400 Seventh Street, S.W. 
U.S. 
Department Washington, D.C. 20590 
of Transportation 
Pipeline and Hazardous 
Materials Safety Administration DEC 1 1 >I:.'. 
Mr. Jesse G. Metcalf 
Vice President, Operations and Technical Services 
Rocky Mountain Pipeline System LLC 
555 Street 
Suite 33 10 
Denver, CO 80202 
Re: CPF No. 5-2004-5001 
Dear Mr. Metcalf: 
Enclosed is the Final Order issued by the Acting Associate Administrator for Pipeline Safety 
in the above-referenced case. The Final Order withdraws several of the allegations of violation 
listed in the Notice of Probable Violation dated Feb. 18, 2004, makes findings of violation with 
respect to some of the other allegations, specifies actions to be taken to comply with the pipeline 
safety regulations, requires amendment of certain integrity management program procedures and 
assesses a civil penalty of $7,000. The penalty payment terms are set forth in the Final Order. 
When the civil penalty is paid and the terms of the compliance order and amendment of 
procedures are completed, as determined by the Director, Western Region, OPS, this 
enforcement action will be closed. Your receipt of the Final Order constitutes service of that 
document under 49 C.F.R. 5 190.5. 
Sincerely, 
q a m e s Reynolds 
Pipeline Compliance Registry 
Office of Pipeline Safety 
Enclosure 
cc: 
Robert Mindess 
Senior Counsel 
Pacific Energy GP, Inc. 
5900 Cherry Avenue 
Long Beach, CA 90805-4408 
CERTIFIED MAIL - RETURN RECEIPT REOUESTED 

DEPARTMENT OF TRANSPORTATION 
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION' 
WASHINGTON, DC 
1 
In the Matter of 1 
) 
Rocky Mountain Pipeline System, ) CPF NO. 5-2004-5001 
) 
Respondent. ) 
FINAL ORDER 
From February 24-27,2003, representatives of the Office of Pipeline Safety (OPS), pursuant to 
49 U.S.C. $60 1 17, conducted an inspection of Rocky Mountain Pipeline System's (Respondent) 
integrity management program at Respondent's offices in Denver, Colorado. 
As a result of the inspection, the Director, Western Region, OPS, issued to Respondent, by letter 
dated February 18,2004, a Notice of Probable Violation, Proposed Civil Penalty, Proposed 
Compliance Order and Notice of Amendment (Notice). In accordance with 49 C.F.R. $ 190.207, 
the Notice proposed finding Respondent had violated various regulatory provisions of 49 C.F.R. 
$195.452, proposed assessing a civil penalty of $34,000 for the alleged violations, and proposed 
that Respondent take certain measures to correct the alleged violations. The Notice also 
proposed, in accordance with 49 C.F.R. $ 190.237, that Respondent amend its integrity 
management program procedures. 
On March 9,2004, Respondent requested a 60-day extension to respond to the Notice, which the 
Regional Director granted on March 15,2004. Respondent submitted its response to the Notice 
on May 20,2004 (Response). Respondent contested the allegations, submitted information to 
explain the allegations and requested a hearing. A hearing was held in the Western Region, 
' This case is no longer before the Research and Special Programs Administration, the agency 
that initiated the case. Effective February 20,2005, the Pipeline and Hazardous Materials Safety 
Administration (PHMSA) was created to further the highest degree of safety in pipeline 
transportation and hazardous materials transportation. See, section 108 of the Norman Y. Mineta 
Research and Special Programs Improvement Act (Public Law 108-426, 1 18 Stat. 2423-2429 
(November 30,2004)). See also, 70 Fed. Reg. 8299 (February 18,2005) redelegating the 
pipeline safety functions to the Administrator, PHMSA. 

OPS, on December 14,2004. After the hearing, Respondent submitted a Closing Statement 
dated March 16,2005. 
FINDINGS OF VIOLATION 
As discussed below, the Notice alleged violations of the integrity management program (IMP) 
requirements in 49 C.F.R. 5 195.452. In general, Respondent questioned whether the allegations 
had any basis in law, since many related to the level of detail in the IMP processes. Respondent 
argued its IMP provided what the regulations literally require but that the procedures may lack 
the detail necessary to satisfy some OPS inspectors. Respondent maintained OPS published a 
protocol after the inspection that provided more guidance to operators on the level of detail 
necessary in IMP procedures. The protocols Respondent refers to were first discussed at a public 
workshop on July 23-24,2002. The initial version of the protocols was posted on OPS's integrity 
management website in conjunction with this workshop. A revised version was posted in January 
2003, The inspection of Respondent's facilities took place in February 2003. Additionally, 
beginning in October 2001, OPS posted answers to FAQs to give hazardous liquid operators 
informal advice about how to carry out the IMP requirements. Thus, guidance was available to 
Respondent before the OPS inspection. 
1tem21 alleged three violations of 5 195.452(f)(l), which requires an operator's integrity 
management program (IMP) to have a process for identifying those pipeline segments in its 
system that could affect a high consequence area. The Notice alleged - 
Respondent could not assure all of its pipelines were accurately reflected in the National 
Pipeline Mapping System (NPMS) (1a); 
Respondent had not identified pipeline facilities, such as breakout tanks and pump 
stations, that could affect high consequence areas, as required by 5 195.452(0(3) (1b); and 
Respondent's process for identifying pipeline segments could not ensure all segments 
that could affect a high consequence area were identified (lc). 
With respect to 1a, Respondent maintained it had submitted its pipeline information to the 
NPMS on June 9,2003. The due date was June 17,2003. Respondent has demonstrated it 
provided the requisite information before the due date; therefore, I am withdrawing the allegation 
of violation. 
In its initial response to 1b, Respondent said it interpreted 195.452(0(3) to apply to pipeline 
assets only. At the hearing, Respondent confirmed its IMP program at the time of the inspection 
did not include non linear facilities, such as pump stations and breakout tanks. At the hearing 
and in its post-hearing response, Respondent said it is surveying the locations and creating a 
facility specific plan and methodology. Respondent said its next revision will include these 
facilities and an expanded description of the methodology. 
Item Numbers refer to the items listed in the Notice dated Feb. 18, 2004. 

Section 195.452 (f)(l) requires an identificationof all pipeline segments that could affect a high 
consequence area. Section 195.452(0(3) requires an operator to integrate all available 
information concerning the entire pipeline. A pipeline is defined in 5195.2 to mean all parts of a 
pipeline facility through which a hazardous liquid moves in transportation. Thus, I find 
Respondent violated $8195.452(f)(l) and 195.452(f)(3) because its IMP failed to identify and 
address all of its pipeline facilities. 
In addressing 1c, Respondent maintained the allegations were unclear. Respondent believed all 
of its segments are readily identifiable and segmentsthat could affect high consequence areas are 
identified on its maps. At the hearing, OPS explained Respondent's IMP did not have a process 
for performing pipeline segment identificationto ensure all segments that could affect high 
consequence areas are included. Respondent maintained its maps provide adequate detail to 
identify all of the pipeline segments that could affect high consequence areas. Respondent also 
included a description of the methodology used to identifj the segments. 
Section 195.453(f)(1) requires an operator to have a process for identifying which of the pipeline 
segments in its system could affect a high consequence area. Sections 1.3 -1.3.6 of Respondent's 
IMP describe the Bass-Trigon RiskCat tool and the Integrity Assessment Program (IAP) risk 
assessment model used in the identificationprocess, factors used to identify segments, future 
identification,data updates and incomplete data. Accordingly, I find Respondent did not violate 
5195.452(f)(l),because its IMP has a process for identifying those segments in its system that 
could affect high consequence area. But this process is deficient and needs to be amended to 
ensure safe operation of the pipeline system. Respondent's process needs to ensure the process 
the consultant used applies to Respondent's system. The approach needs to be better described 
and documented and include a method for reviewing the results provided by the consultant. 
Thus, this item will be included in the Amendment section of this document. 
Item 2 alleged three violations of 49 C.F.R. Ħħ195.452(b)(3). The regulation requires a pipeline 
operator to have in its integrity management program a plan to carry out the baseline assessment 
of line pipe according to the baseline assessmentplan requirements in 8 195.452(c). The Notice 
alleged -
Respondent's baseline assessment plan did not specify or technicallyjustify the choice of 
assessment methods (2a); 
Documentation stated Respondent did not have pre- 1970 electric resistance welded 
(ERW) or lap welded pipe in its system, contrary to information presented to OPS 
inspectors that this type of pipe was in the system. Respondent's assessment tools had 
not considered the seam failure susceptibilityof these types of pipe (2c); and 
Respondent did not have a process for revising the baseline assessment plan (2d). 
For 2a, Respondent initially responded that section 4.10 of its IMP discussed available and 
allowable methods of assessments. Respondent maintained it did not interpret the rule to require 
an operator to specify or technicallyjustify its choice of assessment methods. 

At the hearing, OPS maintained Respondent's IMP did not show its decision making process on 
determining assessment methods. In its closing statement, Respondent said it addressed OPS's 
concerns by explaining sections 4.10 and 4.1 1 address the different assessment methods and 
what conditions must exist to choose a method. 
Respondent's IMP (section 4.10) has procedures discussing assessment methods for the baseline 
assessment. Thus, I do not find a violation of 9 195.452(b)(3). Although Respondent has 
procedures, the procedures are very general statements about types of assessment methods. 
Thus, this item will be included in the Amendment section of this Order because the procedures 
are not adequate to ensure safe operation of Respondent's system. Respondent will be required 
to further amend its procedures to provide more detailed information about how personnel are to 
choose an integrity assessment method if certain conditions exist on a segment of line pipe. 
With respect to 2c, Respondent acknowledged its IMP incorrectly indicated the system had no 
pre-1970 ERW or lap welded pipe. Respondent maintained it has since corrected the statement 
in its IMP (section 4.10) and has implemented procedures for assessing and repairing this pipe. 
At the hearing OPS and Respondent discussed whether Respondent had analyzed the risk 
associated with this type of pipe. Respondent explained the database that performs its risk 
analysis did consider the pipe and the risk algorithm shows the program used this information. 
Section 195.452(b)(3) requires an operator to have a baseline assessment plan that complies with 
the baseline plan requirements in 5 195.452(c). Section 195.452(c)(l)(i) requires an operator to 
use assessment methods capable of assessing seam integrity and of detecting corrosion and 
deformation anomalies if the system has low frequency electric resistance welded (ERW) pipe or 
lap welded pipe and the pipe is susceptible to longitudinal seam failure. Under 9 195.303(d) all 
pre-1970 ERW pipe and lap welded pipe is considered susceptible to longitudinal weld failure 
unless an engineering analysis shows otherwise. 
Respondent has demonstrated the statement in its IMP at the time of the inspection was an error 
that has since been removed. Respondent's risk algorithm also includes an input field for pipe 
seam design. But, according to Respondent's March 2005 closing statement, there were 35 miles 
of lap welded pipe and 2.25 miles of low frequency ERW pipe in its system. Yet, the modified 
procedure Respondent submitted (Section 4.10) only discusses what might happen if pipelines 
acquired in the future contain low frequency ERW pipe. The procedure does not discuss how the 
current pipe in the system wit1 be addressed or how a newly acquired pipe with lap welded pipe 
will be addressed. 
Further, section 4.10 only states appropriate assessment techniques will be evaluated for 
effectiveness in managing the potential threat (i.e., susceptibility to longitudinal seam failure). 
Respondent must either have its IMP provide for assessment methods that address seam issues as 
specified in the regulation (i.e., the assessment method must be capable of assessing seam 
integrity and of detecting corrosion and deformation anomalies) or provide an engineering 

analysis demonstrating the low frequency ERW pipe and lap welded pipe in Respondent's 
system is not susceptible to longitudinal seam failure. And if not determined susceptibleto 
longitudinal seam failure, the procedures must describe the assessment method Respondent will 
use to assess this pipe. 
At the time of the inspection Respondent's procedure was inaccurate. As discussed above, the 
revised procedure is still inaccurate and does not satisfy the regulation. Accordingly, I find 
Respondent violated Ħħ 195.452(b)(3). 
In response to 2d, Respondent initially said sections 2.2,2.2.3,5 and Appendix H of its IMP 
discuss how updates and modifications are to be made. Respondent believes OPS misinterpreted 
the reference to version 5.0 as being the 5threvision. Respondent explained the reference was an 
archive reference inadvertently left in the document. At the hearing Respondent again explained 
the reference to revision 5 was not a 5threvision. Respondent further explained sections 2.2, 
2.2.3, chapter 5 and appendix H of its IMP describe in detail its process for updating and 
modifying its IMP and Respondent will expand the description in the next IMP revision. 
This allegation concerned Respondent's IMP not having a process for revising the baseline 
assessment plan when changes to segment identification occur. This was not a 
misunderstanding over whether Respondent had documented its IMP revisions. As part of the 
requirement to have a baseline assessment plan that conforms with 5 195.452(c),Respondent is to 
document any changes or modification to the assessment plan. Changes include documenting 
when new high consequence areas are identified and included in the baseline assessment plan. 
(See 9 195.452(d)(3)(ii).) The IMP procedures Respondent submitted do not provide for this. 
Accordingly, I find Respondent violated 195.452(b)(3). 
Item 3 alleged four violations of 49 C.F.R. $195.452(f)(8). The regulation requires an operator's 
IMP to have a process for review of integrity assessment results and information analysis by a 
person qualified to evaluate the results and information. The Notice alleged Respondent's IMP - 
did not have a process description for performing reviews of assessment results (3a); 
did not have a process description for ensuring personnel performing these reviews are 
qualified (3b); 
had grading features in the appendix that did not correlate with the rule's repair criteria 
(3c); and 
defines discovery of a condition as occurring up to 30 days after final inspection results 
are received (3d). 
In addressing 3a, Respondent initially responded its IMP has procedures to review and integrate 
integrity assessment results and to confirm assessment results. Respondent referenced several 
sections in its IMP that Respondent maintained showed these processes. 
At the hearing, Respondent described the process for reviewing integrity assessment results. 

Respondent pointed to Section 4.2 of its IMP, which refers to integrating and reviewing data to 
develop a dig prioritization of the findings to confirm anomalies. Respondent agreed to rename 
the section to more specifically identify the review process. Section 7.0 discusses the quality 
control plan for managing integrity assessment data. 
The process flow charts for analyzing data, communication plan and the procedures describing 
data integration and periodic maintenance are not relevant to this alleged violation. The 
requirement to have a process for review of integrity results is separate from the requirement to 
conduct a periodic information analysis. A process for a dig prioritization process is not the 
same as a process for reviewing integrity assessment results. The dig prioritization program may 
come after the review of the assessment results. Only section 7.1 of the IMP Quality Control 
plan on personnel qualifications includes a general statement that a Pacific Energy senior 
engineer will review the assessment results. 
I do not see that any of the IMP sections Respondent referenced describe a process of how 
Respondent's personnel are to evaluate and validate the integrity assessment results. 
Accordingly, I find Respondent violated 9 195.452(0(8). 
In response to 3b, Respondent initially maintained it had not violated any regulation because 
OPS had not cited any regulation requiring such material to be in its IMP. According to 
Respondent, the regulation only requires the persons performing the assessment be qualified, and 
Respondent's personnel are qualified because of their extensive experience. At the hearing OPS 
clarified the allegation concerned whether Respondent's IMP has a process description for 
ensuring personnel reviewing integrity assessments are qualified. Respondent maintained its 
personnel who do these reviews are experienced and it also has a rigorous contractor 
qualification process. Respondent said it revised section 7.1 of its IMP to include information on 
who will perform the assessment review. 
OPS did not allege Respondent's personnel were not qualified; rather, the allegation concerned 
the lack of a process to establish the qualifications of the person performing the review. As one 
of the required IMP elements, a program must have a process for review of integrity assessment 
results by a person qualified to evaluate the results. This is a two-part process: the review of the 
integrity assessment results and the qualification of personnel who will be performing that 
review. 
I find Respondent violated Ħħ 195.452(0(8) because, at the time of the inspection, its IMP did not 
have a process for establishing the person's qualifications to perform the integrity results review. 
Moreover, the revised procedure Respondent submitted in March 2005 still does not establish a 
formal documented process for how Respondent establishes the reviewer is qualified. 
With respect to 3c, Respondent maintained sections 4.4 through 4.8 set forth its repair criteria, 
which are consistent with the IMP repair requirements. Respondent Wher maintained OPS 
reviewed Respondent's Engineering Standard 9000 in a later inspection and found it complied 

with the rule's requirements. At the hearing, Respondent maintained OPS misunderstood the 
purpose of the engineering standard. 
After fbrther review, OPS agrees Respondent's engineering standard 9000 is not inconsistent 
with the repair criteria. Respondent uses the standard in addition to the repair criteria. The 
standard helps categorize the anomalies into subcategories to prioritize the conditions for repair. 
Accordingly, I am withdrawing the allegation of violation. 
For 3d, Respondent initially responded that its program and other documents reflect an 
appropriate response to discovery of a condition. At the hearing, OPS argued Respondent's 
procedure on discovery conflicted with the rule's requirements and implied a longer period for 
discovery. Respondent maintained it addressed these concerns by explaining its bid form 
requires contractors to release their final reports for Respondent to meet the 180-day deadline. In 
its closing statement, Respondent included amended section 4.3, which Respondent maintained 
clarifies information must be received no later than 180 days after the assessment. 
Section 195.452(f)(8) concerns the requirement to have a process for review of integrity 
assessment results and information analysis by a qualified person. But the allegation concerns 
the requirements on discovery of a condition in $1 95.452(h)(2). Thus, I am withdrawing this 
allegation of violation because the regulation cited does not relate to the alleged problem. 
Furthermore, Respondent's revised procedure appears to satisfy OPS's concern about clarifying 
when discovery of a condition occurs to be consistent with the regulation. 
Item 4 alleged Respondent had violated 49 C.F.R. $195.452(f)(4), which requires an operator's 
IMP to have criteria for remedial actions to address integrity issues raised by the assessment and 
information analysis. The Notice alleged Respondent's process description in its program did not 
have sufficient detail on criteria for determining remedial actions Respondent would take to 
address integrity issues. 
In its initial Response, Respondent said its repair criteria are in section 4.0 of its IMP and the 
criteria are consistent with the criteria in the IMP regulation. At the hearing OPS explained that 
Respondent's repair criteria did not have sufficient detail for determining remedial actions. 
Respondent explained its IMP has the repair criteria in sections 4.4 through 4.8 and an 
engineering standard in Appendix C. Its O&M manual also has references to the process 
description for determining remedial actions. Respondent said it revised its IMP to reference the 
O&M Manual. 
I am withdrawing this allegation of violation because Respondent's IMP had the procedures, 
albeit they needed to reference other documents. The revised procedures Respondent submitted 
provide more detail. 
Item 5 alleged three violations of 49 C.F.R. $195.452(e)(l). This regulation requires an operator 
to develop an assessment schedule based on risk factors reflecting the risk conditions on the 

pipeline segment. The regulations list certain risk factors an operator must consider. The Notice 
alleged Respondent - 
had not documented its risk analysis process description (5a); 
needed to establish a process for populating data fields in the risk model with values 
based on the best available information (5b); and 
did not have a process for analyzing the risk of pipeline facilities (5c). 
In response to 5a, Respondent initially maintained OPS had not cited any regulation to support 
the allegation and in any event, section 3.2.2 of its IMP has all the variable definitions. At the 
hearing OPS explained Respondent had not documented the risk analysis process in sufficient 
detail, particularly how it was using the information from the Bass Trigon algorithm model. 
Respondent maintained it allayed this concern by explaining Appendix K to its IMP contains the 
Bass-Trigon methodology user implementation manual for the software program. Respondent 
said it reviews the results of the program and runs them through its management of change. 
Sections 3.2.2,3.2.3,3.2.4 and 6.1.3 explain how the information is used. In its closing 
statement, Respondent submitted a revised section 3.2.2, which Respondent said now includes 
definitions of the variables. 
Section 195.452(e)(l) requires an operator to use risk factors in establishing the assessment 
schedule for the baseline and continuing integrity assessments. Thus, an operator must have a 
process describing the risk analysis it is using to support its assessment schedule. Respondent 
has a basic procedure describing its risk algorithm. Thus, I do not find Respondent violated 
$195.452(e)(1). But, the procedure still lacks sufficient detail to be adequate. Information, such 
as the basis for risk categories and variable weights, needs to be documented. Thus, this item 
will be included in the Amendment section of this Order. 
To address 5b, Respondent initially responded that its risk model was populated with the best 
information available and its IMP addresses the need to include the most current data in the 
database on a continuing basis. At the hearing OPS maintained that Respondent had not 
documented the process for populating the risk model data fields. Respondent explained that 
Appendix K to its IMP has the user implementation manual and the specifics on how the 
information is used is in sections 3.2.2, 3.2.3,3.2.4 and 6.1.3 of the IMP. Respondent further 
said it revised section 3.2.2 to include definitions of the variables and will expand on the 
description in its next revision. 
The requirement in $ 195.452(e)(l) to establish an assessment schedule based on risk factors 
implies the necessity for the operator to use the best available data. Without this data, there is no 
assurance the prioritization process reflects the actual risk conditions. Because Respondent has a 
process describing its risk algorithm that helped generate its assessment schedule, I do not find a 
violation of $195.452(e)(l). Nevertheless, this item will be included in the Amendment section 
of this Order because the process is lacking sufficient detail to be considered adequate. 
Respondent must ensure its IMP procedure provides for including historical data as well as 

current data and input from subject matter experts, and keeping this information updated on a 
continuing basis. For example, as discussed at the informal hearing, Respondent had not 
included historical information from the previous operator into its risk model. 
In response to 5c, Respondent said it understood OPS was concerned Respondent did not have a 
documented process for analyzing the risk posed by the non-linear portions of Respondent's 
pipeline facilities. Respondent maintained it was the first company required to perform a risk 
assessment of its facilities. Respondent explained it has ongoing surveys to address non linear 
facilities. When these surveys are completed, Respondent will perform HAZOP studies to assess 
the risk and create programs for the facilities. Respondent will include the expanded process 
description in its next IMP revision. 
Contrary to Respondent's assertion about being the first cited for this failure, it has been standard 
practice during an IMP inspection for an OPS inspector to determine if an operator has identified 
and evaluated the risks of facilities that can affect high consequence areas. OPS has taken action 
against operators who do not have a process for doing so. 
Nevertheless, I do not find this failure was a violation of $195.452(e)(1). Respondent's failure to 
include its pipeline facilities, such as pump stations and break out tanks, should have been cited 
as a violation of $ 195.452(b)(l) -not having a program that addresses risk on each segment of 
pipeline, or of $ 195.452(0(3) and 195.452(g) -not fulfilling the data and information analysis 
and integration requirements. Since Respondent was not cited for violating these regulations, I 
cannot make a finding of violation. This item will be placed in the warning section of this 
document. 
Item 6 alleged Respondent's integrity management program did not provide sufficient details on 
the methods Respondent would use in evaluating additional preventive and mitigative measures, 
in violation of 49 C.F.R. $ 195.452(i)(l). 
In its Response, Respondent said it believed section 4.8 of its IMP adequately discusses 
preventive and mitigative measures. At the hearing, Respondent explained Appendix J contains 
more detail on the methods it uses. Section 4.8 further discusses the methods and their 
appropriate and effective use. Respondent said its next IMP revision will include more of its 
thought processes on how it decides among the different methods and include references to its 
operator qualification plan and operations manual. 
Because Respondent has a procedure in its IMP for addressing additional preventive and 
mitigative measures, I do not find a violation of $195.452(i)(1). Respondent did not provide 
Appendix J. Thus, I cannot determine if the procedure provides sufficient detail to be adequate 
to protect the high consequence areas. Therefore, this item will remain in the Amendment 
section of this Order. 
Item 7 alleged three violations of 49 C.F.R. $$195.452(e)(l) and (j)(l). The Notice alleged 

Respondent's IMP - 
adid not describe in detail the process for continual evaluation and assessment, and did 
not include a justification for establishing the 5-year and 3-year (bare pipe) reassessment 
intervals (7a); 
adid not describe a methodology for choosing reassessment methods (7b); and 
adid not address OPS notification for reassessment interval extension (7c). 
Section 195.452(e)(l) requires an operator to establish an integrity assessment schedule that 
prioritizes the pipeline segments for assessment, based on all risk factors applicable to each 
segment. Section 195.452Q)(l) requires continual assessment and evaluation of each covered 
pipeline segment. 
In response to 7a, Respondent said its reassessment intervals are directly from the regulation. 
Respondent explained it selected the 5-year interval as an initial reassessment period in the 
absence of historical data and experience demonstrating a different interval is warranted. At the 
hearing Respondent explained sections 4.1 1 and 4.12 of its IMP address the reassessment 
intervals and how changes are handled in the assessment schedule. 
Section 195.452 (j)(l) requires an operator to establish continual assessment at specified 
intervals. Per 8195.452(j)(3) intervals are not to exceed five years, but are to be based on the 
risk the line pipe poses to the high consequence area. 
Section 4.1 1 of Respondent's IMP sets a five-year reassessment period for all segments except 
those with bare pipe. It does not appear the schedule accounted for the risk each segment poses 
to the high consequence area. Respondent's procedures show no process for determining which 
segments are of higher risk or of any basis why all segments pose the same risk and are to be 
assessed at five-year intervals. Respondent's procedures must include justification for the 
determinations made to implement its program. Accordingly, I find Respondent violated 
gg195.452 (e)(l) and (i)(l). 
For 7b, Respondent initially argued its IMP discussed available and allowable methods to 
conduct an integrity assessment. Respondent does not interpret the regulation to require an 
operator to specify or justify the choice of assessment method. In its post-hearing submittal, 
Respondent maintained sections 4.10-4.1 1 of its IMP address the different assessment methods 
available and what conditions must exist to choose one method over another. Respondent 
further explained it uses a combination of methods for different situations and plans to describe 
its methodology in more detail in its next IMP revision. 
Sections 4.10-4.1 1 of Respondent's IMP include statements on current assessment technology 
and preferred assessment methods. Respondent does not have a process for personnel to 
determine which assessment method is preferable in defined circumstances. Further, the 
program does not describe a methodology for choosing integrity reassessment methods. Section 
195.452Q)(5) allows an operator to use certain methods to assess the line pipe. To carry out the 

required continual integrity reassessments per Ħħ 195.452(j)(1), Respondent must have procedures 
describing how its employees are to choose an assessment method based on the line segment 
conditions and the information analysis Respondent is required to conduct. 
Accordingly, I find Respondent did not violate Ħħ195.452(j)(l) because its IMP has procedures 
for reassessment and lists assessment methods. But, as described, the procedures are not 
adequate to ensure safe operation of the pipeline system. Thus, this item will be included in the 
Amendment section of this Order requiring amendment of certain IMP procedures. 
In response to 7c, Respondent explained it does not intend to deviate from the reassessment 
interval it had established. Respondent maintained it did not include an extensive write up to 
avoid the implication an extension is an acceptable practice. Respondent thought it obvious one 
would have to communicate with OPS to request an extension. Respondent said it would revise 
section 4.12 addressing assessment schedule changes to include such language. 
The regulations require reassessment at intervals based on the risk each line segment poses to the 
high consequence areas but no longer than five years. An interval can extend longer than fiveyears 
in limited situations requiring OPS notification and adequate justification supporting the 
extension. Interval extensions are optional. Thus, I do not find a violation of 8 195.452(j)(1) 
because Respondent's procedures on reassessment do not provide for an extension. 
Although Respondent stated it has no intention of deviating from the 5-year interval, 
circumstances, such as unavailable technology, may prevent Respondent from completing the 
assessment within that period. And as the IMP matures, Respondent may determine it can justify 
a longer interval on certain segments. Its IMP procedures should explain the circumstances in 
which an interval extension is allowed, the type of supporting documentation needed and how to 
notify OPS. Procedures should not assume employees know the proper method of notification. 
Accordingly, this item will remain in the Amendment section of this Order. 
Item 8 alleged Respondent violated 49 C.F.R. $1 95.452(0(7) because its integrity management 
program did not define the process for applying performance metrics to evaluate program 
effectiveness. Section 195.452(0(7) requires an operator's integrity management program to 
have methods to measure the program's effectiveness. 
Respondent initially maintained the regulation merely requires the IMP set forth methods to 
measure the program's effectiveness, and its section 5.2.3 meets this requirement. At the hearing 
Respondent said it understood OPS's concern was whether the IMP provides adequate detail on 
how performance metrics will be evaluated. Respondent explained section 5.2.3 contains a 
process for reevaluating the program's effectiveness and it has added the performance metrics in 
ASME B3 1 .G. Respondent said it would include an expanded description of the process in its 
next revision. 
Section 5.2.3 of Respondent's IMP is written in the future tense. The section says Respondent 

will create a plan that includes performance measures. This section also gives suggested 
performance measures from ASME B31.8, rather than actually incorporating the measures into 
the program. Respondent's IMP needs an established process not one Respondent plans to 
establish at some future date. Accordingly, I find Respondent violated 49 C.F.R. 
$195.452(f)(7). 
Item 9 alleged two violations of 49 C.F.R. $ 195.452(1)(l)(ii), which requires an operator to 
maintain certain records to establish compliance with the IMP requirements. The Notice alleged 
Respondent - 
had not recorded revisions to its integrity management program (9a); and 
had not analyzed pipeline integrity information inherited from BP, the previous owner of 
certain pipeline segments (9b). 
In response to 9a, Respondent reiterated the IMP'S reference to version 5 was not a fifth revision 
but a reference to a plan draft and plan footer used for internal circulation. OPS agrees 
Respondent tracked the program changes. Accordingly, I am withdrawing this allegation of 
violation. 
For 9b, Respondent argued OPS had not cited a regulation requiring the specified action. 
Respondent maintained the regulation does not require any specified level of review. 
Respondent explained it was not trying to present BP's past assessments as part of Respondent's 
qualified baseline assessment. Rather, Respondent used the fact of previous assessments in its 
risk ranking algorithm. At the hearing OPS explained Respondent was not analyzing the 
historical information from the previous owner. Respondent said the algorithm used to 
determine ranking of the pipeline segmentstook into account this information but Respondent 
chose not to use the information in its baseline assessment. Respondent believed it better to start 
with a fresh baseline assessment. 
The regulation OPS cited addresses the requirement to maintain for review documents to support 
actions Respondent takes to implement and evaluate each element required in an IMP. 
Respondent had information from the previous operator concerning internal inspection runs but 
could not demonstrate it was integrating this information into its IMP and analyzing the 
information. Thus, I do not find Respondent violated $195.452(1)(l)(ii),because it had the 
records for review. 
Rather, Respondent's failure was not the lack of records to support its action but that Respondent 
failed to integrate this information into its IMP. Section 195.452(e)(l) requires operators, in 
establishing a baseline integrity assessment schedule, to base the schedule on certain factors, 
including the results of previous integrity assessments. Section 195.452(f)(3) requires operators 
to include in their IMP an analysis that integrates all available information about the integrity of 
the entire pipeline. Section 195.452(g)requires operators, in periodically evaluating the integrity 
of the pipeline segments, to analyze all available information about the integrity of the entire 

pipeline system. This information includes data acquired in conjunction with other inspections 
and tests required under Part 195. This historical information is important to assessing the 
current condition of pipeline segments and evaluating the risks posed to high consequence areas. 
The Notice did not allege these violations although they more accurately reflect what 
Respondent failed to do. This item will be included in the Warning section of this document. 
These findings of violation will be considered prior offenses in any subsequent enforcement 
action taken against Respondent. 
WITHDRAWAL OF ALLEGATIONS 
As explained in the section above, the following allegations of violation have been withdrawn. 
The following were withdrawn because Respondent demonstrated compliance with the cited 
regulation. 
l a - Respondent's pipelines were accurately reflected in the National Pipeline Mapping 
System. 
3c -Respondent's engineering standard is consistent with the rule's repair criteria. 
4 - Respondent's IMP has procedures for determining remedial actions. 
9a - IMP interim revisions are recorded. 
The allegations in Notice items 3d, 5c and 9b were withdrawn because the incorrect citation was 
used. Items 5c and 9b are included as warning items, discussed below. 
PENALTY ASSESSMENT 
Under 49 U.S.C. 60122, Respondent is subject to a civil penalty not to exceed $100,000 per 
violation for each day of the violation up to a maximum of $1,000,000 for any related series of 
violations. The Notice proposed a total civil penalty of $34,000 for the three violations of 
195.452(f)(1) (Items 1a, 1b, 1c), three violations of 195.452(b)(3) (Items 2a, 2b, 2c), four 
violations of Ħħ195.452(f)(8) (Items 3a, 3b, 3c, 3d), one violation of Ħħ195.452(0(4) (Item 4)' 
three violations of Ħħ195.452(e)(l) (Items 5a, 5b, 5c), one violation of Ħħ195.452(i)(l) (Item 6), 
two violations of ĦħĦħ195.452(e)(l) and 195.452Cj)(l)(Items 7a and 7b) and one violation of 
195.452(1)(1) (Item 9b). 
49 U.S.C. 60122 and 49 C.F.R. Ħħ 190.225require that, in determining the amount of the civil 
penalty, I consider the following criteria: nature, circumstances, and gravity of the violation, 
degree of Respondent's culpability, history of Respondent's prior offenses, Respondent's ability 
to pay the penalty, good faith by Respondent in attempting to achieve compliance, the effect on 
Respondent's ability to continue in business, and such other matters as justice may require. 
The allegations of violation for items la, 3c, 3d and 4 have been withdrawn and no penalties will 
be assessed. Although I did not make findings of violation with respect to items lc, 2a, 5a, 5b, 6 

and 7b, I found the IMP procedures associated with the cited regulations were inadequate. Thus, 
no civil penalty will be assessed but these items will be included below in the Amendment 
section. Items 5c and 9b will be treated as warning items, and no civil penalty will be assessed 
for these items. 
With respect to the remaining violations, in assessing a civil penalty I have considered that for 
purposes of the Part 195 IMP regulations, Respondent originally was a small operator with 35 
miles of pipeline, until it purchased another operator's system. OPS did not conduct a quick hit 
inspection with Respondent, as it did with some large operators, which would have alerted 
Respondent to the level of detail OPS was expecting of operators with their integrity 
management programs. OPS had public workshops for operators. On its web site OPS posted 
inspection protocols beginning in July 2002, and numerous FAQs beginning in October 2001 to 
help operators implement the IMP regulations. Respondent was either unaware this information 
was available or failed to use it as a resource. 
Nevertheless, I recognize that in developing its IMP Respondent did not have the knowledge and 
experience of a larger operator. 
The Notice proposed a civil penalty of $1,000 for violation of 49 C.F.R. Ħħ195.452(f)(1) (Item 
1b). Other than Respondent misunderstanding the scope of which facilities needed to be 
identified, Respondent did not present any mitigating information. The identification of pipeline 
segments, including all parts of pipeline facility, is a basic and crucial part of the regulation and 
of an integrity management program. I see no basis for reducing this penalty and assess $1,000 
for this violation. 
For the violation of 4 195.452(b)(3) (Item 2c), the Notice proposed a civil penalty of $5,000. 
Respondent has deleted from its IMP the statement about there not being any pre-1970 ERW 
pipe or lap welded pipe in the system. The statement was a mistake and has been deleted. But, 
although the amended procedure now discusses future acquired pipelines having such pipe, there 
is still no discussion of how the existing pipe will be addressed. Because these types of pipe are 
susceptible to longitudinal seam failure, the regulation specifies certain capabilities the integrity 
assessment method must have. It is critical Respondent provide for this in its IMP. 
Respondent's risk analysis, nonetheless, considered the fact this type of pipe was in the system, 
and Respondent has been monitoring the pipe as part of its overall operations and maintenance 
program. Thus, I will reduce the penalty to $3,000. 
The Notice proposed a civil penalty of $2,500 for violation of $195.452(f)(8)(Item 3a). It is 
important Respondent's IMP have a process for how personnel are to review integrity 
assessment results to ensure consistency in the review process and that proper methods are used 
to validate the results. Respondent made a good faith effort to comply and believed its work 
orders and procedures concerning dig prioritization, quality control and communications 
satisfied the regulation. I am reducing the civil penalty to $1,500. 

For the second violation of 8195.452(f)(S)(Item 3b), the Notice proposed a civil penalty of 
$1,000. Again, it is essential Respondent's IMP describe what the qualification process is to 
ensure its personnel will always have the requisite training and qualifications to perform the 
review. As mitigating information Respondent believed it complied with the regulation by 
having qualified personnel with years of experience perform the reviews. Respondent 
misunderstood the necessity to also have a qualification process description. Due to 
Respondent's good faith effort to comply with the requirement, I will reduce the penalty to $500. 
The Notice proposed a civil penalty of $2,000 for violation of $8 195.452(e)(l) and 195.452(j)(1) 
(Item 7a). The purpose of these requirements is for the operator to establish the reassessment 
intervals based on the specific risk factors reflecting the risk conditions on each pipeline segment 
and to prioritize the segments according to these risks. As mitigating information, Respondent 
demonstrated good faith in trying to establish a reassessment interval and believed its across-the 
board three-year interval for bare pipe and five-year interval for all other pipe met the IMP 
requirement because the intervals stayed within the maximum allowable period. Respondent 
planned to update the intervals as it gained more information about the segments. I assess the 
civil penalty for this violation at $1,000. 
Respondent has not maintained a civil penalty will affect its ability to continue in business or that 
it is unable to pay. Accordingly, having reviewed the record and considered the assessment 
criteria, I assess Respondent a total civil penalty of $7,000. 
Payment of the civil penalty must be made within 20 days of service. Federal regulations 
(49 C.F.R. 8 89.21(b)(3)) require this payment be made by wire transfer, through the Federal 
Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed 
instructions are contained in the enclosure. Questions concerning wire transfers should be 
directed to: Financial Operations Division (AMZ- 120), Federal Aviation Administration, Mike 
Monroney Aeronautical Center, P.O. Box 25082, Oklahoma City, OK 73125, (405) 954-4719. 
Failure to pay the $7,000 civil penalty will result in accrual of interest at the current annual rate 
in accordance with 3 1 U.S.C. $ 37 17,3 1 C.F.R. $901.9 and 49 C.F.R. 8 89.23. Pursuant to 
those same authorities, a late penalty charge of six percent (6%) per annum will be charged if 
payment is not made within 1 10 days of service. Furthermore, failure to pay the civil penalty 
may result in referral of the matter to the Attorney General for appropriate action in a United 
States District Court. 
COMPLIANCE ORDER 
The Notice proposed a compliance order with respect to violations of $8195.452(f)(l), 
195.452(b)(3), 195.452(f)(8), 195.452(0(4), 195.452(e)(l), 195.452(i)(1), 195.452(j)(l), 
195.452(f)(7) and 195.452(1)(1) (Notice items la, Ib, lc, 2a, 2c, 2d, 3a, 3b, 3c, 4,5a, 5c, 6,7a, 
7b, 7c, 8,9a and 9b). The allegations of violation concerning 1 a, 3c, 4 and 9a have been 
withdrawn and will not be included in this compliance order. Although I did not make findings 

of violation with respect to items lc, 2a, 5a, 6,7b and 7c, I found the procedures implementing 
the requirements were inadequate and must be amended, as set forth below. Items 5c and 9b will 
be included as warning items. 
As for violations of $$195.452(f)(l), 195.452(b)(3), 195.452(0(8), 195.452(e)(l), 195.452Cj)(l) 
and 195.452(0(7) (items lb, 2c, 2d, 3a, 3b, 7a, 8), Respondent has not demonstrated compliance 
with the applicable regulations. 
Under 49 U.S.C. $ 601 18(a), each person who owns or operates a pipeline facility is required to 
comply with the applicable safety standards established under chapter 60 1. Pursuant to the 
authority of 49 U.S.C. $ 601 18(b) and 49 C.F.R. $ 190.2 17, Respondent is hereby ordered to take 
the following actions to ensure compliance with the pipeline safety regulations applicable to its 
operations. 
1. 
To address violation of $195.452(f)(l)(Item 1 b), Respondent must identify all facilities in 
its pipeline system that could affect a high consequence area and include these facilities 
in its IMP program and implementing procedures. 
To address violation of $ 195.452(b)(3) (Item 2c), Respondent must establish procedures 
that address the pre-1970 ERW and lap welded pipe in its system (current and future 
pipe). Perform and document an engineering seam susceptibility failure analysis to 
determine if any segments with this type of pipe are susceptible to longitudinal seam 
failure. Included detailed procedures addressing assessment methods to assess these 
, 
types of pipe and ensure the assessment methods have the capabilities to specifically 
address seam issues, and detect corrosion and deformation anomalies. Document (and 
perform if not already performed and documented) that the baseline assessment of these 
segments have been done by hydrostatic test or by assessment methods that have the 
capabilities to assess seam integrity and detect corrosion and deformation anomalies. 
3. 
To address violation of $195.452(b)(3) (Item 2d), Respondent's IMP must describe and 
document the process for revising the baseline assessment plan. 
4. 
To address violation of $195.452(b)(3)) (Item 3a), Respondent must have in its IMP a 
procedure describing the process for reviewing assessment results. These procedures 
must document roles and responsibilities, by organizational group or title, for 
implementing required actions, the information personnel must use in reviewing integrity 
assessment results and sources of the information, records required to be generated in the 
process of implementing assessment result reviews and integrity evaluations, and quality 
requirements for the review to assure accuracy and completeness. 
5. 
To address violation of $195.452(b)(3) (Item 3b), Respondent's IMP must have a detailed 
description of how personnel who review integrity assessment results will be qualified, 
and what the requisite qualifications are to perform the review. 

6 . To address violation of $$195.452(e)(l) and (j)(l)(Item 7a), Respondent must include in 
its IMP procedures, the basis for determining its reassessment intervals. These intervals 
are to be based on risk factors reflecting the risk conditions on the pipeline segment. The 
IMP must also include the justification supportingthe reassessment intervals. 
7. To address violation of $ 195.452(f)(7) (Item 8), Respondent must include performance 
metrics in its IMP procedures to measure whether Respondent's program is effective in 
assessing and evaluating the integrity of each pipeline segment in Respondent's system 
and in protecting the high consequence areas. Respondent should refer to Appendix C of 
Part 195 in developing these measures. 
8. Submit documentation demonstrating compliance with each of the above listed items to 
the Regional Director, Western Region, in Lakewood CO, within 30 days following 
receipt of this Final Order. 
9. The Regional Director may extend the period for complying with any of the required 
items if Respondent requests an extension and adequately justifies the reasons for the 
extension. 
AMENDMENT OF PROCEDURES 
The Notice alleged the following inadequacies in Respondent's integrity management program 
and proposed to require amendment of some of Respondent's procedures to comply with the 
requirements of $192.452. 
Respondent's IMP procedures do not specify the process for communicating information 
from field activities, which could result in identifying new or extended segmentsthat 
could affect high consequence areas (Item (1d); 
Respondent's procedures do not include a sensitivity analysis based on a range of break 
sizes and response times. Rather, Respondent's procedures for determining the indirect 
effects of a release for identifying could affect segments were based on a worst-case 
discharge (Item 1e). 
In response to the first alleged inadequacy, Respondent maintained it has several programs in 
place to provide direct feedback to and from the field. Its IMP uses information obtained from 
the field and other sources but is not meant to be redundant by including all procedures and 
policies set forth in other manuals. At the hearing Respondent further explained information 
gathered by its line riders, aerial patrols, maintenance and operations reports are reviewed by its 
district engineer. This information goes to the integrity management team and the individual in 
charge of distribution and implementation of the team's activities. Respondent said this process 
is documented in its operations and maintenance manual and operator qualification plan and 
Respondent will reference these plans in its next IMP revision. 
Because Respondent's submittals did not document IMP revisions to address this inadequacy, 
this item will remain in this Amendment. 

In response to the second alleged inadequacy, Respondent initially said it used a worst-case 
discharge when performing the sensitivity analysis similar to what it does for Part 194 for 
emergency response planning. Respondent argued the IMP rule does not require multiple spill 
volume cases, break sizes and range of response times be examined. At the hearing, Respondent 
said it understood OPS's concern to be Respondent's lack of a procedure to examine the effect of 
spill volume and spill spread to evaluate potential spill impacts on high consequence areas. 
Respondent explained its emergency response plan looks at such data in detail and analyzes the 
worst-case scenario as well as lesser impacts and it will reference this plan in its next IMP 
revision. 
While a worst-case discharge may be the worst case, in some instances a leak can go undetected 
for months or years with a cumulative loss greater than a worst-case discharge. Thus, procedures 
should include several scenarios to determine how the pipeline segment could affect the high 
consequence area. 
As explained above, with respect to items lc, 2a, 5a, 5b, 6, 7b and 7c, although I did not find 
Respondent's procedures violated certain IMP requirements, I found the procedures were not 
adequate to ensure the safe operation of Respondent's system. These items will be included in 
this Amendment. 
Accordingly, I find that Respondent's procedures are inadequate to ensure safe operation of its 
pipeline system. Pursuant to 49 U.S.C. 5 60108(a) and 49 C.F.R. 5 190.237, Respondent is 
ordered to make the following revisions to its integrity management program procedures. 
Respondent must - 
1. 
To address the procedural inadequacy described in itemlc, revise the segment identification 
procedures to better describe the methodology used in identifying pipeline segments in 
Respondent's system. The process must detail each step Respondent takes in determining if a 
segment could affect or could not affect a high consequence area. This process must also include 
the review of results provided by Respondent's consultant to ensure the accuracy of the segment 
identification process. 
2. 
To address the procedural inadequacy described in item 1d, specify how personnel are to use 
feedback from field activities that could result in the identification of new or extended segments 
that could affect high consequence areas. Include which company personnel are to provide this 
information, how it is to be recorded and how this information is to be communicated among 
personnel. 
3. 
To address the procedural inadequacy described in item le, include a sensitivity analysis (as 
opposed to a spill scenario) based on a range of break sizes and response times to ensure the 
process reflects a conservative evaluation of potential spill impacts on high consequence areas. 
4. 
To address the procedural inadequacy described in item 2a, specify in better detail the 
assessment methods that can be used for each segment of pipeline to be assessed. The 
procedures are to include the criteria for choosing a certain method of assessment to address the 

specific risks on each pipeline segment. 
5. 
To address the procedural inadequacy described in item 5a, provide more detail on the risk 
analysis model to include the specific variables Respondent uses for its system, bases for these 
risk factors, variable weights, and the process for populating, maintaining and updating the risk 
analysis input database. 
6. 
To address the procedural inadequacy described in item 5b, specify in detail the process for 
populating and updating the risk model data fields with the best available information from 
records and input from subject matter experts. This process must include use of historical 
information from the previous operator of any pipelines Respondent acquired or acquires. 
7. 
To address the procedural inadequacy described in item 6, describe in detail the process for 
identifying and implementing additional preventive and mitigative measures to protect the high 
consequence areas. This process must include steps for choosing measures, assessing risks 
including the factors to use in analyzing risk, and determining whether and how to implement the 
additional measures. The process must include how leak detection improvements will be 
evaluated and how the need for emergency flow restricting devices will be determined. 
8. 
To address the procedural inadequacy described in item 7b, describe the detailed process for 
choosing an integrity reassessment method. This process must include how an assessment 
method will be determined based on the specific conditions Respondent has identified for the 
pipeline segment, and the information analysis applied to the segment. 
9. 
To address the procedural inadequacy described in item 7c, describe the process for notifying 
OPS if an extension of an integrity reassessment interval is necessary based on the circumstances 
allowed under 49 C.F.R. 8 195.4520)(4), and the necessary supporting documentation to 
accompany any such notification. 
10. 
Submit the amended procedures to the Regional Director, Western Region, OPS within 30 
days following receipt of the Final Order. 
1 1. The Regional Director may extend the period for complying with any of the required items if 
the Respondent requests an extension and adequately justifies the reasons for the extension. 
WARNING ITEMS 
The Notice issued a warning with respect to items 1f and 2b. 
Item 1 f warned Respondent to evaluate the constituents of its pipeline products and evaluate the 
potential impacts by air dispersion on high consequence areas. 
Respondent maintained air dispersion modeling is not required. Respondent said it has product 
quality requirements shippers must meet, and these requirements limit H2S. Respondent 
submitted some chemical analyses of the crude oil it transports. Respondent said, based on its 
testing program, it has determined there is no threat of impact to a high consequence area from 

product constituents. Thus, air dispersion modeling is not needed and it has revised its IMP 
procedures to reflect that determination. 
An operator has to understand how a failure could affect the high consequence areas. This 
includes an air dispersion analysis to determine how fumes from a crude oil release could affect 
the areas. Respondent monitors after spills for benzene, lower explosion limit concentrations of 
h e s and H2S, but does not consider these effects in analyzing the potential effects of spills on 
high consequence areas. Respondent should do so. 
Item 2b warned Respondent that after it had revised its baseline assessment plan, it failed to 
revise its assessment schedule so that at least 50% of segments were assessed by September 30, 
2004. Respondent said OPS's calculation was wrong and Respondent had assessed more than 
50% of the affected segments. Respondent has assessed the required percentage of segments and 
need take no Mher action to address this item. 
As discussed above, with respect to items 5c -lack of a process for analyzing the risk of pipeline 
facilities and 9b -not analyzing integrity information inherited from the previous pipeline owner, 
I did not find violations of the cited regulation because of the incorrect citations. This does not 
mean that Respondent did not commit a violation for these failures in its IMP processes. 
For those warning items described above Respondent has not yet addressed (items 1 f, 5c and 9b), 
Respondent should take the necessary corrective action to come into compliance. Respondent is 
again warned that if OPS finds a violation for any of these items in a subsequent inspection, 
enforcement action will be taken. 
Under 49 C.F.R. 190.2 15, Respondent has a right to petition for reconsideration of this Final 
Order. The petition must be received within 20 days of Respondent's receipt of this Final Order 
and must contain a brief statement of the issue(s). The filing of the petition automatically stays 
the payment of any civil penalty assessed. All other terms of the order, including any required 
corrective action and amendment of procedures, remain in full effect unless the Associate 
Administrator, upon request, grants a stay. The terms and conditions of this Final Order are 
effective upon receipt. 
Date Issued 
Associate Administrator