On September 12, 2024, an Investigator from PHMSA's Office of Hazardous Materials Safety Field Operations ("OHMSFO") conducted an inspection at Respondent's facility in Philadelphia, Pennsylvania, pursuant to 49 U.S.C. § 5121 and 49 CFR § 107.305. PHMSA's Investigator reported one (1) alleged violation of the HMR. At the conclusion of the compliance inspection, PHMSA's Investigator conducted an "exit briefing," during which the Investigator discussed the alleged violation and the required corrective actions with Respondent's representatives.

Upon completion of the inspection, the Investigator submitted a report to the Director of OHMSFO's Eastern Region, who reviewed the report for accuracy and sufficiency of evidence. Based on that review, the Director referred the matter to PHMSA's Office of Chief Counsel, thereby recommending the initiation of a civil penalty action against Respondent, pursuant to 49 CFR § 107.311.

Based on a preliminary assessment of the apparent nature, circumstances, extent, and gravity of the probable violation, as set forth in the Investigator's report, on March 26, 2025, an attorney from PHMSA's Office of Chief Counsel issued a Notice of Probable Violation ("Notice"), alleging one (1) violation of the HMR, and proposing a $15,000 civil penalty. Respondent accepted electronic service of process of the Notice on March 26, 2025.

Respondent provided full corrective action prior to the issuance of the Notice, and PHMSA's attorney reduced the Notice penalty by the maximum permitted at the time of issuance. Following the informal conference, PHMSA's attorney was able to offer a further 25% penalty reduction from the Notice, in the interest of settling the matter, for a new total penalty of $11,250.