{"operation":"document","citation":"CPF 420193001","title":"CAMERON LNG, LLC — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-07-30","effective_on":null,"summary":"CLOSED notice of probable violation citing 193.2011, 193.2017(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420193001.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420193001.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420193001","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420193001","body":"Notice of Probable Violation involving CAMERON LNG, LLC. PHMSA's enforcement data identifies the cited regulations as 193.2011,  193.2017(a). The case was opened on 2019-07-30 and is reported as closed as of 2021-02-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420193001_Closure Letter_02192021.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420193001/420193001_Closure%20Letter_02192021.pdf\n\n420193001_Closure Letter_02192021_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420193001/420193001_Closure%20Letter_02192021_text.pdf\n\n420193001_Consent Agreement and Order_09282020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420193001/420193001_Consent%20Agreement%20and%20Order_09282020.pdf\n\n420193001_Consent Agreement and Order_09282020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420193001/420193001_Consent%20Agreement%20and%20Order_09282020_text.pdf\n\n420193001_NOPV PCP PCO_07302019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420193001/420193001_NOPV%20PCP%20PCO_07302019.pdf\n\n420193001_NOPV PCP PCO_07302019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420193001/420193001_NOPV%20PCP%20PCO_07302019_text.pdf\n\n420193001_Operator Hearing Request Withdrawn_11212019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420193001/420193001_Operator%20Hearing%20Request%20Withdrawn_11212019.pdf\n\n420193001_Operator Response to Notice and Request for Hearing Redacted_08162019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420193001/420193001_Operator%20Response%20to%20Notice%20and%20Request%20for%20Hearing%20Redacted_08162019.pdf\n\n420193001_PHC Hearing Scheduled_09032019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420193001/420193001_PHC%20Hearing%20Scheduled_09032019.pdf\n\n420193001_PHC Hearing Scheduled_09032019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420193001/420193001_PHC%20Hearing%20Scheduled_09032019_text.pdf\n\n420193001_Consent Agreement and Order_09282020_text.pdf\n\nSeptember 28, 2020\nVIA ELECTRONIC MAIL TO: dcallens@cameronlng.com\nMr. Daniel Callens, Jr.\nChief Operating Officer\nCameron LNG, LLC\n2925 Briarpark Drive, Suite 1000\nHouston, Texas 77042\nCPF No. 4-2019-3001\nDear Mr. Callens:\nEnclosed please find a Consent Order incorporating the terms of the Consent Agreement between\nthe Pipeline and Hazardous Materials Safety Administration (PHMSA) and Cameron LNG, LLC,\nwhich was executed on September 25, 2020. Service of the Consent Order and Consent Agreement\nby electronic mail is deemed effective upon the date of transmission as provided under 49 C.F.R.\n§ 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure: Order and Consent Agreement\ncc: Ms. Mary McDaniel, Director, Southwestern Region, OPS, PHMSA\nMs. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS, PHMSA\nMr. Blair Woodward, General Counsel, Cameron LNG, LLC, bwoodward@cameronlng.com\nMr. Brett A. Snyder, Counsel for Cameron LNG, LLC, Blank Rome, LLP,\nbsnyder@blankrome.com\nCONFIRMATION OF RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\n)\nIn the Matter of )\n)\nCameron LNG, LLC, ) CPF No. 4-2019-3001\n)\nRespondent. )\n____________________________________)\nCONSENT AGREEMENT AND ORDER\nWHEREAS, on July 30, 2019, the Director, Southwest Region (Director), Office of Pipeline\nSafety, Pipeline and Hazardous Materials Safety Administration (PHMSA), U.S. Department of\nTranspo1tation, issued to Cameron LNG, LLC (CLNG or Respondent), a Notice of Probable\nViolation, Proposed Civil Penalty, and Proposed Compliance Order (Notice), pursuant to Chapter\n60l of 49 U.S. Code, for alleged violations of 49 C.F.R. §§ 193.2011 (Item 1) and 193.2017 (Item\n2). The Notice proposed assessing an administrative civil penalty of $41,600 for Item 1 and\nordering Respondent to take ce1tain measures to correct Item 2; and\nWHEREAS, on August 16, 2019, CLNG submitted a written response to the Notice, in which the\nRespondent contested both alleged violations, the proposed civil penalty, and the proposed\ncompliance order and requested a-hearing pursuant to 49 C.F.R. § 190.211. CLNG also requested\na meeting with Southwest Region, which took place on or about September 4, 2019, to discuss\nresolution of this enforcement proceeding;\nWHEREAS, subsequent settlement discussions occurred via email and teleconferences; and\nWHEREAS, as result of these good-faith discussions, the Parties have reached agreement on the\nterms and conditions of a settlement, as set forth herein, and agree that this Consent Agreement\nand Order (Agreement) will avoid further administrative proceedings or litigation, that it is the\nmost appropriate means of resolving the issues raised in the Notice, and that it will promote the\npublic interest by advancing the enforcement and safety goals of PHMSA.\nNOW, THEREFORE, upon consent and agreement of the Parties, it is Ordered and Adjudged as\nfollows:\n1\n\n\n\nCPF No. 4-2019-3001\nA. General Provisions.\n1. CLNG acknowledges that, for purposes of this Agreement, the CLNG facility\nlocated in Hackberry, Louisiana, is subject to the jurisdiction of the Federal pipeline safety laws,\n49 U.S.C. 60101, et seq., and the regulations and administrative orders issued thereunder.\n2. CLNG further acknowledges that it received proper notice of PHMSA's action in\nthis proceeding and that the Notice states claims upon which relief may be granted pursuant to 49\nU .S.C. § 60101, et seq., and the regulations and orders issued thereunder.\n3. CLNG agrees to the terms of this Agreement and hereby waives any further\nprocedural requirements with respect to its issuance. CLNG also waives all rights to contest the\nvalidity of this Agreement, including all rights to administrative or judicial hearings or appeals.\n4. For Item I of the Notice, PHMSA re-issues Item I as a Warning Item pursuant to\n49 C.F.R. § 190.205 and withdraws the associated proposed administrative civil penalty. PHMSA\nalso agrees that Item 1 does not constitute a finding of violation and may not be considered by the\nagency as a prior offense in any future enforcement action against Respondent. However, if\nPHMSA finds a violation of this Paragraph 4 in a subsequent inspection or investigation, CLNG\nmay be subject to future enforcement action.\n5. For Item 2 of the Notice, CLNG does not contest this Item or the associated\nproposed compliance order, which is adopted as set forth in Section B herein.\nB. Compliance Measures.\n6. Within 60 days following the Effective Date of this Agreement, as specified below,\nRespondent agrees that it will modify its Emergency Response Procedures to ensure that all events\nrequired to be reported under 49 C.F.R. § 191.5 are adequately defined. The.revised procedure\nmust include guidance for personnel whose responsibilities include gathering appropriate\ninformation and/or reporting on what significant events meet the definition of an incident. In\nrevising the procedures, CLNG must ensure that all appropriate training to the revised procedures\nis completed and documented.\n7. It is requested (not mandated) that CLNG maintain documentation of the safety\nimprovement costs associated with fulfilling this Agreement and submit the total to the Director.\nPHMSA requests that these costs be reported in two categories: (I) total cost associated with the\npreparation/revision of plans, procedures, studies and analyses; and (2) total cost associated with\nreplacements, additions and other changes to pipeline infrastructure.\n8. The Director may grant an extension of time to comply with any portion of\nParagraph 6 above upon a written request timely submitted by the Respondent and demonstrating\ngood cause for an extension. Upon completion of all actions required under Paragraph 6, CLNG\nmay request that the Director close the case.\n2\n\n\n\nCPF No. 4-2019-3001\nC. Dispute Resolution\n9. The Director and CLNG will informally attempt to resolve any disputes arising\nunder this Agreement. If Respondent and the Director are unable to informally resolve the dispute\nwithin 10 calendar days of submittal of Respondent's invoking dispute resolution, CLNG may\nrequest in writing, within 10 calendar days thereafter, a written determination resolving the dispute\nfrom the Associate Administrator for Pipeline Safety by providing all information that Respondent\nbelieves is relevant to the dispute. If the request is submitted as provided herein, the Associate\nAdministrator will issue a final determination in writing. The existence of a dispute and PHMSA's\nconsideration of the matters placed in dispute will not excuse, toll, or suspend any term or\ntimeframe for completion of any work to be performed under this Agreement during the pendency\nof the dispute resolution process, except as agreed by the Director or the Associate Administrator\nin writing.\nD. Miscellaneous.\n10. Nothing in this Agreement affects or relieves CLNG of its responsibility to\ncomply with all applicable requirements of the Federal pipeline safety laws, 49 U.S.C. § 60101,\net seq., and the regulations and orders issued thereunder. Furthermore, nothing in this\nAgreement alters PHMSA's right of access, entry, inspection, and information gathering, or its\nauthority to bring any enforcement action against CLNG pursuant to the Federal pipeline safety\nlaws, the regulations and orders issued thereunder, or any other provision of Federal or state law.\n11. This Agreement does not waive or modify any Federal, state, or local laws or\nregulations applicable to CLNG's pipeline system. This Agreement is not a permit or a\nmodification of a permit under any Federal, state, or local laws or regulations. CLNG remains\nresponsible for achieving and maintaining compliance with all applicable Federal, state, and local\nlaws, regulations and permits.\n12. This Agreement constitutes the final, complete, and exclusive agreement and\nunderstanding between the Parties with respect to this proceeding and the issues embodied in this\nAgreement. The Parties acknowledge that there are no representations, agreements, or\nunderstandings relating to the amount or collection of any civil penalties other than those expressly\ncontained in this Agreement.\n13. This Agreement does not create rights in, or grant any cause of action to, any person\nnot a patty to this Agreement. PHMSA, its officers, employees, agents, and representatives are not\nliable for any injuries, damages or any other cause of action arising from any acts or omissions of\nCLNG or its contractors in carrying out any work required by this Agreement.\n14. This Agreement shall apply to and be binding on PHMSA and CLNG, its officers,\ndirectors, employees, successors and assigns, including, but not limited to, subsequent purchasers.\n15. Respondent's obligations pursuant to this Agreement may be enforced by PHMSA\npursuant to its general enforcement authorities under 49 U.S.C. § 60101, et seq., and 49 C.F.R.\nPart 190.\n3\n\n\n\nCPF No. 4-2019-3001\nE. Effective Date.\n16. CLNG and PHMSA\nThe \"Effective Date\" is the date on which this Agreement has been signed by both\nF. Ratification.\n17. The Parties’ undersigned representatives certify that they are fully authorized to\nenter into the terms and conditions of this Agreement and to execute and legally bind such party\nto this document.\nFor Cameron LNG, LLC (Respondent):\n___________________________________\nDaniel Callens\nChief Operating Officer\nSeptember 16, 2020\n___________________________________\nDate\nFor PHMSA:\n___________________________________\nAlan K. Mayberry\nAssociate Administrator for Pipeline Safety\nSeptember 25, 2020\n___________________________________\nDate\n4\n\n420193001_NOPV PCP PCO_07302019_text.pdf\n\nCERTIFIED MAIL- RETURN RECEIPT REQUESTED\nJuly 30, 2019\nDan Callens\nSenior Vice President, Terminal Operations\nCameron LNG, LLC\n2925 Briarpark, Suite 1000\nHouston, Texas 77042\nDear Mr. Callens:\nOur office submitted a NOPV PCP PCO Letter, CPF 4-2019-3001, DATED, July 22, 2019.\nPlease discard the letter that was submitted previously, and use this letter that is enclosed in the\nplace of it.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure\n\n\n\nNOTICE OF PROBABLE VIOLATION\nPROPOSED CIVIL PENALTY\nand\nPROPOSED COMPLIANCE ORDER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 22, 2019\nDan Callens\nSenior Vice President, Terminal Operations\nCameron LNG, LLC\n2925 Briarpark, Suite 1000\nHouston, Texas 77042\nCPF 4-2019-3001\nDear Mr. Callens:\nOn May 20, 2019, representatives of the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) inspected your Cameron LNG facility in Hackberry, Louisiana.\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:\n2\n\n\n\n1. §193.2011 Reporting.\nIncidents, safety-related conditions, and annual pipeline summary data for LNG\nplants or facilities must be reported in accordance with the requirements of Part 191\nof this subchapter.\n§191.5 Immediate notice of certain incidents.\n(a) At the earliest practicable moment following discovery, but no later than one hour\nafter confirmed discovery, each operator must give notice in accordance with\nparagraph (b) of this section of each incident as defined in §191.3.\n(b) Each notice required by paragraph (a) of this section must be made to the National\nResponse Center either by telephone to 800-424-8802 (in Washington, DC, 202 267-\n2675) or electronically at http://www.nrc.uscg.mil and must include the following\ninformation:\n(1) Names of operator and person making report and their telephone numbers.\n(2) The location of the incident.\n(3) The time of the incident.\n(4) The number of fatalities and personal injuries, if any.\n(5) All other significant facts that are known by the operator that are relevant to the\ncause of the incident or extent of the damages.\n(c) Within 48 hours after the confirmed discovery of an incident, to the extent\npracticable, an operator must revise or confirm its initial telephonic notice required\nin paragraph (b) of this section with an estimate of the amount of product released,\nan estimate of the number of fatalities and injuries, and all other significant facts that\nare known by the operator that are relevant to the cause of the incident or extent of\nthe damages. If there are no changes or revisions to the initial report, the operator\nmust confirm the estimates in its initial report.\nCameron LNG, LLC (CLNG), failed to notify the National Response Center of two\nincidents that occurred at its liquefied natural gas (LNG) facility in accordance with\n§191.5, Immediate notice of certain incidents. CLNG experienced an unintentional release\nof LNG during initial startup operations on January 9, 2019 and again on May 15, 2019.\nThe January 9, 2019, and the May 15, 2019 incidents both involved the release of LNG\nfrom a flanged joint connection, and were not reported through the NRC.\nOn January 9, 2019, during commissioning activities of the BOG compressors, CLNG\nOperations observed an intermittent LNG leak originating at XV-60001, BOG inlet to D-\n6003 BOG Compressor Suction Drum (see CAM-60-PID-0186. A temperature variance in\nthe pipe consequently caused LNG to leak from the XV-60001 outlet flange.\n3\n\n\n\nOn May 15, 2019, CLNG personnel observed LNG dripping near the isolation valve of\nthe low pressure dry flare header at the battery limits between ISBL Train 1 and OSBL in\nWA-110, at the south-east corner of Train 1. At the time of the discovery, both CCJV and\nCLNG did not consider the LNG release an incident or a significant event and therefore\nfailed to make the required NRC notification.\n2. §193.2017 Plans and procedures.\n(a) Each operator shall maintain at each LNG plant the plans and procedures\nrequired for that plant by this part. The plans and procedures must be available upon\nrequest for review and inspection by the Administrator or any State Agency that has\nsubmitted a current certification or agreement with respect to the plant under the\npipeline safety laws (49 U.S.C. 60101 et seq.). In addition, each change to the plans\nor procedures must be available at the LNG plant for review and inspection within\n20 days after the change is made.\nThe CLNG procedure Emergency Response Plan CAM-MN-HS-001, Appendix 5 does not\nprovide sufficient detail for reporting incidents in accordance with §191.5. The procedure\ndoes not outline the required events for reporting, includes unclear direction for the\nreporting of incidents, and does not provide personnel with basic description of company\ndefined events that meet the definition of an incident.\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. Also, for each violation involving LNG\nfacilities, an additional penalty of not more than $77,910 occurring on or after November 27, 2018\nmay be imposed. For each violation involving LNG facilities occurring on or after November 2,\n2018, and before November 27, 2018, an additional penalty of not more than $76,352 may be\nimposed. For each violation involving LNG facilities occurring prior to November 2, 2015, an\nadditional penalty of not more than $75,000 may be imposed. The Compliance Officer has\nreviewed the circumstances and supporting documentation involved in the above probable\nviolation(s) and has recommended that you be preliminarily assessed a civil penalty of $41,600 as\nfollows:\nItem number PENALTY\n1 $41,600\n4\n\n\n\nProposed Compliance Order\nWith respect to items 2 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials\nSafety Administration proposes to issue a Compliance Order to Cameron LNG, LLC. Please refer\nto the Proposed Compliance Order, which is enclosed 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 in\nCompliance 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 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 4-2019-3001 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\n5\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 Cameron LNG, LLC a Compliance Order\nincorporating the following remedial requirements to ensure the compliance of Cameron LNG,\nLLC with the pipeline safety regulations:\n1. 2. 3. In regard to Item Number 2 of the Notice pertaining to the operator’s inadequate\nprocedure for reporting incidents, Cameron LNG LLC shall modify its Emergency\nResponse Procedures to ensure that all events required to be reported under §191.5\nare adequately defined. The revised procedure must include guidance for personnel\nwhose responsibilities include gathering appropriate information and/or reporting\non what significant events meet the definition of an incident. In revising the\nprocedures, Cameron LNG LLC must ensure that all appropriate training to the\nrevised procedures is completed and documented.\nCameron LNG, LLC must complete and submit all documentation for the revisions\nunder Item 1 of this Compliance Order within 60 days of issuance of the Final\nOrder.\nIt is requested (not mandated) that Cameron LNG, LLC maintain documentation of\nthe safety improvement costs associated with fulfilling this Compliance Order and\nsubmit the total to Mary McDaniel, Director, Southwest Region, Pipeline and\nHazardous Materials Safety Administration. It is requested that these costs be\nreported in two categories: 1) total cost associated with preparation/revision of\nplans, procedures, studies and analyses, and 2) total cost associated with\nreplacements, additions and other changes to pipeline infrastructure.\n6\n\n420193001_Closure Letter_02192021_text.pdf\n\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nFebruary 19, 2021\nDan Callens\nChief Operating Officer\nCameron LNG, LLC\n2925 Briarpark Drive, Suite 1000\nHouston, Texas 77042\nCPF 4-2019-3001\nDear Mr. Callens:\nOn July 30, 2019, the Pipeline and Hazardous Material Safety Administration (PHMSA) issued\nCameron LNG a Notice of Probable Violation, Proposed Penalty, and Proposed Compliance Order\nfor alleged violations for §193.2011 and §193.2017. On September 20, 2020, PHMSA and\nCameron LNG entered into a Consent Agreement for the items included in the Notice. In the terms\nof the agreement, Cameron LNG agreed to modify its Emergency Response Procedures to ensure\nall events required to be reported under §191.5 were incorporated.\nCameron LNG submitted its revised Emergency Response Procedures on November 20, 2020. The\nrevised procedures included the reporting requirements required under §191.5. Based on our\nreview of the documentation provided, it has been determined that you have fundamentally\ncomplied with the terms of the Consent Agreement and that this case is now considered closed.\nShould you have questions, please do not hesitate to contact me.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\ncc: Michael Wolf, Manager, Regulatory & Compliance, Cameron LNG,\nmwolf@cameronlng.com\n\n420193001_PHC Hearing Scheduled_09032019_text.pdf\n\nSeptember 3, 2019\nVIA CERTIFIED MAIL AND EMAIL TO: dcallens@cameronlng.com and\nmary.mcdaniel@dot.gov\nMr. Dan Callens\nChief Operating Officer\nCameron LNG, LLC\n2925 Briarpark Drive, Suite 1000\nHouston, Texas 77042\nMs. Mary McDaniel\nDirector, Southwest Region, PHMSA\n8701 South Gessner, Suite 630\nHouston, Texas 77074\nRe: Notice of Hearing, Cameron LNG, LLC\nCPF No. 4-2019-3001\nDear Mr. Callens and Ms. McDaniel:\nIn accordance with 49 C.F.R. § 190.211, an informal hearing will be held regarding the Notice of\nProbable Violation, Proposed Civil Penalty, and Proposed Compliance Order issued by the Office\nof Pipeline Safety in the above-referenced case. The hearing has been scheduled and will take place\non December 3, 2019, beginning at 9:00 a.m. Central Time.\nThe hearing will be at the PHMSA Southwest Region office, 8701 South Gessner, Suite 630,\nHouston, TX 77074. Upon arrival at the building, attendees will be required to present photo\nidentification to security personnel. A contact phone number for the day of the hearing is\n(713) 272-2859.\nBoth parties must submit and exchange any additional written materials they intend to present at\nleast 10 calendar days prior to the hearing (November 23, 2019), along with a list of attendees, and\nthe names of any witnesses who may testify. You may provide this information electronically. If\nyou have any questions, please contact me at (202) 366-6139 or at kristin.baldwin@dot.gov.\nIf you have any questions, please do not hesitate to contact me.\nSincerely,\nKristin Baldwin\nPresiding Official\ncc (email): Ms. Ahuva Battams, Counsel, Southwest Region, Office of Pipeline Safety, PHMSA\nPHMSA Compliance Registry","truncated":false,"body_characters":25226}