# CHEVRON U.S.A. INC — Notice of Probable Violation

**Citation:** CPF 420067005  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2006-09-19

CLOSED notice of probable violation citing 195.452(e)(1), 195.452(g)(4), 195.452(i)(2), 195.452(i)(3), 195.452(i)(4), 195.452(j)(2), 195.452(j)(3), 195.452(k).

## Document text

Notice of Probable Violation involving CHEVRON U.S.A. INC. PHMSA's enforcement data identifies the cited regulations as 195.452(e)(1),  195.452(g)(4),  195.452(i)(2),  195.452(i)(3),  195.452(i)(4),  195.452(j)(2),  195.452(j)(3),  195.452(k). The case was opened on 2006-09-19 and is reported as closed as of 2008-02-13. Proposed civil penalty: $10,000. Assessed civil penalty: $10,000. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420067005_Final Order_02062007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420067005/420067005_Final%20Order_02062007.pdf

CPF_NO_4-2006-7005.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420067005/CPF_NO_4-2006-7005.pdf

420067005_Final Order_02062007.pdf

400 Seventh Street, S.W.
U.S.Department Washington, D.C. 20590
of Transportation
Pipeline and Hazardous
Materials Safety Administration
Ms. Melody Meyer
Vice President, Gulf of Mexico
Chevron USA, Inc.
935 Gravier Street
New Orleans, LA 70 1 12
Re: CPF No. 4-2006-7005
Dear Ms. Meyer:
Enclosed is the Final Order issued by the Acting Associate Administrator for Pipeline Safety
in the above-referenced case. It makes findings of violation and assesses a civil penalty. I
acknowledge receipt of and accept your October 19,2006 payment of $1 0,000 as payment in full
of the civil penalty assessed in the Final Order. The Final Order also specifies actions to be
taken to comply with the pipeline safety regulations. When the terms of the compliance order
are completed, as determined by the Director, Southwest Region, this enforcement action will be
closed. Your receipt of this Final Order constitutes service under 49 C.F.R. 5 190.5.
Sincerely,
James Reynolds
Pipeline Compliance Registry
Office of Pipeline Safety
Enclosure
VU CERTIFIED MAIL -RETURN RECEIPT REQUESTED



DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, DC 20590
In the Matter of
Chevron USA, Inc., CPF NO. 4-2006-7005
Respondent
FINAL ORDER
On June 12 through 16,2006, pursuant to 49 U.S.C. 5 601 17, representatives of the Pipeline and
Hazardous Materials Safety Administration (PHMSA) and Louisiana Department of Natural
Resources conducted an on-site pipeline safety inspection of Respondent's integrity management
program (IMP) and procedures in New Orleans, Louisiana. As a result of the inspection, the
Director, Southwest Region, PHMSA, issued to Respondent, by letter dated September 19, 2006,
a Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order
(Notice). In accordance with 49 C.F.R. 5 190.207, the Notice proposed finding that Respondent
committed violations of 49 C.F.R. 5 195.452 and proposed assessing a civil penalty of $10,000
for the alleged violations. The Notice also proposed that Respondent take certain measures to
correct the alleged violations.
Respondent responded to the Notice by letter dated October 17, 2006. Respondent did not
contest the allegations, agreed to pay the proposed civil penalty, and stated its intent to comply
with the Proposed Compliance Order. Respondent paid the amount of the proposed civil penalty
($10,000) on October 19, 2006, waiving further right to respond and authorizing the entry of this
Final Order.
FINDINGS OF VIOLATION
Pursuant to 49 C.F.R. 5 190.213 and 49 U.S.C. 5 60122, I find that Respondent violated the
following sections of 49 C.F.R. Part 195, as more fully described in the Notice:
49 C.F.R. 5 195.452(e)(l) - failing to establish an integrity assessment schedule that
prioritizes pipeline segments for assessment based on relevant risk factors, including the
factors specified in 5 195.452(e)(l). In addition, Respondent failed to update the risk
model with the most accurate information to reflect current conditions.



49 C.F.R. 5 195.452(f)(4), (f)(8), (g), (h)(l) and (h)(2) - failing to develop sufficient
processes for data integration and information analysis. Respondent's processes for data
integration and information analysis did not document in sufficient detail the processes
performed by the Facility Engineer to support evaluation of the condition of the pipeline
or to make decisions related to the repair or remediation of pipeline defects.
49 C.F.R. 5 195.452(f)(6), (i)(l) and (i)(2) -failing to develop a process for identification
of preventive and mitigative measures that considers all relevant risk factors, including
those factors specified in 5 195.452(i)(l) and (i)(2).
49 C.F.R. fj 195.452(f)(6) and (i)(3) -failing to develop a process for evaluation of leak
detection capabilities. In addition, Respondent failed to perform an evaluation of leak
detection capabilities and modify those capabilities, as necessary, to protect high
consequence areas (HCAs).
49 C.F.R. 5 195.452(f)(6) and (i)(4) -failing to develop a process for determining the
need for emergency flow restricting devices (EFRD). Respondent failed to determine the
need for EFRD and install EFRD as necessary to protect HCAs.
49 C.F.R. 5 195.452(f)(5), (j)(l) and (j)(2) - failing to develop a continual process for
assessment and evaluation. In addition, Respondent failed to establish the frequency for
evaluation based on applicable risk factors, including those factors specified in
5 195.452Q)(2).
49 C.F.R. 5 195.452(f)(5), Q)(1) and (j)(3) -failing to establish intervals and priorities
for continually assessing integrity that are based on applicable risk factors, including
those factors specified in 5 195.452(j)(3).
49 C.F.R. 5 195.452(f)(7) and (k) - failing to develop a process to measure the
effectiveness of its IMP, including methods to measure whether the program is effective
in assessing and evaluating the integrity of each pipeline segment and in protecting
HCAs.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent. Having reviewed the record and considered the assessment
criteria, I assess Respondent a civil penalty of $10,000 for the violations of 5 195.452(f)(6),
( ( 3 , and ()(4). The civil penalty has already been paid by Respondent.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to the violations. Under 49 U.S.C.
5 601 18(a), each person who engages in the transportation of hazardous liquid by pipeline or
who owns or operates a hazardous liquid pipeline facility is required to comply with the
applicable safety standards established under Chapter 601. Pursuant to the authority of 49
U.S.C. 5 601 18(b) and 49 C.F.R. 5 190.2 17, Respondent is ordered to take the following actions
' These violations were numbered Items 4 and 5 in the Notice.



to ensure compliance with the pipeline safety regulations applicable to its operations.
Respondent must-
1. Establish an integrity assessment schedule that prioritizes pipeline segments for
assessment in accordance with 5 195.452(e)(l). The schedule must be based on relevant
risk factors, including those factors specified in 5 195.452(e)(l). Modify the current "risk
evaluation" process for analyzing risks (threats and consequences) to ensure all risk
factors are considered. Develop and document a process to ensure the risk model is
updated with accurate information to reflect current conditions and operating
environment. Develop and document guidelines for the use of subject matter experts to
ensure consistent application of the process and repeatability. The risk evaluation
process must provide a means for identification of significant threats to pipeline integrity.
2. Develop data integration and information analysis processes (5 195.452(g)) to ensure
consistent application and repeatability when those processes are performed by the
Facility Engineer. The processes must integrate additional sources of pertinent risk-
factor data and assessment results to support evaluation of the condition of the pipeline,
or to make decisions related to the repair or remediation of pipeline defects. The
processes must include specified inputs; a detailed process to collect and evaluate the
data; and a description of expected outputs for quality assurance/quality control.
3. Develop a process for identification of additional preventive and mitigative measures in
accordance with 5 195.452(0(6), (i)(l) and (i)(2). The process must be based on an
analysis of relevant risk factors, including those factors specified in 5 195.452(i)(l) and
(i)(2). The process must be documented in sufficient detail to ensure consistent
application. Respondent may integrate its Prevention and Mitigation Manuals, which
address other required programs, into the IMP as appropriate.
4. Develop and document a process for evaluating leak detection capabilities and for
modifying those capabilities, as necessary, in accordance with 5 195.452(0(6) and (i)(3).
Perform an evaluation and any necessary modifications in accordance with the process
developed and 5 195.452(0(6) and (i)(3).
5. Develop and document a process for determining the need for EFRD in accordance with
9 195.452(0(6) and (i)(4). Perform the evaluation and install EFRD where needed to
protect an HCA in accordance with the process developed and 5 195.452(0(6) and (i)(4).
6. Develop and document a continual process for assessment and evaluation in accordance
with 5 195.452(0(5), (j)(l) and (j)(2). The process must document detailed requirements
for performing periodic evaluation as frequently as needed to assure pipeline integrity.
The frequency for evaluation must be based on applicable risk factors, including those
factors specified in 5 195.452(j)(2).
7. Develop and document a process for determining reassessment intervals and priorities for
continually assessing integrity in accordance with 5 195.452(0(5), (j)(l), and (j)(3). The
process must be based on applicable risk factors, including those factors specified in



§ 195.4526)(3), and must provide sufficient detail to ensure that the process can be
consistently applied across all pipeline segments in the IMP.
8. Develop and document a process to measure the effectiveness of its IMP in accordance
with § 195.452(f)(7) and (k). The process must include methods to measure whether the
program is effective in assessing and evaluating the integrity of each pipeline segment
and in protecting HCAs. The process must be sufficiently detailed to ensure consistent
application and must ensure that the results of the evaluation are communicated within
the organization.
9. Maintain documentation of the safety improvement costs associated with fulfilling this
Compliance Order. Report the total costs as follows: (a) total cost associated with
preparation, revision of plans and procedures, and performance of studies and analyses;
and (b) total cost associated with physical changes to the pipeline infrastructure, if
applicable, including replacements and additions.
10. Complete each of the above items and submit documentation of compliance within 30
days of receipt of this Final Order. Documentation shall be submitted to the Director,
Southwest Region, Office of Pipeline Safety, 870 1 South Gessner Dr, Suite 1 1 10,
Houston, TX 77074-2949.
In a letter dated October 24, 2006, Respondent requested additional time to comply with the
terms of the compliance order. An extension of time is not granted by this order, because
Respondent has had additional time by virtue of the effective date of this order. However, the
Director, Southwest Region, may grant an extension of time to comply with any of the above
required items upon a written request timely submitted by the Respondent demonstrating good
cause for an extension.
Failure to comply with this Order may result in administrative assessment of civil penalties up to
$100,000 per day for each violation and in referral to the Attorney General for appropriate relief
in a district court of the United States. The terms and conditions of this Final Order are effective
on receipt.
FEB - 6 2007
ate Issued
~ c t i n ~ Associate Administrator
for Pipeline Safety

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/420067005>
- Source ID: `phmsa-enforcement`
- SHA-256: `756088260940320e36bc3978325ad73e606ebb9ff2359cd260e99ebcbbd23c0f`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-23T21:30:59.830Z
- Document slug: `phmsa-enforcement-420067005`

### Source metadata

```json
{
  "cpf": "420067005",
  "operator": "CHEVRON U.S.A. INC",
  "region": "Southwest",
  "pipelineType": "INTERSTATE LIQUID OFFSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.452(e)(1)",
    "195.452(g)(4)",
    "195.452(i)(2)",
    "195.452(i)(3)",
    "195.452(i)(4)",
    "195.452(j)(2)",
    "195.452(j)(3)",
    "195.452(k)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
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      "name": "420067005_Final Order_02062007.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/420067005/420067005_Final%20Order_02062007.pdf",
      "bytes": 230097,
      "category": "agency_document"
    },
    {
      "name": "CPF_NO_4-2006-7005.pdf",
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  ],
  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "CHEVRON U.S.A. INC"
}
```
