand how to conduct temporary marking, and procedures for insuring pipeline when the excavation involves blasting including leak testing aft\nconducted, in accordance with $ 195.a42(c);\nprocedures for\nprocedures for\nining whether\nintegrity of the\nthe blasting is\nAmend the written procedures to include procedures\nfor ensuring that ISOrS marntarn\na thorough knowledge of corrosion control measures\nin accordance with 195.555;\nAmend the written procedures to include procedures for ensuring that all\nreplaced pipe must be externally coated upon installation in accordance\n, relocated, or\nith $ 195.557;\nAmend the written procedures to include procedures for specifying the\nexternal coatings in accordance with $ 195'559;\nowable tlpes of\n^*^- a +1^^ \",*i++on ^rnnedrrres fo inclrrrle orocedures for specifying\nAIngIlU LIltr wrlt[s,rl PlvvvuurwD rv 'rrvrs*- r'\ninspections of coatings must be done and how any identified coating\nremediated in accordance with $ 195'561;\nhow frequently\nage is to be\n\n\n\n13. 14.\n15.\n16.\n17.\n18.\nt9.\n20,\n21.\n22,\n23\"\n24.\n25.\nAmend the written procedures to include procedures for ensuring that installed on new pipeline within one year, procedures for cathodicall\nunprotected pump station and breakout tank areapiping, and procedures\nburied pipe is cathodically protected, in accordance with $ 195.563;\nic protection is\nprotecting any\nensurins that all\nAmend the written procedures to include procedures for installing and mai\nprotection test leads in accordance with $ 195'567;\nning cathodic\nAmend the written procedures to include procedures for identifying the cri iato be utilized\nfor determining the adequacy of cathodic protection in accordance with $ t95.57r;\nAmend the written procedures to include procedures for determining\nrequire a clcse-inten\"al electrical sur-'re5', and procedt-res fbr ensuring that\nare inspected annually and any deficiencies identified are promptly co with $ 195.573(a),(c), and (e);\nAmend the written procedures to include procedures for electrjcal iso\ninspections in accordance with $ 195.575;\nAmend the written procedures to include procedures for ensuring that i\nare identified and alleviated in accordance with 5 I95.577;\nAmend the written procedures to include procedures for determining the transported products such as sour crude, and procedures for mitigating i\naceordance with $ 195.579(a) and (b);\nAmend the written procedures to include procedures for protecting ex pipeline system from atmospheric corrosion in accordance with $ 195'58\nAmend the written procedures to include procedures for monitoring\ncontrol in accordance with $ 195.583;\nAmend the written procedures to include procedures for correcting\naccordance with $ 195.585;\nAmend the written procedures to include the method for determintng remal\nof corroded pipe in accordance with $ 195.587;\nAmend the written procedures to include up-to-date procedures for\n^^.^+-^r -^^^-r^ i^ ^^nn-Aon^e rrrith A '! OS 5Rq'\nCUIIt-tUi rtruutLlJ llt ovwvruorrwv vv^Lrr J '2J'rv')\nAmend the written procedures to include procedures for ensuring that\nvalve, fitting, or other component is designed to accommodate the pat\ninspection tool in accordance with $ 195'120(a);\nhich areas mav\nin accordance\nand required\nerence currents\niveness of\nl corrosion in\nportions of the\ncorrosl0n\ningwall strength\naining corrosion\nnew line pipe,\ne of an internal\n\n\n\n26. 27.\n28.\n29.\n30.\n31.\nJ L .\na a\nJ J .\n34.\n35.\n36.\nJ t . 5\nwelding will be\nand that\nrdance with\nAmend the written procedures to include procedures for ensuring that all\nperformed by a qualified welder in accordance with qualified welding pr\niecords of all procedures and qualifying tests will be retained, in\n$19s.21a(a) and (b);\nAmend the written procedures to include procedures for ensuring t\nqualified under API 1104 or Section IX of the ASME Boiler and Press\naccordance with $ 195'222;\nAmend the written procedures to include procedures for ensuring the arc burns, and for ensuring that a ground is never welded to a pipe or fi welded. in accordance with 5195'226(b) and (c);\nAmend the written procedures to include procedures for'inspections of\nwith $ 195.228:\nAmend thewrittenprocedures to includeprocedures forthe removal or\nin accordance with $ 195.230;\nAmend the written procedures to include procedures for nondestructive\nwith $ 19s.Ba@);\nAmend the written procedures to include procedures for ensuring that the h\nrequirements for new or relocated pipeline facilities are met in accordance v\nAmend the written procedures to include procedures for ensuring that the\nrequirements for all fittings are met in accordance with $ 195.305;\nAmend the written procedures to include procedures for determining the\nused during pressure testing in accordance with $ 195'306;\nAmend the written proc edures to inc lude proc edures for ensuring that all pi\ntie-ins is pressure tested in accordance with $ 195'308;\nwithin 30 days following receipt of this order, submit a copy of the amen\nthe Director, central Region, oPs, 901 Locust Street, Suite 462, Kansas\n2641.\n!!r:1!-:- .-t^. A--,- r.^.!t^.'.:rinc rcneinf nf t\\ig crder, complete all necessary I\nwlmln L lv uidys lutruwruB rwwwrP! vr Lrr\non the revised operations and maintenance procedures- Retain recor(\nincluding the names of the people trained and the dates the training occu\nall welders are\nVessel Code in\nete removal of\nthat is being\ns in accordance\nr ofweld defects\ng ln accorclance\natic testing\nith $ 19s.302(a);\ntatic testing\nmedium to be\nassociatedwith\nprocedures to\nity, MO 64106-\nnnel training\nof the training\n\n\n\nThe Regional Director may extend the period for complying with any of the\nRespondent requests an extension and adequately justifies the reasons for the ex\nFailure to comply with this Final\n$100,000 per violation per day, or\nOrder may result in the assessment of civil alties of up to\nin the referral of the case for judicial enfo\nUnder 49 C.F.R. $ 190.215, Respondent has a right to submit a petition for Final Order. Should Responiient eiect to do so, the petition must be received ithin 20 davs of\nRespondent's receipt ofthis Final Order and must contain abrief statement of the i of the order, including any required corrective action, remain in full effect un Administrator, upon written request, grants a stay. The terms and conditions of thr\non of this\ns). The terms\nthe Associate\nFinal Order are\neffective on receipt.\nftn?r-aa\nStacey Gerard\nAssociate Administrator\nfor Pipeline Safety\n- 4 2005\nIssued\n\nLLC Amendment to the Final Order CPF No 3-2003-5015.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration #DV 2 9 a005\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nMr. Keith D. Osborn\nExecutive Vice President and Refinery General Manager\nCoffeyville Resources Crude Transportation, LLC\nP.O. Box 570\nCoffeyville, KS 67337\nRe: CPF No. 3-2003-501 5\nDear Mr. Osborn:\nEnclosed is an Amendment to the Final Order issued by the Associate Administrator\nfor Pipeline Safety in the above-referenced case. It removes any reference to Coffeyville\nResources Crude Transportation, LLC (CRCT) as a Respondent on the grounds that all actions\nrequired by the Order to comply with the pipeline safety regulations have been completed\nrendering the Final Order moot as to CRCT. The case is now closed. The decision on the\npetition for reconsideration you filed in connection with this case is being issued\nsimultaneously with this Amendment to the Final Order. Your receipt of this Amendment to\nthe Final Order constitutes service of that document under 49 C.F.R. $ 190.5.\nSincerely,\nJames Reynolds\nPipeline Compliance Registry\nOffice of Pipeline Safety\nEnclosure\ncc: Melissa Anne Heme, Esq.\nDLA Piper Rudnick Gray Cary US LLP\nThe Marbury Building\n6225 Smith Avenue\nBaltimore, MD 2 1209-3600\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\n\n\n\nDEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\nIn the Matter of 1\nFarmland Industries, 1\n1\n1\nRespondent. 1\nCPF NO. 3-2003-5015\nAMENDMENT TO THE FINAL ORDER\nBased on information demonstrating that all actions required by this Order to comply with the\npipeline safety regulations have been completed, I find that the Order is moot as to Coffeyville\nResources Crude Transportation, LLC (CRCT) and remove any reference to CRCT as a\nRespondent.' Accordingly, pursuant to 49 U.S.C. 601 12, I hereby amend the above caption and\namend body of this Final Order to read as follows:\nOn March 3-6,2003, pursuant to 49 U.S.C. $601 17, representatives of the Office of Pipeline\nSafety (OPS) conducted an on-site pipeline safety inspection in Bartlesville, Oklahoma of the\noperations and maintenance procedures for certain hazardous liquid pipeline facilities located in\nthe areas of Coffeyville and Wichita, Kansas then operated by Farmland Industries (Respondent).\nAs a result of the inspection, the Director, Central Region, OPS, by letter dated May 27,2003,\nissued to Farmland Industries a Notice of Probable Violation and Proposed Compliance Order\n(Notice). In accordance with 49 C.F.R. 5 190.207, the Notice proposed finding that Farmland\nIndustries had committed violations of 49 C.F.R. Part 195 by failing to adequately establish and\nfollow written procedures for operations, maintenance, and emergencies. The Notice also\nproposed that Farmland Industries take certain measures to correct the alleged violations.\nBy letter dated June 27,2003, Farmland Industries initially responded to the Notice. In its\nresponse, Farmland acknowledged inadequacies in the written procedures and proposed a time\nschedule for revising its procedural manual to address the inadequacies. On November 19,2003,\nOPS received the revised procedural manual and reviewed it to determine whether all of the\ninadequacies cited in the Notice were addressed. By letter dated February 3,2004, the Director,\nCentral Region, OPS, informed Farmland's Vice President of Petroleum Operations that after\nreviewing the revised manual, the Director had determined that the revisions did not address all\nIn a separate document, a decision on the petition for reconsideration filed by CRCT in connection with\nthis case was issued simultaneously with this Amendment to the Final Order.\n\n\n\nof the inadequacies cited in the Notice, and that some of these revisions had introduced\nadditional inadequacies. Respondent did not request a hearing, and therefore waived its right to\none.\nOn March 3,2004, CRCT succeeded Farmland Industries as the operator of the subject pipeline\nfacilities. By letter dated October 28,2004, further responsive materials were submitted\nincluding a binder containing a further revised operations and maintenance manual and a time\nschedule for conducting the employee training associated with implementing the revised manual.\nFINDINGS OF VIOLATION\nIn its responses, Respondent did not contest the alleged violations in the Notice. Accordingly, I\nfind that Respondent violated the following sections of 49 C.F.R. Part 195, as more fully\ndescribed in the Notice:\n49 C.F.R. 5 195.402(a) - failing to adequately prepare and follow a manual of written\nprocedures for conducting normal operations and maintenance activities and handling\nabnormal operations and emergencies in accordance with the applicable requirements;\n49 C.F.R. 5 195.402(c) - failing to include procedures for conducting pipeline\nmaintenance and repairs in accordance with the applicable requirements.\nThese findings of violation will be considered prior offenses in any subsequent enforcement\naction taken against Respondent.\nCOMPLIANCE ORDER\nThe Notice proposed a Compliance Order with respect to the above referenced violations of $ 5\n195.402(a) and 195.402(c). Under 49 U.S.C. 5 601 18(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. The Regional\nDirector has indicated that Respondent has completed all of the actions specified in the proposed\nCompliance Order. Accordingly, since compliance has been achieved with respect to these\nviolations, it is unnecessary to require Respondent to take further actions in this Order. The terms\nand conditions of this Final Order, as amended, are effective on receipt. This case is closed.\nA\n)oV 2 9 2905\nDate Issued:\n\n320035015_Amended Final Order_11292005.pdf\n\no\nU.S. Deportment\nof Tronsportotion\nPlpellne ond\nHozordous mqtedqts Sofety\nlomlnisrotlon ml|2sffi\nMr. Keith D. Osborn\nExecutive Vice President and Refinery General Manager\nCoffeyville Resources Crude Transportation, LLC\nP.O. Box 570\nCoffeyville,KS 67337\nRe: CPF No. 3-2003-5015\nDear Mr. Osborn:\nEnclosed is an Amendment to the Final Order issued by the Associate\nfor Pipeline Safety in the above-referenced case. It removes any reference to\ninistrator\nille\nResources Crude Transportation, LLC (CRCT) as a Respondent on the grounds all actions\nrequired by the Order to comply with the pipeline safety regulations have been\nrendering the Final Order moot as to CRCT. The case is now closed. The deci on on the\npetition for reconsideration you filed in connection with this case is being i\nsimultaneously with this Amendment to the Final Order. Your receipt of this\nthe Final Order constitutes service of that document under 49 C.F.R. $ 190.5.\nSincerely,\n+* {l--\nJames Reynolds\nPipeline Compliance Registry\nOffice of Pipeline Safety\nEnclosure\nMelissa Anne Hearne, Esq.\nDLA Piper Rudnick Gray Cary US LLP\nThe Marbury Building\n6225 Smith Avenue\nBaltimore, MD 21209-3600\nCERTIFIED MAIL - RETURN RECEIPT REOUESTED\n\n\n\nDEPARTMENT OX' TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINI\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\nIn the Matter of\nFarmland fndustries,\nRespondent.\nCPF No.3-2003-501\nAMENDMENT TO THE FINAL ORDER\nBased on information demonstrating that all actions required by this Order to\npipeline safety regulations have been completed, I find that the Order is moot as\nResources Crude Transportation, LLC (CRCT) and remove any reference to CR\nRespondent.r Accordingly, pursuant to 49 U.S.C. 60112,I hereby amend the\namend body of this Final Order to read as follows:\nOn March 3-6,2003, pursuant to 49 U.S.C. $ 60117, representatives of the Office\nSafety (OPS) conducted an on-site pipeline safety inspection in Bartlesville,\noperations and maintenance procedures for certain hazardous liquid pipeline\nthe areas of Coffeyville and Wichita, Kansas then operated by Farmland\nAs a result of the inspection, the Director, Central Region, OPS, by letter dated\nissued to Farmland Industries a Notice of Probable Violation and Proposed Compl\n(Notice). In accordance with 49 C.F.R. S 190.207, the Notice proposed finding\nIndustries had committed violations of 49 C.F.R. Part 195 by failing to adequately\nfollow written procedures for operations, maintenance, and emergencies. The Not\nproposed that Farmland Industries take certain measures to correct the alleged vi\nBy letter dated lune 27\n2003\n,\n,\nFarmland Industries initially responded to the No\nresponse, Farmland acknowledged inadequacies in the written procedures and\nschedule for revising its procedural manual to address the inadequacies. On\nOPS received the revised procedural manual and reviewed it to determine whether\ninadequacies cited in the Notice were addressed. By letter dated February 3,2004,\nCentral Region, OPS, informed Farmland's Viee Presidcnt of Petroleum\nreviewing the revised manual, the Director had determined that the revisions did\n(Respondent).\n27,2003,\na time\n19,2003,\n1 In a separate document, a decision on the petition for reconsideration filed by CRCT in\nthis case was issued simultaneously with this Amendment to the Final Order.\n\n\n\nI\nI\nof the inadequacies cited\nin the Notice, and that some of these revisions had i\nadditional inadequacies.\nRespondent did not request a hearing, and therefore wai\none.\nOn March 3,2004, CRCT succeeded Farmland Industries as the operator of the\nfacilities. By letter dated October 28,2004, further responsive materials were\nincluding a binder containing a further revised operations and maintenance\nschedule for conducting the employee training associated with implementing the\nFINDINGS OF VIOLATION\nIn its responses, Respondent did not contest the alleged violations\nin the Notice.\nfin