{"operation":"document","citation":"CPF 520105015W","title":"CENEX PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-04-30","effective_on":null,"summary":"CLOSED warning letter citing 195.401(b), 195.404(a), 195.410(a), 195.412(a), 195.420(a), 195.420(c), 195.428(a), 195.428(d), 195.432(b), 195.573(a)(2), 195.573(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520105015w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520105015w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520105015w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520105015W","body":"Warning Letter involving CENEX PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.401(b),  195.404(a),  195.410(a),  195.412(a),  195.420(a),  195.420(c),  195.428(a),  195.428(d),  195.432(b),  195.573(a)(2),  195.573(e). The case was opened on 2010-04-30 and is reported as closed as of 2010-04-30. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520105015W_warning letter_04302010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105015W/520105015W_warning%20letter_04302010_text.pdf\n\n520105015W_warning_letter_04302010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105015W/520105015W_warning_letter_04302010.pdf\n\n520105015W_warning letter_04302010_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 30, 2010\nMr. John Traeger\nManager of Pipelines and Terminals\nCHS, Inc.\n803 Highway 212 South\nLaurel, MT 59044\nCPF 5-2010-5015W\nDear Mr. Traeger:\nOn September 21-25, 2009, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\nCHS Products Pipeline from Laurel, Montana to the Montana/North Dakota Border.\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\nthe probable violations are:\n1. §195.412 Inspection of rights-of-way and crossings under navigable waters.\n(a) Each operator shall, at intervals not exceeding 3 weeks, but at least 26 times\neach calendar year, inspect the surface conditions on or adjacent to each pipeline\nright-of-way. Methods of inspection include walking, driving, flying or other\nappropriate mean of traversing the right-of-way.\n\n\n\nCHS did not ensure that the surface conditions on or adjacent to CHS’s Products Pipeline\nright-of-way are unobstructed and are readily accessible and visible. During the field\ninspection, it was noted that the right-of-way surface conditions of your CHS Products\nPipeline were obstructed as follows:\n• An equipment yard just east of the Yellowstone River near Sidney, Montana where\ntanks, equipment, and vehicles appear to be stored above the buried pipeline.\n• A shed just east of the Rosebud Station.\n• A mobile home just west of the Ponderosa School and just south of King Avenue\nEast in Billings.\n• A shed near King Avenue East and Washington Street in Billings.\n• A Montana Dakota Utilities (MDU) equipment yard just south of King Avenue\nEast in Billings where large amounts of plastic pipe and equipment are stored over\nthe buried pipeline.\n• A Bureau of Land Management equipment yard just south of King Avenue East in\nBillings where equipment is stored over the buried pipeline.\n2. §195.401 General Requirements.\n(b) Whenever an operator discovers any condition that could adversely affect the\nsafe operation of its pipeline system, it shall correct it within a reasonable time.\nHowever, if the condition is of such a nature that it presents an immediate hazard\nto persons or property, the operator may not operate the affected part of the\nsystem until it has corrected the unsafe condition.\nDuring the field inspection of the Glendive Pump Station, it appeared that the pressure gauge\ninstalled on the discharge of Pump Unit #2 was not working.\n3. §195.404 Maps and Records.\n(a) Each operator shall maintain current maps and records of its pipeline systems\nthat include at least the following information:\n(1) Location and identification of the following pipeline facilities:\n(i) Breakout Tanks\n(ii) Pump Stations\n(iii) Scraper and sphere facilities\n(iv) Pipeline valves\n(v) Facilities to which §195.402(c)(9) applies;\n(vi) Rights-of-way; and\n(vii) Safety devices to which §195.428 applies.\n(2) All crossings of public roads, railroads, rivers, buried utilities, and foreign\npipelines.\n(3) The maximum operating pressure of each pipeline.\n(4) The diameter, grade, type, and nominal wall thickness of all pipe.\n\n\n\nThe Glendive Pump Station drawings reviewed during the inspection did not accurately reflect\nthe current configuration of the pipeline. CHS did not ensure that the drawings (maps and\nrecords) accurately reflected the actual pipeline components. Inaccuracies noted include:\n• The rupture pin pressure indicated on the drawing did not match the rupture\npressure record of the actual pin installed at the station.\n• There is a note on the drawing that reads “Relief line to be installed in 2000” when\na relief line is currently installed.\n• PSV numbers on the drawing did not match the PSV numbers on the PSV\ninspection records.\nIn addition, among other various deficiencies during a review of several alignment sheets\nfound that many of the drawings did not reflect the actual pipeline installations, i.e. the\ndrawings did not show the locations where the pipeline has been repaired. Furthermore, it was\nindicated during the inspection that the drawings are in the process of being updated.\nHowever, it appears that CHS did not dedicate sufficient resources to update the drawings.\n4. §195.410 Line Markers.\n(a) Except as provided in paragraph (b) of this section, each operator shall place\nand maintain line markers over each buried pipeline in accordance with the\nfollowing:\n(1) Markers must be located at each public road crossing, at each railroad\ncrossing, and in sufficient number along the remainder of each buried line so that\nits location is accurately known.\n(2) The marker must state at least the following on a background of sharply\ncontrasting color:\n(i) The word “Warning,” “Caution,” or “Danger” followed by the words\n“Petroleum (or the name of the hazardous liquid transported) Pipeline”, or\n“Carbon Dioxide Pipeline,” all of which, except for markers in heavily developed\nurban areas, must be in letters at least 1 inch (25 millimeters) high with an\napproximate stroke of 1/4 inch (6.4 millimeters).\n(ii) The name of the operator and a telephone number (including area code) where\nthe operator can be reached at all times.\nCHS did not comply with Part 195.410 pertaining to the placement of pipeline markers, and\ninclusion of a current phone number. During the field inspection, it was noted that the pipeline\nmarker was not located where it crosses Jupiter Avenue in Glendive, MT. In addition, the\nmarker at the road crossing north of Jupiter Avenue did not include a current phone number\nwhere the operator can be reached at all times.\n\n\n\n5. §195.420 Valve Maintenance.\n(a) Each operator shall maintain each valve that is necessary for the safe\noperation of its pipeline systems in good working order at all times.\nDuring the field inspection, it was noted that the following valves showed evidence that they\nwere leaking minor amounts of product (fresh staining of the valve body):\n• Mainline valve (MP53) on the east side of the Yellowstone River near Sidney, MT.\n• Mainline valve near the Eagles RV Part (MP49).\n6. §195.420 Valve Maintenance.\n(c) Each operator shall provide protection for each valve from unauthorized\noperation and from vandalism.\nDuring the field inspection, it was noted that the following valves were not protected from\nunauthorized operation and from vandalism:\n• Mainline valve (MP53) on the east side of the Yellowstone River near Sidney,\nMontana.\n• Mainline valve near the Eagles RV Part (MP49).\n7. §195.428 Overpressure safety devices and overfill protection systems.\n(a) Except as provided in paragraph (b) of this section, each operator shall, at\nintervals not exceeding 15 months, but at least once each calendar year, or in the\ncase of pipelines used to carry highly volatile liquids, at intervals not to exceed 7\n1/2months, but at least twice each calendar year, inspect and test each pressure\nlimiting device, relief valve, pressure regulator, or other item of pressure control\nequipment to determine that it is functioning properly, is in good mechanical\ncondition, and is adequate from the standpoint of capacity and reliability of\noperation for the service in which it is used.\nDuring the field inspection, the actual rupture pressure of the rupture pin installed at the\nGlendive Station was not accurately identified to ensure adequate from the standpoint of\ncapacity and reliability of operation for the service in which it is used. There was no tag on the\ndevice that identified at what pressure it will break. Furthermore, CHS personnel at the\nGlendive Station were asked how it would be known whether or not the rupture pin was\ncorrectly installed and a definitive answer could not be provided. Meanwhile, a pressure record\nwas provided by CHS personnel for the installed rupture pin indicated a relief valve of 1321\npsig. The Glendive Station drawing however indicated that the rupture pressure of the pin is\n1440 psig.\n\n\n\n8. §195.428 Overpressure safety devices and overfill protection systems.\n(d) After October 2, 2000, the requirements of paragraphs (a) and (b) of this\nsection for inspection and testing of pressure control equipment apply to the\ninspection and testing of overfill protection systems.\nAt the time of inspection, records were not available for the inspections of any of the tank\noverfill protection systems associated with the CHS Products Pipeline breakout tanks.\n9. §195.432 Inspection of in-service breakout tanks.\n(b) Each operator shall inspect the physical integrity of in-service atmospheric\nand low-pressure steel aboveground breakout tanks according to section 4 of API\nStandard 653. However, if structural conditions prevent access to the tank\nbottom, the bottom integrity may be assessed according to a plan included in the\noperations and maintenance manual under §195.402(c)(3).\nCHS did not follow the requirement of Section 4 of API Standard 653 for your aboveground\nbreakout tanks. At the Billings Tank Farm, Tank 280 was seeping oil at several of the riveted\nconnections, seams and flanges. Meanwhile, the recent monthly tank inspection forms did not\nindicate which the tank seams/rivets/flanges were seeping oil. Based on field observations, it\nwas noted that the seepage had been occurring for quite awhile.\nFurthermore, the breakout tank inspection forms are not consistent between facilities and do\nnot always allow for a description of problems with the tank. Generally, the tank inspector can\nonly indicate if a particular item is G (good), F (Fair), or (P) poor but there is no\ndocumentation as to why a particular item is marked F or P. In addition, the forms do not\ninclude a line item to quantify the condition of the chime and a line item to check for\naccumulated material, paint chipping/disbonding, and corrosion on the chime.\n10. §195.573 What must I do to monitor external corrosion control?\n(a) Protected pipelines. You must do the following to determine whether cathodic\nprotection required by this subpart complies with §195.571:\n(2) Identify not more than 2 years after cathodic protection is installed, the\ncircumstances in which a close-interval survey or comparable technology is\npracticable and necessary to accomplish the objectives of paragraph 10.1.1.3 of\nNACE Standard RP 0169 (incorporated by reference, see §195.3).\nCHS neither conducted close intervals surveys on a periodic basis along the entire length of\nyour CHS Products Pipeline nor had a technical justification as to why close interval surveys\n(CIS) are not necessary. A close interval survey was performed in 2006 on a portion of the\npipeline between Laurel and Billings, but the need for CIS surveys in other areas or\nsubsequent surveys was not determined.\n\n\n\n11. §195.573 What must I do to monitor external corrosion control?\n(e) Corrective action. You must correct any identified deficiency in corrosion\ncontrol as required by Sec. 195.401(b). However, if the deficiency involves a\npipeline in an integrity management program under Sec. 195.452, you must\ncorrect the deficiency as required by Sec. 195.452(h).\nCHS did not correct all the deficiencies in corrosion control from your close interval survey\nthat was performed in 2006 on a portion of the pipeline between Laurel and Billings. Several\npotential anomalies (areas of inadequate cathodic protection) were identified in that survey.\nCHS followed up on some of the potential anomalies but CHS did not follow up on others. It\nappears that the potential anomalies are located in HCAs. Meanwhile, CHS personnel could\nnot provide a definitive plan defining when the potential anomalies will be investigated.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of $1,000,000\nfor any related series of violation. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement\naction or penalty assessment proceedings at this time. We advise you to correct the item\nidentified in this letter. Failure to do so will result in CHS, Inc. being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2010-5015W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any portion\nof your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along\nwith the complete original document you must provide a second copy of the document with\nthe portions you believe qualify for confidential treatment redacted and an explanation of why\nyou believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 M. Petronis (#123854)\n\n520105015W_warning_letter_04302010.pdf\n\nSENT TO COMPLIANCE REGISTRY\nHardcopy_ Electronically\n# of Copies L/Date- 30-10\nU.S. Department\nof Transportation\n12300 W. Dakota Ave.., Suite 110\nLakewood, CO 80228\nSafety Administration\nPipeline and Hazardous Materials\nWARNING LETTER\n--\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 30, 2010\nMr. John Traeger\n:\nManager of Pipelines and Terminals\nCHS, Inc.\n803 Highway 212 South\nLaurel, MT 59044\nCPF 5-2010-5015W\nDear Mr. Traeger:\nOn September 21-25, 2009, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\nCHS Products Pipeline from Laurel, Montana to the Montana/North Dakota Border.\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\nthe probable violations are:\n§195.412 Inspection of rights-of-way and crossings under navigable waters.\nappropriate mean of traversing the right-of-way.\n:\n\n\n\nCHS did not ensure that the surface conditions on or adjacent to CHS's Products Pipeline\nright-of-way are unobstructed and are readily accessible and visible. During the field\ninspection, it was noted that the right-of-way surface conditions of your CHS Products\nPipeline were obstructed as follows:\n• An equipment yard just east of the Yellowstone River near Sidney, Montana where\ntanks, equipment, and vehicles appear to be stored above the buried pipeline.\n• A shed just east of the Rosebud Station.\n• A mobile home just west of the Ponderosa School and just south of King Avenue\nEast in Billings.\n• A shed near King Avenue East and Washington Street in Billings.\n• A Montana Dakota Utilities (MDU) equipment yard just south of King Avenue\nEast in Billings where large amounts of plastic pipe and equipment are stored over\nthe buried pipeline.\n• A Bureau of Land Management equipment yard just south of King Avenue East in\nBillings where equipment is stored over the buried pipeline.\n§195.401 General Requirements.\n(b) Whenever an operator discovers any condition that could adversely affect the\nsafe operation of its pipeline system, it shall correct it within a reasonable time.\nHowever, if the condition is of such a nature that it presents an immediate hazard\nto persons or property, the operator may not operate the affected part of the\nsystem until it has corrected the unsafe condition.\nDuring the field inspection of the Glendive Pump Station, it appeared that the pressure gauge\ninstalled on the discharge of Pump Unit #2 was not working.\n3.\n§195.404 Maps and Records.\n(a) Each operator shall maintain current maps and records of its pipeline systems\nthat include at least the following information:\n(1) Location and identification of the following pipeline facilities:\n(i) Breakout Tanks\n(ii) Pump Stations\n(iii) Scraper and sphere facilities\n(iv) Pipeline valves\n(v) Facilities to which §195.402(c)(9) applies;\n(vi) Rights-of-way; and\n(vii) Safety devices to which $195.428 applies.\n(2) All crossings of public roads, railroads, rivers, buried utilities, and foreign\npipelines.\n(3) The maximum operating pressure of each pipeline.\n(4) The diameter, grade, type, and nominal wall thickness of all pipe.\n2\n\n\n\nThe Glendive Pump Station drawings reviewed during the inspection did not accurately reflect\nthe current configuration of the pipeline. CHS did not ensure that the drawings (maps and\nrecords) accurately reflected the actual pipeline components. Inaccuracies noted include:\n• The rupture pin pressure indicated on the drawing did not match the rupture\npressure record of the actual pin installed at the station.\n• There is a note on the drawing that reads \"Relief line to be installed in 2000\" when\na relief line is currently installed.\n• PSV numbers on the drawing did not match the PSV numbers on the PSV\ninspection records.\nIn addition, among other various deficiencies during a review of several alignment sheets\nfound that many of the drawings did not reflect the actual pipeline installations, i.e. the\ndrawings did not show the locations where the pipeline has been repaired. Furthermore, it was\nindicated during the inspection that the drawings are in the process of being updated.\nHowever, it appears that CHS did not dedicate sufficient resources to update the drawings.\n4.\n§195.410 Line Markers.\n(a) Except as provided in paragraph (b) of this section, each operator shall place\nand maintain line markers over each buried pipeline in accordance with the\nfollowing:\n(1) Markers must be located at each public road crossing, at each railroad\ncrossing, and in sufficient number along the remainder of each buried line so that\nits location is accurately known.\n(2) The marker must state at least the following on a background of sharply\ncontrasting color:\n\"Petroleum (or the name of the hazardous liquid transported) Pipeline\", or\n(i) The word \"Warning,\" \"Caution,\" or \"Danger\" followed by the words\n\"Carbon Dioxide Pipeline,\" all of which, except for markers in heavily developed\nurban areas, must be in letters at least 1 inch (25 millimeters) high with an\napproximate stroke of 1/4 inch (6.4 millimeters).\n(i) The name of the operator and a telephone number (including area code) where\nthe operator can be reached at all times.\nCHS did not comply with Part 195.410 pertaining to the placement of pipeline markers, and\nmarker was not located where it crosses Jupiter Avenue in Glendive, MT. In addition. the\ninclusion of a current phone number. During the field inspection, it was noted that the pipeline\nmarker at the road crossing north of Jupiter Avenue did not include a current phone number\nwhere the operator can be reached at all times.\n3\n\n\n\n$195.420 Valve Maintenance.\n(a) Each operator shall maintain each valve that is necessary for the safe\noperation of its pipeline systems in good working order at all times.\nDuring the field inspection, it was noted that the following valves showed evidence that they\nwere leaking minor amounts of product (fresh staining of the valve body):\nMainline valve (MP53) on the east side of the Yellowstone River near Sidney, MT.\nMainline valve near the Eagles RV Part (MP49).\n§195.420 Valve Maintenance.\n(c) Each operator shall provide protection for each valve from unauthorized\noperation and from vandalism.\nDuring the field inspection, it was noted that the following valves were not protected from\nunauthorized operation and from vandalism:\nMontana.\nMainline valve (MP53) on the east side of the Yellowstone River near Sidney,\nMainline valve near the Eagles RV Part (MP49).\n§195.428 Overpressure safety devices and overfill protection systems.\n(a) Except as provided in paragraph (b) of this section, each operator shall, at\nintervals not exceeding 15 months, but at least once each calendar year, or in the\ncase of pipelines used to carry highly volatile liquids, at intervals not to exceed 7\n1/2months, but at least twice each calendar year, inspect and test each pressure\nlimiting device, relief valve, pressure regulator, or other item of pressure control\nequipment to determine that it is functioning properly, is in good mechanical\ncondition, and is adequate from the standpoint of capacity and reliability of\noperation for the service in which it is used.\nDuring the field inspection, the actual rupture pressure of the rupture pin installed at the\nGlendive Station was not accurately identified to ensure adequate from the standpoint of\ncapacity and reliability of operation for the service in which it is used. There was no tag on the\ndevice that identified at what pressure it will break. Furthermore, CHS personnel at the\nGlendive Station were asked how it would be known whether or not the rupture pin was\ncorrectly installed and a definitive answer could not be provided. Meanwhile, a pressure record\nwas provided by CHS personnel for the installed rupture pin indicated a relief valve of 1321\npsig. The Glendive Station drawing however indicated that the rupture pressure of the pin is\n1440 psig.\n4\n\n\n\n§195.428 Overpressure safety devices and overfill protection systems.\n(d) After October 2, 2000, the requirements of paragraphs (a) and (b) of this\nsection for inspection and testing of pressure control equipment apply to the\ninspection and testing of overfill protection systems.\nAt the time of inspection, records were not available for the inspections of any of the tank\noverfill protection systems associated with the CHS Products Pipeline breakout tanks.\n§195.432 Inspection of in-service breakout tanks.\n(b) Each operator shall inspect the physical integrity of in-service atmospheric\nand low-pressure steel aboveground breakout tanks according to section 4 of API\nStandard 653. However, if structural conditions prevent access to the tank\nbottom, the bottom integrity may be assessed according to a plan included in the .-.\noperations and maintenance manual under §195.402(c)(3).\nCHS did not follow the requirement of Section 4 of API Standard 653 for your aboveground\nbreakout tanks. At the Billings Tank Farm, Tank 280 was seeping oil at several of the riveted\nconnections, seams and flanges. Meanwhile, the recent monthly tank inspection forms did not\nindicate which the tank seams/rivets/flanges were seeping oil. Based on field observations, it\n• was noted that the seepage had been occurring for quite awhile.\nFurthermore, the breakout tank inspection forms are not consistent between facilities and do\nnot always allow for a description of problems with the tank. Generally, the tank inspector can\nonly indicate if a particular item is G (good), F (Fair), or (P) poor but there is no\ndocumentation as to why a particular item is marked F or P. In addition, the forms do not\ninclude a line item to quantify the condition of the chime and a line item to check for\naccumulated material, paint chipping/disbonding, and corrosion on the chime.\n10.\n§195.573 What must I do to monitor external corrosion control?\n(a) Protected pipelines. You must do the following to determine whether cathodic\nprotection required by this subpart complies with §195.571:\n(2) Identify not more than 2 years after cathodic protection is installed, the\ncircumstances in which a close-interval survey or comparable technology is\npracticable and necessary to accomplish the objectives of paragraph 10.1.1.3 of\nNACE Standard RP 0169 (incorporated by reference, see §195.3).\nCHS neither conducted close intervals surveys on a periodic basis along the entire length of\nyour CHS Products Pipeline nor had a technical justification as to why close interval surveys\n(CIS) are not necessary. A close interval survey was performed in 2006 on a portion of the\npipeline between Laurel and Billings, but the need for CIS surveys in other areas or\nsubsequent surveys was not determined.\n5\n\n\n\n1l.\n§195.573 What must I do to monitor external corrosion control?\n(e) Corrective action. You must correct any identified deficiency in corrosion\nontrol as required by Sec. 195.401(b). However, if the deficiency involves\nipeline in an integrity management program under Sec. 195.452, vou mus\ncorrect the deficiency as required by Sec. 195.452(h).\nCHS did not correct all the deficiencies in corrosion control from your close interval survey\nthat was performed in 2006 on a portion of the pipeline between Laurel and Billings. Several\npotential anomalies (areas of inadequate cathodic protection) were identified in that survey.\nCHS followed up on some of the potential anomalies but CHS did not follow up on others. It\nappears that the potential anomalles are located in HCAs. Meanwhile, CHS personnel could\nnot provide a definitive plan defining when the potential anomalies will be investigated.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of $1,000,000\nfor any related series of violation. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement\naction or penalty assessment proceedings at this time. We advise you to correct the item\nidentified in this letter. Failure to do so will result in CHS, Inc. being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2010-5015W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any portion\nof your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along\nwith the complete original document you must provide a second copy of the document with\nthe portions you believe qualify for confidential treatment redacted and an explanation of why\nyou believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nA Face\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 M. Petronis (#123854)\n6","truncated":false,"body_characters":26995}