{"operation":"document","citation":"CPF 220122001W","title":"EXXONMOBIL PRODUCTION COMPANY, A DIVISION OF EXXON MOBIL CORPORATION — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-02-09","effective_on":null,"summary":"CLOSED warning letter citing 192.477, 192.745.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220122001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220122001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220122001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220122001W","body":"Warning Letter involving EXXONMOBIL PRODUCTION COMPANY, A DIVISION OF EXXON MOBIL CORPORATION. PHMSA's enforcement data identifies the cited regulations as 192.477,  192.745. The case was opened on 2012-02-09 and is reported as closed as of 2012-02-09. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220122001W_Operator response_03132012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220122001W/220122001W_Operator%20response_03132012.pdf\n\n220122001W_warning letter_02092012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220122001W/220122001W_warning%20letter_02092012.pdf\n\n220122001W_warning letter_02092012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220122001W/220122001W_warning%20letter_02092012_text.pdf\n\n220122001W_warning letter_02092012_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 9, 2012\nMr. Kok-Yew See\nU.S. Production Manager\nExxonMobil U.S. Production, a Division of ExxonMobil Corporation\nP.O. Box 4358\nHouston, Texas 77210-4358\nCPF 2-2012-2001W\nDear Mr. See:\nFrom November 7 to 10, 2011, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) inspected the ExxonMobil US Production (XOM) records\nand procedures in its Theodore, Alabama office and its offshore natural gas pipeline facilities\nin the Mobile Bay and Gulf of Mexico, pursuant to Chapter 601 of 49 United States Code.\nAs a result of the inspection, it appears that XOM has committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violations are:\n1. §192.745 Valve maintenance: Transmission lines.\n(a) Each transmission line valve that might be required during any emergency must\nbe inspected and partially operated at intervals not exceeding 15 months, but at least\nonce each calendar year.\n(b) Each operator must take prompt remedial action to correct any valve found\ninoperable, unless the operator designates an alternative valve.\nXOM did not inspect and partially operate each transmission line valve that might be\nrequired during any emergency at intervals not exceeding 15 months, but at least once\neach calendar year. During the inspection, records dating back to 2008 were reviewed.\nFor Line MO-31-G, the “Hunt Line,” there were valve maintenance records up until\nDecember 2008 and no records thereafter. XOM records indicated that the “Hunt line”\nhad been shut-in since 1999. However, the line has not been “abandoned” in accordance\nwith §192.727(g), which requires that operators file a report upon abandonment for each\nabandoned offshore pipeline facility. Until the “Hunt Line” is abandoned, the\nrequirements of Part 192 still apply.\n\n\n\n2. §192.477 Internal corrosion control: Monitoring.\nIf corrosive gas is being transported, coupons or other suitable means must be used\nto determine the effectiveness of the steps taken to minimize internal corrosion.\nEach coupon or other means of monitoring internal corrosion must be checked two\ntimes each calendar year, but with interval not exceeding 7 1/2 months.\nXOM did not check each coupon or other means of monitoring internal corrosion two\ntimes each calendar year, but with interval not exceeding 7½ months. During the\ninspection, records dating back to 2008 were reviewed. For Line MO-31-G, the “Hunt\nLine,” there were no records indicating that XOM performed monitoring to determine the\neffectiveness of the steps taken to minimize internal corrosion. XOM records show the\n“Hunt line” as being shut-in since 1999. Until the “Hunt Line” is abandoned, the\nrequirements of Part 192 still apply.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of\n$1,000,000 for any related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct\nthe item(s) identified in this letter. Failure to do so will result in XOM being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 2-2012-2001W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n2","truncated":false,"body_characters":4977}