{"operation":"document","citation":"CPF 320145003","title":"BUCKEYE PARTNERS, LP — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-03-28","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.505(d), 195.581(a), 195.583(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320145003.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320145003.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320145003","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320145003","body":"Notice of Probable Violation involving BUCKEYE PARTNERS, LP. PHMSA's enforcement data identifies the cited regulations as 195.505(d),  195.581(a),  195.583(b). The case was opened on 2014-03-28 and is reported as closed as of 2017-03-16. Proposed civil penalty: $271,300. Assessed civil penalty: $271,300. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320145003_Closure Letter_03162017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320145003/320145003_Closure%20Letter_03162017.pdf\n\n320145003_Closure Letter_03162017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320145003/320145003_Closure%20Letter_03162017_text.pdf\n\n320145003_Final Order_09152014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320145003/320145003_Final%20Order_09152014.pdf\n\n320145003_Final Order_09152014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320145003/320145003_Final%20Order_09152014_text.pdf\n\n320145003_NOPV PCP PCO_03282014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320145003/320145003_NOPV%20PCP%20PCO_03282014.pdf\n\n320145003_NOPV PCP PCO_03282014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320145003/320145003_NOPV%20PCP%20PCO_03282014_text.pdf\n\n320145003_Operator Response to Notice_05052014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320145003/320145003_Operator%20Response%20to%20Notice_05052014.pdf\n\n320145003_Closure Letter_03162017_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 16, 2017\nMr. Clark C. Smith\nPresident & Chief Executive Officier\nBuckeye Partners, L.P.\nOne Greenway Plaza\nSuite 600\nHouston, TX 77046\nCPF 3-2014-5003\nDear Mr. Smith:\nOn September 15, 2014, the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) issued to Buckeye Partners, LP, a Final Order in the above-referenced case. This\nOrder included a Compliance Order and Civil Penalty assessment. Based on our review of the\ndocumentation you provided and confirmation of payment of the civil penalty, it has been\ndetermined 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,\nAllan C. Beshore\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\n\n320145003_NOPV PCP PCO_03282014_text.pdf\n\nNOTICE OF PROBABLE VIOLATION\nPROPOSED CIVIL PENALTY\nand\nPROPOSED COMPLIANCE ORDER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 28, 2014\nMr. Carl Ostach\nVice President, Field Operations\nBuckeye Partners, L.P.\n5 TEK Park\n9999 Hamilton Boulevard\nBreinigsville, Pennsylvania 18031\nCPF 3-2014-5003\nDear Mr. Ostach:\nOn May 17, 2011, Buckeye Partners, L.P. (Buckeye) discovered a gasoline leak on Line\n413 at the Findlay Junction facility near Findlay, Ohio. The leak occurred in a two-inch\ndiameter steel riser pipe, connected to a buried twelve-inch pipe through an isolation valve.\nAn above ground pressure transmitter was connected to the top of the two-inch riser pipe.\nThe riser pipe was oriented perpendicular to the twelve-inch pipe and was enclosed in a\nlarge diameter steel culvert, i.e., a vault. A representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States\nCode investigated this leak at Findlay Junction.\nAs a result of the investigation, it appears that you have committed probable Violations of\nthe Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items\ninspected and the probable violations are:\n\n\n\n1. §195.581 Which pipelines must I protect against atmospheric corrosion and what\ncoating material may I use?\n(a) You must clean and coat each pipeline or portion of pipeline that is exposed to the\natmosphere, except pipelines under paragraph (c) of this section.\nBuckeye failed to clean and coat each pipeline or portion of the pipeline that is exposed to\nthe atmosphere. Specifically, Buckeye did not clean and coat a two-inch diameter steel\nriser pipe, connected to a buried twelve-inch pipe through an isolation valve to protect\nagainst corrosion. The pipe was installed in 1997 and, per a metallurgical analysis, the leak\nwas caused by external pitting corrosion on the exterior of the two-inch uncoated pipe. In\naddition to the leaking corroded area, the metallurgical analysis report documented many\nrelatively large and deep pits on the riser with the deepest pits being 71% of the nominal\nwall thickness. The two-inch riser pipe was installed in a vault that was exposed to the\natmosphere with a soil-to-air interface present; therefore, the exceptions in §195.581(c) do\nnot apply.\n2. §195.583 What must I do to monitor atmospheric corrosion control?\n(b) During inspections you must give particular attention to pipe at soil-to-air\ninterfaces, under thermal insulation, under disbonded coatings, at pipe supports, in\nsplash zones, at deck penetrations, and in spans over water.\nBuckeye failed to properly monitor atmospheric corrosion of its pipe at a soil-to-air-\ninterface. Specifically, on August 4, 2010, Buckeye did not perform an adequate inspection\nof riser pipes exposed to the atmosphere in five vaults at the Findlay Junction facility. The\nriser pipes in the vaults contained soil-to-air interfaces. One of the riser pipes had a\ncorrosion failure that resulted in a product release on May 17, 2011. The August 4, 2010,\ninspection documented on Buckeye’s Triennial Visual Inspection Form indicated on the\nRiser Condition section of the form completed as “Air-Ground interface coating in good\ncondition” and “No rust visible.” However, during the onsite failure investigation, less than\na year later, PHMSA observed that none of the riser pipes in the five vaults at Findlay\nJunction facility were coated and rust was visually present. The metallurgical report of the\nfailed riser pipe documented areas of thick corrosion deposits, deep pits and no coating or\npaint present.\n3. §195.505 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n(d) Evaluate an individual if the operator has reason to believe that the individual's\nperformance of a covered task contributed to an accident as defined in Part 195;\n2\n\n\n\nBuckeye failed to properly evaluate an individual that it had reason to believe contributed\nto an accident through the performance of a covered task. Specifically, following the\ndiscovery of a corrosion caused leak at the Findlay Junction facility, Buckeye did not\nevaluate in a timely manner a single employee regarding performance of covered task\n001019 “Inspect Normally Exposed Pipe.” On August 10, 2011, and repeatedly on\nDecember 7, 2011, and March 19, 2012, PHMSA made email information requests\nassociated with the provisions of Buckeye’s Operator Qualification plan. None of these\ninformation requests resulted in evaluation information being provided for this single\nemployee. The atmospheric corrosion inspection on August 4, 2010, was inadequate and\nexternal pitting corrosion was the cause of the May 17, 2011, leak. The metallurgical\nreport documented that there was no evidence of accelerated corrosion mechanisms such as\nbacteria or microbial-influenced corrosion (MIC) that played a role in the leak. On June\n27, 2012, Buckeye completed the accident investigation and concluded that an inadequate\ninspection of the covered task on August 4, 2010, was a causal factor in the pipe failure.\nAn additional email request was made and an answer received on June 24, 2013, indicating\nthat an evaluation had still not been completed.\nProposed Civil Penalty\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the maximum\npenalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a related series of violations. The Compliance Officer has reviewed\nthe circumstances and supporting documentation involved in the above probable violations\nand has recommended that you be preliminarily assessed a civil penalty of $271,300 as\nfollows:\nItem number PENALTY\n1 $123,800\n2 $100,000\n3 $ 47,500\nProposed Compliance Order\nWith respect to items 2 and 3 pursuant to 49 United States Code § 60118, the Pipeline and\nHazardous Materials Safety Administration proposes to issue a Compliance Order to\nBuckeye Partners. Please refer to the Proposed Compliance Order, which is enclosed and\nmade a part of this Notice.\n3\n\n\n\nResponse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline\nOperators in Compliance Proceedings. Please refer to this document and note the response\noptions. Be advised that all material you submit in response to this enforcement action is\nsubject to being made publicly available. If you believe that any portion of your responsive\nmaterial qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete\noriginal document, you must provide a second copy of the document with the portions you\nbelieve qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b). If you\ndo not respond within thirty (30) days of receipt of this Notice, this constitutes a waiver of\nyour right to contest the allegations in this Notice and authorizes the Associate\nAdministrator for Pipeline Safety to find facts as alleged in this Notice without further\nnotice to you and to issue a Final Order.\nIn your correspondence on this matter, please refer to CPF 3-2014-5003 and for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nLinda Daugherty\nDirector, Central Region\nPipeline and Hazardous Materials Safety Administration\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Compliance Proceedings\n4\n\n\n\nPROPOSED COMPLIANCE ORDER\nPursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) proposes to issue to Buckeye Partners, L.P. (Buckeye) a\nCompliance Order incorporating the following remedial requirements to ensure the\ncompliance of Buckeye with the pipeline safety regulations:\n1. 2. 3. In regard to Item 2 of the Notice pertaining to inadequate atmospheric\ncorrosion inspection, all facilities (whether located at the Findlay Junction\nfacility or another location) that were last inspected by employee number\n4496 for atmospheric corrosion shall be re-inspected using a different\nqualified individual knowledgeable in corrosion control. These re-\ninspections must be completed within six months of the date of the Final\nOrder. PHMSA will receive copies of the completed Triennial Visual\nInspection Forms or any form that is used to document these re-inspections\nalong with the associated individual name and qualification information\ncompleting the re-inspection work.\nIn regard to Item 3 of the Notice pertaining to evaluation of an individual\nemployee, re-evaluate the employee completing the August 4, 2010, Task\n001019 “Inspecting Normally Exposed Pipe” inspection and submit\ndocumentation of the re-evaluation within thirty (30) days of the date of the\nFinal Order. If the individual is no longer required to perform this task,\nsubmit documentation within thirty (30) days of the date of the Final Order\nverifying the individual’s status related to this OQ task and identify when\nthis status change occurred.\nIt is requested (not mandated) that Buckeye maintain documentation of the\nsafety improvement costs associated with fulfilling this Compliance Order\nand submit the total to Ms. Linda Daugherty, Director, Central Region,\nPipeline and Hazardous Materials Safety Administration. It is requested that\nthese costs be reported in two categories: 1) total cost associated with\npreparation/revision of plans, procedures, studies and analyses, and 2) total\ncost associated with replacements, additions and other changes to pipeline\ninfrastructure.\n5\n\n320145003_Final Order_09152014_text.pdf\n\nSEPTEMBER 15, 2014\nMr. Clark C. Smith\nPresident\nBuckeye Partners, LP\nOne Greenway Plaza\nSuite 600\nHouston, TX 77046\nRe: CPF No. 3-2014-5003\nDear Mr. Smith:\nEnclosed please find the Final Order issued in the above-referenced case. It makes findings of\nviolation, assesses a civil penalty of $271,300, and specifies actions that need to be taken by\nBuckeye Partners, LP, to comply with the pipeline safety regulations. This is to acknowledge\nreceipt of payment of the full penalty amount, dated May 5, 2014. When the terms of the\ncompliance order have been completed, as determined by the Director, Central Region, this\nenforcement action will be closed. Service of the Final Order by certified mail is deemed\neffective upon the date of mailing, or as otherwise 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: Ms. Linda Daugherty, Director, Central Region, OPS\nMr. Scott Collier, Buckeye Partners, LP\nOne Greenway Plaza, Suite 600, Houston, TX 77046\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____________________________________\n)\nIn the Matter of )\n)\nBuckeye Partners, LP, ) CPF No. 3-2014-5003\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nPursuant to 49 U.S.C. § 60117, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety (OPS), conducted an investigation of an\naccident involving the pipeline system operated by Buckeye Partners, LP (Buckeye or\nRespondent), at Findlay Junction in Ohio. Buckeye owns and operates approximately 6,000\nmiles of hazardous liquid pipelines in the Northeast and Upper Midwest regions.1\nThe investigation arose out of Buckeye discovering a gasoline leak on Line 413 at the company’s\nFindlay Junction facility near Findlay, Ohio on May 17, 2011(Accident). As a result of the\ninvestigation, the Director, Central Region, OPS (Director), issued to Respondent, by letter dated\nMarch 28, 2014, a Notice of Probable Violation, Proposed Civil Penalty, and Proposed\nCompliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed\nfinding that Buckeye had committed various violations of 49 C.F.R. Part 195 and assessing a\ncivil penalty of $271,300 for the alleged violations. The Notice also proposed ordering\nRespondent to take certain measures to correct the alleged violations.\nBuckeye responded to the Notice by letter dated May 5, 2014 (Response). The company did not\ncontest the allegations of violation and paid the proposed civil penalty of $271,300, as provided\nin 49 C.F.R. § 190.227. Payment of the penalty serves to close the case with prejudice to\nRespondent, or to those Items for which a penalty was proposed.\nFINDINGS OF VIOLATION\nIn its Response, Buckeye did not contest the allegations in the Notice that it violated 49 C.F.R.\nPart 195, as follows:\nhttp://www.buckeye.com/BusinessOperations/PipelineTransportationOperations/tabid/584/Default.aspx (last\naccessed August 19, 2014).\n\n\n\n2\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.581(a), which states:\n§ 195.581 Which pipelines must I protect against atmospheric\ncorrosion and what coating material may I use?\n(a) You must clean and coat each pipeline or portion of pipeline\nthat is exposed to the atmosphere, except pipelines under paragraph (c) of\nthis section.\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.581(a) by failing to clean and coat\neach pipeline or portion of pipeline that is exposed to the atmosphere. Specifically, the Notice\nalleged that Buckeye did not clean and coat a two-inch diameter steel riser pipe, which was\nconnected to a buried twelve-inch pipe through an isolation valve, to protect against corrosion.\nThe pipe was installed in 1997. According to a metallurgical analysis conducted after the\nAccident, the leak was caused by external pitting corrosion on the exterior of the two-inch\nuncoated pipe. In addition to the leaking corroded area, the metallurgical analysis documented\nmany relatively large and deep pits on the riser, with the deepest pits being 71% of the nominal\nwall thickness. The two-inch riser pipe was installed in a vault that was exposed to the\natmosphere with a soil-to-air interface present; therefore, the exceptions in § 195.581(c) do not\napply.\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. § 195.581(a) by failing to clean and\ncoat each pipeline or portion of pipeline that is exposed to the atmosphere.\nItem 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.583(b), which states:\n§ 195.583 What must I do to monitor atmospheric corrosion control?\n(a) …\n(b) During inspections you must give particular attention to pipe at\nsoil-to-air interfaces, under thermal insulation, under disbonded coatings,\nat pipe supports, in splash zones, at deck penetrations, and in spans over\nwater.\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.581(b) by failing to properly\nmonitor atmospheric corrosion control by giving particular attention to pipe at soil-to-air\ninterfaces during inspections. Specifically, the Notice alleged that on August 4, 2010, Buckeye\ndid not perform an adequate inspection of riser pipes exposed to the atmosphere in five vaults at\nthe Findlay Junction facility. One of the riser pipes had a corrosion failure that resulted in the\nAccident. The August 4, 2010 inspection record indicated the “air-ground interface coating in\ngood condition” and “no rust visible.” However, during the onsite failure investigation, less than\na year later, PHMSA observed that none of the riser pipes in the five vaults at the Findlay\nJunction facility were coated and rust was visually present. According to the Notice, the\nmetallurgical report of the failed riser pipe documented areas of thick corrosion deposits, deep\npits, and no coating or paint present.\nRespondent did not contest this allegation of violation. Accordingly, based upon a review of all\n\n\n\n3\nof the evidence, I find that Respondent violated 49 C.F.R. § 195.581(b) by failing to properly\nmonitor atmospheric corrosion control by giving particular attention to pipe at soil-to-air\ninterfaces during inspections.\nItem 3: The Notice alleged that Respondent violated 49 C.F.R. § 195.505(d), which states:\n§ 195.505 Qualification program\nEach operator shall have and follow a written qualification program.\nThe program shall include provisions to:\n(a) …\n(d) Evaluate an individual if the operator has reason to believe that the\nindividual's performance of a covered task contributed to an accident as\ndefined in Part 195; . . . .\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.505(d) by failing to properly\nevaluate an individual who the company had reason to believe contributed to an accident through\nthe performance of a covered task. Specifically, the Notice alleged that after the discovery of a\nleak caused by corrosion at the Findlay Junction facility, Buckeye failed to evaluate in a timely\nmanner a single employee regarding performance of Task 001019, “Inspect Normally Exposed\nPipe.” On June 27, 2012, Buckeye completed its own accident investigation and concluded that\nan inadequate inspection of the covered task on August 4, 2010, was a causal factor in the pipe\nfailure. As of June 24, 2013, the company had still failed to complete an evaluation of this\nemployee.\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. § 195.505(d) by failing to properly\nevaluate an individual who the company had reason to believe contributed to an accident through\nthe performance of a covered task.\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$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 $271,300 for the violations cited above.\n\n\n\n4\nItem 1: The Notice proposed a civil penalty of $123,800 for Respondent’s violation of\n49 C.F.R. § 195.581(a), for failing to clean and coat each pipeline or portion of pipeline that is\nexposed to the atmosphere. Buckeye neither contested the allegation nor presented any evidence\nor argument justifying a reduction in the proposed penalty. Accordingly, having reviewed the\nrecord and considered the assessment criteria, I assess Respondent a civil penalty of $123,800 for\nviolation of 49 C.F.R. § 195.581(a).\nItem 2: The Notice proposed a civil penalty of $100,000 for Respondent’s violation of\n49 C.F.R. § 195.583(b), for failing to properly monitor atmospheric corrosion control by giving\nparticular attention to pipe at soil-to-air interfaces during inspections. Buckeye neither contested\nthe allegation nor presented any evidence or argument justifying a reduction in the elimination of\nthe proposed penalty. Accordingly, having reviewed the record and considered the assessment\ncriteria, I assess Respondent a civil penalty of $100,000 for violation of 49 C.F.R. § 195.583(b).\nItem 3: The Notice proposed a civil penalty of $47,500 for Respondent’s violation of\n49 C.F.R. § 195.505(d), for failing to properly evaluate an individual who the company had\nreason to believe contributed to an accident through the performance of a covered task. Buckeye\nneither contested the allegation nor presented any evidence or argument justifying a reduction in\nthe proposed penalty. Accordingly, having reviewed the record and considered the assessment\ncriteria, I assess Respondent a civil penalty of $47,500 for violation of 49 C.F.R. § 195.505(d).\nIn summary, having reviewed the record and considered the assessment criteria for each of the\nItems cited above, I assess Respondent a total civil penalty of $271,300. As noted above,\nBuckeye has paid the full penalty amount by wire transfer dated May 5, 2014.\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Items 2 and 3 in the Notice for\nviolations of 49 C.F.R. §§ 195.583(b) and 195.505(d), respectively. Under\n49 U.S.C. § 60118(a), each person who engages in the transportation of hazardous liquids or who\nowns or operates a pipeline facility is required to comply with the applicable safety standards\nestablished under chapter 601. Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R.\n§ 190.217, Respondent is ordered to take the following actions to ensure compliance with the\npipeline safety regulations applicable to its operations:\n1. With respect to the violation of § 195.583(b) (Item 2), Respondent must re-\ninspect, within six months of the date of this Final Order, all facilities that were last\ninspected by employee number 4496, for atmospheric corrosion, using a different\nqualified individual who is knowledgeable about corrosion control. The operator\nmust provide copies of the completed Triennial Visual Inspection forms or any form\nthat is used to document these re-inspections, along with the associated individual’s\nname and qualification information.\n2. With respect to the violation of § 195.505(d) (Item 3), Respondent must re-\n\n\n\n5\nevaluate the employee who performed the covered task 001019, “Inspecting\nNormally Exposed Pipe” inspection on August 4, 2010, and submit the\ndocumentation of the re-evaluation within thirty (30) days of the date of this Final\nOrder, verifying the individual’s status related to this task and identify when the\nstatus change occurred.\n3. It is requested that Buckeye maintain documentation of the safety improvement\ncosts associated with fulfilling this Compliance Order and submit the total to\nMs. Linda Daugherty, Director, Central Region, Pipeline and Hazardous Materials\nSafety Administration. It is requested that these costs be reported in two categories:\n1) total cost associated with preparation/revision of plans, procedures, studies and\nanalyses; and 2) total cost associated with replacements, additions and other changes\nto pipeline infrastructure.\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.\nFailure to comply with this Order may result in the administrative assessment of civil penalties\nnot to exceed $200,000 for each violation for each day the violation continues or in referral to the\nAttorney General for appropriate relief in a district 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.\n___________________________________ __________________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":26164}