{"operation":"document","citation":"CPF 520081001","title":"SILICON VALLEY POWER — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-01-03","effective_on":null,"summary":"CLOSED notice of probable violation citing 192.905, 192.907(a), 192.911(i), 192.933(a), 192.933(b), 192.937(a), 192.937(b), 192.945(a), 192.947(d).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520081001.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520081001.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520081001","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520081001","body":"Notice of Probable Violation involving SILICON VALLEY POWER. PHMSA's enforcement data identifies the cited regulations as 192.905,  192.907(a),  192.911(i),  192.933(a),  192.933(b),  192.937(a),  192.937(b),  192.945(a),  192.947(d). The case was opened on 2008-01-03 and is reported as closed as of 2010-03-03. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520081001_FinalOrder_03032010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520081001/520081001_FinalOrder_03032010.pdf\n\n520081001_FinalOrder_03032010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520081001/520081001_FinalOrder_03032010_text.pdf\n\n520081001_NOPV PCO letter_01032008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520081001/520081001_NOPV%20PCO%20letter_01032008.pdf\n\n520081001_nopv pco letter_01032008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520081001/520081001_nopv%20pco%20letter_01032008_text.pdf\n\n520081001_operator response_01312008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520081001/520081001_operator%20response_01312008.pdf\n\n520081001_FinalOrder_03032010_text.pdf\n\nMAR 3 2010\nMs. Jennifer Sparacino\nCity Manager\nCity of Santa Clara\nSilicon Valley Power\n1500 Warburton Avenue\nSanta Clara, CA 95050\nRe: CPF No. 5-2008-1001\nDear Ms. Sparacino:\nEnclosed please find the Final Order issued in the above-referenced case. It makes findings of\nviolation and finds that Silicon Valley Power has completed the actions specified in the Notice to\ncomply with the pipeline safety regulations. Therefore, this case is now closed. Service of the\nFinal Order by certified mail is deemed effective upon the date of mailing, or as otherwise\nprovided under 49 C.F.R. § 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 [7009 1410 0000 2472 9932]\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n______________________________\n)\nIn the Matter of )\n)\nSilicon Valley Power, ) CPF No. 5-2008-1001\n)\nRespondent. )\n______________________________)\nFINAL ORDER\nOn August 13 to 16, 2007, 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 Silicon Valley\nPower (Respondent) in Santa Clara, California. Silicon Valley Power, the municipal electric\nutility for the City of Santa Clara, is the operator of the Donald Von Raesfeld Power Plant and an\nassociated 2.5-mile-long natural gas transmission line.1\nAs a result of the inspection, the Director, Western Region, OPS (Director), issued to\nRespondent, by letter dated January 3, 2008, a Notice of Probable Violation and Proposed\nCompliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed\nfinding that Respondent had violated 49 C.F.R. § 192.933(a) and proposed ordering Respondent\nto take certain measures to correct the alleged violation. The Notice also proposed finding that\nRespondent had committed certain other probable violations of 49 C.F.R. Part 192 and warning\nRespondent to take appropriate corrective action to address them or be subject to future\nenforcement action.\nSilicon Valley Power responded to the Notice by letter dated January 31, 2008 (Response).\nRespondent did not contest the allegations of violation and stated that it would comply with all of\nthe terms in the proposed compliance order. Respondent did not request a hearing and therefore\nhas waived its right to one.\n1 http://www.siliconvalleypower.com/about/pico/ (accessed on Feb. 12, 2010).\n\n\n\n2\nFINDING OF VIOLATION\nIn its Response, Silicon Valley Power did not contest the allegation in the Notice that it violated\n49 C.F.R. Part 192, as follows:\nItem 3B: The Notice alleged that Respondent violated 49 C.F.R. § 192.933(a), which states, in\nrelevant part:\n§ 192.933 What actions must be taken to address integrity issues?\n(a) General requirements. An operator must take prompt action to\naddress all anomalous conditions the operator discovers through the\nintegrity assessment. In addressing all conditions, an operator must\nevaluate all anomalous conditions and remediate those that could reduce a\npipeline's integrity. An operator must be able to demonstrate that the\nremediation of the condition will ensure the condition is unlikely to pose a\nthreat to the integrity of the pipeline until the next reassessment of the\ncovered segment.\nThe Notice alleged that Respondent violated § 192.933(a) by failing to take prompt action to\naddress anomalous conditions discovered through its integrity assessment. Specifically, Silicon\nValley Power performed an inline inspection (ILI) tool run of its natural gas transmission line\nand the results demonstrated a corrosion anomaly with 36% wall thickness. The estimated\ncorrosion growth rate for that area indicated that this condition should be repaired before the next\n7-year reassessment interval, but that no such repair was scheduled or completed. Respondent\ndid not contest this allegation of violation. Accordingly, based upon a review of all of the\nevidence, I find that Respondent violated 49 C.F.R. § 192.933(a) by failing to take prompt action\nto address all anomalous conditions the operator discovers through the integrity assessment\nprocess.\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Item 3B in the Notice for a violation of\n49 C.F.R. § 192.933(a). Under 49 U.S.C. § 60118(a), each person who engages in the\ntransportation of gas or who owns or operates a pipeline facility is required to comply with the\napplicable safety standards established under chapter 601. The Director has indicated that\nRespondent has taken the following actions specified in the proposed compliance order:\n1. Respondent excavated all anomaly locations and remediated\nthe alternating current interference that was causing the\naccelerated corrosion growth rate on its natural gas\ntransmission line.\n\n\n\n3\n2. Respondent also performed a close interval survey and an\nalternating current voltage gradient survey of the entire line\nand remediated all areas of interference.\nAccordingly, I find that compliance has been achieved with respect to this violation. Therefore,\nthe compliance terms proposed in the Notice are not included in this Order.\nWARNING ITEMS\nWith respect to Items 1A, 2A, 3A, 4A, 4B, 4C, 5A and 6A, the Notice alleged probable\nviolations of Part 192 but did not propose a civil penalty or compliance order for these items.\nTherefore, these are considered to be warning items. The warnings were for:\n49 C.F.R. §§ 192.947(d), 192.905(a) (Item 1A) ─ Respondent’s alleged failure to\nmaintain a record of its method for determining each high consequence area\n(HCA);\n49 C.F.R. § 192.907(a) (Item 2A) ─ Respondent’s alleged failure to provide\ndocumentation of its completion of its HCA identification;\n49 C.F.R. § 192.933(b) (Item 3A) ─ Respondent’s alleged failure to evaluate and\ncharacterize anomalies within 180 days of discovery;\n49 C.F.R. § 192.937(b) (Item 4A) ─ Respondent’s alleged failure to include ILI\ntool run data in its periodic integrity evaluations for purposes of detecting and\nremediating corrosion;\n49 C.F.R. § 192.937(b) (Item 4B) ─ Respondent’s alleged failure to periodically\nintegrate assessment results with other data in determining its periodic\nreassessment intervals;\n49 C.F.R. § 192.937(a) (Item 4C) ─ Respondent’s alleged failure to establish an\nappropriate reassessment interval in light of the corrosion growth rates that\nexisted on its natural gas transmission line;\n49 C.F.R. § 192.945(a) (Item 5A) ─ Respondent’s alleged failure to track all\nthreat specific metrics as prescribed in the applicable industry standard; and\n49 C.F.R. §§ 192.911(l), 192.915(b) (Item 6A) ─ Respondent’s alleged failure to\ndefine or implement qualification requirements for personnel evaluating integrity\nassessment results.\n\n\n\n4\nRespondent presented information in its Response showing that it had taken certain actions to\naddress the cited items. Accordingly, having considered such information, I find, pursuant to 49\nC.F.R. § 190.205, that probable violations of 49 C.F.R. §§ 192.947(d), 192.905(a), 192.907(a),\n192.933(b), 192.937(a)-(b), 192.945(a), 192.911(l), and 192.915(b) (Notice Items 1A, 2A, 3A,\n4A, 4B, 4C, 5A and 6A ) have occurred and Respondent is hereby advised to correct such\nconditions. In the event that OPS finds a violation of these provisions in a subsequent inspection,\nRespondent may be subject to future enforcement action.\nThe terms and conditions of this Final Order are effective upon receipt of service.\n___________________________________ __________________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n520081001_nopv pco letter_01032008_text.pdf\n\ngq To rpwlhPt. l+~~~ ~\n-„ 1, . pc &py co\nt, i&crt o&itca\ng-. ~f @op;c.\nU. S Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n12300 W Dakota Ave, Suite 110\nLakewood, CO 80228\nNOTICE OF PROBABLE VIOLATION\nand\nPROPOSED COMPLIANCE ORDER\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nJanuary 3, 2008\nMs. Jennifer Sparacino\nSanta Clara City Manager\nSilicon Valley Power\n1500 Warburton Avenue\nSanta Clara, CA 95050\nCPF 5-2008-1001\nDear Ms. Sparacino:\nOn August 13 through August 16, 2007, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\ninspected your Integrity Management Program in Santa Clara, California.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n$192. 947 What records must an operator keep?\n$192. 947 (d) Documents to support any decision, analysis and process developed\nand used to implement and evaluate each element of the baseline assessment plan\nand integrity management program. Documents include those developed and used\nin support of any identification, calculation, amendment, modification, justification,\n\n\n\ndeviation and determination made, and any action taken to implement and evaluate\nany of the program elements;\n$192. 905 (a) General. To determine which segments of an operator's transmission\npipeline system are covered by this subpart, an operator must identify the high\nconsequence areas. An operator must use method (1) or (2) from the definition in g\n192. 903 to identify a high consequence area. An operator may apply one method to\nits entire pipeline system, or an operator may apply one method to individual\nportions of the pipeline system. An operator must describe in its integrity\nmanagement program which method it is applying to each portion of the operator's\npipeline system. The description must include the potential impact radius when\nutilized to establish a high consequence area. (See appendix E. I. for guidance on\nidentifying high consequence areas. )\n~ Item 1A: $192. 947(d) & $192. 905 (a)\nSihcon Valley Power (SVP) did not individually document the method used to\ndetermine each HCA. [A. Ol. b]\nEvidence: IMP Section 1. 4.\n2. $192. 907 What must an operator do to implement this subpart?\n$192. 907 (a) General. No later than December 17, 2004, an operator of a covered\npipeline segment must develop and follow a written integrity management program\nthat contains all the elements described in g 192. 911 and that addresses the risks on\neach covered transmission pipeline segment. The initial integrity management\nprogram must consist, at a minimum, of a framework that describes the process for\nimplementing each program element, how relevant decisions will be made and by\nwhom, a time line for completing the work to implement the program element, and\nhow information gained from experience will be continuously incorporated into the\nprogram. The framework will evolve into a more detailed and comprehensive\nprogram. An operator must make continual improvements to the program.\n~ Item 2A: $192. 907(a)\nSVP did not provide documentation that they completed identification of HCAs by\n12/17/2004. [A. o l. d]\nEvidence: 10/20/2004 Meeting Notes.\n3.\n$192. 933 What actions must be taken to address integrity issues?\n(a) General requirements. An operator must take prompt action to address all\nanomalous conditions the operator discovers through the integrity assessment. In\naddressing all conditions, an operator must evaluate all anomalous conditions and\n\n\n\nremediate those that could reduce a pipeline's integrity. An operator must be able\nto demonstrate that the remediation of the condition will ensure the condition is\nunlikely to pose a threat to the integrity of the pipeline until the next reassessment\nof the covered segment.\n(1) Temporary pressure reduction. If an operator is unable to respond within the\ntime limits for certain conditions specified in this section, the operator must\ntemporarily reduce the operating pressure of the pipeline or take other action that\nensures the safety of the covered segment. An operator must determine any\ntemporary reduction in operating pressure required by this sanction using\nASME/ANSI B31G (incorporated by reference, see g 192. 7) or AGA Pipeline\nResearch Committee Project PR-3-805 (\"RSTRENG, \" incorporated by reference,\nsee g 192. 7) or reduce the operating pressure to a level not exceeding 80 percent of\nthe level at the time the condition was discovered. (See appendix A to this part for\ninformation on availability of incorporation by reference information. ) An operator\nmust notify PHMSA in accordance with g 192. 949 if it cannot meet the schedule for\nevaluation and remediation required under paragraph (c) of this section and\ncannot provide safety through temporary reduction in operating pressure or other\naction. An operator must also notify a State pipeline safety authority when either a\ncovered segment is located in a State where PHMSA has an interstate agent\nagreement, or an intrastate covered segment is regulated by that State.\n(2) Long-term pressure reduction. When a pressure reduction exceeds 365 days, the\noperator must notify PHMSA under g 192. 949 and explain the reasons for the\nremediation delay. This notice must include a technical justification that the\ncontinued pressure reduction will not jeopardize the integrity of the pipeline. The\noperator also must notify a State pipeline safety authority when either a covered\nsegment is located in a State where PHMSA has an interstate agent agreement, or\nan intrastate covered segment is regulated by that State.\n(b) Discovery of condition. Discovery of a condition occurs when an operator has\nadequate information about a condition to determine that the condition presents a\npotential threat to the integrity of the pipeline. A condition that presents a potential\nthreat includes, but is not limited to, those conditions that require remediation or\nmonitoring listed under paragraphs (d)(1) through (d)(3) of this section. An\noperator must promptly, but no later than 180 days after conducting an integrity\nassessment, obtain sufficient information about a condition to make that\ndetermination, unless the operator demonstrates that the 180-day period is\nimpracticable.\n~ Item 3A: $192. 933(b)\nEvaluation and characterization of anomahes indicated by the 12-inch in-hne inspection\n(ILI) assessment was not completed within the 180 days allowed for discovery. [E. 4. b]\nEvidence: Magpie ILI Report for 12\" line.\n\n\n\n~ Item 3B: $192. 933(a)\nNo remediation was performed on the 36% indicated anomaly and none was scheduled\nbefore the next scheduled assessment in seven (7) years, although corrosion growth\nestimates indicate that a quicker response is needed [E. 4. c]\nEvidence: Magpie ILI report for the 12-inch line; 8/6/07 Remediation Schedule; 7/10/07\nRisk Rank and Schedule.\n$192. 937 What is a continual process of evaluation and assessment to maintain a\npipeline's integrity?\n(a) General. After completing the baseline integrity assessment of a covered\nsegment, an operator must continue to assess the line pipe of that segment at the\nintervals specified in g 192. 939 and periodically evaluate the integrity of each\ncovered pipeline segment as provided in paragraph (b) of this section. An operator\nmust reassess a covered segment on which a prior assessment is credited as a\nbaseline under g 192. 921(e) by no later than December 17, 2009. An operator must\nreassess a covered segment on which a baseline assessment is conducted during the\nbaseline period specified in g 192. 921(d) by no later than seven years after the\nbaseline assessment of that covered segment unless the evaluation under paragraph\n(b) of this section indicates earlier reassessment.\n(b) Evaluation. An operator must conduct a periodic evaluation as frequently as\nneeded to assure the integrity of each covered segment. The periodic evaluation\nmust be based on a data integration and risk assessment of the entire pipeline as\nspecified in g 192. 917. For plastic transmission pipelines, the periodic evaluation is\nbased on the threat analysis specified in g 192. 917(d) For all other transmission\npipelines, the evaluation must consider the past and present integrity assessment\nresults, data integration and risk assessment information (g 192. 917), and decisions\nabout remediation (g 192. 933) and additional preventive and mitigative actions (g\n192. 935). An operator must use the results from this evaluation to identify the\nthreats specific to each covered segment and the risk represented by these threats.\n~ Item 4A: $192. 937(b)\nSVP's periodic evaluation of integrity did not include integration of ILI results with\nother information to help determine the cause of corrosion found on the 12-inch and 6-\ninch lines and support decisions on remediation. [F. Ol. a]\nEvidence: IMP section 6. 3; Magpie ILI Reports; No evidence of data integration with\nILI results.\n~ Item 4B: $192. 937(b)\n\n\n\nSVP's periodic evaluations have not adequately integrated assessment results with other\ndata to estabhsh reassessment schedules. [F. O l. b]\nEvidence: IMP section 6. 3; Magpie ILI Reports; No evidence of data integration with\nILI results.\n~ Item 4C: $192. 937(a)\nA seven-year reassessment interval for the 6-inch and 12-inch lines is not technically\nsupported, given the rapid corrosion indicated in the ILI reports. [F. 04. e]\nEvidence: No basis provided for seven (7) year assessment interval, Risk Rank and\nSchedule.\n5. $192. 945 What methods must an operator use to measure program effectiveness?\n(a) General. An operator must include in its integrity management program\nmethods to measure, on a semi-annual basis, whether the program is effective in\nassessing and evaluating the integrity of each covered pipeline segment and in\nprotecting the high consequence areas. These measures must include the four\noverall performance measures specified in ASME/ANSI B31. 8S (incorporated by\nreference, see $192. 7), section 9. 4, and the specific measures for each identified\nthreat specified in ASME/ANSI B31. 8S, Appendix A. An operator must submit the\nfour overall performance measures, by electronic or other means, on a semi-annual\nfrequency to OPS in accordance with $192. 951. An operator must submit its first\nreport on overall performance measures by August 31, 2004. Thereafter, the\nperformance measures must be complete through June 30 and December 31 of each\nyear and must be submitted within 2 months after those dates.\n~ Item 5A: $192. 945(a)\nSVP did not track all threat specific metrics from Table 9 of ASME B31. 8S-2004.\n[I. ol. b]\nEvidence: Performance Measures Spreadsheet; IMP Element ¹9.\n6. $192. 911 What are the elements of an integrity management program?\nAn operator's initial integrity management program begins with a framework (see\ng 192. 907) and evolves into a more detailed and comprehensive integrity\nmanagement program, as information is gained and incorporated into the\nprogram. An operator must make continual improvements to its program. The\ninitial program framework and subsequent program must, at minimum, contain\nthe following elements. (When indicated, refer to ASME/ANSI B31. 8S (ibr, see g\n192. 7) for more detailed information on the listed element. )\n(a) An . . .\n\n\n\n(I) A quality assurance process as outlined in ASME/ANSI B31. 8S, section 12.\nASME B31. 8S-2001, section 12. 2 Quality Management Control.\n(b) Specifically, activities that should be included in the quality control program\nare as follows:\n(4) The people involved in the integrity management program shall be competent,\naware of the program and all of its activities and shall be properly trained to\nexecute the activities within the program. Documentation of such competence,\nawareness and qualification, and the processes for their achievement, shall be part\nof the quality control plan.\n$192. 915 (b) Persons who carry out assessments and evaluate assessment results.\nThe integrity management program must provide criteria for the qualification of\nany person—\n(1) Who conducts an integrity assessment allowed under this subpart; or\n(2) Who reviews and analyzes the results from an integrity assessment and\nevaluation; or\n(3) Who makes decisions on actions to be taken based on these assessments.\n~ Item 6A: $192. 911(l), ASME B31. 8S-2001, section 12. 2(b)(4), $192. 915 (b)\nSVP did not define nor implement qualification requirements for personnel evaluating\nintegrity assessment results. [L. 02. b]\nEvidence: IMP Element ¹12, Appendix ¹12A; IMP Team quahfications spreadsheet;\nQA Plan Roles and Responsibilities Summary.\nPro osed Com liance Order\nPursuant to 49 United States Code f 60118, the Pipeline and Hazardous Materials Safety\nAdministration proposes to issue a Compliance Order to Silicon Valley Power. Please refer to\nthe Proposed Compliance Order that is enclosed and made a part of this Notice.\nWarnin Items\nWith respect to item(s) 1A, 2A, 3A, 4A, 4B, 4C, 5A and 6A, we have reviewed the\ncircumstances and supporting documents involved in this case and have decided not to conduct\nadditional enforcement action or penalty assessment proceedings at this time. We advise you to\npromptly correct these items. Be advised that failure to do so may result in Sihcon Valley\nPower being subject to additional enforcement action.\n\n\n\nRes onse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators\nin Compliance 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 believe 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 quahfy 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 5-2008-1001 and for each document\nyou submit, please provide a copy in electronic format whenever possible.\nSin rely,\nChris oidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Gilliam (¹118623)\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Compliance Proceedings\n\n\n\nPROPOSED COMPLIANCE ORDER\nPursuant to 49 United States Code $ 60118, the Pipeline and Hazardous Materials Safety\nAdmmistration (PHMSA) proposes to issue to Silicon Valley Power a Compliance Order\nincorporating the following remedial requirements to ensure the compliance of Silicon Valley\nPower with the pipeline safety regulations:\nIn regard to Item Number 3B of the Notice pertaming to remediation of\nanomahes with accelerated corrosion growth rates that would require\nreassessment to be performed prior to the seven (7) year reassessment interval,\nSilicon Valley Power must reassess the six-inch (6\") high pressure dehvery\npipehne using ILI. Silicon Valley Power must calculate the corrosion growth\nrate for each anomaly found to exist on the pipeline with a depth greater than five\npercent (5%) through wall measurement or a length greater than one (1) inch in\nany direction.\nFurthermore, Silicon Valley Power must provide a report with the following:\na. Each anomaly and its disposition in regard to remediation or monitored status.\nb. Future assessment and monitoring plans for this pipehne after completing\nremediation of this current assessment.\nc. Detail description as to the cause and remediation of the accelerated corrosion\nmechanism(s).\nSihcon Valley Power must complete the work withm one (1) year of receipt of\nthe Final Order.\nSilicon Valley Power shall maintain documentation of the safety improvement\ncosts associated with fulfilling this Compliance Order and submit the total to\nChris Hoidal, Director, Western Region, Pipeline and Hazardous Materials\nSafety Administration. Costs shall be reported in two categories: 1) total cost\nassociated with preparation/revision of plans, procedures, studies and analyses,\nand 2) total cost associated with replacements, additions and other changes to\npipeline infrastructure.","truncated":false,"body_characters":25902}