# EXXONMOBIL PIPELINE CO — Notice of Probable Violation

**Citation:** CPF 520115003  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2011-02-23

CLOSED notice of probable violation citing 195.254(b), 195.410(a)(1), 195.410(a)(2), 195.412(a), 195.581(a).

## Document text

Notice of Probable Violation involving EXXONMOBIL PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 195.254(b),  195.410(a)(1),  195.410(a)(2),  195.412(a),  195.581(a). The case was opened on 2011-02-23 and is reported as closed as of 2011-11-02. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520115003_Final Order_11022011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520115003/520115003_Final%20Order_11022011.pdf

520115003_Final Order_11022011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520115003/520115003_Final%20Order_11022011_text.pdf

520115003_NOPV PCO_02232011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520115003/520115003_NOPV%20PCO_02232011.pdf

520115003_NOPV PCO_02232011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520115003/520115003_NOPV%20PCO_02232011_text.pdf

520115003_operator response_03242011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520115003/520115003_operator%20response_03242011.pdf

520115003_Final Order_11022011_text.pdf

NOV 2 2011
Mr. Gary W. Pruessing
President
ExxonMobil Pipeline Company
800 Bell Street, Room 741D
Houston, TX 77002
Re: CPF No. 5-2011-5003
Dear Mr. Pruessing:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation and finds that ExxonMobil Pipeline Company has completed the actions specified in
the Notice to comply with the pipeline safety regulations. Therefore, this case is now closed.
Service of the Final Order by certified mail is effective upon the date of mailing as provided
under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Alan Mayberry, Deputy Associate Administrator for Field Operations, Pipeline Safety
Mr. Chris Hoidal, Director, Western Region, PHMSA
Mr. Gary Hartmann, Manager, Safety, Health and Environment Department, EMPCo
ExxonMobil Pipeline Co., 800 Bell St., Room #6038, Houston, Texas 77002
CERTIFIED MAIL – RETURN RECEIPT REQUESTED [71791000164202823906]



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
___________________________________
In the Matter of )
ExxonMobil Pipeline Company, ) CPF No. 5-2011-5003
)
)
)
Respondent. )
___________________________________ )
FINAL ORDER
On July 27-30, 2009, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline and
Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),
conducted an on-site safety inspection of the pipeline facilities operated by ExxonMobil Pipeline
Company (EMPCo or Respondent) in Montana. EMPCo, a subsidiary of Exxon Mobil
Corporation, operates approximately 5,500 miles of pipeline transporting hazardous liquids,
including crude oil, natural gas liquids, and refined petroleum products.1
As a result of the inspection, the Director, Western Region, OPS (Director), issued to
Respondent, by letter dated February 23, 2011, a Notice of Probable Violation and Proposed
Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed
finding that EMPCo had committed certain violations of 49 C.F.R. Part 195 and proposed that
Respondent take certain measures to correct the alleged violations.
EMPCo responded to the Notice by letter dated March 24, 2011 (Response). In its Response, the
company provided information concerning the corrective actions it had taken to remediate the
alleged violations. Respondent did not request a hearing and therefore has waived its right to
one.
FINDINGS OF VIOLATION
The Notice alleged that Respondent committed the following violations of 49 C.F.R. Part 195:
Item 1: The Notice alleged that Respondent violated § 195.410(a)(1), which states:
1 This information is reported by EMPCo in accordance with 49 C.F.R. § 195.49. On its website, the company
states that it transports hazardous liquids through 8,000 miles of operated pipeline.
http://www.exxonmobilpipeline.com/USA-English/EMPCo/ourcompany.aspx (visited Oct. 20, 2011).



2
§ 195.410 Line markers.
(a) Except as provided in paragraph (b) of this section, each operator
shall place and maintain line markers over each buried pipeline in
accordance with the following:
(1) Markers must be located at each public road crossing, at each
railroad crossing, and in sufficient number along the remainder of each
buried line so that its location is accurately known.
The Notice alleged that Respondent violated § 195.410(a)(1) by failing to place line markers in
sufficient number along its buried pipeline so that the location is accurately known where the
line passes through a housing development near Laurel, Montana.
Respondent did not contest the allegation of violation and explained that the company has
remarked the pipeline and installed additional line markers in the identified area. Based upon a
review of the evidence, I find that Respondent violated § 195.410(a)(1) as alleged.
Item 2: The Notice alleged that Respondent violated § 195.410(a)(2), which states:
§ 195.410 Line markers.
(a) . . .
(2) The marker must state at least the following on a background of
sharply contrasting color . . .
(ii) The name of the operator and a telephone number (including area
code) where the operator can be reached at all times.
The Notice alleged that Respondent violated § 195.410(a)(2) by failing to include on several
pipeline markers the operator’s current contact information, including current telephone number
where the operator can be reached at all times. The line markers were located in the housing
development near Laurel, Montana.
Respondent explained that the markers in question were replaced following the PHMSA
inspection and the new markers have the operator’s current contact information. Respondent
also explained that the old telephone number on the markers that were replaced was still an
active number. Based upon a review of the evidence, I find the markers in question did not
display the operator’s current contact information and therefore Respondent violated
§ 195.410(a)(2) as alleged.
Item 3: The Notice alleged that Respondent violated § 195.254(b), which states:
§ 195.254 Above ground components.
(a) Any component may be installed above ground in the following
situations, if the other applicable requirements of this part are complied
with:
(1) Overhead crossings of highways, railroads, or a body of water.
(2) Spans over ditches and gullies.
(3) Scraper traps or block valves.
(4) Areas under the direct control of the operator.



3
(5) In any area inaccessible to the public.
(b) Each component covered by this section must be protected from
the forces exerted by the anticipated loads.
The Notice alleged that Respondent violated § 195.254(b) by failing to protect an aboveground
span over a ditch from the forces exerted by the anticipated loads. The pipeline at station
2211+16 was partially submerged in flowing water and had debris piled against the pipe. In
addition, a stump and tree roots appeared to be exerting forces on the pipeline.
Respondent did not contest the allegation of violation and provided a statement that the company
has removed the vegetation and debris on the right-of-way, scheduled removal of the tree root,
and is evaluating control measures to keep future debris from accumulating over the pipeline.
Based upon a review of the evidence, I find that Respondent violated § 195.254(b) as alleged.
Item 4: The Notice alleged that Respondent violated § 195.412(a), which states:
§ 195.412 Inspection of rights-of-way and crossings under navigable
waters.
(a) Each operator shall, at intervals not exceeding 3 weeks, but at least
26 times each calendar year, inspect the surface conditions on or adjacent
to each pipeline right-of-way. Methods of inspection include walking,
driving, flying or other appropriate means of traversing the right-of-way.
The Notice alleged that Respondent violated § 195.412(a) by failing to inspect the surface
conditions on or adjacent to each pipeline right-of-way. Pipeline spans at certain stations and
other areas of the right-of-way through the housing development were covered by vegetation or
were otherwise obstructed from view by aerial patrols. EMPCo personnel indicated they did not
perform walking inspections of the pipeline at these locations.
Respondent did not contest the allegation of violation and provided a statement that the company
has removed the vegetation and debris for aerial patrols at the span stations and has modified its
inspection practices for the area in the housing development so that it will be inspected by foot
patrol. Based upon a review of the evidence, I find that Respondent violated § 195.412(a) as
alleged.
Item 5: The Notice alleged that Respondent violated § 195.581(a):
§ 195.581 Which pipelines must I protect against atmospheric
corrosion and what coating material may I use?
(a) You must clean and coat each pipeline or portion of pipeline that is
exposed to the atmosphere, except pipelines under paragraph (c) of this
section.
The Notice alleged that Respondent violated § 195.581(a) by failing to clean and coat a portion
of pipeline exposed to the atmosphere located at a span over a canal east of Laurel, Montana.



4
Respondent did not contest the allegation of violation and provided a statement that the company
has cleaned, primed, and painted the identified span crossing. Based upon a review of the
evidence, I find that Respondent violated § 195.581(a) as alleged.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to the violations cited above. Under 49
U.S.C. § 60118(a), each person who engages in the transportation of hazardous liquids by
pipeline or who owns or operates a pipeline facility is required to comply with the applicable
safety standards established under chapter 601.
The Director has indicated that a representative of PHMSA, OPS, conducted a follow-up field
inspection on May 10, 2011, to verify that Respondent has taken the following actions specified
in the proposed compliance order:
1. With respect to the violation of § 195.410(a)(1) (Item 1), Respondent has adequately
marked the pipeline.
2. With respect to the violation of § 195.410(a)(2) (Item 2), Respondent has included
current contact information on the pipeline markers.
3. With respect to the violation of § 195.254(b) (Item 3), Respondent has taken
measures to ensure that excessive forces are not exerted on the pipeline.
4. With respect to the violation of § 195.412(a) (Item 4), Respondent has taken
measures to ensure adequate patrols of the pipeline right-of-way.
5. With respect to the violation of § 195.581(a) (Item 5), Respondent has cleaned and
coated the pipeline span.
Accordingly, I find that compliance has been achieved with respect to these violations.
Therefore, the compliance terms proposed in the Notice are not included in this Order.
The terms and conditions of this Final Order are effective upon service in accordance with 49
C.F.R. § 190.5.
______________________________ ___________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/520115003>
- Source ID: `phmsa-enforcement`
- SHA-256: `f61c6aafb783a6c0238673a6ba62a68c47667caa01db0762f3fe71977ed87473`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-25T11:57:28.181Z
- Document slug: `phmsa-enforcement-520115003`

### Source metadata

```json
{
  "cpf": "520115003",
  "operator": "EXXONMOBIL PIPELINE CO",
  "region": "Western",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.254(b)",
    "195.410(a)(1)",
    "195.410(a)(2)",
    "195.412(a)",
    "195.581(a)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 5,
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```
