{"operation":"document","citation":"CPF 520175011","title":"CALNEV PIPELINE CO — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-07-06","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.402(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520175011.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520175011.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520175011","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520175011","body":"Notice of Probable Violation involving CALNEV PIPELINE CO. PHMSA's enforcement data identifies the cited regulation as 195.402(a). The case was opened on 2017-07-06 and is reported as closed as of 2019-02-25. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520175011_Closure Letter_02252019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175011/520175011_Closure%20Letter_02252019.pdf\n\n520175011_Closure Letter_02252019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175011/520175011_Closure%20Letter_02252019_text.pdf\n\n520175011_Final Order_05012018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175011/520175011_Final%20Order_05012018.pdf\n\n520175011_Final Order_05012018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175011/520175011_Final%20Order_05012018_text.pdf\n\n520175011_NOPV PCO_07062017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175011/520175011_NOPV%20PCO_07062017.pdf\n\n520175011_NOPV PCO_07062017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175011/520175011_NOPV%20PCO_07062017_text.pdf\n\n520175011_Operator Response to Notice_08102017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175011/520175011_Operator%20Response%20to%20Notice_08102017.pdf\n\n520175011_Final Order_05012018_text.pdf\n\nMay 1, 2018\nMr. Steven J. Kean\nPresident and Chief Executive Officer\nKinder Morgan, Inc.\n1001 Louisiana Street, Suite 1000\nHouston, Texas 77002\nRe: CPF No. 5-2017-5011\nDear Mr. Kean:\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 Kinder Morgan’s subsidiary, CALNEV\nPipe Line, LLC, to comply with the pipeline safety regulations. When the terms of the\ncompliance order have been completed, as determined by the Director, Western Region, this\nenforcement action will be closed. Service of the Final Order is effective as provided under\n49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Director, Western Region, Office of Pipeline Safety, PHMSA\nMr. Wayne Simmons, Chief Operating Officer, Products Pipelines, Kinder Morgan\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nCALNEV Pipe Line, LLC, ) CPF No. 5-2017-5011\na subsidiary of Kinder Morgan, Inc., )\n)\n)\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nOn several occasions from September 7, 2016, through November 18, 2016, pursuant to\n49 U.S.C. § 60117, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety (OPS), conducted an on-site pipeline safety\ninspection of the facilities and records of CALNEV Pipe Line, LLC’s (CALNEV or Respondent)\nhazardous liquid pipeline running from Colton, California, to Las Vegas, Nevada. CALNEV, a\nsubsidiary of Kinder Morgan, Inc., (Kinder Morgan) operates this transmission pipeline, which is\napproximately 550 miles long and transports jet fuel and refined products through parallel 14-\ninch and 8-inch diameter pipelines that originate in Colton, California, and extend to terminals in\nBarstow, California, and Las Vegas, Nevada.1 The pipeline system also serves Nellis Air Force\nBase in Las Vegas, Nevada, McCarran International Airport in Las Vegas, Nevada, and Edwards\nAir Force Base in the Mojave Desert in southeastern California.2\nAs a result of the inspection, the Director, Western Region, OPS (Director), issued to\nRespondent, by letter dated July 6, 2017, a Notice of Probable Violation and Proposed\nCompliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed\nfinding that CALNEV had committed two violations of 49 C.F.R. Part 195 and ordering\nRespondent to take certain measures to correct the alleged violations.\nCALNEV responded to the Notice by letter dated August 10, 2017 (Response). The company\ncontested the allegations, offered additional information in response to the Notice, and provided\ninformation concerning the corrective actions it had taken. Respondent did not request a hearing\nand therefore has waived its right to one.\n1 Pipeline Safety Violation Report (Violation Report), (July 6, 2017) (on file with PHMSA), at 1; and Kinder\nMorgan website, available at https://www.kindermorgan.com/pages/business/products_pipelines/calnev.aspx (last\naccessed March 22, 2018).\n2 Kinder Morgan website, available at\nhttps://www.kindermorgan.com/pages/business/products_pipelines/calnev.aspx (last accessed March 22, 2018).\n\n\n\nCPF No. 5-2017-5011\nPage 2\nFINDINGS OF VIOLATION\nThe Notice alleged that Respondent violated 49 C.F.R. Part 195, as follows:\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a), which states:\n§ 195.402 Procedural manual for operations, maintenance, and\nemergencies.\n(a) General. Each operator shall prepare and follow for each pipeline\nsystem a manual of written procedures for conducting normal operations\nand maintenance activities and handling abnormal operations and\nemergencies. This manual shall be reviewed at intervals not exceeding 15\nmonths, but at least once each calendar year, and appropriate changes made\nas necessary to insure that the manual is effective. This manual shall be\nprepared before initial operations of a pipeline system commence, and\nappropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.402(a) by failing to follow for each\npipeline system a manual of written procedures for conducting normal operations and\nmaintenance activities and handling abnormal operations and emergencies. Specifically, the\nNotice alleged that CALNEV did not follow its written procedure, Atmospheric Breakout Tank\nInspections (L-O&M 2101) when it failed to adequately document the condition of three\nbreakout tanks (i.e., Tanks #120, #321, and #521) on monthly inspection reports. Kinder\nMorgan’s L-O&M 2101, Section 3.1.1, states, in relevant part:\nThis in-service inspection shall include a visual inspection of the tank’s\nexterior surfaces. Evidence of leaks; shell distortions; signs of settlement;\ncorrosion; and condition of the foundation, paint and coatings, insulation\nsystems, and appurtenances shall be documented on L-OM2100-02,\nMonthly Breakout Tank Inspection Report and reported to the local\nsupervisor. 3\nThe Notice alleged that CALNEV did not properly document the atmospheric corrosion\nconditions on the Monthly Breakout Tank Inspection reports for the following three tanks:\nTank #120\nThe Notice alleged that the annual inspections conducted by CALNEV’s contractor had\nindicated paint failures and rust observed on Tank #120’s roof, shell and appurtenances for the\n2015 and 2016 annual inspections. However, the 2015 and 2016 monthly inspections conducted\nby CALNEV employees did not record the same information and only indicated the roof, shell\nand its appurtenances were “Okay.” Additionally, the Notice alleged that during its own 2016\ninspection, PHMSA observed atmospheric corrosion and coating degradations on the shell and\nits appurtenances, which were not listed by CALNEV on its Monthly Breakout Tank Inspections\nReports.\n3 Violation Report, Exhibit H (emphasis in original).\n\n\n\nCPF No. 5-2017-5011\nPage 3\nIn its Response, CALNEV acknowledged the failure of its employees to properly document\nobservations about the paint condition on Tank #120.4 However, CALNEV argued that Tank\n#120 did not have atmospheric corrosion or coating degradations on the shell and its\nappurtenances, as alleged in the Notice.5 CALNEV pointed to PHMSA’s website, which defines\nthe term “corrosion” as the deterioration of metal, resulting from a reaction with its\nenvironment.6 CALNEV asserted that the PHMSA inspector only observed a “light, non-\ninjurious surface oxide involving no metal loss” because the atmospheric conditions in Colton,\nCalifornia, were not “conducive to creating a corrosive environment.”7\nHaving reviewed the record, I find that while CALNEV is correct that corrosion can be defined\nas “the deterioration of metal, resulting from a reaction with its environment,” it is important to\nnote that common rust is an example of metal corrosion. In fact, this is explained in the\ndefinition of corrosion that Respondent cited.8 The photographs taken during the PHMSA\ninspection clearly show rust on Tank #120, disproving Respondent’s claim that conditions are\nnot conducive to corrosion.9 Not only did the PHMSA inspector observe and photograph\ncorrosion on Tank #120, this condition was corroborated by the observations of the contractor\nduring the annual inspections, as noted in the annual inspection reports. This condition was not\nproperly documented in accordance with Kinder Morgan’s Atmospheric Breakout Tank\nInspections (L-O&M 2101) procedure and therefore, I find that CALNEV failed to follow its\nown written procedure.\nTank #321 and Tank #521\nThe Notice alleged that the 2015 and 2016 annual inspections by CALNEV’s contractor and\nmonthly inspections by CALNEV personnel indicated paint failures/discolorations on the shells\nand appurtenances of Tanks #321 and #521, but no atmospheric corrosion conditions. During its\nown 2016 inspection, PHMSA observed, in addition to the coating deterioration, atmospheric\ncorrosion on the shells and appurtenances, which was not listed on the monthly inspection\nreports.\nIn its Response, CALNEV asserted that its personnel followed L-O&M 2101 and properly\ndocumented their observations. CALNEV again asserted that the PHMSA inspector was\nmistaken and only observed a “light, non-injurious surface oxide involving no metal loss.”10\n4 Response, at 1.\n5 Id., at 1, 2.\n6 Id., at 2.\n7 Id.\n8 PHMSA Pipeline Glossary, available at https://primis.phmsa.dot.gov/comm/glossary/#Corrosion (last accessed\nFebruary 21, 2018).\n9 Violation Report, Exhibit K.\n10 Response at 1, 2.\n\n\n\nCPF No. 5-2017-5011\nPage 4\nAs discussed above, rust is an example of metal corrosion. During its 2016 inspection, PHMSA\nobserved and photographed rust on Tank #321.11 This condition was not properly documented\nby CALNEV in accordance with Kinder Morgan’s L-O&M 2101 and, therefore, I find that\nCALNEV failed to follow its own written procedure.\nIn summary, after considering all of the evidence, I find that Respondent violated 49 C.F.R.\n§ 195.402(a) by failing to follow for each pipeline system its own manual of written procedures\nfor conducting normal operations and maintenance activities and handling abnormal operations\nand emergencies (specifically, Kinder Morgan’s L-O&M 2101) when it did not properly\ndocument the corrosion conditions for Tank #120, Tank #321, and Tank #521.\nItem 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a), as quoted above,\nby failing to follow for each pipeline system a manual of written procedures for conducting\nnormal operations and maintenance activities and handling abnormal operations and\nemergencies. Specifically, the Notice alleged that CALNEV failed to follow its own written\nprocedure, Inspecting for Atmospheric Corrosion (L-O&M 918) ,when it did not adequately\ndocument atmospheric corrosion conditions at four locations. Kinder Morgan’s L-O&M 918,\nSection 3.4, states, in relevant part:\nVisually inspect all onshore, aboveground piping and structural components for\nevidence of atmospheric corrosion at least once every 3 calendar years, but with\nintervals not to exceed 39 months (L-O&M Procedure 1700, Inspection &\nMaintenance, L-I&M I-1141.00). . .\nDuring inspection, give particular attention to the following components:\na. Flange gaps and bolts\nb. Soil-to-Air Interface\nc. Splash zones\nd. Air/building interface\ne. Crevices\nf. Pipe supports and wear pads\ng. Pipe under insulation\nh. Spans/bridges\ni. Deck penetrations12\nThis procedure includes an attachment for evaluating and grading the conditions of above-\nground piping and associated structural components for signs of atmospheric corrosion. This\nattachment contains sample pictures of atmospheric conditions of above-ground pipe and\ninstructions on how to grade or evaluate the conditions as being “Good,” “Fair,” or “Poor.”13\n11 Violation Report, Exhibit N and Exhibit Q.\n12 Id., Exhibit R (emphasis in original).\n13 Id., Exhibit S.\n\n\n\nCPF No. 5-2017-5011\nPage 5\nThe Notice alleged that CALNEV’s 2014, 2015, and 2016 atmospheric-corrosion inspection\nrecords, as well as the 2014 and 2016 Bridge/Span inspection reports, indicated all the\natmospheric-corrosion conditions on the above-ground pipes were evaluated as “Good.” At the\ntime of the inspection, however, PHMSA observed and photographed several above-ground\npipes and components with atmospheric corrosion that should have been evaluated as “Fair” or\n“Poor,” according to L-O&M 918. The incorrect evaluations involved the following four\nlocations:\nColton North Terminal\nThe Notice alleged during its 2016 inspection, PHMSA observed signs of atmospheric corrosion\non the soil-to-air interface of the pipe at the Colton North Terminal, coating disbondment on the\npipe, corrosion and pitting on the pipe under the above-ground flange that had inadvertently been\nburied, an above-ground valve body that was also inadvertently buried, and signs of corrosion\npitting and coating deterioration on pump equipment.\nValley Wells Pump Station\nThe Notice alleged that during its 2016 inspection, PHMSA observed that pump equipment at\nthe Valley Wells Pump Station had been inadvertently buried and showed signs of atmospheric\ncorrosion.\nWith respect to these two locations, CALNEV agreed that there may have been “some coating\ndeterioration,” but disagreed with the allegations regarding atmospheric corrosion.14 In addition,\nCALNEV stated that its procedure L-O&M 918 applied to the inspection of above-ground\ncomponents for corrosion, not for inspecting coating. CALNEV further argued that components\nbelow ground were subject to a different Kinder Morgan inspection procedure (L-O&M 903).\nFinally, CALNEV argued there were no conditions at the above two locations involving metal\nloss on the components and no condition that could affect the safe operation of the components\nbefore the next inspection.15\nI am unpersuaded by CALNEV’s arguments. Having reviewed the record, I note, as mentioned\nabove, that Kinder Morgan’s procedure directs employees to an attachment - L-O&M 918\nAtmospheric Corrosion Inspection Guidelines - for guidelines on “grading coating condition.”\nThese guidelines specifically utilize levels of coating deterioration for grading atmospheric\ncorrosion. Additionally, while CALNEV asserted that observed conditions did not involve metal\nloss or any effect on safe operations, L-O&M 918 and the attachment do not instruct conditions\nto be graded as “Good” in the absence of metal loss or conditions affecting safe operations.\nRather the procedures require the evaluation and grading of levels of corrosion based on certain\ncriteria and illustrations related to the condition of the coating and topcoat, location of corrosion,\nand the presence of any pitting or scale.\n14 Response at 2.\n15 Id.\n\n\n\nCPF No. 5-2017-5011\nPage 6\nFurther, the photographs clearly show the coating was not “intact” or “limited to ‘chalking’” and\nthat the atmospheric corrosion was beyond mere “minor surface corrosion,” and, therefore,\nshould not have been graded “Good,” according to Kinder Morgan’s own Atmospheric\nCorrosion Inspection Guidelines.\n16 The photographs also show that the components were\ninstalled as above-ground components, but had become surrounded by mostly gravel. If the\ncomponents were meant to be buried, they would have had to meet different coating\nrequirements that would protect against external corrosion caused by the elements of the soil\nenvironment, whereas, in this case, after digging less than 1/2 inch of gravel to expose the\ncomponents, the riser pipe connected to the flange showed severe external corrosion and no\ncoating.\nTherefore, I find that CALNEV failed to follow its procedures when it did not properly grade\ncorrosion conditions at the above two locations.\nLas Vegas Terminal\nThe Notice alleged that during its 2016 inspection, PHMSA observed a metallic contact between\nan above-ground pipe and a metallic support. The inspector also observed that the surface area\nwithin the vicinity of the metallic contact showed galvanic corrosion activity. Because of this\nexisting condition, the Notice alleged, the PHMSA inspector was unable to conduct an accurate\natmospheric-corrosion inspection on the contact surface.\nIn its Response, CALNEV stated that it had submitted to PHMSA the two most recent Facility\nRisk Evaluations, which indicated “no substantial risk related to atmospheric corrosion.”\nCALNEV also stated it had provided wall-thickness evaluations for the pipe in question,\ndemonstrating “no wall loss.”17 CALNEV also noted that the pipe was resting on a 3/4-inch\npiece of hot roll steel that was “designed to wear due to pipe movement, and thus eliminate\ndegradation of the pipeline wall thickness.”18\nPHMSA has since reviewed the information provided by CALNEV following the 2016 PHMSA\ninspection, accepts this documentation, and therefore withdraws this alleged violation for Item 2.\nBaldy Mesa Aqueduct Pipe Span\nThe Notice alleged during its 2016 inspection, PHMSA observed signs of atmospheric corrosion\non a span of 14-inch pipe at the California Aqueduct overhead crossing near Baldy Mesa Road.\nIn its Response, CALNEV asserted that it had recently discovered, after reviewing additional\nrecords, that the PHMSA inspector was observing a casing and not a carrier pipe. At the time of\nthe inspection, a Kinder Morgan employee had incorrectly advised the PHMSA inspector that it\nwas a carrier pipe.\n16 Violation Report, Exhibits S, V and W.\n17 Response at 3.\n18 Id.\n\n\n\nCPF No. 5-2017-5011\nPage 7\nHaving reviewed the evidence in the record, I find that by failing to correctly identify the\ninspected component as a casing on its inspection forms, CALNEV did not accurately complete\nthe 2014-2016 Annual Bridge/Span Inspection Report form. Therefore, CALNEV failed to\nfollow its procedures when it did not properly document the inspection at the above location.\nIn summary, after considering all of the evidence, I find that Respondent violated 49 C.F.R.\n§ 195.402(a) by failing to follow for each pipeline system a manual of written procedures for\nconducting normal operations and maintenance activities and handling abnormal operations and\nemergencies (specifically, Kinder Morgan’s L-O&M 918) when it did not properly document\nconditions at three locations. The allegation related to the Las Vegas Terminal, however, is\nwithdrawn.\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 and 2 in the Notice for\nviolations of 49 C.F.R. § 195.402(a). Under 49 U.S.C. § 60118(a), each person who engages in\nthe transportation of hazardous liquids or who owns or operates a pipeline facility is required to\ncomply with the applicable safety standards established under chapter 601.\nWith regard to the violations of § 195.402(a) (Items 1 and 2), Respondent argued that the\ncompliance terms should be withdrawn. While CALNEV agreed that it had failed to follow a\nportion of its procedures in “one very narrow circumstance,” but that one instance had since been\ncorrected.19 CALNEV argued that the compliance terms were unnecessary,20 and that it had\nbeen fully compliant with the regulations and its procedures.21 Since I have already determined\nthat Respondent violated § 195.402(a) as discussed above, the proposed compliance order is not\nwithdrawn in its entirety, but only that portion pertaining to the Las Vegas Terminal. The\ncompliance order is also modified based on CALNEV’s response to the allegation relating to the\nBaldy Mesa Aqueduct Pipe Span for Item 2.\nAs for Item 1 and for all the facilities covered under Item 2 (except for the Las Vegas Terminal),\npursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is\nordered to take the following actions to ensure compliance with the pipeline safety regulations\napplicable to its operations:\n1. With respect to the violation of § 195.402(a) (Items 1 and 2), Respondent must\nrequalify all its personnel who conducted atmospheric corrosion inspections from\n2014 to 2016, and provide adequate training in evaluating atmospheric corrosion\nconditions of pipeline systems and in-service breakout tanks;\n19 Id., at 1.\n20 Id., at 4.\n21 Id., at 1 and 4.\n\n\n\nCPF No. 5-2017-5011\nPage 8\n2. With respect to the violation of § 195.402(a) (Item 2), Respondent must amend\nthe Bridge/Span Inspection Report Form to include an indication on the form that the\npipe spans inspected are pipe casing;\n3. With respect to the violation of § 195.402(a) (Item 2), Respondent must conduct a\nfull survey to locate all pipeline components that have been inadvertently buried and\nmitigate any issues found; and\n4. Submit to the Director, Western Region, OPS, within 180 days following receipt\nof this Final Order, written documentation of steps taken to satisfy Compliance Order\nItems 1 through 3 above.\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.\nIn addition, pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217,\nRespondent is requested (not mandated) to take the following action:\nCALNEV should maintain documentation of the safety improvement costs associated\nwith fulfilling this Compliance Order and submit the total to Director, Western\nRegion, Pipeline and Hazardous Materials Safety Administration. It is requested that\nthese costs 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.\nFailure to comply with this Order may result in the administrative assessment of civil penalties\nnot to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), for each violation for\neach day the violation continues or in referral to the Attorney General for appropriate relief in a\ndistrict court of the United States.\nUnder 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this Final\nOrder to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey\nAvenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of\nChief Counsel, PHMSA, at the same address, no later than 20 days after receipt of service of this\nFinal Order by Respondent. Any petition submitted must contain a statement of the issue(s) and\nmeet all other requirements of 49 C.F.R. § 190.243. The terms of the order, including corrective\naction, remain in effect unless the Associate Administrator, upon request, grants a stay. The\nterms and conditions of this Final Order are effective upon service in accordance with 49 C.F.R.\n§ 190.5.\nMay 1, 2018\n___________________________________ __________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n520175011_Closure Letter_02252019_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 25, 2019\nMr. Steven J. Kean\nPresident and Chief Executive Officer\nKinder Morgan, Inc.\n1001 Louisiana Street, Suite 1000\nHouston, Texas 77002\nCPF 5-2017-5011\nCase Closure\nDear Mr. Kean:\nOn May 1, 2018, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued to Kinder Morgan’s subsidiary, CALNEV Pipeline, LLC a Final Order in the above-\nreferenced case. This Order included a Compliance Order. Based on our review of the\ndocumentation you provided on January 31, 2019 in your office at Orange, California, it has\nbeen determined 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\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 M. Garcia","truncated":false,"body_characters":24651}