{"operation":"document","citation":"CPF 420195024","title":"TRANSMONTAIGNE OPERATING COMPANY L.P. — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-12-30","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.452(h)(4)(iii)(e), 195.452(j)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420195024.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420195024.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420195024","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420195024","body":"Notice of Probable Violation involving TRANSMONTAIGNE OPERATING COMPANY L.P.. PHMSA's enforcement data identifies the cited regulations as 195.452(h)(4)(iii)(e),  195.452(j)(2). The case was opened on 2019-12-30 and is reported as closed as of 2020-10-05. Proposed civil penalty: $46,600. Assessed civil penalty: $46,600. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420195024_Closure Letter_10052020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195024/420195024_Closure%20Letter_10052020.pdf\n\n420195024_Closure Letter_10052020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195024/420195024_Closure%20Letter_10052020_text.pdf\n\n420195024_Final Order_07272020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195024/420195024_Final%20Order_07272020.pdf\n\n420195024_Final Order_07272020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195024/420195024_Final%20Order_07272020_text.pdf\n\n420195024_NOPV PCP PCO_12302019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195024/420195024_NOPV%20PCP%20PCO_12302019.pdf\n\n420195024_NOPV PCP PCO_12302019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195024/420195024_NOPV%20PCP%20PCO_12302019_text.pdf\n\n420195024_Operator Response to Notice_01302020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195024/420195024_Operator%20Response%20to%20Notice_01302020.pdf\n\n420195024_Closure Letter_10052020_text.pdf\n\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nOctober 5, 2020\nMr. Fred Boutin\nChief Executive Officer\nTransMontaigne Operating Company, L.P.\n200 Mansell Court East, Suite 600\nRoswell, Georgia 30076\nCPF 4-2019-5024\nDear Mr. Boutin:\nOn July 27, 2020, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued\nto TransMontaigne Operating Company a Final Order in the above-referenced case. This Order\nincluded a Compliance Order and Civil Penalty assessment. Based on our review of the\ndocumentation you provided and confirmation of payment of the civil penalty, 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,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n\n420195024_Final Order_07272020_text.pdf\n\nJuly 27, 2020\nVIA ELECTRONIC MAIL TO: fboutin@transmontaigne.com\nMr. Fred Boutin\nChief Executive Officer\nTransMontaigne Operating Company, LP\n200 Mansell Court East, Suite 600\nRoswell, Georgia 30076\nRe: CPF No. 4-2019-5024\nDear Mr. Boutin:\nEnclosed please find the Final Order issued in the above-referenced case. It makes one finding\nof violation and assesses a civil penalty of $46,600, and specifies actions that need to be taken by\nTransMontaigne Operating Company, LP, to comply with the pipeline safety regulations. When\nthe civil penalty has been paid and the terms of the compliance order completed, as determined\nby the Director, Southwest Region, this enforcement action will be closed. This enforcement\naction closes automatically upon receipt of payment. Service of the Final Order by electronic\nmail is effective upon the date of transmission 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. James F. Dugan, Executive Vice President, TransMontaigne Operating Company,\nLP, jdugan@transmontaigne.com\nMr. Edward J. Luebke, Vice President of Pipeline Operations, TransMontaigne Operating\nCompany, LP, eluebke@transmontaigne.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__________________________________________\nIn the Matter of )\nTransMontaigne Operating Company, LP, ) CPF No. 4-2019-5024\n)\n)\n)\nRespondent. )\n__________________________________________)\nFINAL ORDER\nFrom January 7 through June 21, 2019, pursuant to 49 U.S.C. § 60117, representatives of the\nPipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS), conducted an on-site pipeline safety inspection TransMontaigne Operating Company,\nLP’s (TransMontaigne or Respondent) Diamondback Pipeline system in Brownsville, Texas.\nThe Diamondback Pipeline system consists of 16.3 miles of 6-inch and 16.3 miles of 8-inch\npipeline running parallel to each other in Brownsville, Texas, from the Mexico-U.S. Border to\nthe Port of Brownsville.1\nAs a result of the inspection, the Director, Southwest Region, OPS (Director), issued to\nRespondent, by letter dated December 30, 2019, a Notice of Probable Violation, Proposed Civil\nPenalty, and Proposed Compliance Order (Notice), which also included a warning pursuant to\n49 C.F.R. § 190.205. In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that\nTransMontaigne had violated 40 C.F.R. § 194.452(j)(2) and proposed assessing a civil penalty of\n$46,600 for the alleged violation. The Notice also proposed ordering Respondent to take certain\nmeasures to correct the alleged violation. The warning item required no further action, but\nwarned the operator to correct the probable violations or face possible future enforcement action.\nTransMontaigne responded to the Notice by letter dated January 30, 2020 (Response). The\ncompany did not contest the allegation of violation in Item 1, agreed to complete the proposed\ncompliance actions, and requested that the proposed civil penalty be reduced based on actions it\nhad taken and proposed to take in the future. The company also requested the removal of the\nwarning associated with Item 1. Respondent did not request a hearing and therefore has waived\nits right to one.\nFINDING OF VIOLATION\nIn its Response, TransMontaigne did not contest the allegation in the Notice that it violated 49\nC.F.R. Part 195, as follows:\n1 See Pipeline Safety Violation Report, dated December 30, 2019 (Violation Report), at 1 (on file with PHMSA).\n\n\n\nCPF No. 4-2019-5024\nPage 2\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.452(j)(2), which states:\n§ 195.452 Pipeline integrity management in high consequence areas.\n(j) What is a continual process of evaluation and assessment to\nmaintain a pipeline's integrity?\n(1) . . .\n(2) Evaluation. An operator must conduct a periodic evaluation as\nfrequently as needed to assure pipeline integrity. An operator must base the\nfrequency of evaluation on risk factors specific to its pipeline, including the\nfactors specified in paragraph (e) of this section. The evaluation must\nconsider the results of the baseline and periodic integrity assessments,\ninformation analysis (paragraph (g) of this section), and decisions about\nremediation, and preventive and mitigative actions (paragraphs (h) and (i)\nof this section).\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.452(j)(2) by failing to conduct a\nperiodic evaluation as frequently as needed to ensure the integrity of each pipeline segment that\ncould affect a high consequence area (HCA). Specifically, the Notice alleged that\nTransMontaigne failed to conduct its periodic Emergency Flow Restriction Device (EFRD)\nstudies in accordance with its own Pipeline Integrity Assessment and Management Manual,\nSection 6.06: EFRD Need Evaluation Factors (Section 6.06). According to the Notice, Section\n6.06 states that the company’s Integrity Manager will re-evaluate the need for additional EFRDs\non each pipeline segment at least every five years, beginning in 2011. TransMontaigne allegedly\nfailed to provide any records to show that the required EFRD evaluations were in fact performed\nin 2011 and 2016, as required.\nRespondent did not contest this allegation of violation. Accordingly, based upon a review of all\nof the evidence, I find that Respondent violated 49 C.F.R. § 195.452(j)(2) by failing to conduct a\nperiodic evaluation as frequently as needed to ensure the integrity of each pipeline segment that\ncould affect an HCA.\nThis finding of violation will be considered a prior offense 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\nrelated series of violations.2 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; any effect that\nthe penalty may have on its ability to continue doing business; and the good faith of Respondent\nin attempting to comply with the pipeline safety regulations. In addition, I may consider the\n2 These amounts are adjusted annually for inflation. See 49 C.F.R. § 190.223.\n\n\n\nCPF No. 4-2019-5024\nPage 3\neconomic benefit gained from the violation without any reduction because of subsequent\ndamages, and such other matters as justice may require. The Notice proposed a total civil\npenalty of $46,600 for the violation cited above.\nItem 1: The Notice proposed a civil penalty of $46,600 for Respondent’s violation of 49 C.F.R.\n§ 195.452(j)(2), for failing to conduct its EFRD studies in accordance with its Pipeline Integrity\nAssessment and Management Manual, Section 6.06, as frequently as needed to ensure the\nintegrity of each covered segment.\nIn its Response, TransMontaigne did not contest the findings with regard to each assessment\ncriterion used to calculate the proposed civil penalty amount, but requested that the proposed\ncivil penalty be reduced or waived based on the company’s historical commitment to integrity\nmanagement and safe operations, as well as future process improvements. According to its\nResponse, TransMontaigne stated that it has taken the necessary actions to improve leak\ndetection and mitigation for the Diamondback Pipeline by installing a mainline block valve and\nrelocating another block valve to improve accessibility, thus automating the location.\nTransMontaigne indicated that it has already conducted a High Consequence Area and EFRD\nAnalysis of the Diamondback system and will re-evaluate the need for additional EFRDs.\nNotwithstanding the stated improvements to its approach to integrity management for the\nDiamondback Pipeline system, which are commendable, there is no evidence in the record that\nwould support a reduction or elimination of the proposed civil penalty. Past history and\ncommitment to integrity management do not excuse failing to comply with federal regulatory\nresponsibilities in a timely manner. Likewise, potential future actions taken to come into\ncompliance are those that PHMSA would expect of any prudent operator and do not serve as the\nbasis for a penalty reduction.\nAccordingly, having reviewed the record and considered the assessment criteria, I assess\nRespondent a civil penalty of $46,600 for violation of 49 C.F.R. § 195.452(j)(2).\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 $46,600.\nPayment of the civil penalty must be made within 20 days of service. Federal regulations\n(49 C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer through the Federal\nReserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed\ninstructions are contained in the enclosure. Questions concerning wire transfers should be\ndirected to: Financial Operations Division (AMK-325), Federal Aviation Administration, Mike\nMonroney Aeronautical Center, 6500 S MacArthur Blvd, Oklahoma City, Oklahoma 79169.\nThe Financial Operations Division telephone number is (405) 954-8845.\nFailure to pay the $46,600 civil penalty will result in accrual of interest at the current annual rate\nin accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to\nthose same authorities, a late penalty charge of six percent (6%) per annum will be charged if\npayment is not made within 110 days of service. Furthermore, failure to pay the civil penalty\nmay result in referral of the matter to the Attorney General for appropriate action in a district\ncourt of the United States.\n\n\n\nCPF No. 4-2019-5024\nPage 4\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Item 1 in the Notice for violations of\n49 C.F.R. § 195.452(j)(2). Under 49 U.S.C. § 60118(a), each person who engages in the\ntransportation of hazardous liquids or who owns or operates a pipeline facility is required to\ncomply with the applicable safety standards established under chapter 601. Pursuant to the\nauthority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the\nfollowing actions to ensure compliance with the pipeline safety regulations applicable to its\noperations:\n1. With respect to the violation of § 195.452(j)(2) (Item 1), Respondent must:\na. Re-evaluate the need for additional EFRDs for the Diamondback Pipeline\nsystem by conducting a study on each pipeline segment to ensure the integrity\nof each covered segment.\nb. Within 60 days following receipt of this Final Order, TransMontaigne must\nprovide PHMSA Southwest Region with documentation that verifies\ncompletion of the requirements of this compliance order.\nThe Director may grant an extension of time to comply with any of the required items upon a\nwritten request timely submitted by the Respondent and demonstrating good cause for an\nextension.\nIt is requested (not mandated) that Respondent maintain documentation of the safety\nimprovement costs associated with fulfilling this Compliance Order and submit the total to the\nDirector. It is requested that these costs be reported in two categories: (1) total cost associated\nwith preparation/revision of plans, procedures, studies and analyses; and (2) total cost associated\nwith replacements, additions and other changes to pipeline infrastructure.\nFailure to comply with this Order may result in the administrative assessment of civil penalties\nnot to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), for each violation for\neach day the violation continues or in referral to the Attorney General for appropriate relief in a\ndistrict court of the United States.\nWARNING ITEM\nWith respect to Item 1, the Notice alleged probable violation of Part 195, but identified it as a\nwarning item pursuant to § 190.205. The warning was for:\n49 C.F.R. § 195.452(h)(4(iii)(E) (Item 1) ─ Respondent’s alleged failure to\nschedule evaluation and remediation within 180 days of discovery of an area of\ngeneral corrosion with a predicted metal loss greater than 50 percent of nominal\nwall.\n\n\n\nCPF No. 4-2019-5024\nPage 5\nTransMontaigne requested withdrawal of Item 1 because the anomaly that was called out as\nshowing 43 percent external metal loss in 2011 and 59 percent metal loss in 2016, was\nmischaracterized in the latter survey, which resulted in the grading of the condition in 2016 as a\n180-day condition. Upon subsequent confirmation, TransMontaigne maintains that, upon\nsubsequent confirmation, the company determined that the anomaly had been conservatively\ngraded by the ILI service providers and did not meet the 180-day condition threshold for\nremediation.\nPHMSA appreciates the explanation provided by TransMontaigne in response to this warning\nitem. However, under § 190.205, PHMSA does not adjudicate warning items to determine\nwhether a probable violation occurred or not. If OPS finds a violation of this provision in a\nsubsequent inspection, Respondent may 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\nstays the payment of any civil penalty assessed. The other terms of the order, including any\ncorrective action, remain in effect unless the Associate Administrator, upon request, grants a\nstay. If Respondent submits payment of the civil penalty, the Final Order becomes the final\nadministrative decision 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.\nJuly 27, 2020\n___________________________________ __________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n420195024_NOPV PCP PCO_12302019_text.pdf\n\nNOTICE OF PROBABLE VIOLATION\nPROPOSED CIVIL PENALTY\nand\nPROPOSED COMPLIANCE ORDER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 30, 2019\nFred Boutin\nChief Executive Officer\nTransMontaigne Operating Company\n200 Mansell Ct East, Suite 600\nRoswell, Georgia 30076\nCPF 4-2019-5024\nDear Mr. Boutin:\nFrom January 7 to June 21, 2019, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.) inspected your Diamondback Pipeline in Brownsville, Texas.\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:\n1. § 195.452 Pipeline integrity management in high consequence areas.\n(h) What actions must an operator take to address integrity issues?\n(4) Special Requirements for scheduling remediation\n\n\n\n2. (iii) 180-day conditions. Except for conditions listed in paragraph\n(h)(4)(i) or (ii) of this section, an operator must schedule evaluation and\nremediation of the following within 180 days of discovery of the\ncondition:\n(E) An area of general corrosion with a predicted metal loss\ngreater than 50% of nominal wall.\nTransMontaigne failed to schedule evaluation and remediation within 180 days of\ndiscovery of an area of general corrosion with a predicted metal loss greater than 50% of\nnominal wall. In April 2016, TransMontaigne conducted an assessment on its 8”\nDiamondback pipeline. TransMontaigne is required to review and evaluate these\ninterpretations, categorize the anomalies per § 195.452(h)(4), and prepare a repair and\nmitigation strategy no later than 180 days after the assessment. TransMontaigne failed to\nreview and evaluate the interpretations of the 2016 in-line inspection run, and did not\nprepare a repair and mitigation strategy no later than 180 days after the assessment as\nrequired by its Pipeline Integrity Assessment and Management Manual.\n§ 195.452 Pipeline integrity management in high consequence areas.\n(j) What is a continual process of evaluation and assessment to maintain a pipeline's\nintegrity?\n(2) Evaluation. An operator must conduct a periodic evaluation as frequently\nas needed to assure pipeline integrity. An operator must base the frequency of\nevaluation on risk factors specific to its pipeline, including the factors specified\nin paragraph (e) of this section. The evaluation must consider the results of the\nbaseline and periodic integrity assessments, information analysis (paragraph\n(g) of this section), and decisions about remediation, and preventive and\nmitigative actions (paragraphs (h) and (i) of this section).\nTransMontaigne failed to conduct its Emergency Flow Restriction Device (EFRD) studies\nin accordance with its Pipeline Integrity Assessment and Management Manual, Section\n6.06: EFRD Need Evaluation Factors as needed to ensure pipeline integrity of each covered\nsegment. This section states that the Integrity Manager will re-evaluate the need for\nadditional EFRDs on each pipeline segment at least every five years beginning in 2011.\nTransMontaigne provided no records to indicate they performed the required EFRD\nevaluations in 2011 and 2016 as required.\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$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related\nseries of violations. For violation occurring on or after November 27, 2018 and before July 31,\n2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum\npenalty not to exceed $2,132,679. For violation occurring on or after November 2, 2015 and before\nNovember 27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a\n2\n\n\n\nmaximum penalty not to exceed $2,090,022. For violations occurring prior to November 2, 2015,\nthe maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty\nnot to exceed $2,000,000 for a related series of violations. The Compliance Officer has reviewed\nthe circumstances and supporting documentation involved for the above probable violations and\nhas recommended that you be preliminarily assessed a civil penalty of $46,600 as follows:\nItem number PENALTY\n2 $46,600\nWarning Item\nWith respect to item 1, we have reviewed the circumstances and supporting documents involved\nin this 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 2 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials Safety\nAdministration proposes to issue a Compliance Order to TransMontaigne Operating Company,\nL.P. 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\nEnforcement 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.\n3\n\n\n\nIn your correspondence on this matter, please refer to CPF 4-2019-5024 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\ncc: Edward J. Luebke, Vice President of Pipeline Operations, TransMontaigne Operating\nCompany, 200 Mansell Ct East, Suite 600, Roswell, Georgia 30076\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Enforcement 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 TransMontaigne Operating Company, a\nCompliance Order incorporating the following remedial requirements to ensure the compliance of\nTransMontaigne with the pipeline safety regulations:\n1. 2. 3. In regard to Item Number 2 of the Notice pertaining to TransMontaigne’s failure to\nconduct emergency flow restriction device (EFRD) studies as required by the\nOperator’s Pipeline Integrity Assessment and Management Manual.\nTransMontaigne must re-evaluate the need for additional EFRDs by conducting a\nstudy on each pipeline segment to ensure pipeline integrity of each covered segment.\nWithin 60 days following receipt of a Final Order, TransMontaigne must provide\nPHMSA Southwest Region with documentation that verifies completion of Item 1 of\nthis compliance order.\nIt is requested (not mandated) that TransMontaigne Operating Company, L.P.\nmaintain documentation of the safety improvement costs associated with fulfilling\nthis Compliance Order and submit the total to Mary L. McDaniel, Director,\nSouthwest Region, Pipeline and Hazardous Materials Safety Administration. It is\nrequested that these costs 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 infrastructure.\n5","truncated":false,"body_characters":25695}