{"operation":"document","citation":"CPF 420155009","title":"WEST TEXAS GULF PIPELINE CO — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-04-08","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.50(a), 195.50(b), 195.50(c), 195.50(d), 195.52, 195.54.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420155009.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420155009.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420155009","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420155009","body":"Notice of Probable Violation involving WEST TEXAS GULF PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 195.50(a),  195.50(b),  195.50(c),  195.50(d),  195.52,  195.54. The case was opened on 2015-04-08 and is reported as closed as of 2015-11-03. Proposed civil penalty: $141,000. Assessed civil penalty: $141,000. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420155009_Final Order_11032015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155009/420155009_Final%20Order_11032015.pdf\n\n420155009_Final Order_11032015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155009/420155009_Final%20Order_11032015_text.pdf\n\n420155009_NOPV PCP PCO 04082015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155009/420155009_NOPV%20PCP%20PCO%2004082015_text.pdf\n\n420155009_NOPV PCP PCO_04082015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155009/420155009_NOPV%20PCP%20PCO_04082015.pdf\n\n420155009_Operator Response to Notice_05082015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155009/420155009_Operator%20Response%20to%20Notice_05082015.pdf\n\n420155009_Final Order_11032015_text.pdf\n\nNovember 3, 2015\nMr. Robert Owens\nChief Executive Officer\nSunoco Pipeline, L.P.\n1818 Market Street, Suite 1500\nPhiladelphia, PA 19106\nRe: CPF No. 4-2015-5009\nDear Mr. Owens:\nEnclosed please find the Final Order issued in the above-referenced case. It makes findings of\nviolation and assesses a civil penalty of $141,000. This is to acknowledge receipt of payment of\nthe full penalty amount, by wire transfer, dated May 7, 2015. This enforcement action is now\nclosed. Service of the Final Order by certified mail is deemed effective upon the date of mailing,\nor 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: Mr. Rod M. Seeley, Region Director, Southwest Region, OPS\nMr. David Chalson, Vice President, Operations, Sunoco Pipeline, L.P.\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____________________________________\nIn the Matter of )\n)\n)\nWest Texas Gulf Pipeline Company, )\na subsidiary of Sunoco Pipeline, L.P. )\nRespondent. )\n____________________________________)\n) CPF No. 4-2015-5009\nFINAL ORDER\nOn March 4, 2015, pursuant to 49 U.S.C. § 60117, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety (OPS), received an information request for\nan alleged accident on the West Texas Gulf Pipeline Company (WTG or Respondent) facility,\nOPID #22442. WTG owns a 580-mile long crude oil pipeline from Colorado City, Texas to\nLongview, Texas, and operates as a subsidiary of Sunoco Pipeline L.P. (Sunoco). The WTG\nfacility at issue is located in Wortham, Texas. The alleged accident was described as having\noccurred while Sunoco and its contractors were performing pipeline modifications at the facility\nand resulted in a release of crude oil, ignition of the crude oil, and a serious injury requiring in-\npatient hospitalization, on or about February 19, 2013. After receiving the information request,\nPHMSA initiated an investigation into the alleged accident.\nAs a result of the investigation, the Region Director, Southwest Region, OPS (Director), issued\nto Respondent, by letter dated April 8, 2015, a Notice of Probable Violation and Proposed\nCompliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed\nfindings that Respondent violated 49 C.F.R. §§ 195.52 and 195.54 and proposed assessing a civil\npenalty of $141,000 for the alleged violations.\nRespondent responded to the Notice by letter dated May 8, 2015 (Response). The company did\nnot contest the allegations of violation and paid the proposed civil penalty of $141,000, as\nprovided in 49 C.F.R. § 190.227. Payment of the penalty serves to close the case with prejudice\nto Respondent.\nFINDINGS OF VIOLATION\nIn its Response, Respondent did not contest the allegations in the Notice that it violated 49\nC.F.R. Part 195, as follows:\n\n\n\nCPF No. 4-2015-5009\nPage 2\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.52, which states in part:\n§ 195.52 Immediate notice of certain accidents.\n(a) Notice requirements. At the earliest practicable moment following\ndiscovery of a release of the hazardous liquid or carbon dioxide\ntransported…, the operator of the system must give notice, in accordance\nwith paragraph (b) of this section, of any failure that:\n(1) Caused a death or a personal injury requiring hospitalization;\n(2) Resulted in either a fire or explosion not intentionally set by the\noperator\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.52 by failing to provide notice at\nthe earliest practicable moment following the discovery of the release of hazardous liquids at its\nfacility in Wortham, Texas. Specifically, the Notice alleged that the National Response Center\nhad no record of a report for the accident that occurred on or about February 19, 2013 at\nRespondent’s facility or any affiliated Sunoco facility. Additionally, PHMSA’s investigation\nrevealed that Sunoco conducted an internal investigation of the accident but failed to provide\nnotice to the National Response Center. Respondent did not contest this allegation of violation.\nAccordingly, based upon a review of all of the evidence, I find that Respondent violated 49\nC.F.R. § 195.52 by failing to provide notice at the earliest practicable moment following the\ndiscovery of the release of hazardous liquids at its facility in Wortham, Texas.\nItem 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.54, which states in part:\n§ 195.54 Accident reports.\n(a) Each operator that experiences an accident that is required to be reported under\n§ 195.50 must, as soon as practicable, but not later than 30 days after discovery of the\naccident, file an accident report on DOT Form 7000-1.\n§ 195.50 Reporting accidents\nAn accident report is required for each failure in a pipeline system subject to this part in\nwhich there is a release of the hazardous liquid or carbon dioxide transported resulting in\nany of the following:\n(a) Explosion or fire not intentionally set by the operator;\n(b) Release of 5 gallons or more of hazardous liquid or carbon dioxide…;\n(c) Death of any person;\n(d) Personal injury necessitating hospitalization\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.54 by failing to submit a written\nDOT Form 7000-1 for the accident in which there was a release of hazardous liquid resulting in\nan explosion and injury necessitating hospitalization. Specifically, the Notice alleged that\nRespondent violated 49 C.F.R. § 195.54 because the Wortham facility accident involved both an\nignition of crude oil and injury requiring hospitalization. Consequently, under § 195.54 the\naccident was required to be reported on DOT form 7000-1. Respondent did not contest this\nallegation of violation. Accordingly, based upon a review of all of the evidence, I find that\n\n\n\nCPF No. 4-2015-5009\nPage 3\nRespondent violated 49 C.F.R. § 195.54 by failing to submit a written DOT Form 7000-1 for the\naccident that occurred on or about February 19, 2013 in its Wortham, Texas facility.\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 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; and any effect\nthat the penalty may have on its ability to continue doing business; and the good faith of\nRespondent in attempting to comply with the pipeline safety regulations. In addition, I may\nconsider the economic benefit gained from the violation without any reduction because of\nsubsequent damages, and such other matters as justice may require. The Notice proposed a total\ncivil penalty of $141,000 for the violations cited above.\nItem 1: The Notice proposed a civil penalty of $70,500 for Respondent’s violation of 49 C.F.R.\n§195.52, for failing to provide notice at the earliest practicable moment following the discovery\nof the release of hazardous liquids at its facility in Wortham, Texas. Respondent neither\ncontested the allegation nor presented any evidence or argument justifying a reduction in the\nproposed penalty. Accordingly, having reviewed the record and considered the assessment\ncriteria, I assess Respondent a civil penalty of $70,500 for violation of 49 C.F.R. §195.52.\nItem 2: The Notice proposed a civil penalty of $70,500 for Respondent’s violation of 49 C.F.R.\n§ 195.54, for failing to submit a written DOT Form 7000-1 for an accident in which there was a\nrelease of hazardous liquid resulting in an explosion and injury necessitating hospitalization.\nRespondent neither contested the allegation nor presented any evidence or argument justifying a\nreduction in the proposed penalty. This probable violation is a repeat violation of CPF# 4-2010-\n5010, Item 2. Accordingly, having reviewed the record and considered the assessment criteria, I\nassess Respondent a civil penalty of $70,500 for violation of 49 C.F.R. § 195.54.\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 $141,000, which has already been\npaid in full.\n1 The Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011, Pub. L. No. 112-90, § 2(a)(1), 125 Stat.\n1904, January 3, 2012, increased the civil penalty liability for violating a pipeline safety standard to $200,000 per\nviolation for each day of the violation, up to a maximum of $2,000,000 for any related series of violations.\n\n\n\nCPF No. 4-2015-5009\nPage 4\nThe terms and conditions of this Final Order are effective upon service in accordance with 49\nC.F.R. § 190.5.\n___________________________________ __________________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n420155009_NOPV PCP PCO 04082015_text.pdf\n\nNOTICE OF PROBABLE VIOLATION\nPROPOSED CIVIL PENALTY\nand\nPROPOSED COMPLIANCE ORDER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 8, 2015\nMr. David Chalson\nVice President, Operations\nSunoco Pipeline, L. P.\n1818 Market Street, Suite 1500\nPhiladelphia, PA 19106\nCPF 4-2015-5009\nDear Mr. Chalson:\nOn March 4, 2015, the Pipeline and Hazardous Materials Administration (PHMSA), Southwest\nRegion Office of Pipeline Safety (SW Region, OPS) received an information request for an\nalleged event on the West Texas Gulf Pipeline Company, OPID #22442, which is operated by\nSunoco Logistics Partners, L. P. (Sunoco). The alleged accident was described as having\noccurred while Sunoco and its contractors were performing pipeline modifications at the\nWortham facility and having resulted in a release of crude oil, ignition of the crude oil, and a\nserious injury requiring in-patient hospitalization, on or about February 19, 2013.\nPHMSA, SW Region initiated an investigation into the alleged accident. As a result of the\ninvestigation, it appears that you have committed probable violations of the Pipeline Safety\nRegulations, Title 49, Code of Federal Regulations. The items inspected and the probable\nviolations are:\n\n\n\n1. §195.52 Immediate notice of certain accidents.\n(a) Notice requirements. At the earliest practicable moment following discovery of a\nrelease of the hazardous liquid or carbon dioxide transported resulting in an event\ndescribed in §195.50, the operator of the system must give notice, in accordance with\nparagraph (b) of this section, of any failure that:\n(1) Caused a death or a personal injury requiring hospitalization;\n(2) Resulted in either a fire or explosion not intentionally set by the operator;\nSunoco failed to provide immediate notice of an accident that occurred on February 19, 2013 on\nits West Texas Gulf Pipeline at its facility in Wortham, Texas. The accident involved a release\nof crude oil, ignition of the crude oil, and an injury requiring in-patient hospitalization. The\nNational Response Center has no record of a report for the accident on or about February 19,\n2013 for the Wortham, TX, West Texas Gulf Pipeline or any affiliated Sunoco entities.\nThis probable violation is a repeat violation of CPF# 4-2010-5010, Item 1.\n2. §195.54 Accident Reports.\n(a) Each operator that experiences an accident that is required to be reported under\n§195.50 must, as soon as practicable, but not later than 30 days after discovery of\nthe accident, file an accident report on DOT Form 7000-1.\n§195.50 Reporting accidents.\nAn accident report is required for each failure in a pipeline system subject to this\npart in which there is a release of the hazardous liquid or carbon dioxide\ntransported resulting in any of the following:\n(a) Explosion or fire not intentionally set by the operator….\n(d) Personal injury necessitating hospitalization;\nSunoco failed to submit a written DOT Form 7000-1 for an accident that occurred on February\n19, 2013, on its West Texas Gulf Pipeline at its Wortham facility in which a release of crude oil\ninvolved an ignition of product and an injury requiring in-patient hospitalization.\nThis probable violation is a repeat violation of CPF# 4-2010-5010, Item 2.\nProposed Civil Penalty\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\n2\n\n\n\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\nrelated series of violations. The Compliance Officer has reviewed the circumstances and\nsupporting documentation involved in the above probable violation(s) and has recommended that\nyou be preliminarily assessed a civil penalty of $141,000 as follows:\nItem number PENALTY\n1 $ 70,500\n2 $ 70,500\nProposed Compliance Order\nWith respect to Item 2, pursuant to 49 United States Code § 60118, PHMSA proposes to issue a\nCompliance Order to Sunoco. Please refer to the Proposed Compliance Order, which is\nenclosed and made a part of this Notice.\nResponse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators\nin Compliance Proceedings. Please refer to this document and note the response options. All\nmaterial you submit in response to this enforcement action may be made publicly available. If\nyou believe that any portion of your responsive material qualifies for confidential treatment\nunder 5 U.S.C. 552(b), along with the complete original document you must provide a second\ncopy of the document with the portions you believe qualify for confidential treatment redacted\nand an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b). If you do not respond within 30 days of receipt of this Notice,\nthis constitutes a waiver of your right to contest the allegations in this Notice and authorizes the\nAssociate Administrator 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 4-2015-5009 and for each document\nyou submit, please provide a copy in electronic format whenever possible.\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\ncc via e-mail: TGNardozzi@SunocoLogistics.com, LEJensen@SunocoLogistics.com\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Compliance Proceedings\n3\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 Sunoco Logistics Partners, L. P. (Sunoco) a\nCompliance Order incorporating the following remedial requirements to ensure the compliance\nof Sunoco with the pipeline safety regulations:\n1. In regard to Item Number 2 of the Notice pertaining to Sunoco’s failure to submit\nDOT Form 7000-1 for the accident that occurred on or about February 19, 2013,\nSunoco shall submit Form 7000-1 within 10 calendar days of the issuance of this\nFinal Order. Additionally, Sunoco shall provide to PHMSA any incident\ninvestigation report(s) completed by Sunoco, and identify any corrective action(s)\ntaken to date to prevent recurrence of a similar event.\n2. It is requested (not mandated) that Sunoco maintain documentation of the safety\nimprovement costs associated with fulfilling this Compliance Order and submit\nthe total to R. M. Seeley, Director, Southwest Region, Pipeline and Hazardous\nMaterials Safety Administration. It is requested that these costs be reported in\ntwo categories: 1) total cost associated with preparation/revision of plans,\nprocedures, studies and analyses, and 2) total cost associated with replacements,\nadditions and other changes to pipeline infrastructure.\n4\n\n420155009_NOPV PCP PCO_04082015.pdf\n\nu.s. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n8701 South Gessner, Suite 111 0\nHouston, TX 77074\nNOTICE OF PROBABLE VIOLATION\nPROPOSED CIVIL PENALTY\nand\nPROPOSED COMPLIANCE ORDER\nCERTIFIED MAIL -RETURN RECEIPT REQUESTED\nApril 8, 2015\nMr. David Chalson\nVice President, Operations\nSunoco Pipeline, L. P.\n1818 Market Street, Suite 1500\nPhiladelphia, PA 19106\nCPF 4-2015-5009\nDear Mr. Chalson:\nOn March 4, 2015, the Pipeline and Hazardous Materials Administration (PHMSA), Southwest\nRegion Office of Pipeline Safety (SW Region, OPS) received an information request for an\nalleged event on the West Texas Gulf Pipeline Company, OPID #22442, which is operated by\nSunoco Logistics Partners, L. P. (Sunoco ). The alleged accident was described as having\noccurred while Sunoco and its contractors were performing pipeline modifications at the\nWortham facility and having resulted in a release of crude oil, ignition of the crude oil, and a\nserious injury requiring in-patient hospitalization, on or about February 19, 2013.\nPHMSA, SW Region initiated an investigation into the alleged accident. As a result of the\ninvestigation, it appears that you have committed probable violations of the Pipeline Safety\nRegulations, Title 49, Code of Federal Regulations. The items inspected and the probable\nviolations are:\n\n\n\n1. §195.52 Immediate notice of certain accidents.\n(a) Notice requirements. At the earliest practicable moment following discovery of a\nrelease of the hazardous liquid or carbon dioxide transported resulting in an event\ndescribed in §195.50, the operator of the system must give notice, in accordance with\nparagraph (b) of this section, of any failure that:\n(1) Caused a death or a personal injury requiring hospitalization;\n(2) Resulted in either a fit·e or explosion not intentionally set by the operator;\nSunoco failed to provide immediate notice of an accident that occurred on February 19, 2013 on\nits West Texas Gulf Pipeline at its facility in Wortham, Texas. The accident involved a release\nof crude oil, ignition of the crude oil, and an injury requiring in-patient hospitalization. The\nNational Response Center has no record of a report for the accident on or about February 19,\n2013 for the Wortham, TX, West Texas Gulf Pipeline or any affiliated Sunoco entities.\nThis probable violation is a repeat violation of CPF# 4-2010-5010, Item 1.\n2. §195.54 Accident Reports.\n(a) Each operator that experiences an accident that is required to be reported under\n§195.50 must, as soon as practicable, but not later than 30 days after discovery of\nthe accident, file an accident report on DOT Form 7000-1.\n§195.50 Reporting accidents.\nAn accident report is required for each failure in a pipeline system subject to this\npart in which there is a release of the hazardous liquid or carbon dioxide\ntransported resulting in any of the following:\n(a) Explosion or fire not intentionally set by the operator ....\n(d) Personal injury necessitating hospitalization;\nSunoco failed to submit a written DOT Form 7000-1 for an accident that occurred on February\n19, 2013, on its West Texas Gulf Pipeline at its Wortham facility in which a release of crude oil\ninvolved an ignition of product and an injury requiring in-patient hospitalization.\nThis probable violation is a repeat violation of CPF# 4-2010-5010, Item 2.\nProposed Civil Penalty\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\n2\n\n\n\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\nrelated series of violations. The Compliance Officer has reviewed the circumstances and\nsupporting documentation involved in the above probable violation(s) and has recommended that\nyou be preliminarily assessed a civil penalty of $141,000 as follows:\nItem number\n1\n2\nPENALTY\n$70,500\n$70,500\nProposed Compliance Order\nWith respect to Item 2, pursuant to 49 United States Code § 60118, PHMSA proposes to issue a\nCompliance Order to Sunoco. Please refer to the Proposed Compliance Order, which is\nenclosed and made a part of this Notice.\nResponse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators\nin Compliance Proceedings. Please refer to this document and note the response options. All\nmaterial you submit in response to this enforcement action may be made publicly available. If\nyou believe that any portion of your responsive material qualifies for confidential treatment\nunder 5 U .S.C. 552(b ), along with the complete original document you must provide a second\ncopy of the document with the portions you believe qualify for confidential treatment redacted\nand an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b). If you do not respond within 30 days of receipt of this Notice,\nthis constitutes a waiver of your right to contest the allegations in this Notice and authorizes the\nAssociate Administrator 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 4-2015-5009 and for each document\nyou submit, please provide a copy in electronic format whenever possible.\nSincerely,\n~4\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\ncc via e-mail: TGNardozzi@SunocoLogistics.com, LEJensen@SunocoLogistics.com\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Compliance Proceedings\n3\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 Sunoco Logistics Partners, L. P. (Sunoco) a\nCompliance Order incorporating the following remedial requirements to ensure the compliance\nof Sunoco with the pipeline safety regulations:\n1. In regard to Item Number 2 of the Notice pertaining to Sunoco's fai lure to submit\nDOT Form 7000-1 for the accident that occurred on or about February 19, 2013,\nSunoco shall submit Form 7000-1 within 10 calendar days of the issuance of this\nFinal Order. Additionally, Sunoco shall provide to PHMSA any incident\ninvestigation report(s) completed by Sunoco, and identify any corrective action(s)\ntaken to date to prevent recurrence of a similar event.\n2. It is requested (not mandated) that Sunoco maintain documentation of the safety\nimprovement costs associated with fulfilling this Compliance Order and submit\nthe total to R. M. Seeley, Director, Southwest Region, Pipeline and Hazardous\nMaterials Safety Administration. It is requested that these costs be reported in\ntwo categories: 1) total cost associated with preparation/revision of plans,\nprocedures, studies and analyses, and 2) total cost associated with replacements,\nadditions and other changes to pipeline infrastructure.\n4","truncated":false,"body_characters":24744}