{"operation":"document","citation":"CPF 520100005","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":"2010-02-12","effective_on":null,"summary":"CLOSED notice of probable violation citing 192.225, 192.245, 192.463(a), 192.491.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520100005.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520100005.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520100005","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520100005","body":"Notice of Probable Violation involving AMERIGAS EAGLE PROPANE LP. PHMSA's enforcement data identifies the cited regulations as 192.225,  192.245,  192.463(a),  192.491. The case was opened on 2010-02-12 and is reported as closed as of 2012-08-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520100005_closure letter_08022012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520100005/520100005_closure%20letter_08022012.pdf\n\n520100005_closure letter_08022012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520100005/520100005_closure%20letter_08022012_text.pdf\n\n520100005_FinalOrder_05252011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520100005/520100005_FinalOrder_05252011.pdf\n\n520100005_FinalOrder_05252011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520100005/520100005_FinalOrder_05252011_text.pdf\n\n520100005_NOPV PCO_02122010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520100005/520100005_NOPV%20PCO_02122010.pdf\n\n520100005_NOPV PCO_02122010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520100005/520100005_NOPV%20PCO_02122010_text.pdf\n\n520100005_operator response_03172011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520100005/520100005_operator%20response_03172011.pdf\n\n520100005_Re-issued NOPV PCO_01062011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520100005/520100005_Re-issued%20NOPV%20PCO_01062011.pdf\n\n520100005_Re-issued NOPV PCO_01062011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520100005/520100005_Re-issued%20NOPV%20PCO_01062011_text.pdf\n\n520100005_FinalOrder_05252011_text.pdf\n\nMAY 25 2011\nMr. Ron Templeman\nGeneral Manager\nAmerigas Eagle Propane, L.P.\n91-290 Hanua Street\nKapolei, HI 96707-1783\nRe: CPF No. 5-2010-0005\nDear Mr. Templeman:\nEnclosed please find the Final Order issued in the above-referenced case. It makes findings of\nviolation and specifies actions that need to be taken by Amerigas Eagle Propane, L.P., to comply\nwith the pipeline safety regulations. When the terms of the compliance order have been\ncompleted, as determined by the Director, Western Region, this enforcement action will be\nclosed. Service of the Final Order by certified mail is deemed effective upon the date of mailing,\nor as otherwise provided 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 [7005 1160 0001 0075 9336]\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)\nAmerigas Eagle Propane, L.P., ) CPF No. 5-2010-0005\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nOn December 8, 2008, 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 gas\ndistribution systems on several of the Hawaiian Islands, including 12 propane tank systems on\nthe island of Oahu.\nAs a result of the inspection, the Director, Western Region, OPS (Director), issued to\nRespondent, by letter dated February 12, 2010, 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 various violations of 49 C.F.R. Part 192 and proposed\nordering Respondent to take certain measures to correct the alleged violations. By letter dated\nJanuary 6, 2011, the Director reissued the Notice after learning that Amerigas had not received\nhis previous letter.1\nAmerigas responded to the Notice by letter dated March, 17, 2011 (Response). The company\nindicated it was “not contesting the Compliance Order,” provided information concerning the\ncorrective actions it had taken, and submitted copies of its revised procedures. Respondent did\nnot request a hearing and therefore has waived its right to one.\nFINDINGS OF VIOLATION\nThe Notice alleged that Respondent violated 49 C.F.R. Part 192, as follows:\n1 In the February 12, 2010 Notice, the Director alleged that Amerigas had failed to comply with the service line test\nrequirements in 49 C.F.R. § 192.511 in October 1984. The Director did not include that allegation of violation in\nthe January 6, 2011 Notice. See In the Matter of Alon USA, LP, C.P.F. 5-2004-5021, Decision on Petition for\nReconsideration (Oct. 22, 2009) (finding that PHMSA enforcement actions under 49 C.F.R. Part 190 are subject to a\n5-year statute of limitations).\n\n\n\n2\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.463(a), which states:\n§ 192.463 External corrosion control: Cathodic protection.\n(a) Each cathodic protection system required by this subpart must provide\na level of cathodic protection that complies with one or more of the applicable\ncriteria contained in appendix D of this part. If none of these criteria is\napplicable, the cathodic protection system must provide a level of cathodic\nprotection at least equal to that provided by compliance with one or more of\nthese criteria.\nThe Notice alleged that Amerigas violated 49 C.F.R. § 192.463(a) by failing to provide the level\nof cathodic protection required under the applicable criteria. Specifically, the Notice alleged that\nRespondent did not provide any cathodic protection for two segments of buried, 1-inch steel\npiping at the Ewa Complex and Maile Center. The Notice further alleged that the total length of\nthose unprotected segments was approximately 200 feet.\nAmerigas did not contest this allegation in its Response. Accordingly, after considering all of\nthe evidence, I find that Respondent violated 49 C.F.R. 192.463(a) by failing to provide the level\nof cathodic protection required under the applicable criteria.\nItem 2: The Notice alleged that Respondent violated 49 C.F.R. § 192.491, which states:\n§ 192.491 Corrosion control records.\n(a) Each operator shall maintain records or maps to show the location of\ncathodically protected piping, cathodic protection facilities, galvanic anodes,\nand neighboring structures bonded to the cathodic protection system. Records\nor maps showing a stated number of anodes, installed in a stated manner or\nspacing, need not show specific distances to each buried anode.\n(b) Each record or map required by paragraph (a) of this section must be\nretained for as long as the pipeline remains in service.\n(c) Each operator shall maintain a record of each test, survey, or inspection\nrequired by this subpart in sufficient detail to demonstrate the adequacy of\ncorrosion control measures or that a corrosive condition does not exist. These\nrecords must be retained for at least 5 years, except that records related to §§\n192.465 (a) and (e) and 192.475(b) must be retained for as long as the pipeline\nremains in service.\nThe Notice alleged that Amerigas violated 49 C.F.R. 192.491 by failing to maintain any\ncorrosion control records for a 250-foot, 3-inch line at the Westbridge Complex.\nRespondent did not contest this allegation in its Response. Accordingly, after considering all of\nthe evidence, I find that Amerigas violated 49 C.F.R. 192.491 by failing to maintain corrosion\ncontrol records for its pipeline system.\nItem 3: The Notice alleged that Respondent violated 49 C.F.R. § 192.225, which states:\n\n\n\n3\n§ 192.225 Welding procedures.\n(a) Welding must be performed by a qualified welder in accordance with\nwelding procedures qualified under section 5 of API 1104 (incorporated by\nreference, see § 192.7) or section IX of the ASME Boiler and Pressure Vessel\nCode “ Welding and Brazing Qualifications” (incorporated by reference, see\n§ 192.7) to produce welds meeting the requirements of this subpart. The\nquality of the test welds used to qualify welding procedures shall be\ndetermined by destructive testing in accordance with the applicable welding\nstandard(s).\n(b) Each welding procedure must be recorded in detail, including the\nresults of the qualifying tests. This record must be retained and followed\nwhenever the procedure is used.\nThe Notice alleged that Respondent violated 49 C.F.R. 192.225 by failing to have any welding\nprocedures for its steel pipelines.\nIn its Response, Amerigas did not contest the allegation but submitted a copy of section 5.5a of\nits Operations and Maintenance Manual, Welding of Steel in Pipelines.\nsection as being applicable to 10 different Code provisions. It consists of a two-paragraph\nwritten procedure but does not include detailed requirements for welder qualifications or re-\nqualifications, weld suitability or testing, or recordkeeping. Therefore, this procedure does not\nsatisfy the requirements of § 192.225.\n2 Amerigas identified that\nAccordingly, after considering all of the evidence, I find that Amerigas violated 49 C.F.R.\n§ 192.225 by failing to have each welding procedure recorded in detail for its steel pipelines.\nItem 4: The Notice alleged that Respondent violated 49 C.F.R. § 192.245, which states:\n§ 192.245 Repair or removal of defects.\n(a) Each weld that is unacceptable under §192.241(c) must be removed or\nrepaired. Except for welds on an offshore pipeline being installed from a\npipeline vessel, a weld must be removed if it has a crack that is more than 8\npercent of the weld length.\n(b) Each weld that is repaired must have the defect removed down to\nsound metal and the segment to be repaired must be preheated if conditions\nexist which would adversely affect the quality of the weld repair. After repair,\nthe segment of the weld that was repaired must be inspected to ensure its\nacceptability.\n(c) Repair of a crack, or of any defect in a previously repaired area\nmust be in accordance with written weld repair procedures that have been\nqualified under § 192.225. Repair procedures must provide that the\nminimum mechanical properties specified for the welding procedure used\nto make the original weld are met upon completion of the final weld\nrepair.\n2 The written procedures submitted by Amerigas with its Response bear an effective date of February 2, 2010; these\nprocedures replaced the previous version which had an effective date of November 1, 2008. Because the procedures\nwhich were submitted are inadequate for purposes of § 192.225, there is no need to decide the factual question of\nwhether such procedures were in effect at the time of the December 2008 OPS inspection.\n\n\n\n4\nThe Notice alleged that Respondent violated 49 C.F.R. 192.245 by failing to have any written\nprocedures for the repair or removal of weld defects.\nIn its Response, Amerigas did not contest the allegation but submitted a copy of section 5.5a of\nits Operations and Maintenance Manual, Welding of Steel in Pipelines. Amerigas identified that\nsection as being applicable to 10 different Code provisions. It consists of a two-paragraph\nwritten procedure, but does not include any detailed requirements for the repair or removal of\nweld defects.3\nAccordingly, after considering all of the evidence, I find that Amerigas violated 49 C.F.R.\n192.245 by failing to have adequate written procedures for the repair or removal of weld defects.\nThese findings of violation will be considered prior offenses in any subsequent enforcement\naction taken against Respondent.\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Items 1, 2, 3, and 4 in the Notice for\nviolations of 49 C.F.R. §§ 192.463(a), 192.491, 192.225, and 192.245, respectively. Under 49\nU.S.C. § 60118(a), each person who engages in the transportation of gas or who owns or\noperates a pipeline facility is required to comply with the applicable safety standards established\nunder chapter 601. The Director has indicated that Respondent has taken the following actions\nto address some of the cited violations:\nWith respect to the violation of 49 C.F.R. § 192.463(a) (Item 1), Amerigas is no\nlonger providing regulated gas propane service to the customers at Ewa Complex or\nMaile Center. Therefore, the cathodic protection requirements no longer apply to the\nburied, 1-inch steel piping at those locations.\nWith respect to the violation of 49 C.F.R. § 192.491 (Item 2), Amerigas has replaced\nthe 3-inch steel pipe at the Westbridge Complex with a 2-inch polyethylene pipe,\nwhich does not require cathodic protection or the maintenance of corrosion control\nrecords.\nAccordingly, I find that compliance has been achieved with respect to these violations.\nTherefore, the compliance terms proposed in the Notice for Items 1 and 2 are not included in this\nOrder.\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 § 192.225 (Item 3), Respondent must establish\nadequate written welding procedures for its steel pipelines.\n3 See 49 C.F.R. § 192.225 (b) (stating that “[e]ach welding procedure must be recorded in detail, including the\nresults of the qualifying tests,” and that “[t]his record must be retained and followed whenever the procedure is\nused.”).\n\n\n\n5\n2. With respect to the violation of § 192.245 (Item 4), Respondent must establish\nadequate written procedures for the repair or removal of weld defects.\n3. Within 90 days of receipt of this Final Order, Respondent must complete the\nactions specified in Items 1 and 2 above.\n4. It is requested that Respondent maintain documentation of the safety improvement\ncosts associated with fulfilling the terms of this Compliance Order and that the total\nbe submitted to Mr. Chris Hoidal, Director, Western Region, PHMSA. It is further\nrequested that those costs be reported in two categories: 1) total costs associated with\nthe preparation/revision of plans, procedures, studies, and analyses and 2) total costs\nassociated with replacements, additions, and other changes to pipeline infrastructure.\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.\nFailure to comply with this Order may result in administrative assessment of civil penalties not\nto exceed $100,000 for each violation for each day the violation continues or in referral to the\nAttorney General for appropriate relief in a district court of the United States.\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 petitions received no later than 20 days after receipt of service of this Final Order by\nthe Respondent, provided they contain a brief statement of the issue(s) and meet 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\n520100005_Re-issued NOPV PCO_01062011_text.pdf\n\nNOTICE OF PROBABLE VIOLATION\nand\nPROPOSED COMPLIANCE ORDER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 6, 2011\nMr. Ron Templeman\nGeneral Manager\nAmerigas Eagle Propane, L.P.\n91-290 Hanua Street\nKapolei, HI 96707-1783\nCPF 5-2010-0005\nDear Mr. Templeman:\nThis Notice of Probable Violation and Proposed Compliance Order was originally sent on\nFebruary 12, 2010, but we did not receive the certified mail return receipt. Subsequent contact\nwith Amerigas Eagle Propane, L.P. confirmed your company did not receive this Notice. As a\nresult, we are re-issuing this Notice.\nOn December 8, 2008, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\nAmerigas Eagle Propane, L.P. (Amerigas) facilities in Kapolei, Hawaii.\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\n\n\n1. § 192.463 External corrosion controls: Cathodic Protection.\na) Each cathodic protection system required by this subpart must provide a level\nof cathodic protection that complies with one or more of the applicable criteria\ncontained in Appendix D of this part. If none of these criteria is applicable, the\ncathodic protection system must provide a level of cathodic protection at least equal\nto that provided by compliance with one or more of these criteria.\nAmerigas is not providing any cathodic protection (CP) for the one-inch buried steel piping at\nthe Ewa Complex and Maile Center. The total length of inadequate protected piping for both\nlocations is approximately 200 feet. Amerigas must provide adequate cathodic protection for\nthe buried steel piping.\n2. §192.491 Corrosion control records.\n(a) Each operator shall maintain records or maps to show the location of\ncathodically protected piping, cathodic protection facilities, galvanic anodes, and\nneighboring structures bonded to the cathodic protection system. Records or maps\nshowing a stated number of anodes, installed in a stated manner or spacing, need\nnot show specific distances to each buried anode.\n(b) Each record or map required by paragraph (a) of this section must be retained\nfor as long as the pipeline remains in service.\n(c) Each operator shall maintain a record of each test, survey, or inspection\nrequired by this subpart in sufficient detail to demonstrate the adequacy of\ncorrosion control measures or that a corrosive condition does not exist. These\nrecords must be retained for at least 5 years, except that records related to\n§§192.465(a) and (e) and 192.475 (b) must be retained for as long as the pipeline\nremains in service.\nAmerigas did not maintain corrosion control records for the 250-foot long, 3-inch diameter line\nat the Westridge Complex. No pipe-to-soil readings or other cathodic protection records to\ndemonstrate adequate corrosion control for this line were available.\n3. §192.225 Welding procedures.\n(a) Welding must be performed by a qualified welder in accordance with welding\nprocedures qualified under section 5 of API 1104 (incorporated by reference, see\n§192.7) or section IX of the ASME Boiler and Pressure Vessel Code \" Welding and\nBrazing Qualifications\" (incorporated by reference, see §192.7) to produce welds\nmeeting the requirements of this subpart. The quality of the test welds used to\nqualify welding procedures shall be determined by destructive testing in\naccordance with the applicable welding standard(s).\n\n\n\n(b) Each welding procedure must be recorded in detail, including the results of the\nqualifying tests. This record must be retained and followed whenever the\nprocedure is used.\nAmerigas does not have any welding procedures for its steel pipelines. Amerigas must have\nqualified welding procedures for any repair work requiring welding.\n4. §192.245 Repair or removal of defects.\n(a) Each weld that is unacceptable under §192.241(c) must be removed or repaired.\nExcept for welds on an offshore pipeline being installed from a pipeline vessel, a\nweld must be removed if it has a crack that is more than 8 percent of the weld\nlength.\n(b) Each weld that is repaired must have the defect removed down to sound metal\nand the segment to be repaired must be preheated if conditions exist which would\nadversely affect the quality of the weld repair. After repair, the segment of the\nweld that was repaired must be inspected to ensure its acceptability.\n(c) Repair of a crack, or of any defect in a previously repaired area must be in\naccordance with written weld repair procedures that have been qualified under\n§192.225. Repair procedures must provide that the minimum mechanical\nproperties specified for the welding procedure used to make the original weld are\nmet upon completion of the final weld repair.\nAmerigas does not have any weld repair procedures for its steel pipelines. Amerigas must\nfollow welding procedures on any repairs requiring welding.\nProposed Compliance Order\nWith respect to items 1 to 5, pursuant to 49 United States Code § 60118, the Pipeline and\nHazardous Materials Safety Administration proposes to issue a Compliance Order to Amerigas.\nPlease refer to the Proposed Compliance Order, which is enclosed and made a part of this\nNotice.\nResponse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators\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 qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\n\n\n\nqualifies 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 5-2010-0005 and for each document\nyou submit, please provide a copy in electronic format whenever possible.\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Compliance Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 P. Nguyen (#122343)\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 Amerigas a Compliance Order incorporating the\nfollowing remedial requirements to ensure the compliance of Amerigas with the pipeline safety\nregulations:\n1. In regard to Item Number 1 of the Notice pertinent to the buried pipe at the Ewa\nComplex and Maile Center, Amerigas must provide adequate cathodic protection\nin accordance with § 192.463(a) External corrosion controls: Cathodic\nProtection.\n2. In regard to Item Number 2 of the Notice pertaining to the 3-inch diameter pipe\nat the Westridge Complex, Amerigas must maintain records of each corrosion\ncontrol test, survey and inspection in accordance with §192.491 (a), (b) and (c) -\nCorrosion control records.\n3. In regard to Item Number 4 of the Notice pertaining to welding procedures,\nAmerigas must establish written welding procedures for its steel pipelines in\naccordance with §192.225 (a) and (b) – Welding procedures.\n4. In regard to Item Number 5 of the Notice pertaining to weld repairs, Amerigas\nmust establish weld repair procedures for its steel pipelines §192.245 – Repair or\nremoval of defects.\n5. Within 90 days from the receipt of the Final Order, Amerigas must complete all\nitems contained in this proposed compliance order.\n6. Amerigas shall maintain documentation of the safety improvement costs\nassociated with fulfilling this Compliance Order and submit the total to Chris\nHoidal, Director, Western Region, Pipeline and Hazardous Materials Safety\nAdministration. Costs shall be reported in two categories: 1) total cost associated\nwith preparation/revision of plans, procedures, studies and analyses, and 2) total\ncost associated with replacements, additions and other changes to pipeline\ninfrastructure.\n\n520100005_closure letter_08022012_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 2, 2012\nMr. Ron Templeman\nGeneral Manager\nAmerigas Eagle Propane, L.P.\n91-290 Hanua Street\nKapolei, HI 96707-1783\nRE: CPF 5-2010-0005\nClosure Letter\nDear Mr. Templeman:\nOn May 25, 2011, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued\nto Amerigas Eagle Propane, L.P. a Final Order in the above-referenced case. This Order included\nrequirements to establish adequate procedures for welding, and the repair or removal of weld\ndefects. Based on our review of the documentation you provided on August 4, 2011, it has been\ndetermined that you have complied with the terms of this Order.\nAccordingly, this case is now closed and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 P. Nguyen (#122343)","truncated":false,"body_characters":25391}