# PLAINS PIPELINE, L.P. — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 420075011
- **title:** PLAINS PIPELINE, L.P. — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2007-04-18
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.402(a), 195.404(b), 195.412(a), 195.420(c), 195.54(a), 195.581(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-420075011.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-420075011.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-420075011
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420075011
**body:**

Notice of Probable Violation involving PLAINS PIPELINE, L.P.. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.404(b),  195.412(a),  195.420(c),  195.54(a),  195.581(a). The case was opened on 2007-04-18 and is reported as closed as of 2009-06-09. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420075011_Final Order_11072008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075011/420075011_Final%20Order_11072008.pdf

420075011_final order_11072008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075011/420075011_final%20order_11072008_text.pdf

420075011_Notice letter_04182007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075011/420075011_Notice%20letter_04182007.pdf

420075011_notice letter_04182007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075011/420075011_notice%20letter_04182007_text.pdf

420075011_Operator Response_05232007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075011/420075011_Operator%20Response_05232007.pdf

420075011_notice letter_04182007_text.pdf

U. S. Department
of Transportotion
Pipeline and
Hazardous Materlats
Safety Administratioll
erat S Gassner, Suins 111D
Hansrnn, TX 77074
NOTICE OF PROBABLE VIOLATION
and
PROPOSED COMPI IANCE ORDER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
April 18, 2007
Mr. Harry N. Pefannis
President
Plains Pipeline, L. P.
P. O. Box 4468
Houston, TX 77210
CPF 4-2007-5011
Dear Mr. Pefannis:
On May 23 — 27, June 14 - 16 and 20 — 24, September 12 - 16, and October 24 — 28, 2005, a
representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA)
pursuant to Chapter 601 of 49 United States Code inspected your Johnson Bayou to Sabine
Pass System; Basin Pipeline System from Cushing, OK to Jal, NM; Red River System from
Gushing, OK to Longview, TX; and your Ferriday System from Greensburg, LA to Delhi Station,
LA.
As a result of these inspections, it appears that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and
the probable violations are:
II195. 54 Accident reports.
(a) Each operator that experiences an accident that is required to be reported
under ('f195. 50 shall as soon as practicable but not later than 30 days after
discovery of the accident, prepare and file an accident report on DOT Form 7000-
1, or a facsimile.



At Sabine Pass, a 4 barrel spill on March 6, 2003, was not reported to DOT.
Plains Pipeline, L. P (Plains) personnel thought the leaking seal on the pump at
the tank header was iurisdictional to the Coast Guard. Coast Guard regulations
did not require the reporting of the spill due to the spill's small volume that was
totally contained on site.
Plains personnel self reported the incident and submitted a copy of Plains'
interne 'Spill Report' of the incident to the PHMSA representative.
B. On the Ferriday System, a 3 barrel spill that occurred on September 18, 2005, at
Canebrake Station was not reported to DOT within 30 days.
On October 26, 2005, the PHMSA representative noticed evidence of a recent
spill near tank 936 while performing a field inspection of the Canebrake Station.
Plains personnel were able to show it had been reported to the Louisiana
Department of Natural Resources, but not to DOT.
$195. 402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a
manual of written procedures for conducting normal operations and maintenance
activities and handling abnormal operations and emergencies. This manual shall
be reviewed at intervals not exceeding 15 months, but at least once each calendar
year, and appropriate changes made as necessary to insure that the manual is
effective. This manual shall be prepared before initial operations of a pipeline
commence, and appropriate parts shall be kept at locations where operations and
maintenance aictivities are conducted.
A. (c) Maintenance and normal operations. The manual required by
paragraplh (a) of this section must include procedures for the following to
provide safety during maintenance and normal operations:
(13) Periodically reviewing the work done by operator to determine the
effectiveness of the procedures used in normal operation and maintenance
and taking corrective action where deficiencies are found.
On the Basin Pipeline System, Plains is failing to perform its annual review of
personnel work to determine the effectiveness of its normal O&M procedures
A reading of Plains' O&M Manual, Section 402, page 3 shows that Form 702 in
Appendix C is used to meet the requirements of $195. 402(c)(13) and
i3195. 403(b). Part of Section 402, page 3 is paraphrased below to show how
failure to fill out Form 702 for each job classification each year results in a
probable violation of $195. 402(c)(13).
As per Plains' O&M Manual, Section 402, page 3; Form 702 in Appendix C.
'ANNUAL PERSONNEL TRAIIUING REVIEW', is to be filled out each year for



each employee, and be evaluated to address the functional competencies of
operation, maintenance, safety,
and emergency procedures as they relate to each person's job classification.
Form 702 had not been filled out for each employee for each of the last three
years. It was observed that very few Form 702s had been filled out.
$195. 430 Firefighting equipment.
Each operator shall maintain adequate firefighting equipment at eaohi pump
station and breakout tank area. The equipment must be-
(aj In proper operating condition at all times;
On the Basin Pipeline System, three fire extinguishers at Lindsey Station had not
been maintained as required by Plains' O&M Manual, Section 419.
During the Field Inspection at Lindsey station, it was discovered that there was
no record of monthly inspections for 24 months, from May, 2003 to April, 20ti5,
for three fire extinguishers. Monthly inspections of fire extinguishers are required
in Plains' O&M Manual, Section 419.
5195. 404 Maps add Records.
(bj Eat-hi operator shall maintain for at least 3 yesirs daily o peratting iresords
that iindiicate-
A. (1j Tihe discharge piressuse at each pump station;
On the 18asin Pipeline System, Plains was not able to show the pressure history
for the 'Basin Midland Discharge Pressure' for May 18, 2004.
The Midland Station discharge pressure history of May 18, 2004, as recreated
from SCADA records does not accurately represent the probable actual
pressures on that date.
(2j Any emergency or abnormal operation to wthlich the proceduires under
C(1 95. 402 apply.
On the Basin Pipeline System, the pressure history of the abnormal event of May
1, 2004 could not be shown as data from April 27 to May 4, 2004 was not
retrievable.



tt195. 412 Inspection of rights-of-way and crossings under navigable waters.
(a) Each operator shall, at intervals not exceeding 3 weetts, but at least 26
times each calendar year, inspect the surface conditions on or adjaceitt to
each pipeline right-of-way. Methods of inspection include walking, driving,
flying or other appropriate mean of traversing the right-of-way.
Qn the Basin Pipeline System, the Midland to Colorado City records show
inspection gaps between February 17 and April 1, 2004 (44 days); May 14 artd
September 29, 2004 (138 days); and September 29 and October 31, 2004 (52
days).
Each of the three time spans are in excess of the 21 day maximum Mitig. -ition
for one of the inspection gaps is that one of the pilots died in a plane crash, and
several weeks of records were destroyed in the crash. Records indicate the
entire pipeline is usually flown weekly.
%1 95. 426 Valve maiintenianice.
(c) Each operator shall provide protection for each v;alve from
unauthorized operation and from vandalism.
A number of the Plains Pipeline LP pipeline valves do not have protection from
vandalism at the sites The valves were chained and locked to prevent
unauthorized use, but these locations did not provide any deterrence against
vandalism. Local personnel did provide additional information regarding this
issue.
During the inspections it was noted that Plains' preferred method of complying
with 195. 420(c) is to install locked chain link fencing around the va ves. Tnis was
evident in the four Plains units that were inspected, where the ma)ority of above
ground valves were located in locked fences.
Some of the remaining valves in those units were located above ground with no
fences. The number of above ground valves that were observed without fences
by the inspector on the four units exceeded five, and the lack of fencing was
pointed out to Plains personnel at the time of the inspections.
It should be pointed out that all of the unfenced valves were chain locked and
most had steel barricade posts installed. A review of your procedures by car
inspectors did not reveal any alternative method of security for valve cites
acceptable to you. Plains should review their program, procedures, and facilities
to ensure they are compliant with this regulation.



6. ()195. 581 Which pipelines must I protect against atmospheric corrosion . .
(a) You must clean and coat each pipeline or portion of pipeline that is
exposed to the atmosphere, except pipe!ines under paragraph (c) of this
section.
(b) Coating material must be suitable for the prevention of atmospheric
coi I'os ton.
On the Red River System, four spans, at RL 77. 84, MP 22. 39, RL 66. 4, and RL
46. 9, were not properly coated for prevention of atmospheric corrosion
During the Field Inspection, the span at RL 77. 84 had subsurface coating in poor
condition, the span at MP 22. 39, Hwy 74, was bare exposed pipe across a ditch;
the span at RL 66. 41, N of Hall Rd, was about 50' of bare pipe across a 30' deep
gulley; and
the span at RL 46. 9, creek span N side CR 5060, was about 50' of bare pipe
across a 12' deep creek. It is noted that a 'Mitigation Plan for Red River East
Pipeline Pipe Exposures' was submitted following the inspection.
Pro osed Com liance Order
Pursuant to 49 United States Code g 60118, the Pipeline and Hazardous Materials Safety
Administration proposes to issue a Compliance Order to Plains, with respect to items 2 and 6.
Please refer to the Proposed Compliance Order, which is enclosed and made a part of this
fdotice.
With respect to items 1, 3, 4, and 5, we have reviewed the circumstances and supporting
documents involved in this case and have decided not to conduct additional enforcement aotiion
or penalty assessment proceedings at this time. We advise you to promptly correct these items.
Be advised that failure to do so may result in Plains being subject to additional enforcement
action.
Res onse To This Notice
Enclosed as part of this Notice is a document entitled Response Options for Pipehne Otferatdrs
in Compliance Proceedings. Please refer to this document and note the response opttorite Be
advised that all material you submit in response to this enforcement action is subject to being
made publicly available. If you believe that any portion of your responsive material qualifies for
confidential treatment under 5 U. S. C. 552(b), along with the complete original document you
must provide a second a second copy of the document with the portions you believe qualify for
confidential treatment redacted and an explanation of why you should believe the redacted
information qualifies for confidential treatment under 5 U. S. C. 552(b) If you do not respond
within 30 days of receipt of this Notice, this constitutes a waiver of your rights to contest the
allegations in this Notice and authonzes the Associate Administrator for Pipeline Safety to find
facts as alleged in this Notice without further notice to you and to issue a Final Order.



In your correspondence on this matter, please refer to CPF 4-2007-5011 and for each document
you submit, please prowde a copy in electronic format whenever possible.
Sincerely,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous
Materials Safety Administration
Enclosure: Proposed Compliance Order
Response Options for Pipeline Operators in Compliance Proceedings



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code g 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Plains Pipeline, L. P. a Compliance Order
incorporating the following remedial requirements to ensure the compliance of Plains Pipeline,
L. P with the pipeline safety regulations:
In regard to Item Number 2 of the Notice, pertaining to periodically reviewing
work done by the Operator to determine the effectiveness of the procedures; you
will submit copies of Form 702 for each employee associated with the Basin
Pipeline System The Forms will be completed in accordance with your O&M
Manual. You will also submit a letter describing how the Forms were used to
determine the effectiveness of the procedures used in normal operation and
maintenance and taking corrective action where deficiencies are found. The
Forms and the letter will be submitted to this office within 30 days following
receipt of the Final Order.
In regard to Item Number 6 of the Notice pertaining to proper coating of exposed
spans for prevention of atmospheric corrosion, you will perform an audit to
ensure that Plains is in compliance with $195. 581. This audit shall consist of:
A. Review all applicable procedures and amend as necessary.
B. Survey all applicable segments of Plains pipe lines, paying particular
attention to pipe spans to ensure that they are protected from
atmospheric corrosion, and meet applicable procedures.
C. Based upon the review and survey, develop a plan for repairing/recoating
of facilities to bring Plains into compliance.
Results of surveys and plans, with time tables, must be submitted to Mr. R. M.
Seeley, Director, Southwest Region, within 30 days following the receipt of the
Final Order. All Items shall be completed within 90 days following receipt of the
final Order.
Plains Pipeline, L. P. shall maintain documentation of the safety improvement
costs associated with fulfilling this Compliance Order and submit the total to Mr.
R. M. Seeley, Director, Southwest Region, Pipeline and Hazardous Materials
Safety Administration. Costs shall be reported in two categories: 1) total cost
associated with preparation/revision of plans, procedures, studies and analysis,
and 2) total cost associated with replacements, additions and other changes to
pipeline infrastructure

420075011_final order_11072008_text.pdf

U S Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Ave S E
Washington DC 20590
No'It' 7 gp08
Mr. Harry N. Pefannis
President
Plains Pipeline, L. P.
333 Clay St.
Suite 1600
,
Houston, TX 77002
Re: CPF No. 4-2007-5011
Dear Mr. Pefannis:
Enclosed is the Final Order issued in the above-referenced case. It makes findings of violation,
specifies certain actions to be taken to comply with the pipeline safety regulations, and
acknowledges that Plains Pipeline has completed other actions specified in the Notice. When the
terms of the compliance order have been completed, as determined by the Director, Southwest
Region, this enforcement action will be closed Your receipt of the Final Order constitutes
service of that document under 49 C. F. R ( 190. 5,
Thank you for your cooperation in this matter
Sincerely,
Jeffrey D. Wiese
Associate Admmistrator
for Pipeline Safety
Enclosure
cc: Mr. R. M. Seeley, Director, Southwest Region, PHMSA
CERTIFIED MAIL — RETURN RECEIPT RE UESTED



U. S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D. C. 20590
In the Matter of
Plains Pipeline, L. P.
,
Respondent.
CPF No. 4-2007-5011
FINAL ORDER
On May 23-27, June 14-16 and 20-24, September 12-16 and October 24-28, 2005, pursuant to 49
U. S. C. $ 60117, a representative of the Pipeline and Hazardous Materials Safety Administration,
Office of Pipeline Safety (OPS), conducted an on-site pipeline safety inspection of the facilities
and records of the following lines operated by Plains Pipeline, L. P. (Plains or Respondent):
Johnson Bayou to Sabine Pass; Basin Pipeline System between Cushing, Oklahoma, and Jal,
New Mexico; Red River System between Cushing, Oklahoma, and Longview, Texas; and the
Ferriday System from Greensburg, Louisiana, to Delhi Station, Louisiana. Plains, a subsidiary of
Plains All American Pipeline, L. P.
,
is engaged in the interstate pipeline transportation of crude
oil and refined petroleum products.
As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to
Respondent, by letter dated April 18, 2007, a Notice of Probable Violation and Proposed
Compliance Order (Notice). In accordance with 49 C. F. R. $ 190. 207, the Notice proposed
finding that Respondent had committed violations of 49 C. F. R. )$ 195. 402(c)(13) and
195. 581(a) and proposed ordering Respondent to take certain measures to correct the alleged
violations. The Notice also proposed finding that Respondent had committed other probable
violations of 49 C. F. R. )( 195. 54(a), 195. 430(a), 195. 404(b)(1) and (2), 195. 412(a), and
195. 420(c) and warned Respondent to take appropriate corrective action to address them or be
subject to future possible enforcement action.
Respondent responded to the Notice by letter dated May 23, 2007 (Response). Respondent
provided comments regarding the alleged violations and proposed compliance order, as well as
information concerning the corrective actions it had already taken to comply with the cited safety
regulations. Respondent did not request a hearing and therefore has waived its right to one.
FINDINGS OF VIOLATION
The Notice alleged that Respondent violated 49 C. F. R. Part 195 as follows:



Item 2A: The Notice alleged that Respondent violated 49 C. F, R $ 195, 402(c)(13), which states:
g 195. 402 Procedural manual for operations, maintenance, and emergencies.
(a) General Each operator shall prepare and follow for each pipeline system a
manual of written procedures for conducting normal operations and maintenance
activities and handling abnormal operations and emergencies. This manual shall be
reviewed at intervals not exceeding 15 months, but at least once each calendar year,
and appropriate changes made as necessary to insure that the manual is effective. This
manual shall be prepared before initial operations of a pipeline system commence,
and appropriate parts shall be kept at locations where operations and maintenance
activities are conducted. . . .
(c) Maintenance and normal operations The manual required by paragraph (a)
of this section must include procedures for the following to provide safety during
maintenance and normal operations;. . .
(13) Periodically reviewing the work done by operator personnel to determine
the effectiveness of the procedures used in normal operation and maintenance and
taking corrective action where deficiencies are found. . . .
The Notice alleged that Respondent violated 49 C. F. R. $ 195. 402(c)(13) by failing to follow its
own procedures, which required an annual review of the work performed by Plains' personnel to
determine the effectiveness of Respondent's normal operations and maintenance (OEM)
procedures. According to its OAM Manual, Respondent's personnel were supposed to fill out
Form 702 (" Annual Personnel Training Review" ) each year for every employee in order to
address their finictional competencies of operation, maintenance, safety, and emergency
procedures under $ 195. 402(c)(13). The OPS inspector observed that Form 702 had not been
filled out for each employee for the last three years. The inspector further observed that very few
Form 702s had ever been filled out. In its Response, Plains did not contest this Item but
submitted information requested by OPS pursuant to the proposed compliance order.
Accordingly, I find that Respondent violated 49 C. F. R. $ 195. 402(c)(13) by failing to follow its
procedures and perform periodic reviews of the work done by personnel to determine the
effectiveness of the procedures used in normal OAM.
Item 6: The Notice alleged that Respondent violated 49 C. F. R. $ 195. 581(a), which states:
g 195. 5S1 Which pipeliues must I protect against atmospheric corrosion and
what coating material may I use?
(a) You must clean and coat each pipeline or portion of pipeline that is exposed to
the atmosphere, except pipelines under paragraph (c) of this section.
(b) Coating material must be suitable for the prevention of atmospheric corrosion.
(c) Except portions of pipelines in offshore splash zones or soil-to-air interfaces,
you need not protect against atmospheric corrosion any pipeline for which you
demonstrate by test, investigation, or experience appropriate to the environment of
the pipeline that corrosion will—
(1) Only be a light surface oxide; or
(2) Not affect the safe operation of the pipeline before the next scheduled
inspection.



The Notice alleged that four spans of exposed pipe on Respondent's Red River System were not
properly coated for prevention of atmospheric corrosion. Specifically, the span at RL 77. 84 had
subsurface coating in poor condition; the span at MP 22. 39, Highway 74, had bare exposed pipe
across a ditch; the span at RL 66. 41, north of Hall Road, had approximately 50 feet of bare pipe
across a 30-foot-deep gully; and the span at RL 46. 9, on the creek span north of CR 5060, had
approximately 50 feet of bare pipe across a 12-foot-deep creek. In its Response, Plains did not
contest this allegation and did not demonstrate by test, investigation, or experience appropriate to
the environment of the pipeline that corrosion will: only be a light surface oxide; or not affect the
safe operation of the pipeline before the next scheduled inspection. Accordingly, I find that
Respondent violated 49 C. F. R. $ 195. 581(a) by failing to clean and coat each portion of pipeline
exposed to the atmosphere with a coating material suitable for the prevention of atmospheric
corrosion.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Items 2A and 6 in the Notice for
violations of 49 C. F. R. $$ 195. 402(c)(13) and 195. 581(a), respectively. Under 49 U S. C.
$ 60118(a), each person who engages in the transportation of gas or hazardous liquids or who
owns or operates a pipeline facility is required to comply with the applicable safety standards
established under chapter 601.
With regard to Item 2A, Respondent submitted information indicating that Plains had procedures
in place to review periodically the work of its personnel to determine the effectiveness of its
procedures used in normal operation and maintenance and in taking corrective action whenever
deficiencies were found. These materials have been reviewed by the Director and found to
satisfy the requirements of 49 C. F. R. $ 195. 402(c)(13). Therefore, no additional corrective
action is necessary for Item 2A.
With regard to Item 6, Respondent submitted information indicating that Plains had developed a
mitigation plan subsequent to the inspection that included a survey of its facilities and a schedule
of repairs over three years. However, Respondent's submittal lacked a detailed report on each of
the 45 pipe exposure sites, including precise location, description of the corrective measures
taken, or the dates that the work was performed or scheduled. Also, Respondent provided cost
estimates for future repairs, rather than the actual cost of repairing the 45 pipe exposure sites.
Accordingly, further action is required. Pursuant to the authority of 49 U. S, C. $ 60118(b) and 49
C. F. R. $ 190. 217, Respondent is ordered to take the following actions to ensure compliance with
the pipeline safety regulations applicable to its operations. Respondent must—
1. In regard to Item 6 of the Notice pertaining to the four spans of exposed pipe, the
results of Respondent's surveys and plans, with time tables, must be submitted to
the Director within 30 days following the receipt of the Final Order.



2, In regard to Item 6 of the Notice pertaining to the four spans of exposed pipe,
Respondent shall maintain documentation of the safety improvement costs
associated with fulfilling this Compliance Order and submit the total to the
Director within 30 days following the receipt of the Final Order. Costs shall be
reported in two categories: 1) total cost associated with preparation/revision of
plans, procedures, studies, and analysis; and 2) total cost associated with
replacements, additions and other changes to pipeline infrastructure.
The Director may grant an extension of time to comply with any of the required items upon a
written request timely submitted by the Respondent demonstrating good cause for an extension.
Failure to comply with this Order may result in administrative assessment of civil penalties not
to exceed $100, 000 for each violation for each day the violation continues or in referral to the
Attorney General for appropriate relief in a district court of the United States.
WARNING ITEMS
With respect to Items 1, 2B, 3, 4, and 5, the Notice alleged various probable violations of Part
195 but did not propose a civil penalty or compliance order for these items. Therefore, these are
considered to be warning items. The warnings were for:
49 C. F. R. $ 195, 54(a) (Item I) — Respondent's alleged failure to report two
accidents to DOT within 30 days;
49 C. F. R. $ 195. 430(a) (Item 2B) — Respondent's alleged failure for 24 months,
from May, 2003 to April, 2005, to record monthly inspections for three fire
extinguishers at Lindsey Station, as required by Respondent's OAM Manual,
Section 419;
49 C. F. R. $ 195. 404(b)(1) and (2) (Item 3) — Respondent's alleged failure to
maintain for at least three years daily operating records that indicate accurate
discharge pump pressure histories, for May 1, 2004 and May 18, 2004, on the
Basin Pipeline System;
49 C. F. R. $ 195. 412(a) (Item 4) - Respondent's alleged failure to inspect the
surface conditions on the Basin Pipeline System right-of-way at intervals not
exceeding three weeks; and
49 C. F. R. $ 195. 420(c) (Item 5) — Respondent's alleged failure to provide
protection against vandalism at several valve sites.
Respondent presented information in its Response showing that it had taken certain actions to
address the cited items. Having considered such information, I find, pursuant to 49 C. F. R.
) 190. 205, that probable violations of 49 C. F. R. $ 195. 54(a) (Notice Item 1), 49 C. F. R.
$ 195. 430(a) (Notice Item 2B), 49 C. F. R $ 195. 404(b)(1) and (2) (Notice Item 3), 49 C. F. R.
$ 195. 412(a) (Notice Item 4) and 49 C. F. R. $ 195. 420(c) (Notice Item 5) have occurred and
Respondent is hereby advised to correct such conditions.



In the event that OPS finds a violation for any of these items in a subsequent inspection,
Respondent may be subject to future enforcement action.
Under 49 C. F. R. $ 190, 215, Respondent has a right to submit a Petition for Reconsideration of
this Final Order. The petition must be received within 20 days of Respondent's receipt of this
Final Order and must contain a brief statement of the issue(s). The terms of the order, including
any required corrective action and amendment of procedures, shall remain in full force and effect
unless the Associate Administrator, upon request, grants a stay. The terms and conditions of this
Final Order shall be effective upon receipt.
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Date Issued
- **truncated:** false
- **body characters:** 27754