{"operation":"document","citation":"CPF 420192001","title":"GENESIS OFFSHORE HOLDINGS, LLC — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-01-28","effective_on":null,"summary":"CLOSED notice of probable violation citing 192.479(a), 192.605(a), 192.605(c)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420192001.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420192001.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420192001","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420192001","body":"Notice of Probable Violation involving GENESIS OFFSHORE HOLDINGS, LLC. PHMSA's enforcement data identifies the cited regulations as 192.479(a),  192.605(a),  192.605(c)(4). The case was opened on 2019-01-28 and is reported as closed as of 2020-01-24. Proposed civil penalty: $52,400. Assessed civil penalty: $52,400. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420192001_Final Order_01242020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420192001/420192001_Final%20Order_01242020.pdf\n\n420192001_Final Order_01242020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420192001/420192001_Final%20Order_01242020_text.pdf\n\n420192001_NOPV PCP PCO_01282019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420192001/420192001_NOPV%20PCP%20PCO_01282019.pdf\n\n420192001_NOPV PCP PCO_01282019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420192001/420192001_NOPV%20PCP%20PCO_01282019_text.pdf\n\n420192001_Operator Response to Notice_02262019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420192001/420192001_Operator%20Response%20to%20Notice_02262019.pdf\n\n420192001_NOPV PCP PCO_01282019_text.pdf\n\nNOTICE OF PROBABLE VIOLATION\nPROPOSED CIVIL PENALTY\nand\nPROPOSED COMPLIANCE ORDER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 28, 2019\nJeff Gifford\nVice President\nGENESIS OFFSHORE HOLDINGS, LLC\n919 Milam St. Suite 2100\nHouston, Texas 77002\nCPF 4-2019-2001\nDear Mr. Gifford:\nOn, March 6, 2017 through June 12, 2017, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49\nUnited States Code (U.S.C.) inspected procedures, records, and facilities for your Viosca Knoll,\nIndependence Trail, Anaconda, and High Island offshore gas pipeline systems in the Gulf of\nMexico.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n\n\n\n1. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(c) Abnormal operation. For transmission lines, the manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety when operating design\nlimits have been exceeded:\n(4) Periodically reviewing the response of operator personnel to determine the effectiveness\nof the procedures controlling abnormal operation and taking corrective action where\ndeficiencies are found.\nGenesis Offshore Holdings failed to follow its O&M Gas Manual procedure for conducting\nperiodic reviews. Genesis could not provide records to show the periodic reviews were conducted\nfor work done by operating personnel.\nGenesis O&M Procedure Manual – Gas - Abnormal Operation (Section 300) 3.3 requires that the\nPipeline Control Room Manager and all Location Supervisors shall periodically review the\nresponse of their personnel to determine the effectiveness of these abnormal operation procedures\nand take corrective action where deficiencies are found. Additionally, Section 200, 2.0, item 4\nrequires that Form 201A to be completed for everyone during the effectiveness review.\nDuring the audit, PHMSA requested a copy of form 201A as an example of record review. Genesis\nprovided a copy of form 601A, which is the form referred to in O&M Procedure Manual -Liquid,\nbut it applies to both gas and liquid systems which is inconsistent with O&M Procedure Manual -\nGas requirements.\n2. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of written\nprocedures for conducting operations and maintenance activities and for emergency\nresponse. For transmission lines, the manual must also include procedures for handling\nabnormal operations. This manual must be reviewed and updated by the operator at intervals\nnot exceeding 15 months, but at least once each calendar year. This manual must be prepared\nbefore operations of a pipeline system commence. Appropriate parts of the manual must be\nkept at locations where operations and maintenance activities are conducted.\nGenesis failed to follow its procedure (Abnormal Operation - Section 300 in the O&M\nSection 3.1) using the appropriate forms to document and record the communications and\nactions taken by the field personnel and control room during and after Abnormal Operation\nCondition.\nDuring the audit, the PHMSA inspector reviewed two Abnormal Operation Conditions\nlisted on console 4 in the Control Room report (9/27/2016_AC Power Fail, and\n11/20/2016_Outgoing Valve shows open). The PHMSA inspector noticed that there were\nno forms or documentation generated as per the procedure to record the communications\nand actions taken by the field personnel. Genesis informed the PHMSA inspector, they\nonly use phone calls and e-mail to communicate such actions.\n2\n\n\n\n3. §192.479 Atmospheric corrosion control: General\n(a) Each operator must clean and coat each pipeline or portion of pipeline that is\nexposed to the atmosphere, except pipelines under paragraph (c) of this section.\nGenesis failed to clean and coat portions of their pipeline exposed to the atmosphere at the\n30” HVLT-301D valve area and at the 30” HVRT-304A valve area. The PHMSA inspector\nobserved disbonded coating, atmospheric corrosion, and severe pitting on flanges, risers,\nvalves, and the pipeline.\nProposed Civil Penalty\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$213,268 per violation per day the violation persists, up to a maximum of $2,132,679 for a related\nseries of violations. For violation occurring on or after November 2, 2015 and before November\n27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum\npenalty not to exceed $2,090,022. For violations occurring prior to November 2, 2015, the\nmaximum penalty may not exceed $200,000 per violation per day, with a maximum penalty not to\nexceed $2,000,000 for a related series of violations. The Compliance Officer has reviewed the\ncircumstances and supporting documentation involved in the above probable violations and has\nrecommended that you be preliminarily assessed a civil penalty of $52,400 as follows:\nItem number\nPENALTY\n2\n3\n$24,500\n$27,900\nWarning Items\nWith respect to item 1 we have reviewed the circumstances and supporting documents involved in\nthis case and have decided not to conduct additional enforcement action or penalty assessment\nproceedings at this time. We advise you to promptly correct this item. Failure to do so may result\nin additional enforcement action.\nProposed Compliance Order\nWith respect to item 3 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials Safety\nAdministration proposes to issue a Compliance Order to GENESIS OFFSHORE HOLDINGS,\nLLC. Please refer to the Proposed Compliance Order, which is enclosed and made a part of this\nNotice.\nResponse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. All\n3\n\n\n\nmaterial you submit in response to this enforcement action may be made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. 552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, or request a\nhearing under 49 CFR § 190.211. 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. If you are responding to this Notice, we propose that you\nsubmit your correspondence to my office within 30 days from receipt of this Notice. This period\nmay be extended by written request for good cause.\nIn your correspondence on this matter, please refer to CPF 4-2019-2001 and, for each document\nyou submit, please provide a copy in electronic format whenever possible.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Compliance Proceedings\n4\n\n\n\nPROPOSED COMPLIANCE ORDER\nPursuant to 49 United States Code §60118, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) proposes to issue to GENESIS OFFSHORE HOLDINGS, LLC\na Compliance Order incorporating the following remedial requirements to ensure the compliance\nof GENESIS OFFSHORE HOLDINGS, LLC with the pipeline safety regulations:\n1. 2. In regard to Item Number 3 of the Notice pertaining to atmospheric corrosion and\ncoating damage on portions of pipeline that are exposed to the atmosphere on\nplatform HIA-573 on HIOS gas gathering system, Genesis must complete remedial\naction and submit documentation to PHMSA’s Southwest Region Director within\n30 days of issuance of the Final Order.\nIt is requested (not mandated) that GENESIS OFFSHORE HOLDINGS, LLC\nmaintain documentation of the safety improvement costs associated with fulfilling\nthis Compliance Order and submit the total to the Director, Southwest Region,\nPipeline and Hazardous Materials Safety Administration. It is requested that these\ncosts be reported in two categories: 1) total cost associated with\npreparation/revision of plans, procedures, studies and analyses, and 2) total cost\nassociated with replacements, additions and other changes to pipeline\ninfrastructure.\n5\n\n420192001_Final Order_01242020_text.pdf\n\nJanuary 24, 2020\nMr. Grant E. Sims\nChief Executive Officer\nGenesis Energy, LP\n919 Milam Street, Suite 2100\nHouston, Texas 77002\nRe: CPF No. 4-2019-2001\nDear Mr. Sims:\nEnclosed please find the Final Order issued in the above-referenced case to your subsidiary,\nGenesis Offshore Holdings, LLC (Genesis). It makes findings of violation and assesses a civil\npenalty of $52,400. It further finds that Genesis has completed the actions specified in the Notice\nto comply with the pipeline safety regulations. Therefore, when the civil penalty has been paid,\nthis enforcement action will be closed. Service of the Final Order by certified mail is effective\nupon the date of mailing, as provided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Ms. Mary McDaniel, Director, Southwest Region, Office of Pipeline Safety, PHMSA\nMr. Jeffrey W. Gifford, Vice President, HSSE, Genesis Energy, LP, 919 Milam Street,\nSuite 2100, Houston, Texas 77002\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 )\nGenesis Offshore Holdings, LLC, ) CPF No. 4-2019-2001\na subsidiary of Genesis Energy, LP, )\n)\n)\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nFrom March 6 through June 12, 2017, pursuant to 49 U.S.C. § 60117, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS), conducted an on-site pipeline safety inspection of the facilities and records of Genesis\nOffshore Holdings, LLC’s (Genesis or Respondent) offshore gas pipeline systems in the Gulf of\nMexico. Genesis is a subsidiary of Genesis Energy, LP, which has approximately 1,000 miles of\noffshore gas pipelines in the Gulf of Mexico.1\nAs a result of the inspection, the Director, Southwest Region, OPS (Director), issued to Respondent,\nby letter dated January 28, 2019, a Notice of Probable Violation, Proposed Civil Penalty, and\nProposed Compliance Order (Notice), which also included a warning pursuant to 49 C.F.R.\n§ 190.205. In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Genesis had\ncommitted two violations of 49 C.F.R. Part 192 and proposed assessing a civil penalty of $52,400\nfor the alleged violations. The Notice also proposed ordering Respondent to take certain measures\nto correct one of the alleged violations. The warning item required no further action but warned the\noperator to correct the probable violation or face possible future enforcement action.\nGenesis Energy, LP, on behalf of Genesis, responded to the Notice by letter dated February 26,\n2019 (Response). The company did not expressly contest either of the two allegations of violation,\nbut did offer additional information in response to the Notice. Respondent did not request a hearing\nand therefore has waived its right to one.\nFINDINGS OF VIOLATION\nThe Notice alleged that Respondent violated 49 C.F.R. Part 192, as follows:\n1 Genesis Energy, LP’s website, available at https://www.genesisenergy.com/operations/pipeline/offshore/naturalgas/\n(last accessed January 16, 2020).\n\n\n\nCPF No. 4-2019-2001\nPage 2\nItem 2: The Notice alleged that Respondent violated 49 C.F.R. § 192.605(a), which states:\n§ 192.605 Procedural manual for operations, maintenance, and\nemergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual\nof written procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least once each\ncalendar year. This manual must be prepared before operations of a pipeline\ncommence. Appropriate parts of the manual must be kept in locations where\noperations and maintenance activities are conducted.\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.605(a) by failing to follow its own\nmanual of written procedures for handling abnormal operations. Specifically, the Notice alleged\nthat Genesis failed to follow Section 3.1 of its Operations and Maintenance (O&M) Manual, which\nrequired that the “cause, consequences, and actions taken regarding the abnormal operation shall be\nreported in writing to the affected Operations Area Manager(s). Where appropriate, the report shall\ninclude recommendations to prevent a recurrence.” Section 3.1 goes on to list specific information\nthat should be included in the report, including, “at a minimum, the date and time of occurrence,\ndescription of the abnormal operation, sequence of events, personnel involved, and steps taken to\nrectify the situation.”2 During the inspection, Genesis did not provide any records generated in\naccordance with Section 3.1 of its O&M Manual for two abnormal operating conditions (AOCs)\nshown on Console 4 in its control room. Instead, Genesis informed PHMSA that phone calls and e-\nmails were used to communicate this information.\nIn its Response, Genesis noted that its control room utilized a different reporting format for AOCs\nand that this information had been provided to PHMSA during the 2017 inspection.3 It also noted\nthat, since the time of the 2017 inspection, Genesis control room staff had held weekly conference\ncalls to go over the latest AOCs, AOCs that had been corrected, and those that were outstanding.4\nFinally, the operator attached a copy of its Form 810.01 Report of Abnormal Operating Conditions\nto its Response.5\nAfter reviewing Form 810.01 and Table 1 in Genesis’s Response, I find that neither documents all\nof the information required to be reported in writing in Section 3.1 of Genesis’s O&M Manual.\nFirst, it is unclear whether Form 810.01 was provided to PHMSA during the inspection, or if this is\na newly-created or revised form submitted to PHMSA after the inspection. In its Region\n2 Pipeline Safety Violation Report (Violation Report), (January 28, 2019) (on file with PHMSA), at Exhibit A,\nViolation 2, Genesis Operations and Maintenance – Section 300.\n3 Response, at 3 (Table 1, listing out the date, time, and location of the AOC and a narrative section).\n4 Id.\n5 In its Response to Item 2, the operator also made note of Section 1.3.3 of its Liquids O&M Manual that discusses\nreviews for effectiveness. However, this relates to Item 1 in the Notice, which was a warning item and therefore is not\ndiscussed here.\n\n\n\nCPF No. 4-2019-2001\nPage 3\nRecommendation, the Region noted that it was not provided with a copy of Form 810.01 during the\ninspection. There is no date on the form, and the operator does not otherwise clarify when the\ndocument was created. Regardless, I do not believe this form captures the requirements of Section\n3.1 of Genesis’s O&M Manual. For example, the form does not include the consequences of an\nAOC. Second, the table that is included in Genesis’s Response does not include sufficient\ninformation to comply with Section 3.1 of the operator’s O&M Manual. For example, it does not\ninclude steps taken to rectify the AOC. Finally, the operator’s weekly conference calls to discuss\nAOCs, while a good practice, do not comport with the requirement in Section 3.1 that these\ndiscussions “shall be reported in writing to the affected Operation Area Manager(s)” (emphasis\nadded).\nAccordingly, after considering all of the evidence, I find that Respondent violated 49 C.F.R.\n§ 192.605(a) by failing to follow Section 3.1 of its manual of written procedures for recording\nabnormal operations.\nItem 3: The Notice alleged that Respondent violated 49 C.F.R. § 192.479(a), which states:\n§ 192.479 Atmospheric corrosion control: General.\n(a) Each operator must clean and coat each pipeline or portion of pipeline that\nis exposed to the atmosphere, except pipelines under paragraph (c) of this section.\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.479(a) by failing to clean and coat\neach non-excepted pipeline or portion of pipeline that is exposed to the atmosphere. Specifically,\nthe Notice alleged that Genesis failed to clean and coat the 30-inch HVLT-201D valve area and the\n30-inch HVRT-304A valve area. During the inspection, the PHMSA inspector observed disbonded\ncoating, atmospheric corrosion, and severe pitting on flanges, risers, valves and the pipeline at these\nlocations.\nRespondent did not contest this allegation of violation. Accordingly, based upon a review of all of\nthe evidence, I find that Respondent violated 49 C.F.R. § 192.479(a) by failing to clean and coat\neach non-excepted pipeline or portion of pipeline that is exposed to the atmosphere.\nThese findings of violation will be considered prior offenses in any subsequent enforcement action\ntaken 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 related\nseries of violations.6 In determining the amount of a civil penalty under 49 U.S.C. § 60122 and 49\nC.F.R. § 190.225, I must consider the following criteria: the nature, circumstances, and gravity of\nthe violation, including adverse impact on the environment; the degree of Respondent’s culpability;\nthe history of Respondent’s prior offenses; any effect that the penalty may have on its ability to\ncontinue doing business; and the good faith of Respondent in attempting to comply with the\n6 These amounts are adjusted annually for inflation. See 49 C.F.R. § 190.223.\n\n\n\nCPF No. 4-2019-2001\nPage 4\npipeline safety regulations. In addition, I may consider the economic benefit gained from the\nviolation without any reduction because of subsequent damages, and such other matters as justice\nmay require. The Notice proposed a total civil penalty of $52,400 for the violations cited above.\nItem 2: The Notice proposed a civil penalty of $24,500 for Respondent’s violation of 49 C.F.R.\n§ 192.605(a), for failing to follow its manual of written procedures for handling abnormal\noperations. Genesis failed to comply with a requirement that was clearly applicable and did not\nhave a reasonable justification for its non-compliance. Accordingly, having reviewed the record\nand considered the assessment criteria, I assess Respondent a civil penalty of $24,500 for violation\nof 49 C.F.R. § 192.605(a).\nItem 3: The Notice proposed a civil penalty of $27,900 for Respondent’s violation of 49 C.F.R.\n§ 192.479(a), for failing to clean and coat each non-excepted pipeline or portion of pipeline that is\nexposed to the atmosphere. Genesis neither contested the allegation nor presented any evidence or\nargument justifying a reduction in, or elimination of, the proposed penalty. The proposed penalty\namount takes into account that Genesis failed to comply with a requirement that was clearly\napplicable, and did not have a reasonable justification for its non-compliance. Accordingly, having\nreviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of\n$27,900 for violation of 49 C.F.R. § 192.479(a).\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 $52,400.\nPayment of the civil penalty must be made within 20 days of service. Federal regulations (49\nC.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer through the Federal Reserve\nCommunications System (Fedwire), to the account of the U.S. Treasury. Detailed instructions are\ncontained in the enclosure. Questions concerning wire transfers should be directed to: Financial\nOperations Division (AMK-325), Federal Aviation Administration, Mike Monroney Aeronautical\nCenter, 6500 S MacArthur Blvd, Oklahoma City, Oklahoma 79169. The Financial Operations\nDivision telephone number is (405) 954-8845.\nFailure to pay the $52,400 civil penalty will result in accrual of interest at the current annual rate in\naccordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to those\nsame authorities, a late penalty charge of six percent (6%) per annum will be charged if payment is\nnot made 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 United\nStates.\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Item 3 in the Notice for violation of 49\nC.F.R. § 192.479(a). Under 49 U.S.C. § 60118(a), each person who engages in the transportation of\ngas or who owns or operates a pipeline facility is required to comply with the applicable safety\nstandards established under chapter 601. The Director indicates that Respondent has taken the\nfollowing actions specified in the proposed compliance order:\n\n\n\nCPF No. 4-2019-2001\nPage 5\n1. With respect to the violation of § 192.479(a) (Item 3), Respondent has completed\nremedial actions and submitted documentation to PHMSA reflecting corrective\nactions it has taken on portions of its pipeline exposed to the atmosphere on platform\nHIA-573 on the HIOS gas gathering system.\nAccordingly, I find that compliance has been achieved with respect to this violation. Therefore, the\ncompliance terms proposed in the Notice are not included in this Order.\nWARNING ITEM\nWith respect to Item 1, the Notice alleged a probable violation of Part 192 but did not propose a\ncivil penalty or compliance order for this item. Therefore, this is considered to be a warning\nitem. The warning was for:\n49 C.F.R. § 192.605(c)(4) (Item 1) ─ Respondent’s alleged failure to have a manual\nof written procedures for periodically reviewing the response of operator personnel\nto determine the effectiveness of the procedures controlling abnormal operation and\ntaking corrective action where deficiencies are found.\nGenesis presented information in its Response showing that it had taken certain actions to address\nthe cited item. If OPS finds a violation of this provision in a subsequent inspection, Respondent\nmay be subject to future enforcement action.\nUnder 49 C.F.R. § 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, no later than 20 days after receipt of service of the\nFinal Order by Respondent. Any petition submitted must contain a brief statement of the issue(s)\nand meet all other requirements of 49 C.F.R. § 190.243. The filing of a petition automatically stays\nthe payment of any civil penalty assessed. The other terms of the order, including any corrective\naction, remain in effect unless the Associate Administrator, upon request, grants a stay. If\nRespondent submits payment of the civil penalty, the Final Order becomes the final administrative\ndecision and the right to petition for reconsideration is waived.\nThe terms and conditions of this Final Order are effective upon service in accordance with 49\nC.F.R. § 190.5.\nJanuary 24, 2020\n____________________________________ ________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":25602}