{"operation":"document","citation":"CPF 420105007","title":"HOLLY ENERGY PARTNERS - OPERATING, L.P. — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-02-26","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.571, 195.573(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420105007.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420105007.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420105007","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420105007","body":"Notice of Probable Violation involving HOLLY ENERGY PARTNERS - OPERATING, L.P.. PHMSA's enforcement data identifies the cited regulations as 195.571,  195.573(e). The case was opened on 2010-02-26 and is reported as closed as of 2010-12-07. Proposed civil penalty: $45,000. Assessed civil penalty: $45,000. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420105007_Closure_12072010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420105007/420105007_Closure_12072010.pdf\n\n420105007_Closure_12072010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420105007/420105007_Closure_12072010_text.pdf\n\n420105007_FinalOrder_10182010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420105007/420105007_FinalOrder_10182010.pdf\n\n420105007_FinalOrder_10182010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420105007/420105007_FinalOrder_10182010_text.pdf\n\n420105007_NOPV PCP PCO_02262010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420105007/420105007_NOPV%20PCP%20PCO_02262010.pdf\n\n420105007_NOPV PCP PCO_02262010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420105007/420105007_NOPV%20PCP%20PCO_02262010_text.pdf\n\n420105007_Response to NOPV PCP PCO_03292010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420105007/420105007_Response%20to%20NOPV%20PCP%20PCO_03292010.pdf\n\n420105007_Response to NOPV PCP PCO_05272010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420105007/420105007_Response%20to%20NOPV%20PCP%20PCO_05272010.pdf\n\n420105007_FinalOrder_10182010_text.pdf\n\nOCT 18 2010\nMr. Mark Cunningham\nVice President, Operations\nHolly Energy Partners, L.P.\n100 Crescent Court, Suite 1600\nDallas, TX 75201\nMr. Terry Hurlburt\nSenior Vice President, Operations\nEnterprise Products Operating, L.P.\nP. O. Box 4324\nHouston, TX 77210-4324\nRe: CPF No. 4-2010-5007\nDear Mr. Cunningham and Mr. Hurlburt:\nEnclosed please find the Final Order issued in the above-referenced case. It makes findings of\nviolation, assesses a civil penalty of $45,000, and specifies actions that need to be taken by Holly\nEnergy Partners, L.P., and Enterprise Products Operating, L.P., to comply with the pipeline\nsafety regulations. This is to acknowledge receipt of payment of the full penalty amount, by wire\ntransfer, dated March 31, 2010. When the terms of the compliance order have been completed,\nas determined by the Director, Southwest Region, 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: Mr. R. M. Seeley, Director, Southwest Region, PHMSA\nCERTIFIED MAIL – RETURN RECEIPT REQUESTED [7005 1160 0001 0041 0282]\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)\nHolly Energy Partners, L.P., ) CPF No. 4-2010-5007\n)\nand )\n)\nEnterprise Products Operating, L.P., )\n)\nRespondents. )\n____________________________________)\nFINAL ORDER\nOn November 3-7, 2008, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),\nconducted an on-site pipeline safety inspection of the Rio Grande Pipeline in Artesia, New\nMexico, which Holly Energy Partners, L.P. (Holly), operated and partially owned at the time of\nthe inspection.\nAs a result of the inspection, the Director, Southwest Region, OPS (Director), issued to Holly, by\nletter dated February 26, 2010, a Notice of Probable Violation, Proposed Civil Penalty, and\nProposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice\nproposed finding that Holly had violated 49 C.F.R. §§ 195.571 and 195.573(e), and proposed\nassessing a civil penalty of $45,000 for the alleged violations. The Notice also proposed that\nHolly be required to take certain measures to correct the alleged violations.\nHolly responded to the Notice by letter dated March 29, 2010 (Holly Response). The company\ndid not contest the allegations of violation and paid the proposed civil penalty of $45,000 as\nprovided in 49 C.F.R. § 190.227. Holly stated that it transferred operation of, and its majority\nownership in, the Rio Grande Pipeline on December 1, 2009, and that it would therefore be\nunable to satisfy any terms of the proposed compliance order with respect to that facility. By\nletter dated May 27, 2010, Enterprise Products Operating, L.P. (Enterprise), a subsidiary of\nEnterprise Products Partners, L.P., informed PHMSA that it was the new operator and majority\nowner of the Rio Grande Pipeline (Enterprise Response). The company explained that it had\nreceived the Notice and stated that it intended to satisfy the terms of the proposed compliance\norder. Neither Holly nor Enterprise requested a hearing, and therefore they have each waived\ntheir right to one.\n\n\n\n3\nIn their Responses, the Respondents did not contest the following allegations in the Notice:\nItem 1: The Notice alleged that Holly violated 49 C.F.R. § 195.471, which states:\n§ 195.471 What criteria must I use to determine the adequacy of\ncathodic protection?\nCathodic protection required by this Subpart must comply with one or\nmore of the applicable criteria and other considerations for cathodic\nprotection contained in paragraphs 6.2 and 6.3 of NACE SP 0169\n(incorporated by reference, see §195.3).\nThe Notice alleged that Holly failed to ensure that cathodic protection complied with applicable\n195.571 specifies that cathodic protection must comply with one or more of the criteria\ncriteria in paragraphs 6.2 and 6.3 of NACE Standard RP 0169 (NACE RP 0169).1 Section\nestablished in paragraphs 6.2 and 6.3 of NACE RP 0169. Paragraph 6.2.2.1.1 of NACE RP0169\nestablishes one of the criteria as a negative potential of at least 850 mV with the cathodic\nprotection applied.\nThe Notice alleged, based on records of pipe-to-soil readings, that thirteen specific test points on\nHolly’s system did not meet the -850 mV cathodic protection criterion at various points during\nthe period from 2005 to 2008. Holly did not contest this allegation of violation.\nRecords of pipe-to-soil readings indicated that Holly failed to maintain adequate cathodic\nprotection levels at the thirteen locations identified in the Notice. Accordingly, based upon a\nreview of all of the evidence, I find that Holly violated 49 C.F.R. § 195.471 by failing to ensure\nthat cathodic protection complied with the -850 mV criterion contained in paragraph 6.2 of\nNACE RP 0169.\nItem 2: The Notice alleged that Holly violated 49 C.F.R. § 195.573(e), which states:\n§ 195.573 -- What must I do to monitor external corrosion control?\n(a) . . . .\n(e) Corrective action. You must correct any identified deficiency in\ncorrosion control as required by §195.401(b). However, if the deficiency\ninvolves a pipeline in an integrity management program under §195.452,\nyou must correct the deficiency as required by §195.452(h).\nThe Notice alleged that Holly violated 49 C.F.R. § 195.573(e) by failing to correct identified\ndeficiencies in corrosion control as required by § 195.401(b). As described in Item 1, Holly\nfailed to demonstrate that adequate cathodic protection levels were maintained for the thirteen\nlocations identified in the Notice. Pipe-to-soil readings at ten of those locations exceeded the\n-850 mV criterion for at least two consecutive years. Any such inadequate reading constitutes a\ndeficiency in corrosion control that, per § 195.401(b), must be corrected “within a reasonable\n1 NACE International Standard Recommended Practice 0169, “Control of External Corrosion on Underground or\nSubmerged Metallic Piping Systems,” incorporated by reference at § 195.3.\n\n\n\n4\ntime,” which PHMSA has interpreted to mean before the next annual cathodic protection\ninspection cycle.2 The Notice alleged further that Holly’s corrosion control procedures did not\nspecify a timeline for correction of identified deficiencies in corrosion control.\nIn its Response, Holly did not contest the allegation of violation, but it described the actions it\nhad taken to address the inadequate pipe-to-soil readings. Holly stated that, after it took over\noperations of the Rio Grande Pipeline in 2005, it recognized the deficiencies indicated by the\ninadequate readings. The company stated that it attempted to address these inadequate readings\nby installing new impressed current cathodic protection systems and by replacing and upgrading\nexisting anode beds. According to the company, these steps failed to correct the pipe-to-soil\nreadings, and therefore it conducted an internal inspection tool assessment. Because this\nassessment showed no defects that met the criteria for repair, Holly determined that the\ninadequate pipe-to-soil readings did not indicate conditions that were detrimental to the safety of\nthe pipeline.\nAlthough Holly took certain corrective actions in response to the low readings, the record\ndemonstrates, and Holly did not contest, that the cathodic protection deficiencies were not\ncorrected within a reasonable time pursuant to §§ 195.573(e) and 195.401(b).\nAccordingly, based upon a review of all of the evidence, I find that Holly violated 49 C.F.R.\n§ 195.573 by failing to correct identified deficiencies in corrosion control within a reasonable\ntime.\nThese findings of violation will be considered prior offenses in any subsequent enforcement\naction taken against Holly.\nHaving reviewed the record and considered the assessment criteria, I assess Holly a civil penalty\nof $45,000 for the violations, which has already been paid.\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Items 1 and 2 in the Notice for\nviolations of 49 C.F.R. §§ 195.571 and 195.573(e), respectively. Under 49 U.S.C. § 60118(a),\neach person who engages in the transportation of hazardous liquids or who owns or operates a\npipeline facility is required to comply with the applicable safety standards established under\nchapter 601.\nBecause Enterprise received the Notice and is now the operator of the Rio Grande Pipeline, it is\nresponsible for satisfying the terms of the Compliance Order relating to the pipeline system at\nissue in this proceeding. Holly is responsible for complying with the terms of the Compliance\nOrder relating to its own procedures.\n2 See, e.g., In the Matter of Colonial Pipeline Co., Final Order, CPF 1-2002-5009, 2003 WL 25429887 (Dec. 10,\n2003) (finding violations of § 195.401(b) for cathodic protection deficiencies lasting two or three consecutive years).\n\n\n\n5\nPursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Enterprise is ordered\nto take the following actions to ensure compliance with the pipeline safety regulations applicable\nto its operations:\n1. Enterprise must provide documentation to the Director, Southwest Region, that\nsubstantiates that the Rio Grande Pipeline system throughout West Texas is in\ncompliance with § 195.573. This documentation must include the pipe-to-soil test\npoints listed in Tables I and II of the Notice.\n2. Within 30 days of receipt of this Final Order, Enterprise must provide the\ndocumentation described above to the Director, Southwest Region, Office of Pipeline\nSafety, PHMSA, 8701 South Gessner, Suite 1110, Houston, TX 77074.\n3. Enterprise must maintain documentation of the safety improvement costs associated\nwith fulfilling this Compliance Order and submit that total to the Director, Southwest\nRegion. Costs shall be reported in two categories: (1) total cost associated with\npreparation and revision of plans, procedures, studies, and analyses, and (2) total cost\nassociated with replacements, additions, and other changes to pipeline infrastructure.\nPursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Holly is ordered to\ntake the following actions to ensure compliance with the pipeline safety regulations applicable to\nits operations:\n1. Holly must provide documentation to the Director, Southwest Region, demonstrating\nthat its corrosion control procedures contain language that specifies a timeline for\ncorrection of identified deficiencies in corrosion control, as indicated by inadequate\npipe-to-soil readings. These procedures must be consistent with the requirements of\n§§ 195.401(b) and 195.452(h).\n2. Within 30 days of receipt of this Final Order, Holly must provide the documentation\ndescribed above to the Director, Southwest Region, Office of Pipeline Safety,\nPHMSA, 8701 South Gessner, Suite 1110, Houston, TX 77074.\n3. Holly must maintain documentation of the safety improvement costs associated with\nfulfilling this Compliance Order and submit that total to the Director, Southwest\nRegion. Costs shall be reported in two categories: (1) total cost associated with\npreparation and revision of plans, procedures, studies, and analyses, and (2) total cost\nassociated with replacements, additions, and other changes to 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 either Respondent and demonstrating good cause for an\nextension.\nFailure to comply with this Order may result in administrative assessment of civil penalties not\nto exceed $100,000 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.\n\n\n\n6\nUnder 49 C.F.R. § 190.215, each Respondent has a right to submit a Petition for Reconsideration\nof this 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 this Final Order by the\nRespondents, provided they contain a brief statement of the issue(s) and meet all other\nrequirements of 49 C.F.R. § 190.215. Unless the Associate Administrator, upon request, grants a\nstay, the 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\n\n420105007_Closure_12072010_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 7, 2010\nMr. Mark Cunningham\nVice President, Operations\nHolly Energy Partners, L.P.\n100 Crescent Court, Suite 1600\nDallas, TX 75201\nMr. Terry Hurlburt\nSenior Vice President, Operations\nEnterprise Products Operating, L.P.\nP.O. Box 4324\nHouston, TX 77210-4324\nCPF 4-2010-5007\nDear Mr. Cunningham and Mr. Hurlburt:\nOn October 18, 2010, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued to Holly Energy Partners, L.P. and Enterprise Products Operating, L.P. a Final Order in\nthe above-referenced case. This Order makes findings of violations and specified actions that\nneeded to be taken by Holly Energy Partners, L.P. and Enterprise Products Operating, L.P. in a\nCompliance Order. Based on our review of the documentation you provided, 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,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous\nMaterials Safety Administration\n\n420105007_NOPV PCP PCO_02262010_text.pdf\n\nNOTICE OF PROBABLE VIOLATION\nPROPOSED CIVIL PENALTY\nand\nPROPOSED COMPLIANCE ORDER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 26, 2010\nMr. Mark Cunningham\nVice President, Operations\nHolly Energy Partners\n100 Crescent Ct., Suite 1600\nDallas, Texas 75201\nCPF 4-2010-5007\nDear Mr. Cunningham:\nOn November 3 – 7, 2008, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code inspected Holly\nEnergy Partners (HEP) Rio Grande Pipeline Company’s records and procedures in Artesia,\nNew Mexico.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violations are:\n1. §195.571 Cathodic protection required by this subpart must comply with one or\nmore of the applicable criteria and other considerations for cathodic protection\ncontained in paragraphs 6.2 and 6.3 of NACE Standard RP 0169 (incorporated by\nreference, see §195.3).\nDuring the records review of the Rio Grande Pipeline, the PHMSA inspector asked HEP for\ntheir corrosion control procedures and pipe-to-soil records. After reviewing the corrosion\ncontrol procedures and pipe-to-soil records, the PHMSA inspector found several test points\nthat did not meet the -0.850 V corrosion criteria early in 2008 (see Table I) and for two and\nfour consecutive years between 2005 and 2008 (see Table II). HEP’s procedure referred to in\ntheir O&M manual as 6.0 HEP-O&M-195.563 (Cathodic Protection) states that the following:\n\n\n\n“Sufficient current must flow from soil to pipe to maintain a constant voltage difference at the\nsoil-metal interface of 0.25 volt (approximately -0.85 volt between pipe and copper sulfate\nelectrode in contact with soil) or more.”\nHEP failed to demonstrate adequate cathodic protection levels were maintained for the\nlocations identified in Tables I and II below by failing to meet the criteria specified in their\ncorrosion control procedures.\nTable I\n850 mV Criteria - 2008 Low Pipe-to-Soil Data\nRelative\nMilepost\nLocation\nDescription\nPipe-to-Soil\nReading (V)\n2005\nPipe-to-Soil\nReading (V)\n2006\nPipe-to-Soil\nReading (V)\n2007\nPipe-to-Soil\nReading (V)\n2008\n114.800 Test Lead\nMarker #172\n- 0.894 - 0.970 - 1.202 - 0.770\n121.600 Booster Sta.\n& Block Valve\n- 0.850 - 0.900 - 0.895 -0.707\n121.900 Kinder\nMorgan 20”\nCrossing\n- 1.130 - 0.913 - 0.891 -0.751\n2. §195.573(e) Corrective action. You must correct any identified deficiency in\ncorrosion control as required by §195.401(b). However, if the deficiency involves a\npipeline in an integrity management program under §195.452, you must correct the\ndeficiency as required by §195.452(h).\nDuring the records review of the Rio Grande Pipeline, the PHMSA inspector asked HEP for\ntheir corrosion control procedures and pipe-to-soil records. After reviewing the pipe-to-soil\nrecords, the PHMSA inspector found several test points that did not meet the -0.850 V\ncorrosion criteria for two and four consecutive years (see Table II). Pipelines having\ninadequate test readings for two consecutive years or more of annual survey data cannot\nprovide adequate levels of cathodic protection. The operator should have the evaluations and\ndecisions made and action started within a few months (proportionately less where required\nmonitoring is less than a year), and correction completed by the next scheduled monitoring.\nAdditionally, HEP’s corrosion control procedures do not contain language that specifying the\ntiming of corrective actions or the definition of “prompt action” or “reasonable time” as it\npertains to the correction of pipe to soil readings that fail to meet the minimum criteria.\n2\n\n\n\nTable II\n850 mV Criteria - Consecutive Low Pipe-to-Soil Data\nRelative\nMilepost\nLocation\nDescription\nPipe-to-Soil\nReading (V)\n2005\nPipe-to-Soil\nReading (V)\n2006\nPipe-to-Soil\nReading (V)\n2007\nPipe-to-Soil\nReading (V)\n2008\n75.300 Test Lead\nMarker #132\n- 0.622 - 0.594 - 0.771 - 0.667\n96.000 Test Lead\nMarker #153\nN/R N/R - 0.844 -0.683\n96.400 Test Lead N/R N/R - 0.661 -0.506\n96.500 Test Lead N/R -0.827 - 0.620 -0.550\n97.000\nTest Lead\nMarker #154\nKM#60\nN/R N/R - 0.670 -0.515\n100.000 Test Lead\nMarker #157\nKM#57\n- 0.712 - 0.735 - 0.724 -0.640\n103.000 Test Lead\nMarker #160\n- 0.754 - 0.719 N/R N/R\n107.900\nTest Lead\nMarker #165 - 0.773 - 0.815 - 0.700 -0.704\n112.900\nTest Lead\nMarker #170 - 0.638 - 0.844 - 0.798 -0.552\n113.800 Test Lead\nMarker #171\nKM#43\n- 0.680 - 0.800 - 0.832 -0.494\nN/R - Not Relevant to establish the non-compliance.\nProposed Civil Penalty\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of $1,000,000\nfor any related series of violations. The Compliance Officer has reviewed the circumstances\nand supporting documentation involved in the above probable violations and has\nrecommended that you be preliminarily assessed a civil penalty of $45,000 as follows:\nItem number PENALTY\n1 $22,500\n2 $22,500\nProposed Compliance Order\nWith respect to items 1 and 2 pursuant to 49 United States Code § 60118, the Pipeline and\nHazardous Materials Safety Administration proposes to issue a Compliance Order to Holly3\n\n\n\nEnergy Partners. Please refer to the Proposed Compliance Order, which is enclosed and\nmade a part of this Notice.\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 the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not\nrespond within 30 days of receipt of this Notice, this constitutes a waiver of your right to\ncontest the allegations in this Notice and authorizes the Associate Administrator for Pipeline\nSafety to find facts as alleged in this Notice without further notice to you and to issue a Final\nOrder.\nIn your correspondence on this matter, please refer to CPF 4-2010-5007 and for each\ndocument you submit, please provide a copy in electronic format whenever possible\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous\nMaterials Safety Administration\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Compliance Proceedings\n4\n\n\n\nPROPOSED COMPLIANCE ORDER\nPursuant to 49 U.S.C. § 60118, the Office of Pipeline Safety proposes to issue to Holly Energy\nPartners a Compliance Order incorporating the following requirements to assure the\ncompliance of Holly Energy Partners with the pipeline safety regulations applicable to its\noperations.\n1. In regard to Items 1 and 2 of the Notice, Holly Energy must provide this office\ndocumentation that substantiates that the Rio Grande Pipeline system throughout\nWest Texas is in compliance with 49 CFR §195.573. This demonstration must\ninclude those pipe-to-soil test points specifically noted on Tables I and II of this letter.\nAdditionally, Holly Energy must provide this office its corrosion control procedure\nensuring that it contains language that specifies the timing of corrective as it pertains\nto the correction of pipe to soil readings that fail to meet the minimum criteria.\n2. Submit the results of the Proposed Compliance Order item above to the Region\nDirector, Southwest Region, Office of Pipeline Safety, Pipeline and Hazardous\nMaterials Safety Administration, 8701 South Gessner, Suite 1110, Houston, Texas\n77074. This is to be accomplished within 30 days following receipt of the Final\nOrder.\n3. Holly Energy shall maintain documentation of the safety improvement costs\nassociated with fulfilling this Compliance Order and submit the total to R. M. Seeley\nDirector, Southwest Region, Pipeline and Hazardous Materials Safety\nAdministration. Costs shall be reported in two categories: 1) total cost associated\nwith preparation/revision of plans, procedures, studies and analyses, and 2) total\ncost associated with replacements, additions and other changes to pipeline\ninfrastructure.\n5","truncated":false,"body_characters":24341}