{"operation":"document","citation":"CPF 120085003W","title":"MOBIL  PIPE  LINE COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-08-13","effective_on":null,"summary":"CLOSED warning letter citing 195.567(a), 195.573(a)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120085003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120085003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120085003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120085003W","body":"Warning Letter involving MOBIL  PIPE  LINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.567(a),  195.573(a)(2). The case was opened on 2008-08-13 and is reported as closed as of 2008-08-13. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120085003W_Warning Letter_08132008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120085003W/120085003W_Warning%20Letter_08132008_text.pdf\n\n120085003W_Warning_Letter_08132008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120085003W/120085003W_Warning_Letter_08132008.pdf\n\n120085003W_Warning Letter_08132008_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 13, 2008\nMr. Jimmie James\nNorthern Operations Manager\nExxonMobil Pipeline Company\n3225 Gallows Hill Road\nFairfax, VA 22037\nCPF 1-2008-5003W\nDear Mr. James:\nDuring the week of April 8, 2008, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nyour pipeline system between Portland and Bangor, Maine.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n\n\n\n1. §195.567 Which pipelines must have test leads and what must I do to install and\nmaintain the leads?\n(a) General. Except for offshore pipelines, each buried or submerged pipeline or\nsegment of pipeline under cathodic protection required by this subpart must have\nelectrical test leads for external corrosion control. However, this requirement does\nnot apply until December 27, 2004 to pipelines or pipeline segments on which test\nleads were not required by regulations in effect before January 28, 2002.\nDuring the field review of the pipeline, ExxonMobil attached the voltmeter test lead to a flaw in\nthe coating of exposed piping to conduct pipe-to-soil tests to monitor the effectiveness of the\ncathodic protection. The pipeline is subject to the criteria in the regulation, necessitating the\nneed for test leads since December 27, 2004.\nThe inspector observed the lack of test leads during the field review at the mainline valve\nstations at Meadow Lane (MP 116.6), Winter Port (MP 110.9) and at Litchfield (MP 52.52).\n2. §195.573 What must I do to monitor external corrosion control?\n(a) Protected pipelines. You must do the following to determine whether cathodic\nprotection required by this subpart complies with Sec. 195.571:\n(2) Identify not more than 2 years after cathodic protection is installed, the\ncircumstances in which a close-interval survey or comparable technology is\npracticable and necessary to accomplish the objectives of paragraph 10.1.1.3 of\nNACE Standard RP 0169 (incorporated by reference, see §195.3).\n2\n\n\n\nNACE Standard RP 0169 paragraph 10.1.1.3 states:\nWhen practicable and determined necessary by sound engineering practice, a detailed\n(close interval) potential survey should be conducted to (a) assess the effectiveness of the\ncathodic protection system; (b) provide base line operating data; (c) locate areas of\ninadequate protection levels; (d) identify locations likely to be affected by construction,\nstray currents or other unusual environmental conditions; or (e) select areas to be\nmonitored periodically.\nExxonMobil could not identify the circumstances in which a close interval survey (CIS) or\ncomparable technology should be conducted on its entire pipeline system between Portland and\nBangor, Maine to meet the objectives of paragraph 10.1.1.3 of NACE Standard RP 0169.\nExxonMobil did perform one CIS during 2007 on a 15-mile segment of its 124-mile pipeline in\nthe Falmouth area where it ran parallel to a Northern Utilities pipeline. The Operator stated that\nno other CIS was planned for the line and that ExxonMobil was comfortable with the data\nprovided by ILI analysis of its pipeline as comparable technology to accomplish the objectives of\nthe NACE standard. While ILI data may be useful in determining flaws or damage on the\npipeline it does not serve to satisfy (a) through (e) above of the NACE standard.\nAs stated in the Discussion of Comments to Amendment 195-73 (FR/Vol.66, No.248/Thursday,\n12.27.01/page 66999):\nAlthough the final rule does not prescribe a frequency of close-interval surveys, operators\nwill have to describe in their maintenance procedures the circumstances in which a close-\ninterval survey or comparable technology is practicable and necessary to accomplish the\nobjectives of paragraph 10.1.1.3 of the NACE Standard, and then follow those procedures.\n3\n\n\n\nThe operator could present no procedures detailing the circumstances including needed\nfrequency in which CIS or comparable technology could be used to accomplish the objectives of\nthe paragraph 10.1.1.3 of NACE RP0169.\nExxonMobil needs a method to analyze the Portland Bangor Pipeline in accordance with the\nregulations to satisfy Section 10.1.1.3 of NACE Standard RP 0169.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violation persists up to a maximum of $1,000,000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the items identified in this letter.\nFailure to do so will result in ExxonMobil Pipeline Company being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2008-5003W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n4\n\n120085003W_Warning_Letter_08132008.pdf\n\nU.S. Department\nof Transportation\n409 3\" St. S.W. Suite 300\nPipeline and\nWashington, D.C. 20024\nHazardous Materials\nSafety Administration\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 13, 2008\nMr. Jimmie James\nNorthern Operations Manager\nExxonMobil Pipeline Company\n3225 Gallows Hill Road\nFairfax, VA 22037\nCPF 1-2008-5003W\nDear Mr. James:\nDuring the week of April 8, 2008, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nyour pipeline system between Portland and Bangor, Maine.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n\n\n\n1.\n§195.567 Which pipelines must have test leads and what must I do to install and\nmaintain the leads?\n(a) General. Except for offshore pipelines, each buried or submerged pipeline or\nsegment of pipeline under cathodic protection required by this subpart must have\nelectrical test leads for external corrosion control. However, this requirement does\nnot apply until December 27, 2004 to pipelines or pipeline segments on which test\nleads were not required by regulations in effect before January 28, 2002.\nDuring the field review of the pipeline, ExxonMobil attached the voltmeter test lead to a flaw in\nthe coating of exposed piping to conduct pipe-to-soil tests to monitor the effectiveness of the\ncathodic protection. The pipeline is subject to the criteria in the regulation, necessitating the\nneed for test leads since December 27, 2004.\nThe inspector observed the lack of test leads during the field review at the mainline valve\nstations at Meadow Lane (MP 116.6). Winter Port (MP 110.9) and at Litchfield (MP 52.52).\n$195.573 What must I do to monitor external corrosion control?\n(a) Protected pipelines. You must do the following to determine whether cathodic\nprotection required by this subpart complies with Sec. 195.571:\n(2) Identify not more than 2 years after cathodic protection is installed, the\ncircumstances in which a close-interval survey or comparable technology is\npracticable and necessary to accomplish the objectives of paragraph 10.1.1.3 of\nNACE Standard RP 0169 (incorporated by reference, see §195.3).\n2\n\n\n\nNACE Standard RP 0169 paragraph 10.1.1.3 states:\nWhen practicable and determined necessary by sound engineering practice, a detailed\n(close interval) potential survey should be conducted to (a) assess the effectiveness of the\ncathodie protection system; (b) provide base line operating data; (c) locate areas of\ninadequate protection levels; (d) identify locations likely to be affected by construction,\nstray currents or other unusual environmental conditions; or (e) select areas to be\nmonitored periodically.\nExxonMobil could not identify the circumstances in which a close interval survey (CIS) or\ncomparable technology should be conducted on its entire pipeline system between Portland and\nBangor, Maine to meet the objectives of paragraph 10.1.1.3 of NACE Standard RP 0169.\nExxonMobil did perform one CIS during 2007 on a 15-mile segment of its 124-mile pipeline in\nthe Falmouth area where it ran parallel to a Northern Utilities pipeline. The Operator stated that\nno other CIS was planned for the line and that ExxonMobil was comfortable with the data\nprovided by ILI analysis of its pipeline as comparable technology to accomplish the objectives of\nthe NACE standard. While ILI data may be useful in determining flaws or damage on the\npipeline it does not serve to satisfy (a) through (e) above of the NACE standard.\nAs stated in the Discussion of Comments to Amendment 195-73 (FR/Vol.66, No.248/Thursday,\n12.27.01/page 66999):\nAlthough the final rule does not prescribe a frequency of close-interval surveys, operators\nwill have to describe in their maintenance procedures the circumstances in which a close-\ninterval survey or comparable technology is practicable and necessary to accomplish the\nobjectives of paragraph 10.1.1.3 of the NACE Standard, and then follow those procedures.\n3\n\n\n\nU.S. Department\nof Transportation\n409 31° St. S.W. Suite 300\nPipeline and\nWashington, D.C. 20024\nHazardous Materials\nSafety Administration\nThe operator could present no procedures detailing the circumstances including needed\nfrequency in which CIS or comparable technology could be used to accomplish the objectives of\nthe paragraph 10.1.1.3 of NACE RP0169.\nExxonMobil needs a method to analyze the Portland Bangor Pipeline in accordance with the\nregulations to satisfy Section 10.1.1.3 of NACE Standard RP 0169.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violation persists up to a maximum of $1,000,000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the items identified in this letter.\nFailure to do so will result in ExxonMobil Pipeline Company being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2008-5003W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nBjusty\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n4","truncated":false,"body_characters":12437}