{"operation":"document","citation":"CPF 420205005","title":"NUSTAR PIPELINE OPERATING PARTNERSHIP L.P. — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-02-04","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.452(j)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420205005.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420205005.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420205005","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420205005","body":"Notice of Probable Violation involving NUSTAR PIPELINE OPERATING PARTNERSHIP L.P.. PHMSA's enforcement data identifies the cited regulation as 195.452(j)(1). The case was opened on 2020-02-04 and is reported as closed as of 2020-09-11. Proposed civil penalty: $10,300. Assessed civil penalty: $10,300. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420205005_Final Order_09032020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205005/420205005_Final%20Order_09032020.pdf\n\n420205005_Final Order_09032020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205005/420205005_Final%20Order_09032020_text.pdf\n\n420205005_NOPV PCP PCO_02042020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205005/420205005_NOPV%20PCP%20PCO_02042020.pdf\n\n420205005_NOPV PCP PCO_02042020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205005/420205005_NOPV%20PCP%20PCO_02042020_text.pdf\n\n420205005_Operator Response to Notice_03272020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205005/420205005_Operator%20Response%20to%20Notice_03272020.pdf\n\n420205005_Final Order_09032020_text.pdf\n\nSeptember 3, 2020\nVIA ELECTRONIC MAIL TO: brad.barron@nustarengery.com\nMr. Brad Barron\nPresident and Chief Executive Officer\nNuStar Energy, LP\n19003 IH-10 West\nSan Antonio, Texas 78257\nRe: CPF No. 4-2020-5005\nDear Mr. Barron:\nEnclosed please find the Final Order issued in the above-referenced case to NuStar Pipeline\nOperating Partnership, LP, a subsidiary of NuStar Energy, LP. It makes one finding of violation\nand assesses a civil penalty of $10,300. The penalty payment terms are set forth in the Final\nOrder. This enforcement action closes automatically upon receipt of payment. Service of the\nFinal Order by electronic mail is effective upon the date of transmission as provided under 49\nC.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. Gary Koegeboehn, Vice President - Pipeline Operations, NuStar Energy, LP,\ngary.koegeboehn@nustarenergy.com\nMr. Mike Dillinger, Senior Counsel, NuStar Energy, LP, mike.dillinger@nustarenergy.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\nIn the Matter of )\nNuStar Pipeline Operating Partnership, LP, ) CPF No. 4-2020-5005\na subsidiary of NuStar Energy, LP )\nRespondent. )\n)\n)\n)\n)\nFINAL ORDER\nFrom August 9 through December 17, 2019, pursuant to 49 U.S.C. § 60117, a representative of\nthe Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS), conducted a records review of NuStar Pipeline Operating Partnership, LP, a subsidiary of\nNuStar Energy, LP (NuStar or Respondent). NuStar operates the Hermann Pipeline, a four-inch\nanhydrous ammonia pipeline located in Hermann, Missouri.1\nAs a result of the records review, the Director, Southwest Region, OPS (Director), issued to\nRespondent, by letter dated February 4, 2020, a Notice of Probable Violation, Proposed Civil\nPenalty, and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the\nNotice proposed finding that NuStar violated 49 C.F.R. § 195.452(j)(1) and proposed assessing a\ncivil penalty of $10,300 for the alleged violation. The Notice also proposed ordering Respondent\nto take certain measures to correct the alleged violation.\nAfter requesting an extension, NuStar responded to the Notice by letter dated March 27, 2020\n(Response). The company contested the allegation, offered additional information in response to\nthe Notice, and requested that the Notice be converted to a Warning Letter and that the Proposed\nCompliance Order be deemed complete. Respondent did not request a hearing and therefore has\nwaived its right to one.\nFINDING OF VIOLATION\nThe Notice alleged that Respondent violated 49 C.F.R. Part 195, as follows:\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.452(j)(1), which states:\n1 Pipeline Safety Violation Report (Violation Report), at 1 (Feb. 4, 2020) (on file with PHMSA).\n\n\n\nCPF No. 4-2020-5005\nPage 2\n§ 195.452 Pipeline integrity management in high consequence areas.\n(a) ….\n(j) What is a continual process of evaluation and assessment to\nmaintain a pipeline's integrity?\n(1) General. After completing the baseline integrity assessment, an\noperator must continue to assess the line pipe at specified intervals and\nperiodically evaluate the integrity of each pipeline segment that could affect\na high consequence area.\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.452(j)(1) by failing to continue to\nassess its line pipe at specified intervals and periodically evaluate the integrity of each pipeline\nsegment that could affect a high consequence area. Specifically, the Notice alleged that NuStar\nfailed to assess the Hermann Pipeline within the required five-year interval, not to exceed 68\nmonths.2 NuStar performed its last in-line inspection (ILI) assessment of the Hermann Pipeline\non November 19, 2013, and did not complete another one within the five-year assessment\ninterval, not to exceed 68 months (no later than July 19, 2019).\nIn its Response, NuStar noted that it had encountered technical and equipment availability issues\nthat led to the prolonged completion of a successful ILI assessment, which was eventually\ncompleted in March 2020.3 Specifically, NuStar stated that in March 2017, the company began\npreparations for an ILI assessment of the Hermann Pipeline, consisting of a series of three ILI\ntools: (1) a gauge tool; (2) a deformation tool; and (3) a magnetic-flux leakage (MFL) tool.4\nWhile the gauge and deformation tool runs were successful, the MFL tool was only able to\nachieve 62 percent coverage due to technical issues associated with certain bends in the four-inch\npipeline. As a result, NuStar scheduled a second ILI assessment for the spring of 2019.\nNuStar reported that during the second ILI assessment, the gauge tool ran successfully.5 The\nlaunch of the deformation tool, however, was delayed due to equipment availability problems\nand plant outages.6 The deformation tool finally launched on June 26, 2019.7 During the tool\nrun, the deformation tool became lodged in the pipeline approximately 2.8 miles downstream of\nthe launcher. After unsuccessful attempts to dislodge the tool, NuStar notified PHMSA of the\n2 Pursuant to 49 C.F.R. § 195.452(j)(3), an operator must establish a five-year interval, not to exceed 68 months, for\ncontinually assessing the line pipe’s integrity.\n3 Response, at 2.\n4 The company noted that MFL tools have historically experienced challenges associated with small diameter\npipelines because “… the size of the pipeline limits the ability of the tools to traverse the pipeline at an optimal\nvelocity which ensures sufficient inspection coverage and quality results.” Id.\n5 The gauge tool ran on April 23, 2019. Id.\n6 The deformation tool had to be sourced from Germany. Id.\n7 Id.\n\n\n\nCPF No. 4-2020-5005\nPage 3\ndelays and incomplete tool runs on July 19, 2019.8\nPursuant to § 195.452(j)(4)(ii), if an operator requires a longer assessment period due to\nunavailable technology, it must notify PHMSA 180 days before the end of the five-year interval,\njustify the reason(s) why it cannot comply, demonstrate what action(s) it is taking to evaluate the\nintegrity of the line in the interim, and provide an estimate of when the assessment can be\ncompleted. In this case, NuStar did not notify PHMSA 180 days in advance of the assessment\ndeadline that it needed additional time to complete the ILI runs due to unavailable technology.\nInstead, the company did not notify PHMSA until the day of the regulatory deadline, July 19,\n2019, to report that it would not meet the five-year assessment interval. NuStar did not complete\nits ILI assessment on the Hermann Pipeline until March 2020.\nThis provision in § 195.452(j)(4)(ii) provides a “safe harbor” mechanism by which operators\nwho experience technical difficulties in meeting the five-year assessment interval can alert\nPHMSA to any delays and make alternative provisions to ensure safety until those problems can\nbe resolved. NuStar, however, did not take advantage of this flexibility provided by the Code.\nAccordingly, after considering all of the evidence, I find that Respondent violated 49 C.F.R.\n§ 195.452(j)(1) by failing to assess the Hermann Pipeline at specified intervals and periodically\nevaluate the integrity of each pipeline segment that could affect a high consequence area.\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.9 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\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 $10,300 for the violation cited above.\nItem 1: The Notice proposed a civil penalty of $10,300 for Respondent’s violation of 49 C.F.R.\n8 The tool was ultimately cut out of the pipeline in November 2019. In December 2019, a root cause analysis by the\nILI tool vendor determined that there was a foreign metal object on the magnet segment that was located at the weld,\nbut ultimately was unable to identify the actual cause of the failure. Id.\n9 These amounts are adjusted annually for inflation. See 49 C.F.R. § 190.223.\n\n\n\nCPF No. 4-2020-5005\nPage 4\n§ 195.452(j)(1) for a failure to assess the Hermann Pipeline at specified intervals and\nperiodically evaluate the integrity of each pipeline segment that could affect a high consequence\narea. In its Response, NuStar presented additional information to explain why the company did\nnot conduct the ILI assessment within the five-year period. Specifically, NuStar explained that\nequipment unavailability, plant outages, and unforeseen complications with the first MFL tool\ncaused the company to exceed the regulatory deadline. I will address each argument separately\nbelow.\nFirst, the regulatory deadline already provides operators an additional eight-month allowance to\ncomplete their five-year assessments by permitting operators to extend beyond the 60-month\ndeadline to 68-months.10 This extension of time provides flexibility to allow for unforeseeable\nevents (e.g., permitting delays, weather, tool failures) that could affect the ability to successfully\ncomplete an assessment on time.11 Additionally, while it is unfortunate, unavailable internal\ninspection technology is not uncommon in the pipeline industry. Therefore, PHMSA has\npromulgated regulations to address situations where operators face unavailable technology issues\nthat may delay integrity assessments. As discussed above, NuStar did not avail itself of this\nopportunity to timely notify PHMSA of the delay.\nSecond, NuStar contended that unforeseen complications with the first MFL tool caused delays.\nIn its Response, the company noted that small-diameter pipelines, like the Hermann line, have\nhistorically experienced challenges with MFL tools. Therefore, the company should have known\nthat its four-inch diameter line might experience potential complications with the MFL tool.\nEven if NuStar believed the MFL tool would run successfully, it learned otherwise when the first\nrun resulted in only 62 percent coverage in 2017. The company even considered replacing bends\nin the line, and initiated discussions with another tool vendor in 2018 after the first MFL tool\nfailed.12 Despite the complications of the first tool run, NuStar did not schedule a second tool\nrun until 2019. The deformation tool ran in June 2019, one month before the regulatory\ndeadline, and beyond the time allowance to notify PHMSA that it required a longer assessment\nperiod. Therefore, I do not find either explanation warrants a reduction in the proposed penalty.\nFurther, the proposed penalty amount took into consideration NuStar’s good-faith efforts to\ncomply with the regulation and proposed a lower penalty that took such efforts into account.13\nAfter the first unsuccessful MFL tool run, NuStar discussed replacing problematic bends in the\nline, and initiated discussions with another tool vendor. When NuStar scheduled the second\nassessment, the company reasonably did not anticipate any problems with the deformation tool,\nsince they ran it successfully in 2017.\n10 See 49 C.F.R. § 195.452(j)(3).\n11 PHMSA Hazardous Liquid Integrity Management FAQ 5.11 (last revised Dec. 19, 2007) available at\nhttps://www.phmsa.dot.gov/pipeline/hazardous-liquid-integrity-management/hl-im-faqs (last accessed July 28,\n2020).\n12 Response, at 2.\n13 See Violation Report, at 10 (determining that the company “had a reasonable justification for its\nnoncompliance”).\n\n\n\nCPF No. 4-2020-5005\nPage 5\nAccordingly, having reviewed the record and considered the assessment criteria, I assess\nRespondent a civil penalty of $10,300 for violation of 49 C.F.R. § 195.452(j)(1).\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\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 $10,300 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.\nCOMPLIANCE ORDER WITHDRAWAL\nThe Notice proposed a compliance order with respect to Item 1 in the Notice for violation of 49\nC.F.R. § 195.452(j)(1). 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.\nWith regard to the violation of § 195.452(j)(1) (Item 1), Respondent argued the proposed\ncompliance terms should be deemed complete. Specifically, the Proposed Compliance Order\nrequired NuStar to conduct an assessment of the Hermann Pipeline within 90 days of the\nissuance of a final order.14 In its Response, NuStar reported that it completed the MFL tool run\nby March 2020. The company also informed PHMSA that it had updated its procedures to\nensure timely notice to PHMSA of assessment delays and implementation of interim safety\nmeasures to ensure the integrity of the pipeline should unforeseen circumstances arise with\nrespect to tool technology and equipment availability.15 The company also noted that it was\nexploring alternative assessment methods and technologies for its four-inch-diameter Hermann\nPipeline.16\nDespite not running these tools concurrently, or within the five-year assessment interval, NuStar\nsuccessfully ran a gauge tool (April 2019), a deformation tool (May 2017) and a MFL tool\n(March 2020) on its Hermann Pipeline. The Region did not provide any explanation why the\n14 Notice, at 4.\n15 Response, at Exhibit 4, Draft Revisions to NuStar IM Variance Procedure.\n16 Response, at 3.\n\n\n\nCPF No. 4-2020-5005\nPage 6\nCompliance Order should remain in place given the fact that the operator has completed its\nreassessment (despite doing so beyond the five-year interval). Therefore, the Compliance Order\nis withdrawn. It is important to note, however, that running internal inspection tools years apart\nis not recommended. Given the capabilities of current technology, an operator who elects to use\ninternal inspection assessment methods should run a metal loss tool and a deformation device in\na similar time frame to maximize the value of data integration.17 Further, running the tools in\nclose proximity allows the operator to readily identify potentially serious anomalies such as\ndents with metal loss. Therefore, I strongly recommend that NuStar amend its written\nprocedures to require that its deformation tool and metal loss tool be run as concurrently as\npossible during the five-year assessment interval.\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.\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 this\nFinal Order by Respondent. Any petition submitted must contain a statement of the issue(s) and\nmeet 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 corrective\naction, remain in effect unless the Associate Administrator, upon request, grants a stay.\nThe terms and conditions of this Final Order are effective upon service in accordance with 49\nC.F.R. § 190.5.\nSeptember 3, 2020\n___________________________________ __________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety\n17 See § 195.452(g) (requiring operators to analyze all available information about the integrity of the entire pipeline\nand the consequences of a failure, including data gathered during integrity assessments).\n\n420205005_NOPV PCP PCO_02042020_text.pdf\n\nNOTICE OF PROBABLE VIOLATION\nPROPOSED CIVIL PENALTY\nand\nPROPOSED COMPLIANCE ORDER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 4, 2020\nBrad Barron\nPresident and Chief Executive Officer\nNuStar Energy L.P.\n19003 IH-10 Frontage Road\nSan Antonio, Texas 78257\nCPF 4-2020-5005\nDear Mr. Barron:\nFrom August 9, 2019 through December 17, 2019, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter\n601 of 49 United States Code (U.S.C.) reviewed an Integrity Management (IM) notification\nsubmitted on July 19, 2019, by NuStar Pipeline Operating Partnership L.P. (NuStar).\nAs a result of the review, it is alleged that you have committed a probable violation of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and the\nprobable violation is:\n\n\n\n1. § 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(1) General. After completing the baseline integrity assessment, an operator must\ncontinue to assess the line pipe at specified intervals and periodically evaluate the\nintegrity of each pipeline segment that could affect a high consequence area.\nNuStar failed to continue to assess the line pipe at specified intervals and periodically evaluate the\nintegrity of each pipeline segment that could affect a high consequence area after completing the\nbaseline integrity assessment. NuStar is required to continue to assess its pipelines and\nperiodically evaluate the integrity of its lines at intervals no longer than 5 years (68 months), as\nspecified in § 195.452(j)(3). NuStar failed to assess its 4-inch Hermann anhydrous ammonia\npipeline located in Hermann, Missouri within the required 5-year (not to exceed 68 months)\ninterval.\nOn August 23, 2019, PHMSA confirmed that the last successful completed assessment (MFL) was\nperformed on November 19, 2013, which would require NuStar to complete its next assessment\nno later than November 18, 2018. NuStar has not completed the required assessment.\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\nbefore November 27, 2018, the maximum penalty may not exceed $209,002 per violation per day,\nwith a maximum penalty not to exceed $2,090,022. For violations occurring prior to November\n2, 2015, the maximum penalty may not exceed $200,000 per violation per day, with a maximum\npenalty not to exceed $2,000,000 for a related series of violations. The Compliance Officer has\nreviewed the circumstances and supporting documentation involved for the above probable\nviolation(s) and has recommended that you be preliminarily assessed a civil penalty of $10,300 as\nfollows:\nItem number PENALTY\n1 $10,300\n2\n\n\n\nProposed Compliance Order\nWith respect to item number 1 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous\nMaterials Safety Administration proposes to issue a Compliance Order to NuStar. Please refer to\nthe 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\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\nyou believe that any portion of your responsive material qualifies for confidential treatment under\n5 U.S.C. 552(b), along with the complete original document you must provide a second copy of\nthe document 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 4-2020-5005 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: Gary Koegeboehn, Vice President Operations, NuStar Pipeline Operating Partnership, L.P.,\n19003 IH-10 West, San Antonio, Texas 78257\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Enforcement 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 NuStar Pipeline Operating Partnership L.P (NuStar)\na Compliance Order incorporating the following remedial requirements to ensure the compliance\nof NuStar with the pipeline safety regulations:\n1. 2. In regard to Item Number 1 of the Notice pertaining to NuStar’s failure to conduct\na continual assessment of its 4-inch Hermann anhydrous ammonia pipeline located\nin Hermann Missouri, NuStar must conduct an assessment of the 4-inch line within\n90-days of the issuance of a Final Order. NuStar must submit evidence of the\ncompletion of the assessment to PHMSA for verification\nIt is requested (not mandated) that NuStar maintain documentation of the safety\nimprovement costs associated with fulfilling this Compliance Order and submit the\ntotal to Mary McDaniel, Director, Southwest Region, Pipeline and Hazardous\nMaterials Safety Administration. It is requested that these costs be reported in two\ncategories: 1) total cost associated with preparation/revision of plans, procedures,\nstudies and analyses, and 2) total cost associated with replacements, additions and\nother changes to pipeline infrastructure.\n4","truncated":false,"body_characters":25779}