# CHEVRON PIPE LINE CO — Warning Letter

**Citation:** CPF 520140005W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2014-11-12

CLOSED warning letter citing 192.605(a).

## Document text

Warning Letter involving CHEVRON PIPE LINE CO. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2014-11-12 and is reported as closed as of 2014-11-12. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520140005W_warning letter_11122014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520140005W/520140005W_warning%20letter_11122014.pdf

520140005W_warning letter_11122014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520140005W/520140005W_warning%20letter_11122014_text.pdf

520140005W_warning letter_11122014_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
November 12, 2014
Mr. Randy Curry
President
Chevron Pipe Line Co.
4800 Fournace Place Rm. C382A
Bellaire, TX 77401-2324
CPF 5-2014-0005W
Dear Mr. Curry:
On September 17-20, 2012, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your
Northern California Gas Lines in Pittsburg, California.
As a result of the inspection, it appears that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the
probable violation is:
1. §192.605(a) Procedural manual for operations, maintenance, and emergencies
Each operator shall include the following in its operating and maintenance plan:



(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed and
updated by the operator at intervals not exceeding 15 months, but at least one each
calendar year. This manual must be prepared before operations of a pipeline
system commence. Appropriate parts of the manual must be kept at locations
where operations and maintenance activities are conducted.
Chevron Pipe Line Company (Chevron) did not follow their procedure, Core Gas Pipeline
Operating and Maintenance 9.0 Maintenance Procedures Section 9.3.4.2, on calibrating gas
detection instruments. The procedure stated that Chevron personnel were to “calibrate each leak
detection instrument in accordance with the manufacturer's recommended calibration
instructions” and also “on a regular schedule, considering the type of instrument and how the
instrument is used.” The procedure also reminded personnel to “check hydrogen flame ionization
(HFI) systems and CGI instruments for calibration at least once each month while in use.”
Chevron was found to have insufficient documented evidence of periodic calibration of its gas
detection instruments. A single record of calibration for a DP4 instrument performed by Heath
Consultants on October 28, 2009 was found during the inspection. No calibration records, as
required by their leak survey procedures, were found from 2010 and 2011 to validate the 2010
and 2011 annual leak surveys, in which a gas detection instrument was used. Chevron must
follow its procedures in accordance with 192.605(a), and conduct and document periodic
calibration of its gas detection instruments.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000
per violation per day the violation persists up to a maximum of $2,000,000 for a related series of
violations. For violations occurring prior to January 4, 2012, the maximum penalty may not
exceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a
related series of violations. We have reviewed the circumstances and supporting documents
involved in this case, and have decided not to conduct additional enforcement action or penalty
assessment proceedings at this time. We advise you to correct the item identified in this letter.
Failure to do so will result in Chevron Pipe Line Co. being subject to additional enforcement
action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 5-2014-0005W. Be advised that all material you submit in response to this enforcement
action is subject to being made publicly available. If you believe that any portion of your
responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the
complete original document you must provide a second copy of the document with the portions
you believe qualify for confidential treatment redacted and an explanation of why you believe
the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).
2



Sincerely,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 C. Ishikawa (#138142)
3

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/520140005W>
- Source ID: `phmsa-enforcement`
- SHA-256: `2a10b6901544c182dd4959d378005f5a8b02a4f718b2f70dde79564229a3b4a0`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T01:41:59.053Z
- Document slug: `phmsa-enforcement-520140005w`

### Source metadata

```json
{
  "cpf": "520140005W",
  "operator": "CHEVRON PIPE LINE CO",
  "region": "Western",
  "pipelineType": "GAS INTRASTATE ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "192.605(a)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
    {
      "name": "520140005W_warning letter_11122014.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520140005W/520140005W_warning%20letter_11122014.pdf",
      "bytes": 52184,
      "category": "agency_document"
    },
    {
      "name": "520140005W_warning letter_11122014_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520140005W/520140005W_warning%20letter_11122014_text.pdf",
      "bytes": 9008,
      "category": "agency_document"
    }
  ],
  "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 PIPE LINE CO"
}
```
