# EXXON PIPELINE COMPANY — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 120025004
- **title:** EXXON PIPELINE COMPANY — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2002-07-02
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.402(c)(3).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-120025004.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-120025004.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-120025004
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120025004
**body:**

Notice of Probable Violation involving EXXON PIPELINE COMPANY. PHMSA's enforcement data identifies the cited regulation as 195.402(c)(3). The case was opened on 2002-07-02 and is reported as closed as of 2003-09-16. Proposed civil penalty: $25,000. Assessed civil penalty: $25,000. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120025004.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120025004/120025004.pdf

120025004_Final_Order_07292003.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120025004/120025004_Final_Order_07292003.pdf

120025004_final_order_07292003_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120025004/120025004_final_order_07292003_text.pdf

120025004_final_order_07292003_text.pdf

U S Oepor Iinsnt
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AttinntslnNIon
RQO SRVenlh Sl 5 W
WRERPISEO D C 20SSO
~
JUL 29 2003
Mr Andrew K Turner
Vice President
Mobil Pipe Linc Company
Post Office Box 2220
Houston, Texas 77252-2220
RE CPF No 1-2002-5004
Dear Mr Turner,
~
Enclosed is thc Fmal Order issued by thc Associate Admnustrator for Pipehne Safety in the
above-referenced case It makes a findmg of violanon and assesses a civil penalty of $25, 000 The
penalty payment terms are set forth m the Final Order. Ths enforcement action closes automatically
upon payment Your receipt of the Fmal Order constitutes service of that document under 49 C F R
$1905
Smcerely,
Gwendolyn M. Hill
Pipchnc Comphance Registry
Office of Pipchne Safety
FnL loDLiic
LERIII II I) MAIL - REIURA RPCEIP1 RI IVI'PA'PPD



DEPARTMENT OF TRANSPORTATION
~
RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, DC 20590
ln thc Matter of
Mobil Pipe Line Company,
Respondent.
)
) CPF No 1-2002-5004
~
On July 26, 2001, a representative of the Office of Ptpclme Safety (OPS) conducted an mvestigation
of the January 24, 2001 acmdent mvolvmg Respondent's pipehnc m Lancaster, Pennsylvania As
a result of the investigation, the Director, Eastern Region, OPS, issued to ExxonMobil Pipehne
Company by lcttcr dated July 2, 2002, a Notice of Probablc Vtolauon and Proposed Civil Penalty
(Notice) In accordance with 49 C F R I] 190. 207, the Nohce proposed findtng that ExxonMobil
Pipehne Company had violated 49 C F R tt 195 402 snd proposed assessmg a civil penalty of
$25, 000 for thc alleged violation
Mobil Pipe Line Company responded to the Notice by letter dated August 12, 2002 (Response) In
its letter, Mobil Pipe Lmc Company acknowledged recmpt of the Notice and stated, 'The Lancaster
Junction Station is owned and operated by [Mobil Pipe Lme Company] [ExxonMobil Pipeline
Company] provides services lo [Mobd Pipe Lme Company] at the Lancaster Junction Station Afier
carefully rcvicwing the probable violations contained m thc Notice, we take no exception As a
follow-up to the incident, we have implemented retraining and counsehng to ensure adherence to
[ExxonMobil Pipchnc Company's "Job SafetyAnalyscs"] and work permitproccdures [Mobil Pipe
Lme Company] will pay the penalty by wire transfer
Mobil Pipe Lme Company has therefore tdennficd itself as the true Respondent in ttus case
Respondent did not request a hearing, consequently Respondent waived its nght to one
In its Response, Respondent did not contest the alleged violation m the Notice Accordingly I find
that Respondent violated the followmg section of 49 C. F R Part 195, as more fully descnbcd m the
Notice



49C F R $195402
(a) — faihng to follow, for its Lancaster Junction facthty, its manual of written procedures
for conducting normal operauons and miuntenancc activiues and handhng abnormal
operations and emergencies, before performing its hydrotcst operation on July 24,
2001 such as securing work permits, completing a Job safety analysis or notifying
Respondent's Operations Control Center because the work could impact surveillance
or control of the pipehne facihties, and
(c)- fat lmg to mclude, m its manual, procedures for operatmg, mamtammg, and rcpainng
the pi pehne system in accordance with each of the requircmcnts of Subparts F and H
of Part 195
This ftndmg of violation will be considered a pnor offense m any subsequent enforcement action
taken against Respondent
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 scncs of
violations
49 U S C $60122 and 49 C F R Ii190 225 require that, in dcterminmg the amount of the civil
penalty, I consider the following criteria nature, circumstances, and gravity of the violauon, degree
of Respondent's culpabihty, history of Respondent's pnor offenses, Respondent's abihty to pay the
penalty, good fiuth by Respondent in attemptmg to acluevc comph ance, the effect on Respondent's
abihty to continue m business, and such other matters as Justice may require
The Notice proposed a civil penalty of $25, 000 for the violation Accordmg to the Accident Rcport
Respondent filed on August 28, 2001, ExxonMobtl Pipchne Company employees performed a
hydrostatic test on Respondent's 2 5 mile 4" spur lmc running mto the Lancaster terminal on
July 24, 2001 The spur hnc had been decommissioned and was isolated from the main hnc at the
Junction to Lancaster Termmal the day before Unleaded gasolme was present in the mam hne, but
was not flowing lt was under approximately 600 pounds of pressure A bhnd flange was placed
on the 4" check valve in preparation for brtntpng the spur hne back into service Upon completion
of the hydrostatic test, a contractor's employee began looserung every other bolt from the bhnd
flange on the 4" check valve Afler the second bolt was loosened on the flange, a small amount of
product began to leak from the flange The matnhne, on wluch the 4" check valve was attached, was
still under pressure and the valves on both sides of the tee were open When the contractor's
employee learned that the lme was still pressured, hc re-tightened one of the bolts on the flange A
fcw moments later the flange gasket failed Unleaded gasolme and its vapors were released from
the flange and were iyutcd by the rumung diesel engme of a parked vehicle Approximately 702
barrels were released, most of which were consumed by fire



Respondent's mvestigation of the accident rcvealcd that the ExxonMobii Pipehne Company pro) ect
leader did not perform lob safety analyses or detiuled work procedures nor sought work permits
before conductmg the hydrotest The mvcstigation also revealed that the premature loosemng of
bolts to "save time" was a direct cause of thc acmdent Respondent did not ensure that the
ExxonMobi1 Pipebne Company employees providing services to Respondent followed Respondent's
manual of written procedures for conductmg normal operations and mamtenance acuvities and
handhng abnormal operations and emergenmes This is somewhat surprising considcnng the fact
that Respondent uses ExxonMobil Pipelme Company's "Safety Manual " The release date of the
manual was March 2001
Respondent's manual is detailed and specific regardinglob safety analyses and work permits The
oblecuve of the &ob safety analysis is "[t]o prevent acadcnts by identifying existing and potential
hazards and takmg actions to ehmmate them or significantly reduce them to an acceptable level
before a )ob bctpns " The work permit "ensures safe work practices are followed and pmvides
documentauon for work associated with Special Operahons, Hot Work, Confined Space, and Control
of Hazardous Energy" Hydrotestmg is cited as an example of "Special Operations" Respondent
is fortunate that the accident did noi have more serious consequcnccs Had Respondent ensured that
its manual was followed, thc acmdent could have bccn avoided
Respondent has not shown any circumstance that would )ustify reducing the civil penalty
Accordingly, havmg reviewed the reord and considered the assessment cntena, 1 assess respondent
a civd penalty of $25, 000 A detemunation has bccn made that Respondent has the abihty to pay
this penalty without adversely affecting its abihty to contmuc m business
Paymcn( of thc civil penalty must be made wttlun 20 days of service Federal regulations (49 C F R
8921(b)(3)) require this payment be made by wire transfer, through the Federal Reserve
Communicauons system (Fedwire), to the account of the U S Treasury Detailed instructions are
contamed m the enclosure Questions concernmg wire transfers should be directed to Financial
Operations Division (AMZ-120), Federal Aviation Admiiustration, Mike Monroney Aeronautical
Center, P 0 Box 25082, Oklahoma City, OK 73125, (405) 954-4719
Failure to pay the 525, 000 civil penalty will result m accrual of mterest a the current annual rate m
accordance with 31 U S C ii 3717, 31 C F R ti 901 9 snd 49 C F R (i 89 23 Pursuant to those same
authonues, a late penalty charge of six percent (6'lo) per annum will be charged if payment is noi
made within 110 days of service Furthermore, failure to pay the civil penalty may result m referral
of the matter to the Attorney General for appropnate action m a United States Distnct Court
Under 49 C F R (i 190 215, Respondent has a right to peution for reconsideration of this Fmal
Order However, if the civil penalty is paid, thc case closes autoinatically and Respondent waives
the nght to petition for reconsideration The fihng of thc petition automatically stays the payment



4I
of sny civil penalty assessed The pehtion must be received withm 20 days of Respondent's receipt i
ol' this Fmal Order and must contain a bnef statement of the issue(s) The terms and conditions of
this Fmal Order are effective on recept.
JUL 29 2003
Date Issued
Stscey Gerard
W Associate Adnumstrator
for Pipehne Safety
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