{"operation":"document","citation":"CPF 320055015","title":"PHILLIPS 66 PIPELINE LLC — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2005-03-14","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.402(a), 195.428, 195.440, 195.442(c)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320055015.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320055015.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320055015","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320055015","body":"Notice of Probable Violation involving PHILLIPS 66 PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.428,  195.440,  195.442(c)(2). The case was opened on 2005-03-14 and is reported as closed as of 2010-10-28. Proposed civil penalty: $184,500. Assessed civil penalty: $39,000. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320055015_Final Order _09132010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320055015/320055015_Final%20Order%20_09132010.pdf\n\n320055015_Final Order _09132010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320055015/320055015_Final%20Order%20_09132010_text.pdf\n\nDecision on Petition for Reconsideration LLC CPF No 3-2005-5015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320055015/Decision%20on%20Petition%20for%20Reconsideration%20LLC%20CPF%20No%203-2005-5015.pdf\n\n320055015_Final Order _09132010_text.pdf\n\nSEP 13 2010\nMr. Brian S. Coffman\nPresident\nConocoPhillips Pipe Line Company\n600 North Dairy Ashford\nHouston, TX 77079\nRe: CPF No. 3-2005-5015\nDear Mr. Coffman:\nEnclosed please find the Final Order issued in the above-referenced case. It makes findings of\nviolation and assesses a civil penalty of $39,000. The penalty payment terms are set forth in the\nFinal Order. When the civil penalty has been paid this enforcement action will be closed.\nService of the Final Order by certified mail is deemed effective upon the date of mailing, or as\notherwise provided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: David Barrett, Director, Central Region, PHMSA\nVan P. Williams, Esq., Senior Counsel, ConocoPhillips\nCERTIFIED MAIL – RETURN RECEIPT REQUESTED [7009 1410 0000 2472 2742]\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 )\nConocoPhillips Pipe Line Company, ) CPF No. 3-2005-5015\n)\n)\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nOn March 22-26, April 1-2 and 5-9, June 7-11, September 20-24, and October 6, 2004, pursuant\nto 49 U.S.C. § 60117, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety (OPS), conducted an on-site pipeline safety\ninspection of the facilities and records of ConocoPhillips Pipe Line Company (CPPL or\nRespondent) in Wichita, Kansas, Jefferson City, Missouri, Decatur, Illinois, East Chicago,\nIndiana, Cheyenne, Wyoming and Sidney, Nebraska. CPPL operates several hazardous liquid\npipeline facilities at and in between these locations. Nationwide, CPPL operates over 11,000\nmiles of pipelines and related pipeline facilities.\nAs a result of the inspection, the Director, Central Region, OPS (Director), issued to Respondent,\nby letter dated March 14, 2005, a Notice of Probable Violation and Proposed Civil Penalty\n(Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that CPPL had\nviolated 49 C.F.R. §§ 195.402 and 195.428(a) and proposed assessing a civil penalty of $184,500\nfor the alleged violations. The Notice also proposed finding that Respondent had committed\ncertain other probable violations of 49 C.F.R. Part 195 and warning CPPL to take appropriate\ncorrective action or be subject to future enforcement action.\nRespondent responded to the Notice by letter dated April 18, 2005 (Response). CPPL contested\none of the allegations and requested a hearing. A hearing was held on September 24, 2007 in\nKansas City, Missouri, with an attorney from the Office of Chief Counsel, PHMSA, presiding.\nAt the hearing, Respondent was represented by counsel. After the hearing, Respondent provided\na post-hearing statement and additional documents for the record, by letter dated\nNovember 28, 2007 (Closing).\nFINDINGS OF VIOLATION\nThe Notice alleged that Respondent violated 49 C.F.R. Part 195, as follows:\n\n\n\n3\nItem 1b: 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\nand maintenance activities and handling abnormal operations and\nemergencies. This manual shall be reviewed at intervals not exceeding 15\nmonths, but at least once each calendar year, and appropriate changes\nmade as necessary to insure that the manual is effective. This manual\nshall be prepared before initial operations of a pipeline system commence,\nand appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\nItem 1b of the Notice alleged that CPPL violated 49 C.F.R. § 195.402(a) by failing to follow its\nmanual of written procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies (O&M Manual). Specifically, it alleged that\nCPPL failed to properly adjust the set point for a high pressure shutdown switch on its Blue Line.\nRespondent’s O&M Manual specified that the switch was to be set at 1085 pounds per square\ninch gauge (psig), but CPPL documents collected during the OPS field inspection indicated that\nthe switch was set to 1210 psig. Respondent did not contest this allegation. Accordingly, based\nupon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.402(a) by\nfailing to follow its manual of written procedures for conducting normal operations and\nmaintenance activities and handling abnormal operations and emergencies.\nItem 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.428(a), which states:\n§ 195.428 Overpressure safety devices and overfill protection systems.\n(a) Except as provided in paragraph (b) of this section, each operator\nshall, at intervals not exceeding 15 months, but at least once each calendar\nyear, or in the case of pipelines used to carry highly volatile liquids, at\nintervals not to exceed 7 ½ months, but at least twice each calendar year,\ninspect and test each pressure limiting device, relief valve, pressure\nregulator, or other item of pressure control equipment to determine that it\nis functioning properly, is in good mechanical condition, and is adequate\nfrom the standpoint of capacity and reliability of operation for the service\nin which it is used.\nThe Notice alleged that CPPL violated 49 C.F.R. § 195.428(a) by failing to test relief valves on\ncertain highly volatile liquids (HVL) pipelines at intervals not to exceed 7 ½ months.\nSpecifically, it alleged that Respondent failed to test 387 thermal relief valves during certain\n2003 and 2004 valve inspections. The Notice also alleged that Respondent failed to test an\nadditional 49 thermal relief valves during 2004 inspections. Thermal relief valves are intended\nto prevent overpressure of the pipeline due to increases in ambient temperature. CPPL visually\ninspected these valves but did not actually test them.\n\n\n\n4\nCPPL contested this allegation on numerous grounds. First, Respondent argued that OPS had\n“approved” the company’s procedures that provided for visual inspection of relief valves, rather\nthan physical testing, by not raising the issue during a 1999 inspection.1 I find this argument\nunpersuasive. OPS inspections often cover dozens of regulations, safety issues and operator\nprocedures. There is no requirement that OPS allege every possible violation or raise every\npossible issue after an inspection. Nor does the review of procedures during an inspection\nconstitute an approval of procedures by OPS. OPS has the enforcement discretion to allege the\nviolations it determines appropriate under the circumstances of each case. Moreover, OPS did,\nin fact, notify CPPL that the agency considered its practice of not physically testing the relief\nvalves to be a probable violation of the regulation. On July 1, 2003, approximately 9 months\nbefore the OPS inspection in this case, OPS issued a warning letter to CPPL warning the\ncompany that its practice of not testing the relief valves during inspections was a probable\nviolation of § 195.428. 2\nNext, CPPL argued that no violations are warranted for its failure to perform tests of the relief\nvalves in 2003. Respondent argued that because the 2003 OPS warning letter did not contain a\ncompliance order, the company had time to amend its procedures and the agency’s ability to\nlater allege violations for CPPL’s conduct in 2003 was foreclosed.\n3\nI find Respondent’s\nargument unpersuasive. Immediately upon receipt of the 2003 warning letter, CPPL was on\nnotice that OPS considered its practice of visual inspection of relief valves to be a violation of\n§ 195.428. CPPL should have promptly begun testing valves, yet it failed to do so until March\n2004, approximately 9 months after the OPS warning.\nCPPL also contested the number of valves that OPS alleged were not tested. In its Violation\nReport, OPS included a summary of valves allegedly not tested. In the Violation Report, OPS\nalso included a document entitled “Thermals Not Pop Tested According to 195.428,” which\nlisted the valves CPPL had not tested. However, the Violation Report included only a sample of\nCPPL’s actual valve inspection records, and only those for a portion of the 2003-2004 time\nperiod at issue. For the 2003 time period, CPPL admitted that it did not test its thermal relief\nwere on HVL pipelines. Therefore, I find that 196 thermal relief valves were not tested in 2003.\nvalves on its HVL lines.4 CPPL stated that it has 384 relief valves, approximately 51% of which\nRegarding the 2004 time period, OPS’s Violation Report contains very few records of 2004\nvalve tests. In its Closing, CPPL provided numerous records of 2004 tests. While some of these\nrecords show that tests were performed in 2004, others are inconclusive. Respondent provided\ncomputer generated records of certain valve inspections but they do not show that tests were\n1 Response at 2; Closing at 1-4. Respondent argued that OPS had “approved” the thermal pressure device\ninstallation and maintenance procedures of Heritage Phillips, CPPL’s predecessor, during a 1999 audit.\n2 In the Matter of ConocoPhillips Pipe Line Company, Notice of Probable Violation, CPF No. 3-2003-5017 (Jul. 1,\n2003). Though titled a Notice of Probable Violation, this matter consisted only of warning items. OPS prepared the\nletter after April and May, 2003 inspections of CPPL facilities and records.\n3 Closing at 5.\n4 Id.\n\n\n\n5\nperformed.5 Given the limited evidence in the Violation Report and the inconclusive nature of\ncertain 2004 records provided by CPPL, there is insufficient evidence on which to make a\nfinding of violation for the majority of the 2004 valve inspections. The record only supports a\nfinding that CPPL failed to test 22 thermal relief valves in 2004.6\nIn summary, I find that CPPL violated 49 C.F.R. § 195.428(a) by failing to test relief valves on\ncertain HVL pipelines at intervals not to exceed 7 ½ months. Specifically, I find that CPPL\nfailed to test 196 thermal relief valves in 2003 and 22 thermal relief valves in 2004.\nASSESSMENT OF PENALTY\nUnder 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed\n$100,000 per violation for each day of the violation, up to a maximum of $1,000,000 for any\nrelated series of violations. 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 $184,500 for the violations cited above.\nItem 1(b): The Notice proposed a civil penalty of $3,000 for Respondent’s violation of 49\nC.F.R. § 195.402(a), for failing to follow its manual of written procedures for normal operations\nand maintenance activities. CPPL neither contested the allegation nor presented any evidence or\nargument justifying a reduction or elimination of the proposed penalty. CPPL’s failure to adjust\nthe set point for a high pressure shutdown switch in accordance with the pressure limit in its\nO&M Manual reduced the margin of safety provided by the regulation. When properly\ncalibrated, shutdown switches can protect pipeline integrity by preventing pipeline failures and\nruptures. The modest penalty proposed for this item is consistent with the relatively low gravity\nof the violation. Accordingly, having reviewed the record and considered the assessment\ncriteria, I assess Respondent a civil penalty of $3,000 for violation of 49 C.F.R. § 195.402(a).\nItem 2: The Notice proposed a civil penalty of $181,500 for Respondent’s violations of 49\nC.F.R. § 195.428(a) by failing to test numerous thermal relief valves on certain HVL pipelines at\nintervals not to exceed 7 ½ months. At the hearing, OPS explained that the proposed penalty had\nbeen arrived at by assigning a monetary value for each missed thermal relief valve. The Notice\nproposed finding that Respondent failed to test 387 valves in 2003 and 2004 and an additional 49\nvalves in 2004. Having found that CPPL failed to test 196 thermal relief valves in 2003 and 22\nof these valves again in 2004, I find that a reduced total civil penalty is appropriate.\n5 CPPL provided screen printouts from its electronic work order system, but these records do not list all thermal\nreliefs and lack information on whether or to what settings the tests were performed.\n6 Closing at 6.\n\n\n\n6\nRespondent is fully culpable for its failure to test the valves. At least as early as July 1, 2003,\nCPPL was on notice that PHMSA viewed its practice of not testing these valves as a probable\nviolation of § 195.428(a). Yet CPPL failed to begin actual testing of the valves until\napproximately 9 months later. Thermal relief valves are important to pipeline safety because,\nwhen in proper working order, they can prevent pipeline overpressure that could lead to ruptures\nand leaks. CPPL increased the potential consequences of a pipeline overpressure by failing to\ntest large numbers of such valves. The modest proposed penalties for this item are far below the\nmaximum per-violation penalty of $100,000 per violation per day. Accordingly, having\nreviewed the record and considered the assessment criteria, I assess Respondent a reduced civil\npenalty of $36,000 for violation of 49 C.F.R. § 195.428(a).\nIn summary, having reviewed the record and considered the assessment criteria for each of the\nItems cited above, I assess Respondent a reduced total civil penalty of $39,000.\nPayment of the civil penalty must be made within 20 days of service. Federal regulations\n(49 C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer through the Federal\nReserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed\ninstructions are contained in the enclosure. Questions concerning wire transfers should be\ndirected to: Financial Operations Division (AMZ-341), Federal Aviation Administration, Mike\nMonroney Aeronautical Center, P.O. Box 269039, Oklahoma City, Oklahoma 73125. The\nFinancial Operations Division telephone number is (405) 954-8893.\nFailure to pay the $39,000 civil penalty will result in accrual of interest at the current annual rate\nin accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to\nthose same authorities, a late penalty charge of six percent (6%) per annum will be charged if\npayment is not made within 110 days of service. Furthermore, failure to pay the civil penalty\nmay result in referral of the matter to the Attorney General for appropriate action in a district\ncourt of the United States.\nWARNING ITEMS\nWith respect to Items 1a, 3 and 4, the Notice alleged probable violations of 49 C.F.R.\n§§ 195.402(a), 195.440 and 195.442(c)(2), but did not propose a civil penalty or compliance\norder for these Items. Therefore, these are considered to be warning items. The warnings were\nfor:\n49 C.F.R. § 195.402(a) (Item 1a) - Respondent’s failure to conduct an annual review of\nits manual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies within the required 15-\nmonth interval;\n49 C.F.R. § 195.440 (Item 3) - Respondent’s alleged failure to establish a continuing\neducational program for landowners or tenants that do not live in the pipeline corridor;\nand\n49 C.F.R. § 195.442(c)(2) (Item 4) - Respondent’s alleged failure to provide notification\nto excavators as often as needed to make them aware of the company’s damage\nprevention program.\n\n\n\n7\nHaving considered such information, I find, pursuant to 49 C.F.R. § 190.205, that probable\nviolations of 49 C.F.R. §§ 195.402(a), 195.440 and 195.442(c)(2) have occurred and Respondent\nis hereby advised to correct such conditions. If OPS finds a violation for any of these items in a\nsubsequent inspection, Respondent may be subject to future enforcement action.\nUnder 49 C.F.R. § 190.215, Respondent has the right to submit a Petition for Reconsideration of\nthis Final Order. The petition must be sent to: Associate Administrator, Office of Pipeline\nSafety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC\n20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address. PHMSA\nwill accept petitions received no later than 20 days after receipt of service of the Final Order by\nthe Respondent, provided they contain a brief statement of the issue(s) and meet all other\nrequirements of 49 C.F.R. § 190.215. The filing of a petition automatically stays the payment of\nany civil penalty assessed but does not stay any other provisions of the Final Order, including\nany required corrective actions. If Respondent submits payment of the civil penalty, the Final\nOrder becomes the final administrative decision and the right to petition for reconsideration is\nwaived.\nThe terms and conditions of this Final Order are effective upon service in accordance with 49\nC.F.R. § 190.5.\n___________________________________ __________________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\nDecision on Petition for Reconsideration LLC CPF No 3-2005-5015.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration NOV 2 8 2005\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 the decision on the petition for reconsideration filed on your behalf by\nDLA Piper Rudnick Gray Cary in the above-referenced pipeline safety enforcement case. For\nthe reasons discussed therein, the Associate Administrator for Pipeline Safety has denied your\npetition. Based on certain information provided in the petition, however, the Associate\nAdministrator has decided to amend the March 4,2005 Final Order to remove any reference\nto Coffeyville Resources Crude Transportation, LLC (CRCT) as a Respondent on the grounds\nthat all actions required by the Order to comply with the pipeline safety regulations have been\ncompleted rendering the Order moot as to CRCT. Thus, the amendment to the Final Order\nprovides equivalent relief to that sought in your petition. A copy of the amended Order is\nenclosed. Your receipt of the decision constitutes service under 49 C.F.R. $ 190.5.\nSincerely,\nJames Reynolds\nPipeline Compliance Registry\nOffice of Pipeline Safety\nEnclosures\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 REOUESTED\n\n\n\nDEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, DC 20590\n)\nIn the Matter of )\n)\nCoffeyville Resources Crude ) CPF No. 3-2003-5015\nTransportation LLC, 1\n1\nPetitioner )\nDECISION ON PETITION FOR RECONSIDERATION\nBackground\nOn March 4, 2005, pursuant to 49 U.S.C.S. § 601 12 (2004), the Associate Administrator for\nPipeline Safety issued a Final Order in this case finding that the written procedures for\noperations, maintenance and emergencies for Petitioner's pipeline facility did not comply with\nthe applicable requirements in violation of 49 C.F.R. Part 195. The Final Order did not assess\nany monetary civil penalties for the violations, but it directed Petitioner to take certain actions to\ncomply with the pipeline safety regulations.\nOn April 22, 2005, Petitioner filed a petition for reconsideration of the Final Order. In its\npetition, Petitioner stated that a change in company ownership had occurred before the Final\nOrder was issued as the result of a bankruptcy proceeding. Petitioner contended that it was not\nliable for this regulatory enforcement proceeding because liability for such regulatory\nproceedings did not transfer from the bankrupt former owner under the particular Asset Purchase\nAgreement it had executed.\nDiscussion\nWe are not persuaded that the fact that an asset sale took place or that it took place in the context\nof bankruptcy is necessarily determinative of the question of liability. In its petition, Petitioner\nasserted that liability \"did not transfer to [Petitioner] as part of the Asset Purchase ~~reement.\"'\nPetitioner, however, did not provide any documentation, such as a copy of the relevant portion of\nthe agreement itself, describing those liabilities that Petitioner did agree to assume in the sale.\nThus, Petitioner failed to support its assertions about which liabilities were assumed and which\nwere not assumed with any actual evidence. Moreover, Petitioner failed to demonstrate that\n- -\n1 Petition for Reconsideration (Petition) dated April 22,2005 at page 2.\n\n\n\n2\nformal notice of the asset sale was afforded to OPS at the time. As a result, it appears that OPS\nwas unable to avail itself of any rights it would have had as a party in interest.\nIn addition, we are not aware of any provision of the pipeline safety laws that would preclude the\nOffice of Pipeline Safety (OPS) from pursuing an ongoing Compliance Order action against a\nsuccessor where substantial continuity of the pipeline's operations was maintained throughout.2\nTo the contrary, a situation where OPS was unable to pursue administrative enforcement actions\nagainst successor owners where the pipeline business operated continuously would directly\nconflict with the overall purpose of the pipeline safety laws and regulations to ensure that the\nnation's pipeline systems are operated safely.\nThe transportation of hazardous liquids by pipeline involves inherent risks to public safety and is\ntherefore a heavily regulated industry. In the normal course, buyers of pipeline assets are\nexpected to become aware of any open safety, environmental, and other regulatory proceedings\ninvolving the pipeline they are considering purchasing by conducting a due diligence\ninvestigation prior to the acquisition and are expected to carry out any pipeline safety-related\nobligations appropriately. In this case, company personnel were aware all along that OPS had\nmade a preliminary determination that the written procedures for operations, maintenance, and\nemergencies for the subject pipeline were inadequate under the relevant regulations, and that\nOPS had opened an enforcement action and issued a Proposed Compliance Order as a r e ~ u l t . ~\nAccordingly, the petition for reconsideration is denied. This decision on reconsideration is the\nfinal administration action in this proceeding.4\nDate Issued\n\\ As o 'ate Administrator\nipeline Safety\n2 The pipeline safety laws are codified at 49 U.S.C. 60101 et seq. Section 601 18(b) provides the U.S. Secretary of\nTransportation with broad authority to issue a Compliance Order. This authority in turn has been delegated to the\nAssociate Administrator for Pipeline Safety.\n3 For example, well after the ownership change, CRTC submitted materials responsive to this enforcement action\nprior to issuance of the Final Order and never raised any liability defense. See Letter from Sam A. McCorrnick,\nCRCT, to Hans Shieh, OPS, dated October 28,2004, carbon copy to Keith Osborn.\nIn a separate document issued simultaneously with this decision, an amendment to the March 4,2005 Final Order\nremoved any reference to CRCT as a Respondent on the grounds that all actions required by the Order to comply\nwith the pipeline safety regulations were completed rendering the Order moot and providing equivalent relief to that\nsought by Petitioner.","truncated":false,"body_characters":25262}