{"operation":"document","citation":"CPF 32024045NOPV","title":"ENBRIDGE STORAGE (CUSHING) L.L.C. — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-05-10","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.446(a), 195.446(c)(2), 195.446(c)(3), 195.446(e)(2), 195.446(e)(5).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024045nopv.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024045nopv.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024045nopv","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32024045NOPV","body":"Notice of Probable Violation involving ENBRIDGE STORAGE (CUSHING) L.L.C.. PHMSA's enforcement data identifies the cited regulations as 195.446(a),  195.446(c)(2),  195.446(c)(3),  195.446(e)(2),  195.446(e)(5). The case was opened on 2024-05-10 and is reported as closed as of 2025-11-20. Proposed civil penalty: $78,200. Assessed civil penalty: $75,300. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32024045NOPV_Closure Letter_11202025_(23-264643).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024045NOPV/32024045NOPV_Closure%20Letter_11202025_(23-264643).pdf\n\n32024045NOPV_Closure Letter_11202025_(23-264643)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024045NOPV/32024045NOPV_Closure%20Letter_11202025_(23-264643)_text.pdf\n\n32024045NOPV_Final Order_09262025_(23-264643).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024045NOPV/32024045NOPV_Final%20Order_09262025_(23-264643).pdf\n\n32024045NOPV_Final Order_09262025_(23-264643)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024045NOPV/32024045NOPV_Final%20Order_09262025_(23-264643)_text.pdf\n\n32024045NOPV_Operator Response to Notice (Supplemental) and Request for PCP Reconsideration_05052025_(23-264643).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024045NOPV/32024045NOPV_Operator%20Response%20to%20Notice%20(Supplemental)%20and%20Request%20for%20PCP%20Reconsideration_05052025_(23-264643).pdf\n\n32024045NOPV_Operator Response to Notice (Supplemental)_07052024_(23-264643).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024045NOPV/32024045NOPV_Operator%20Response%20to%20Notice%20(Supplemental)_07052024_(23-264643).pdf\n\n32024045NOPV_Operator Response to Notice_06072024_(23-264643).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024045NOPV/32024045NOPV_Operator%20Response%20to%20Notice_06072024_(23-264643).pdf\n\n32024045NOPV_PCP PCO_05102024_(23-264643).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024045NOPV/32024045NOPV_PCP%20PCO_05102024_(23-264643).pdf\n\n32024045NOPV_PCP PCO_05102024_(23-264643)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024045NOPV/32024045NOPV_PCP%20PCO_05102024_(23-264643)_text.pdf\n\n32024045NOPV_Closure Letter_11202025_(23-264643)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\n901 Locust Street, Suite 480\nKansas City, MO 64106\nVIA ELECTRONIC MAIL TO: kevin.ruffatto@enbridge.com; jeffrey.cremin@enbridge.com\nNovember 20, 2025\nMr. Kevin Ruffatto\nVP, US Operations\nEnbridge Storage (Cushing), LLC\n915 N Eldridge Parkway, Suite 1100\nHouston, TX 77079\nRE: CPF 3-2024-045-NOPV\nDear Mr. Ruffatto:\nOn September 26, 2025, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued to Enbridge Storage (Cushing), LLC (Enbridge) a Final Order, pursuant to 49 CFR\n§ 190.213, in the above-referenced case. This Order included a Compliance Order and Civil\nPenalty assessment. Based on our review of the documentation provided and confirmation of\npayment of the civil penalty, it has been determined that Enbridge has complied with the terms of\nthe 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,\nDavid Barrett\nActing Director, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Jeff Cremin, Manager Regulatory Compliance, Enbridge Storage,\njeffrey.cremin@enbridge.com\n\n32024045NOPV_Final Order_09262025_(23-264643)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nSeptember 26, 2025\nVIA ELECTRONIC MAIL TO: colin.gruending@enbridge.com\nColin K. Gruending\nExecutive Vice President and President, Liquids Pipelines\nEnbridge Inc.\n200 Fifth Avenue Place\n425 – 1st Street SW\nCalgary, Alberta, Canada T2P 3L8\nRe: CPF No. 3-2024-045-NOPV\nDear Mr. Gruending:\nEnclosed please find the Final Order issued in the above-referenced case. It withdraws one of\nthe allegations of violation, makes other findings of violation, assesses a reduced civil penalty of\n$75,300, and specifies actions that need to be taken by Enbridge Storage (Cushing), LLC to\ncomply with the pipeline safety regulations. The penalty payment terms are set forth in the Final\nOrder. When the civil penalty has been paid and the terms of the compliance order completed,\nas determined by the Director, Central Region, this enforcement action will be closed. Service of\nthe Final Order by e-mail is effective upon the date of transmission and acknowledgement of\nreceipt as provided under 49 CFR § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nLinda Daugherty\nActing Associate Administrator\nfor Pipeline Safety\nEnclosure (Final Order)\ncc: Mr. David Barrett, Acting Director, Central Region, Office of Pipeline Safety, PHMSA\nMr. Eric Anderson, Regulatory Compliance, Enbridge Storage (Cushing), LLC,\neric.anderson@enbridge.com\n\n\n\nCPF No. 3-2024-045-NOPV\nPage 2\nMr. Kevin Ruffatto VP, US Operations, Enbridge Storage (Cushing), LLC,\nkevin.ruffatto@enbridge.com\nMr. Jeff Cremin, PE, Manager, US Liquid Pipeline Compliance, Enbridge Storage\n(Cushing), LLC, jeffrey.cremin@enbridge.com\nMr. Steven Dahnke, Manager, Safety and Quality, Enbridge Storage (Cushing), LLC,\nsteven.dahnke@enbridge.com\nCONFIRMATION OF RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nEnbridge Storage (Cushing), LLC, )\na subsidiary of Enbridge Inc., ) CPF No. 3-2024-045-NOPV\n)\n)\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nFrom September 18 to September 28, 2023, pursuant to 49 U.S.C. § 60117, a representative of\nthe Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS), conducted an on-site pipeline safety inspection of the control room management records\nand procedures of Enbridge Storage (Cushing), LLC (Enbridge) at its control room in Cushing,\nOklahoma. Enbridge manages 23 miles of hazardous liquid pipelines and 110 breakout tanks at\ntwo separate facilities in Cushing, Oklahoma.\nAs a result of the inspection, the Director, Central Region, OPS (Director), issued to Respondent,\nby letter dated May 10, 2024, a Notice of Probable Violation, Proposed Civil Penalty, and\nProposed Compliance Order (Notice). In accordance with 49 CFR § 190.207, the Notice\nproposed finding that Enbridge had committed three violations of 49 CFR Part 195, proposed\nassessing a civil penalty of $78,200 for the alleged violations, and proposed ordering Respondent\nto take certain measures to correct the alleged violations. The Notice also included a warning\nitem pursuant to 49 CFR § 190.205, which warned Respondent to correct the probable violation\nor face possible future enforcement action.\nEnbridge Inc., the parent company of Enbridge, responded to the Notice by letter dated June 7,\n2024 (Response). On June 20, 2024, Central Region requested clarification of Respondent’s\nwritten response. On July 5, 2024, Respondent submitted a Supplemental Response\n(Supplemental Response) to clarify that it was contesting Item 1 and requested a meeting with\nthe Central Region. A meeting was held on July 11, 2024, where Respondent presented\nadditional information regarding the operation of its system. On May 5, 2025, Respondent\nsubmitted a Second Supplemental Response (Second Supplement Response), where it argued the\nproposed penalties should be eliminated or significantly reduced. Respondent did not request a\nhearing and therefore has waived its right to one.\n\n\n\nCPF No. 3-2024-045-NOPV\nPage 2\nFINDINGS OF VIOLATION\nThe Notice alleged that Respondent violated 49 CFR Part 195, as follows:\nItem 1: The Notice alleged that Respondent violated 49 CFR § 195.446(c)(3), which states:\n§ 195.446 Control room management.\n(a) . . . .\n(c) Provide adequate information. Each operator must provide its\ncontrollers with the information, tools, processes and procedures necessary\nfor the controllers to carry out the roles and responsibilities the operator has\ndefined by performing each of the following:\n(1) . . . .\n(3) Test and verify an internal communication plan to provide adequate\nmeans for manual operation of the pipeline safely, at least once each\ncalendar year, but at intervals not to exceed 15 months;\nThe Notice alleged that Respondent violated 49 CFR § 195.446(c)(3) by failing to test and verify\nan internal communication plan to provide adequate means for manual operation of the pipeline\nsafely, at least once each calendar year, but at intervals not to exceed 15 months. Specifically,\nthe Notice alleged that Enbridge failed to test and verify its internal communication plan in 2021\nand that the test conducted in 2020 was inadequate.\nIn its Response, Enbridge contested Item 1. Enbridge stated that it tested its communication plan\non October 21, 2021, and provided associated records and additional details about its internal\ncommunication plan testing process.\nIn a recommendation for final action submitted pursuant to section 190.209(b)(7), the Director\nrecommended withdrawing the alleged violation of section 195.446(c)(3).\nBased upon the foregoing, I hereby order that Item 1 be withdrawn.\nItem 3: The Notice alleged that Respondent violated 49 CFR § 195.446(e)(2), which states:\n§ 195.446 Control room management.\n(a) . . . .\n(e) Alarm management. Each operator using a SCADA system must\nhave a written alarm management plan to provide for effective controller\nresponse to alarms. An operator's plan must include provisions to:\n(1) . . . .\n(2) Identify at least once each calendar month points affecting safety\nthat have been taken off scan in the SCADA host, have had alarms inhibited,\ngenerated false alarms, or that have had forced or manual values for periods\nof time exceeding that required for associated maintenance or operating\n\n\n\nCPF No. 3-2024-045-NOPV\nPage 3\nactivities;\nThe Notice alleged that Respondent violated 49 CFR § 195.446(e)(2) by failing to identify at\nleast once each calendar month points affecting safety that have been taken off scan in the\nSCADA host, have had alarms inhibited, generated false alarms, or that have had forced or\nmanual values for periods of time exceeding that required for associated maintenance or\noperating activities. Specifically, the Notice alleged that Enbridge failed to have and follow a\nwritten alarm management plan to provide for effective controller response to alarms because the\nplan failed to define the points affecting safety that require identification, failed to require\nrecords of their identification, and failed to include all consoles in each monthly review.\nIn its Response, Enbridge did not contest Item 3.\nAccordingly, after considering all of the evidence, I find that Respondent violated 49 CFR\n§ 195.446(e)(2) by failing to identify at least once each calendar month points affecting safety\nthat have been taken off scan in the SCADA host, have had alarms inhibited, generated false\nalarms, or that have had forced or manual values for periods of time exceeding that required for\nassociated maintenance or operating activities.\nItem 4: The Notice alleged that Respondent violated 49 CFR § 195.446(e)(5), which states:\n§ 195.446 Control room management.\n(a) . . . .\n(e) Alarm management. Each operator using a SCADA system must\nhave a written alarm management plan to provide for effective controller\nresponse to alarms. An operator's plan must include provisions to:\n(1) . . . .\n(5) Monitor the content and volume of general activity being directed to\nand required of each controller at least once each calendar year, but at\nintervals not exceeding 15 months, that will assure controllers have\nsufficient time to analyze and react to incoming alarms; and\nThe Notice alleged that Respondent violated 49 CFR § 195.446(e)(5) by failing to monitor the\ncontent and volume of general activity being directed to and required of each controller at least\nonce each calendar year, but at intervals not exceeding 15 months, to assure controllers have\nsufficient time to analyze and react to incoming alarms. Specifically, the Notice alleged that\nEnbridge failed to complete the workload study required by section 195.446(e)(5) for consoles\n96, 98, and 99 in calendar year 2022.\nIn its Response, Enbridge did not contest Item 4.\nAccordingly, after considering all of the evidence, I find that Respondent violated 49 CFR\n§ 195.446(e)(5) by failing to monitor the content and volume of general activity being directed to\nand required of each controller at least once each calendar year, but at intervals not exceeding 15\nmonths, to assure controllers have sufficient time to analyze and react to incoming alarms.\n\n\n\nCPF No. 3-2024-045-NOPV\nPage 4\nThese findings of violation will be considered prior offenses in any subsequent enforcement\naction taken against Respondent.\nASSESSMENT OF PENALTY\nUnder 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed\n$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any\nrelated series of violations.1\nIn determining the amount of a civil penalty under 49 U.S.C. § 60122 and 49 CFR § 190.225, I\nmust consider the following criteria: the nature, circumstances, and gravity of the violation,\nincluding adverse impact on the environment; the degree of Respondent’s culpability; the history\nof Respondent’s prior offenses; any effect that the penalty may have on its ability to continue\ndoing business; the good faith of Respondent in attempting to comply with the pipeline safety\nregulations; and self-disclosure or actions to correct a violation prior to discovery by PHMSA.\nIn addition, I may consider the economic benefit gained from the violation without any reduction\nbecause of subsequent damages, and such other matters as justice may require.\nThe Notice proposed a total civil penalty of $78,200 for the violations cited above. Effective\nMay 20, 2025, PHMSA revised its proposed civil penalty calculation policy to use the version of\nthe Civil Penalty Worksheet in effect when the alleged violation occurred. The new policy\nreduces the total proposed civil penalty in this case to $75,300.\nItem 3: The Notice proposed a civil penalty of $39,100 for Respondent’s violation of 49 CFR\n§ 195.446(e)(2), for failing to identify at least once each calendar month points affecting safety\nthat have been taken off scan in the SCADA host, have had alarms inhibited, generated false\nalarms, or that have had forced or manual values for periods of time exceeding that required for\nassociated maintenance or operating activities. The new policy for calculating a proposed civil\npenalty did not change the proposed civil penalty for this item.\nIn its Response, Enbridge neither contested the allegation nor presented any evidence or\nargument justifying a reduction in the proposed penalty. Likewise, in its Supplemental\nResponse, which was submitted at the request of the Central Region to clarify Enbridge’s\nresponse to Item 1, Enbridge did not contest the allegation or the proposed penalty for Item 3.\nAccordingly, Enbridge has waived its opportunity to contest the proposed penalty amount.\nTen months later, on May 5, 2025, Respondent submitted a Second Supplemental Response,\nwhich argued the penalty for Item 3 should be eliminated or withdrawn because the Notice did\nnot provide an explanation of the penalty calculations and because the violations only involved\n“procedural and administrative shortcomings.” Enbridge also suggested its proactive safety\nculture warranted reduction or elimination of the civil penalties. Having already waived its\nopportunity to contest the penalty, the Second Supplemental Response was untimely, per 49 CFR\n1 These amounts are adjusted annually for inflation. See 49 CFR § 190.223 for adjusted amounts.\n\n\n\nCPF No. 3-2024-045-NOPV\nPage 5\n§ 190.208.\nAfter reviewing the record, I find the proposed penalty amount supported by the evidence in the\nrecord. With respect to the gravity of the violation, the Pipeline Safety Violation Report in Part\nE6 indicated that “[p]ipeline safety was minimally affected” by Respondent’s violation of 49\nCFR § 195.446(e)(2). Therefore, the penalty calculation appropriately reflected that the\nviolation did not constitute a significant safety concern. As indicated in the Pipeline Safety\nViolation Report Part E5 – Circumstances, PHMSA discovered the violation, it was not self-\ndisclosed by Enbridge. In Part E7– Culpability, Respondent did not receive an available credit\nbecause Enbridge did not take actions to correct the violation before PHMSA learned of the\nviolation. For these reasons, I find the proposed civil penalty is supported by the facts in the\nrecord.2\nAccordingly, having reviewed the record and considered the assessment criteria, I assess\nRespondent a civil penalty of $39,100 for violation of 49 CFR § 195.446(e)(2).\nItem 4: The Notice proposed a civil penalty of $39,100 for Respondent’s violation of 49 CFR\n§ 195.446(e)(5), for failing to monitor the content and volume of general activity being directed\nto and required of each controller at least once each calendar year, but at intervals not exceeding\n15 months, to assure controllers have sufficient time to analyze and react to incoming alarms.\nThe new policy for calculating a proposed civil penalty reduces the proposed civil penalty for\nthis item to $36,200.\nIn its Response, Enbridge neither contested the allegation nor presented any evidence or\nargument justifying a reduction in the proposed penalty. Likewise, in its Supplemental\nResponse, which was submitted at the request of the Central Region to clarify Enbridge’s\nresponse to Item 1, Enbridge did not contest the allegation or the proposed penalty for Item 4.\nAccordingly, Enbridge waived its opportunity to contest the proposed penalty amount. In its\nSecond Supplemental Response, Enbridge argued the penalty for Item 4 should be eliminated or\nwithdrawn because the Notice did not provide an explanation of the penalty calculations and\nbecause the violations only involved “procedural and administrative shortcomings.” Enbridge\nalso suggested its proactive safety culture warranted reduction or elimination of the civil\npenalties. As noted above, the Second Supplemental Response was untimely, per 49 CFR §\n190.208.\nAfter reviewing the record, I find the proposed penalty amount supported by the evidence in the\nrecord. With respect to the gravity of the violation, the Pipeline Safety Violation Report in Part\nE6 indicated that “[p]ipeline safety was minimally affected” by Respondent’s violation of 49\nCFR § 195.446(e)(5). Therefore, the penalty calculation appropriately reflected that the\nviolation did not constitute a significant safety concern. As indicated in the Pipeline Safety\nViolation Report Part E5 – Circumstances, PHMSA discovered the violation, it was not self-\n2 I note further that the Notice included the legal citations that establish the assessment criteria used to calculate the\npenalty. PHMSA also makes available in all proceedings a detailed calculation worksheet, which may be requested\nalong with other records as provided by 49 U.S.C. § 60117(b)(1)(C) and 49 CFR § 190.209. Enbridge never\nrequested the case file. Notwithstanding, Central Region produced the case file, including the penalty calculation\nworksheet, after receiving the Second Supplemental Response.\n\n\n\nCPF No. 3-2024-045-NOPV\nPage 6\ndisclosed. In Part E7 – Culpability, Respondent did not receive an available credit because\nEnbridge did not correct the violation before PHMSA learned of the violation. For these\nreasons, I find the proposed civil penalty is supported by the facts in the record.\nAccordingly, having reviewed the record and considered the assessment criteria, I assess\nRespondent a reduced civil penalty of $36,200 for violation of 49 CFR § 195.446(e)(5).\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 $75,300.\nPayment of the civil penalty must be made within 20 days after receipt of this Final Order.\nFederal regulations (49 CFR § 89.21(b)(3)) require such payment to be made by wire transfer\nthrough the Federal Reserve Communications System (Fedwire), to the account of the U.S.\nTreasury. Detailed instructions are contained in the enclosure. Questions concerning wire\ntransfers should be directed to: Financial Operations Division (AMK-325), Federal Aviation\nAdministration, Mike Monroney Aeronautical Center, 6500 S MacArthur Blvd, Oklahoma City,\nOklahoma 79169. The Financial Operations Division telephone number is (405) 954-8845.\nFailure to pay the civil penalty will result in accrual of interest at the current annual rate in\naccordance with 31 U.S.C. § 3717, 31 CFR § 901.9 and 49 CFR § 89.23. Pursuant to those same\nauthorities, a late penalty charge of six percent (6%) per annum will be charged if payment is not\nmade within 110 days of service. Furthermore, failure to pay the civil penalty may result in\nreferral of the matter to the Attorney General for appropriate action in a district court of the\nUnited States.\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Items 1 and 3 in the Notice for\nviolations of 49 CFR § 195.446(c)(3) and 195.446(e)(2), respectively. Under 49 U.S.C.\n§ 60118(a), each person who engages in the transportation of hazardous liquids or who owns or\noperates a pipeline facility is required to comply with the applicable safety standards established\nunder chapter 601. As discussed above, Item 1 has been withdrawn. Therefore, the compliance\nterms proposed in the Notice for that item are not included in this Order. Pursuant to the\nauthority of 49 U.S.C. § 60118(b) and 49 CFR § 190.217, Respondent is ordered to take the\nfollowing actions to ensure compliance with the pipeline safety regulations applicable to its\noperations:\n1. With respect to the violation of section 195.446(e)(2) (Item 3), Respondent must\namend its procedure related to monthly alarm review, conduct two consecutive\nmonthly reviews, and provide the amended procedures and inspection records to the\nDirector within 120 days of receipt of the Final Order.\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.\n\n\n\nCPF No. 3-2024-045-NOPV\nPage 7\nPHMSA requests that Respondent maintain documentation of the safety improvement costs\nassociated with fulfilling this Compliance Order and submit the total to the Director. It is\nrequested that these costs be reported in two categories: (1) total cost associated with\npreparation/revision of plans, procedures, studies and analyses; and (2) total cost associated with\nreplacements, additions and other changes to pipeline infrastructure.\nFailure to comply with this Order may result in the administrative assessment of civil penalties\nnot to exceed $200,000, as adjusted for inflation (see 49 CFR § 190.223 for adjusted amounts),\nfor each violation for each day the violation continues or in referral to the Attorney General for\nappropriate relief in a district court of the United States.\nWARNING ITEM\nWith respect to Item 2, the Notice alleged probable violation of Part 195, but identified it as a\nwarning item pursuant to section 190.205. The warning was for:\n49 CFR § 195.446(c)(2) (Item 2) ─ Respondent’s alleged failure to conduct a\npoint-to-point verification between SCADA displays and related field equipment\nwhen field equipment is added or moved and when other changes that affect\npipeline safety are made to field equipment of SCADA displays.\nEnbridge presented information in its Response showing that it will take certain actions to\naddress the cited item. If OPS finds a violation of this provision in a subsequent inspection,\nRespondent may be subject to future enforcement action.\nUnder 49 CFR § 190.243, Respondent may submit a Petition for Reconsideration of this Final\nOrder to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey\nAvenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of\nChief Counsel, PHMSA, at the same address. The written petition must be received no later than\n20 days after receipt of the Final Order by Respondent. Any petition submitted must contain a\nstatement of the issue(s) and meet all other requirements of 49 CFR § 190.243. The filing of a\npetition automatically stays the payment of any civil penalty assessed. The other terms of the\norder, including corrective action, remain in effect unless the Associate Administrator, upon\nrequest, grants a stay. The terms and conditions of this Final Order are effective upon service in\naccordance with 49 CFR § 190.5.\n___________________________________ __________________________\nLinda Daugherty Date Issued\nActing Associate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":25245}