{"operation":"document","citation":"CPF 520070022","title":"AMERIGAS EAGLE PROPANE LP — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-10-19","effective_on":null,"summary":"CLOSED notice of probable violation citing 191.1, 192.603(b), 192.614.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520070022.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520070022.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520070022","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520070022","body":"Notice of Probable Violation involving AMERIGAS EAGLE PROPANE LP. PHMSA's enforcement data identifies the cited regulations as 191.1,  192.603(b),  192.614. The case was opened on 2007-10-19 and is reported as closed as of 2010-12-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520070022_FinalOrder_12202010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520070022/520070022_FinalOrder_12202010.pdf\n\n520070022_FinalOrder_12202010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520070022/520070022_FinalOrder_12202010_text.pdf\n\n520070022_NOPV PCO letter_10192007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520070022/520070022_NOPV%20PCO%20letter_10192007.pdf\n\n520070022_nopv pco letter_10192007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520070022/520070022_nopv%20pco%20letter_10192007_text.pdf\n\n520070022_operator response to notice_11162007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520070022/520070022_operator%20response%20to%20notice_11162007.pdf\n\n520070022_FinalOrder_12202010_text.pdf\n\nDEC 20 2010\nMr. Ron Templeman\nGeneral Manager\nAmerigas Eagle Propane, L.P.\n91-280 Hanua Street\nKapolei, HI 96707-1783\nRe: CPF No. 5-2007-0022\nDear Mr. Templeman:\nEnclosed please find the Final Order issued in the above-referenced case. It withdraws one of\nthe allegations of violation, makes two findings of violation, and finds that Amerigas Eagle\nPropane, L.P., has completed the actions specified in the Notice to comply with the pipeline\nsafety regulations. Therefore, this case is now closed. Service of the Final Order by certified\nmail is deemed effective upon the date of mailing, or as otherwise provided under 49 C.F.R.\n§ 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. Chris Hoidal, Director, Western Region, PHMSA\nCERTIFIED MAIL – RETURN RECEIPT REQUESTED [7005 1160 0001 0041 0794]\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 )\nAmerigas Eagle Propane, L.P., ) CPF No. 5-2007-0022\n)\n)\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nOn November 13, 2006, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),\nconducted an on-site pipeline safety inspection of the facilities and records of Amerigas Eagle\nPropane, L.P. (Amerigas or Respondent), in Kapolei, Hawaii. Amerigas operates propane\ndistribution systems on the island of Oahu.\nsystems at shopping centers on Oahu.\n1 OPS’s inspection included a visit to three of those\nAs a result of the inspection, the Director, Western Region, OPS (Director), issued to\nRespondent, by letter dated October 19, 2007, a Notice of Probable Violation and Proposed\nCompliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed\nfinding that Amerigas had committed three violations of 49 C.F.R. Parts 191 and 192 and\nproposed ordering Respondent to take certain measures to correct the alleged violations.\nAmerigas responded to the Notice by letter dated November 16, 2007 (Response). The company\ncontested 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\nThe Notice alleged that Respondent violated 49 C.F.R. Parts 191 and 192, as follows:\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 191.1, which states in relevant\npart:\n1 Amerigas affiliates operate propane distribution systems on the islands of Maui and Hawaii.\n\n\n\n2\n§ 191.1 Scope.\n(a) This part prescribes requirements for the reporting of incidents,\nsafety-related conditions, and annual pipeline summary data by operators\nof gas pipeline facilities located in the United States or Puerto Rico,\nincluding pipelines within the limits of the Outer Continental Shelf as that\nterm is defined in the Outer Continental Shelf Lands Act (43 U.S.C.\n1331).\nThe Notice alleged that Amerigas had never submitted an annual report and had no operations\nand maintenance manual.\nIn its Response, Amerigas objected to the allegation of violation and stated that:\n1) It operates a limited number of propane distribution systems in Hawaii that are subject to\nPHMSA’s jurisdiction, but that “none of those systems services 100 customers or more\nfrom a single source.”\n2) Section 191.1 “is simply a description of scope, and it does not contain any specific\nrequirements.”\n3) The OPS inspector did not request any documentation of compliance with the Part 191\nreporting requirements.\n4) The company had an operations and maintenance manual available at the time of the\ninspection.\nPer § 191.11(b), “The annual report required by this section need not be submitted with respect\nto . . . petroleum gas systems which serve fewer than 100 customers from a single source.”\nAmerigas stated that it is an operator of a petroleum gas system which serves fewer than 100\ncustomers from a single source, and OPS has provided no evidence to the contrary. In the\nabsence of such evidence, I cannot conclude that Amerigas is subject to the reporting\nrequirements of § 191.11.\nFurther, as Amerigas stated, § 191.1 does not contain any specific requirements; rather, it\ndescribes, in broad terms, the scope of Part 191. Accordingly, the substance of the allegations in\nthe Notice does not correspond to the regulation cited, and I cannot find that Respondent violated\n§ 191.1.\nBased on the foregoing, I order that Item 1 be withdrawn.\nItem 2: The Notice alleged that Respondent violated 49 C.F.R. §§ 192.603§ 192.605, which\nstates in relevant part:\n§ 192.603 General Provisons.\n(a) . . . .\n(b) Each operator shall keep records necessary to administer the\nprocedures established under § 192.605.\n(c) . . . .\n\n\n\n3\n§ 192.605 Procedural manual for operations, maintenance, and\nemergencies.\n(a) General. Each operator shall prepare and follow for each pipeline,\na manual of written procedures for conducting operations and maintenance\nactivities and for emergency response. . . .\n(b) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following, if\napplicable, to provide safety during maintenance and operations. . . .\n(1) . . . .\n(d) Safety-related condition reports. The manual required by\nparagraph (a) of this section must include instructions enabling personnel\nwho perform operation and maintenance activities to recognize conditions\nthat potentially may be safety-related conditions that are subject to the\nreporting requirements of § 191.23 of this subchapter.\n(e) Surveillanace, emergency respondse, and accident investigation. The\nprocedures required by §§ 192.613(a), 192.615, and 192.617 must be\nincluded in the manual required by paragraph (a) of this section.\nIn particular, the Notice alleged that Respondent violated 49 C.F.R §§ 192.603(b) and\n192.605(a)-(b) and (d)-(e) by failing to develop an adequate manual of operations and\nmaintenance procedures for its propane distribution systems and to keep the records necessary to\nadminister those procedures. Amerigas provided a copy of its operations and maintenance\nmanual with its Response and stated that the alleged violation lacked merit.\nThe operations and maintenance manual submitted by Respondent bears an effective date of\nOctober 10, 2007, almost 11 months after the OPS inspection. That manual also replaced the\nversion that had been in effect since June 1, 1998, thereby indicating that it had not been revised\nfor more than eight years at the time of the OPS inspection. In addition, Respondent has not\nintroduced any records necessary for the proper administration of the procedures in its manual,\nand an Amerigas employee told the OPS inspector “that [the] records necessary for compliance\nwith [its] written procedures . . . ha[d] never existed.”2\nAccordingly, after considering all of the evidence, I find that Respondent violated 49 C.F.R.\n§§ 192.603(b) and 192.695(a)-(b) and (d)-(e) by failing to develop an adequate manual of\noperations and maintenance procedures for its propane distribution systems and to keep the\nrecords necessary to administer those procedures.\nItem 3: The Notice alleged that Respondent violated 49 C.F.R. § 192.614, which states in\nrelevant part:\n§ 192.614 Damage prevention program.\n(a) Except as provided in paragraphs (d) and (e) of this section, each\noperator of a buried pipeline must carry out, in accordance with this\nsection, a written program to prevent damage to that pipeline from\nexcavation activities. . . .\n2 OPS Violation Report at 4.\n\n\n\n4\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.614 by failing to carry out a\ndamage prevention program, as demonstrated by the absence of any records. In its Response,\nAmerigas stated that the OPS inspector did not request any records related to its damage\nprevention program, and that it had procedures for carrying out that program in its operations and\nmaintenance manual. Respondent submitted its O&M manual with its Response, and stated that\nSection 5.3, entitled Damage Prevention Program, demonstrated its compliance with § 192.614.\nThe O&M manual that Respondent submitted contains markings on each page indicating an\neffective date of October 10, 2007. These markings also indicate that this version of the O&M\nmanual replaced a version dated June 1, 1998. The effective date of the O&M manual was\nnearly a year after the date of the inspection. Although this version of the manual is probative\nfor the purposes of determining whether Respondent satisfied the terms of the compliance order,\nit does not provide evidence that Respondent had an adequate damage prevention program at the\ntime of the inspection. Thus, Respondent provided no evidence that it had a damage prevention\nprogram in place at the time of the inspection.\nAccordingly, after considering all of the evidence, I find that Respondent violated 49 C.F.R.\n§ 192.614(a) by failing to carry out a damage prevention program.\nThis finding of violation will be considered a prior offense in any subsequent enforcement action\ntaken against Respondent.\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Items 1, 2, and 3 in the Notice for\nviolations of 49 C.F.R. §§ 191.1, 192.605, and 192.614, respectively. Under 49 U.S.C.\n§ 60118(a), each person who engages in the transportation of gas or who owns or operates a\npipeline facility is required to comply with the applicable safety standards established under\nchapter 601.\nBecause I ordered that Items 1 and 2 be withdrawn, the compliance terms proposed in the Notice\nas to those Items are not included in this Order.\nThe Director indicates that Respondent has taken the following actions specified in the proposed\ncompliance order:\n1. With respect to the violation of §§ 192.603(b) and 192.695(a)-(b) and (d)-(e)\n(Item 2), a December 2008 OPS inspection confirmed that Respondent has developed\na sufficient manual of operations and maintenance procedures for its propane\ndistribution systems and for keeping the records necessary to administer those\nprocedures.\n2. With respect to the violation of §192.614 (Item 3), Respondent has submitted a\nwritten damage prevention.\n\n\n\n5\nAccordingly, I find that compliance has been achieved with respect to these violations.\nTherefore, the compliance terms proposed in the Notice for Item 2 and 3 are not included in this\nOrder.\nUnder 49 C.F.R. § 190.215, Respondent has a right to submit a Petition for Reconsideration of\nthis Final Order. The petition must be sent to: Associate Administrator, Office of Pipeline\nSafety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC\n20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address. PHMSA\nwill accept a petition received no later than 20 days after receipt of this Final Order by the\nRespondent, provided it contains a brief statement of the issue(s) and meets all other\nrequirements of 49 C.F.R. § 190.215. Unless the Associate Administrator, upon request, grants a\nstay, the terms and conditions of this Final Order are effective upon service in accordance with\n49 C.F.R. § 190.5.\n___________________________________ __________________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n520070022_nopv pco letter_10192007_text.pdf\n\nSENT T't\n~ C(. 'Mt'LtaNt 'E kEGtST\nHardcopy t. . 'lect ron tcally\n¹ of Cop~es L! Date ~1+ 'ito f\n1papp W Dakota Ave Suite 11p\nLakewood, CO Sp2&&\nU. S. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\nNOTICE OF PROBABLE VIOLATION\nand\nPROPOSED COMPLIANCE ORDER\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nOctober 19, 2007\nMr. Ron Templeman, P. E.\nAmerigas Propane\n91 — 290 Hanua Street\nKapolei, HI 96707-1783\nCPF 5-2007-0022\nDear Mr. Templeman:\nOn November 13, 2006, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\ndistribution facilities in Kapolei, Hawaii.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n$191. 1 Scope\n(a) This part prescribes requirements for the reporting of incidents, safety-related\nconditions, and annual pipeline summary data by operators of gas pipeline facilities\nlocated in the United States or Puerto Rico, including pipelines within the limits of\nthe Outer Continental Shelf as that term is defined in the Outer Continental Shelf\nLands Act t43 U. S. C. 1331].\n\n\n\nRecords were unavailable at the time of the inspection to substantiate compliance with\nthis section. Amerigas has never submitted an Annual Report, and acknowledged that\nOperation and Maintenance procedures have never been initiated.\n$192. 605 Procedural manual for operations, maintenance, and emergencies\nEach operator shall include the following in its operating and maintenance plan:\n(a) General. Each operator shall prepare and follow for each pipeline, a manual\nof written procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least one each\ncalendar year. This manual must be prepared before operations of a pipeline\nsystem commence. Appropriate parts of the manual must be kept at locations\nwhere operations and maintenance activities are conducted.\n(b) Maintenance and normal operations. The manual required by paragraph (a)\nof this section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in accordance with each of\nthe requirements of this subpart and Subpart M of this part.\n(2) Controlling corrosion in accordance with the operations and maintenance\nrequirements of Subpart I of this part.\n(3) Making construction records, maps, and operating history available to\nappropriate operating personnel.\n(4) Gathering of data needed for reporting incidents under Part 191 of this chapter\nin a timely and effective manner.\n(5) Starting up and shutting down any part of the pipeline in a manner designed to\nassure operation within the MAOP limits prescribed by this part, plus the build-up\nallowed for operation of pressure-limiting and control devices.\n(6) Maintaining compressor stations, including provisions for isolating units or\nsections of pipe and for purging before returning to service.\n(7) Starting, operating and shutting down gas compressor units.\n(8) Periodically reviewing the work done by operator personnel to determine the\neffectiveness and adequacy of the procedures used in normal operation and\nmaintenance and modifying the procedure when deficiencies are found.\n(9) Taking adequate precautions in excavated trenches to protect personnel from\nthe hazards of unsafe accumulations of vapor or gas, and making available when\nneeded at the excavation, emergency rescue equipment, including a breathing\napparatus and, a rescue harness and line.\n(10) Systematic and routine testing and inspection of pipe-type or bottle-type\nholders including-\n(i) Provision for detecting external corrosion before the strength of the container\nhas been impaired;\n\n\n\n(ii) Periodic sampling and testing of gas in storage to determine the dew point of\nvapors contained in the stored gas which, if condensed, might cause internal\ncorrosion or interfere with the safe operation of the storage plant; and,\n(iii) Periodic inspection and testing of pressure limiting equipment to determine\nthat it is in safe operating condition and has adequate capacity.\n(11) Responding promptly to a report of a gas odor inside or near a building,\nunless the operator's emergency procedures under $192. 615(a)(3) specifically apply\nto these reports.\n(c) Safety-related condition reports. The manual required by paragraph (a) of this\nsection must include instructions enabling personnel who perform operation and\nmaintenance activities to recognize conditions that potentially may be safety-related\nconditions that are subject to the reporting requirements of $191. 23 of this\nsubchapter.\n(d) Surveillance, emergency response, and accident investigation. The procedures\nrequired by $/192. 613(a), 192. 615, and 192. 617 must be included in the manual\nrequired by paragraph (a) of this section.\nWhen Operation and Mamtenance procedures are developed in accordance with\n$192. 603, Amerigas must maintain records to admmister these procedures for operation\nof its pipeline system.\n3. $192. 614 Damage prevention program\n(a) Except for pipelines listed in paragraphs (d) and (e) of this section, each\noperator of a buried pipeline shall carry out in accordance with this section a\nwritten program to prevent damage to that pipeline by excavation activities. For\nthe purpose of this section, \"excavation activities\" include excavation, blasting,\nboring, tunneling, backfilling, the removal of above ground structures by either\nexplosive or mechanical means, and other earth moving operations. An operator\nmay perform any of the duties required by paragraph (b) of this section through\nparticipation in a public service program, such as a \"one-call\" system, but such\nparticipation does not relieve the operator of responsibility for compliance with this\nsection.\n(b) An operator may comply with any of the requirements of paragraph (c) of this\nsection through participation in a public service program, such as a one-call\nsystem, but such participation does not relieve the operator of responsibility for\ncompliance with this section. However, an operator must perform the duties of\nparagraph (c)(3) of this section through participation in a one-call system, if that\none-call system is a qualified one-call system. In areas that are covered by more\nthan one qualified one-call system, an operator need only join one of the qualified\none-call systems if there is a central telephone number for excavators to call for\nexcavation activities, or if the one-call systems in those areas communicate with one\nanother. An operator's pipeline system must be covered by a qualified one-call\nsystem where there is one in place. For the purpose of this section, a one-call system\n\n\n\nis considered a \"qualified one-call system\" if it meets the requirements of section\n(b)(1) or (b)(2) of this section.\n(1) The state has adopted a one-call damage prevention program under Sec. 198. 37\nof this chapter; or\n(2) The one-call system:\n(i) Is operated in accordance with Sec. 198. 39 of this chapter;\n(ii) Provides a pipeline operator an opportunity similar to a voluntary participant\nto have a part in management responsibilities;\nAnd\n(iii) Assesses a participating pipeline operator a fee that is proportionate to the\ncosts of the one-call system's coverage of the operator's pipeline.\n(c) The damage prevention program required by paragraph (a) of this section\nmust, at a minimum:\n(1) Include the identity, on a current basis, of persons who normally engage in\nexcavation activities in the area in which the pipeline is located.\n(2) Provides for notification of the public in the vicinity of the pipeline and actual\nnotification of the persons identified in paragraph (c)(1) of this section of the\nfollowing as often as needed to make them aware of the damage prevention\nprogram:\n(i) The program's existence and purpose; and\n(ii) How to learn the location of underground pipelines before excavation activities\nare begun.\n(3) Provide a means of receiving and recording notification of planned excavation\nactivities.\n(4) If the operator has buried pipelines in the area of excavation activity, provide\nfor actual notification of persons who give notice of their intent to excavate of the\ntype of temporary marking to be provided and how to identify the markings.\n(5) Provide for temporary marking of buried pipelines in the area of excavation\nactivity before, as far as practical, the activity begins.\n(6) Provide as follows for inspection of pipelines that an operator has reason to\nbelieve could be damaged by excavation activities:\n(i) The inspection must be done as frequently as necessary during and after the\nactivities to verify the integrity of the pipeline; and\n(ii) In the case of blasting, any inspection must include leakage surveys\n(d) A damage prevention program under this section is not required for the\nfollowing pipelines:\n(1) Pipelines located offshore.\n(2) Pipelines, other than those located offshore, in Class 1 or 2 locations until\nSeptember 20, 1995.\n(3) Pipelines to which access is physically controlled by the operator.\n(e) Pipelines operated by persons other than municipalities (including operators of\nmaster meters) whose primary activity does not include the transportation of gas\nneed not comply with the following:\n(1) The requirement of paragraph (a) of this section that the damage prevention\nprogram be written; and\n\n\n\n(2) The requirements of paragraphs (c)(1) and (c)(2) of this section.\nRecords were unavailable at the time of the inspection to substantiate that a program was\nin place to prevent damage to its pipelines as a result of excavation.\nPro osed Com liance Order\nPursuant to 49 United States Code ( 60118, the Pipehne and Hazardous Materials Safety\nAdministration proposes to issue a Compliance Order to Amerigas. Please refer to the Proposed\nComphance Order that is enclosed and made a part of this Notice.\nRes onse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators\nin Comphance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you beheve that any portion of your responsive material qualifies\nfor confidential treatment under 5 U. S. C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nquahfies for confidential treatment under 5 U. S. C. 552(b). If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue a Final Order.\nIn your correspondence on this matter, please refer to CPF 5-2007-0022 and for each document\nyou submit, please provide a copy m electronic format whenever possible.\nSincerel,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosures: Proposed Comphance Order\nResponse Options for Pipeline Operators in Comphance Proceedings\ncc: PHP-60 Comphance Registry\nPHP-500 J. Kenerson (¹116801)\n\n\n\nPROPOSED COMPLIANCE ORDER\nPursuant to 49 United States Code ) 60118, the Pipehne and Hazardous Materials Safety\nAdministration (PHMSA) proposes to issue to Amerigas Propane a Compliance Order\nincorporating the following remedial requirements to ensure the compliance of Amerigas\nPropane with the pipeline safety regulations:\nIn regard to Item Number 1 of the Notice pertaining to establishing procedures for\nreporting incidents, safety-related conditions, and annual pipeline summary data by\noperators of gas pipeline facilities, Amerigas must prepare, submit, and follow a written\nprocedure.\nIn regard to Item Number 2 of the Notice pertaining to the requirement to keep records\nthat administer its procedures, prepare a manual of written procedures for conducting\noperations and maintenance activities and for emergency response, reporting incidents\nunder Part 191, as well as all other requirements under $192. 605 applicable to\nAmerigas's operation, Amerigas must submit and follow written procedures to fill the\nrequirements for conducting operations and maintenance activities and for emergency\nresponse, reporting incidents under Part 192, as well as all other requirements under\n192. 605 applicable to Amerigas's operation.\nIn regard to Item Number 3 of the Notice pertaining to establishment of a damage\nprevention program, Amerigas must submit a written program to prevent damage tg its\npipeline by excavation activities.\nAmerigas Propane shall maintain documentation of the safety improvement costs\nassociated with fulfilling this comphance Order and submit the total to Chris Hoidal,\nDirector, Western Region, Pipeline and Hazardous Materials Safety Administration.\nCosts shall 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.","truncated":false,"body_characters":26287}