{"operation":"document","citation":"CPF 42021013NOPV","title":"EXXONMOBIL PRODUCTION COMPANY, A DIVISION OF EXXON MOBIL CORPORATION — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-03-04","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.440(c), 195.442(a), 195.49, 195.505(i), 195.555.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021013nopv.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021013nopv.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021013nopv","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42021013NOPV","body":"Notice of Probable Violation involving EXXONMOBIL PRODUCTION COMPANY, A DIVISION OF EXXON MOBIL CORPORATION. PHMSA's enforcement data identifies the cited regulations as 195.440(c),  195.442(a),  195.49,  195.505(i),  195.555. The case was opened on 2021-03-04 and is reported as closed as of 2022-01-26. Proposed civil penalty: $39,200. Assessed civil penalty: $19,600. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42021013NOPV_Closure Letter_01262022_(20-172153).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021013NOPV/42021013NOPV_Closure%20Letter_01262022_(20-172153).pdf\n\n42021013NOPV_Closure Letter_01262022_(20-172153)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021013NOPV/42021013NOPV_Closure%20Letter_01262022_(20-172153)_text.pdf\n\n42021013NOPV_Final Order_12212021_(20-172153).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021013NOPV/42021013NOPV_Final%20Order_12212021_(20-172153).pdf\n\n42021013NOPV_Final Order_12212021_(20-172153)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021013NOPV/42021013NOPV_Final%20Order_12212021_(20-172153)_text.pdf\n\n42021013NOPV_Operator Response to Notice_04022021_(20-172153).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021013NOPV/42021013NOPV_Operator%20Response%20to%20Notice_04022021_(20-172153).pdf\n\n42021013NOPV_PCP PCO_03042021_(20-172153).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021013NOPV/42021013NOPV_PCP%20PCO_03042021_(20-172153).pdf\n\n42021013NOPV_PCP PCO_03042021_(20-172153)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021013NOPV/42021013NOPV_PCP%20PCO_03042021_(20-172153)_text.pdf\n\n42021013NOPV_Final Order_12212021_(20-172153)_text.pdf\n\nDecember 21, 2021\nVIA ELECTRONIC MAIL TO: liam.m.mallon@exxonmobil.com\nMr. Liam Mallon\nPresident\nExxonMobil Upstream Oil & Gas Company, US Conventional\n22777 Springwoods Village Parkway\nSpring, Texas 77389\nRe: CPF No. 4-2021-013-NOPV\nDear Mr. Mallon:\nEnclosed please find the Final Order issued in the above-referenced case. It withdraws two of\nthe allegations of violation, makes other findings of violation, assesses a reduced civil penalty of\n$19,600, and specifies actions that need to be taken by ExxonMobil Upstream Oil & Gas\nCompany, US Conventional, to comply with the pipeline safety regulations. The penalty\npayment terms are set forth in the Final Order. When the civil penalty has been paid and the\nterms of the compliance order completed, as determined by the Director, Southwest Region, this\nenforcement action will be closed. Service of the Final Order by e-mail is effective upon the\ndate 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. Otis Dickinson, Santa Ynez Unit Safety, Security, Health, and Environment\nSupervisor, ExxonMobil Upstream Oil & Gas, US Conventional,\notis.dickinson@exxonmobil.com\nMr. Adolfo Calero, Regulatory Specialist, ExxonMobil Upstream Oil & Gas, US\nConventional, adolfo.a.calero@exxonmobil.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 )\n)\n)\nExxonMobil Upstream Oil & Gas Co., US Conventional, )\n)\nRespondent. )\n____________________________________)\n) CPF No. 4-2021-013-NOPV\nFINAL ORDER\nFrom July 7, 2020 through September 25, 2020, pursuant to 49 U.S.C. § 60117, a representative\nof the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline\nSafety (OPS), conducted an on-site pipeline safety inspection of the facilities and records of the\nSanta Ynez Unit, owned and operated by ExxonMobil Upstream Oil & Gas Company, US\nConventional (ExxonMobil or Respondent) off the coast of California. The Santa Ynez Unit\nconsists of three offshore production platforms (Heritage, Harmony, and Hondo) and an onshore\noil and natural gas processing facility (the Las Flores Processing Plant). PHMSA inspected the\n11.2-mile transportation pipeline originating offshore on Platform Harmony and traveling\nonshore to the Las Flores Processing Plant.\nAs a result of the inspection, the Director, Southwest Region, OPS (Director), issued to\nRespondent, by letter dated March 4, 2021, 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 ExxonMobil had committed four violations of 49 C.F.R. Part 195,\nproposed assessing a civil penalty of $39,200 for the alleged violations, and proposed ordering\nRespondent to take certain measures to correct the alleged violations. The Notice also included\nan additional warning item pursuant to 49 C.F.R. § 190.205, which required no further action,\nbut warned the operator to correct the probable violation or face possible future enforcement\naction.\nExxonMobil responded to the Notice by letter dated April 2, 2021 (Response). ExxonMobil\ncontested several of the allegations and offered additional information in response to the Notice.\nRespondent did not request a hearing and therefore has waived its right to one.\nFINDINGS OF VIOLATION\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.49, which states, in\nrelevant part:\n\n\n\nCPF No. 4-2021-013-NOPV\nPage 2\n§ 195.49 Annual report.\nEach operator must annually complete and submit DOT Form PHMSA\nF 7000-1.1 for each type of hazardous liquid pipeline facility operated at the\nend of the previous year. An operator must submit the annual report by June\n15 each year, except that for the 2010 reporting year the report must be\nsubmitted by August 15, 2011….\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.49 by failing to annually complete\nand submit DOT Form PHMSA F 7000-1.1 (Annual Report) for each type of hazardous liquid\npipeline facility operated at the end of the previous year by June 15. Specifically, the Notice\nalleged that ExxonMobil failed to complete and submit its 2019 Annual Report by June 15,\n2020. Instead, the company submitted its 2019 Annual Report on July 8, 2020. After submittal,\nPHMSA discovered mileage discrepancies by system type between the 2018 and 2019 Annual\nReports.\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. § 195.49 failing to timely submit its\n2019 Annual Report.\nItem 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.440(c), which states:\n§ 195.440 Public awareness.\n(a) . . .\n(c) The operator must follow the general program recommendations,\nincluding baseline and supplemental requirements of API RP 1162, unless\nthe operator provides justification in its program or procedural manual as to\nwhy compliance with all or certain provisions of the recommended practice\nis not practicable and not necessary for safety.\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.440(c) by failing to follow the\ngeneral program recommendations, including baseline and supplemental requirements of\nAmerican Petroleum Institute (API) Recommended Practice (RP) 1162, unless the operator\nprovides justification in its program or procedural manual as to why compliance with all or\ncertain provisions of the recommended practice is not practicable and not necessary for safety.\nSpecifically, the Notice alleged that although ExxonMobil incorporated API RP 1162 into its\nPublic Awareness Program, it failed to implement certain requirements. During the inspection,\nExxonMobil could not provide documentation or other evidence to demonstrate that it had\nperformed an annual review of its program pursuant to API RP 1162 Section 8.3, or that it had\nassessed its program effectiveness every 4 years as required by API RP 1162 Section 8.4.\nIn its Response, ExxonMobil provided additional information about its Public Awareness\nProgram, including details regarding how the company performs annual reviews to measure\nprogram effectiveness. On April 13, 2021, ExxonMobil submitted documents to PHMSA\ndemonstrating that the company performed annual program effectiveness reviews for 2016-2019.\nAlthough it is unclear why these documents were not timely provided to PHMSA upon request\nduring the onsite inspection, these records demonstrate that ExxonMobil complied with the cited\nrequirements.\n\n\n\nCPF No. 4-2021-013-NOPV\nPage 3\nAccordingly, after considering all of the evidence, I find ExxonMobil did not violate 49 C.F.R.\n§ 195.440(c). Based upon the foregoing, I hereby order that Item 2 be withdrawn.\nItem 4: The Notice alleged that Respondent violated 49 C.F.R. § 195.505(i), which states, in\nrelevant part:\n§ 195.505 Qualification program.\nEach operator shall have and follow a written qualification program.\nThe program shall include provisions to:\n(a) . . .\n(i) After December 16, 2004, notify the Administrator or a state agency\nparticipating under 49 U.S.C. Chapter 601 if the operator significantly\nmodifies the program after the administrator or state agency has verified\nthat it complies with this section….\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.505(i) by failing to notify PHMSA\nthat it significantly modified its Operator Qualification (OQ) program after PHMSA had verified\nit complied with 49 C.F.R. § 195.505. Specifically, the Notice alleged that ExxonMobil failed to\nnotify PHMSA after it made significant modifications to its OQ program, including the removal\nof covered assets, approval of OQ modules for various covered tasks, changes in course\nmaterials, and changes to its evaluation process, by replacing its computer-based training with a\nthird-party service provider.\nIn its Response, ExxonMobil contested this allegation of violation. Specifically, the company\nexplained that it did not consider these changes to significantly modify its OQ program and\ntherefore, it did not need to report the changes to PHMSA. ExxonMobil considered these\nchanges to be insignificant for several reasons: (1) the removal of its covered asset—the Mobile\nBay pipeline system, located in Alabama—did not affect the OQ Program implemented at the\nSanta Ynez Unit facility in California; (2) the course materials (computer-based training and OQ\nmodules) were replaced with updated content from the same third-party service provider; and (3)\nthe method of evaluation for its OQ Program was not changed, and still consists of a knowledge-\nbased component and a hands-on observation.\n49 C.F.R. § 195.505(i) requires an operator to notify PHMSA if it “significantly modifies” its\nOQ program. Therefore, in order to determine if ExxonMobil should have notified PHMSA of\nthese changes to its OQ program, I must determine if they are “significant changes.” In 2009,\nPHMSA published an Advisory Bulletin that defined “significant changes” to an operator’s OQ\nprogram that would warrant notification to PHMSA.1 The Advisory Bulletin explained that “[a]s\napplicable to OQ program modifications, significant includes but is not limited to: increasing\nevaluation intervals, increasing span of control ratios, eliminating covered tasks, mergers and/or\nacquisition changes, evaluation method changes such as written vs. observation, and wholesale\nchanges made to OQ plan.”2\n1 Pipeline Safety: Operator Qualification (OQ) Program Modifications, 74 FR 64123-01, Dec. 7, 2009.\n2 I also note that ExxonMobil’s Management of Change (MOC) procedures require that “high impact changes” be\nreported to PHMSA, including the “addition/deletion of a covered task, change in acceptable method of evaluations,\nor an increase in the span-of-control or the frequency of evaluation.” See PHMSA Pipeline Safety Violation Report\nat Exhibit E-3 (Mar. 4, 2021) (on file with PHMSA).\n\n\n\nCPF No. 4-2021-013-NOPV\nPage 4\nAfter reviewing the changes ExxonMobil made to its OQ program, I do not find they were\nsignificant changes that required notification. First, the removal of the Mobile Bay pipeline\nsystem in Alabama did not impact the OQ Program administered at the Santa Ynez Unit in\nCalifornia. Second, in its Response, ExxonMobil explained that the course materials referenced\nin its MOC procedures were updates to existing course materials from the same third-party\nservice provider. There is nothing in the record to demonstrate that these module updates served\nto change evaluation methods (e.g., written vs. observation) or otherwise constituted wholesale\nchanges to the OQ program.\nIn sum, none of the changes referenced in the Notice that ExxonMobil made to its OQ program\nsignificantly modified or made wholesale changes to its OQ program. The company did not\nmake changes to covered tasks, modify acceptable evaluation methods, or increase span-of-\ncontrol or frequency of evaluations. Further, although some “merger and/or acquisition changes”\nmay constitute significant modifications to an OQ program, there is nothing in the record to\nsuggest that the sale of its assets in Alabama changed the implementation of its OQ program in\nCalifornia.3 PHMSA has previously found that a change in assets without corresponding\nchanges to the OQ plan is not a significant modification required to be reported.4 Accordingly,\nsince ExxonMobil did not significantly modify its OQ program, it did not need to submit\nnotification to PHMSA of these changes.\nAccordingly, after considering all of the evidence, I find ExxonMobil did not violate 49 C.F.R.\n§ 195.505(i) as alleged in the Notice. Based upon the foregoing, I hereby order that Item 4 be\nwithdrawn.\nItem 5: The Notice alleged that Respondent violated 49 C.F.R. § 195.555, which states:\n§ 195.555 What are the qualifications for supervisors?\nYou must require and verify that supervisors maintain a thorough\nknowledge of that portion of the corrosion control procedures established\nunder § 195.402(c)(3) for which they are responsible for insuring\ncompliance.\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.555 by failing to require and verify\nthat supervisors maintain a thorough knowledge of that portion of the corrosion control\nprocedures established under § 195.402(c)(3) for which they are responsible for ensuring\ncompliance. According to ExxonMobil’s written procedures, “[a]nnually, supervisors will\nindicate, by signing DOT Form TR, that they understand the corrosion control procedures\nemployed for the DOT pipelines they steward....” During the inspection, however, PHMSA\ndiscovered that these forms were completed by ExxonMobil’s Safety and Risk Advisor, and not\nthe requisite supervisors, as required by § 195.555 and ExxonMobil’s procedures. The Notice\n3 For example, in a prior enforcement case, PHMSA found an operator violated § 195.505(i) when it failed to notify\nPHMSA following an acquisition that involved merging multiple OQ programs and removing certain covered tasks.\nIn the Matter of Targa NGL Pipeline Co., Final Order, CPF No. 4-2020-5017, 2021 WL 663175 (Feb. 12, 2021).\n4 See In the Matter of Tristate NLA, LLC, Final Order, CPF No. 4-2020-006-NOPV, 2021 WL 4055261 (Aug. 9,\n2021) (finding an operator did not commit a violation of § 192.805(i) when the operator acquired additional pipeline\nfacilities but the acquisition did not result in any changes to its OQ program).\n\n\n\nCPF No. 4-2021-013-NOPV\nPage 5\nfurther alleged that several of the company’s supervisors had let their corrosion control training\nlapse.\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. § 195.555 failing to require and verify\nthat supervisors maintain a thorough knowledge of that portion of the corrosion control\nprocedures established under § 195.402(c)(3) for which they are responsible for ensuring\ncompliance.\nThese findings of violation will be considered prior offenses in any subsequent enforcement\naction taken against Respondent.\nASSESSMENT OF PENALTY\nUnder 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed\n$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any\nrelated series of violations.5\nIn determining the amount of a civil penalty under 49 U.S.C. § 60122 and 49 C.F.R. § 190.225, I\nmust consider the following criteria: the nature, circumstances, and gravity of the violation,\nincluding adverse impact on the environment; the degree of Respondent’s culpability; the history\nof Respondent’s prior offenses; any effect that the penalty may have on its ability to continue\ndoing business; the good faith of Respondent in attempting to comply with the pipeline safety\nregulations; and self-disclosure or actions to correct a violation prior to discovery by PHMSA.\nIn addition, I may consider the economic benefit gained from the violation without any reduction\nbecause of subsequent damages, and such other matters as justice may require. The Notice\nproposed a total civil penalty of $39,200 for the violations cited above.\nItem 2: The Notice proposed a civil penalty of $19,600 for Respondent’s alleged violation of 49\nC.F.R. § 195.440(c). Since this alleged violation has been withdrawn, the proposed penalty is\nnot assessed.\nItem 5: The Notice proposed a civil penalty of $19,600 for Respondent’s violation of 49 C.F.R.\n§ 195.555, for failing to require and verify that supervisors maintain a thorough knowledge of\nthat portion of the corrosion control procedures established under § 195.402(c)(3) for which they\nare responsible for ensuring compliance. Although pipeline safety was minimally affected,\nExxonMobil failed to comply with a requirement that was clearly applicable and did not provide\na justification for its noncompliance. Accordingly, having reviewed the record and considered\nthe assessment criteria, I assess Respondent a civil penalty of $19,600 for violation of 49 C.F.R.\n§ 195.555.\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 $19,600.\nPayment of the civil penalty must be made within 20 days of service. Federal regulations (49\n5 These amounts are adjusted annually for inflation. See 49 C.F.R. § 190.223.\n\n\n\nCPF No. 4-2021-013-NOPV\nPage 6\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 $19,600 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.\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Items 1, 2, 4, and 5 in the Notice for\nviolations of 49 C.F.R. §§ 195.49, 195.440(c), 195.505(i) and 195.555, respectively. Under 49\nU.S.C. § 60118(a), each person who engages in the transportation of hazardous liquids or who\nowns or operates a pipeline facility is required to comply with the applicable safety standards\nestablished under chapter 601. Since Items 2 and 4 have been withdrawn, the associated\ncompliance terms for each item are also withdrawn.\nIn response to Item 1, the Director has indicated that Respondent submitted a corrected 2019\nSupplemental Annual Report to PHMSA. Accordingly, I find that compliance has been\nachieved with respect to this violation. Therefore, the compliance terms proposed in the Notice\nfor Item 1 are not included in this Order.\nAs for the remaining compliance terms, pursuant to the authority of 49 U.S.C. § 60118(b) and 49\nC.F.R. § 190.217, Respondent is ordered to take the following actions to ensure compliance with\nthe pipeline safety regulations applicable to its operations:\n1. With respect to the violation of § 195.555 (Item 5), Respondent must ensure that\nits supervisors annually sign a DOT Form TR to indicate that they understand the\nprocedures employed for the pipelines that they are responsible within 30 days of\nreceipt of the Final Order. ExxonMobil must also ensure all supervisors have the\nrequired training that is up-to-date and submit updated training records to PHMSA for\nreview within 30 days of receipt of the Final 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.\nPHMSA requests that Respondent maintain documentation of the safety improvement costs\nassociated with fulfilling this Compliance Order and submit the total to the Director. 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 associated with\n\n\n\nCPF No. 4-2021-013-NOPV\nPage 7\nreplacements, additions and other changes to pipeline infrastructure.\nFailure to comply with this Order may result in administrative assessment of civil penalties not\nto exceed $200,000, as adjusted for inflation (see 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 3, the Notice alleged a probable violation of Part 195, but identified it as a\nwarning item pursuant to § 190.205. The warning was for:\n49 C.F.R. § 195.442(a) (Item 3) ─ Respondent’s alleged failure to carry out its\nwritten program to prevent damage to that pipeline from excavation activities\nIf OPS finds a violation of this provision in a subsequent inspection, Respondent may be subject\nto 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 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.\nDecember 21, 2021\n___________________________________ __________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n42021013NOPV_Closure Letter_01262022_(20-172153)_text.pdf\n\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nJanuary 26, 2022\nLiam Mallon\nPresident\nExxonMobil Upstream Oil & Gas Company, US Conventional\n22777 Springwoods Village Parkway\nSpring, Texas 77389\nCPF 4-2021-013-NOPV\nDear Mr. Mallon:\nOn December 21, 2021, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued to ExxonMobil Upstream Oil & Gas Company, US Conventional (ExxonMobil), a Final\nOrder in the above-referenced case. This Order included a Compliance Order requirement to\nensure ExxonMobil’s supervisors had up-to-date training and assessed a Civil Penalty. Based on\nPHMSA’s review of the documentation provided by ExxonMobil and confirmation of payment of\nthe Civil Penalty, it has been determined that ExxonMobil has complied with the terms of the Final\nOrder.\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","truncated":false,"body_characters":24649}