# EXXONMOBIL PRODUCTION COMPANY, A DIVISION OF EXXON MOBIL CORPORATION — Warning Letter

- **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:** Not available
- **summary:** CLOSED warning letter citing 192.477, 192.745.
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- **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.

Official case documents:

220122001W_Operator response_03132012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220122001W/220122001W_Operator%20response_03132012.pdf

220122001W_warning letter_02092012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220122001W/220122001W_warning%20letter_02092012.pdf

220122001W_warning letter_02092012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220122001W/220122001W_warning%20letter_02092012_text.pdf

220122001W_warning letter_02092012_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
February 9, 2012
Mr. Kok-Yew See
U.S. Production Manager
ExxonMobil U.S. Production, a Division of ExxonMobil Corporation
P.O. Box 4358
Houston, Texas 77210-4358
CPF 2-2012-2001W
Dear Mr. See:
From November 7 to 10, 2011, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA) inspected the ExxonMobil US Production (XOM) records
and procedures in its Theodore, Alabama office and its offshore natural gas pipeline facilities
in the Mobile Bay and Gulf of Mexico, pursuant to Chapter 601 of 49 United States Code.
As a result of the inspection, it appears that XOM has committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and
the probable violations are:
1. §192.745 Valve maintenance: Transmission lines.
(a) Each transmission line valve that might be required during any emergency must
be inspected and partially operated at intervals not exceeding 15 months, but at least
once each calendar year.
(b) Each operator must take prompt remedial action to correct any valve found
inoperable, unless the operator designates an alternative valve.
XOM did not inspect and partially operate each transmission line valve that might be
required during any emergency at intervals not exceeding 15 months, but at least once
each calendar year. During the inspection, records dating back to 2008 were reviewed.
For Line MO-31-G, the “Hunt Line,” there were valve maintenance records up until
December 2008 and no records thereafter. XOM records indicated that the “Hunt line”
had been shut-in since 1999. However, the line has not been “abandoned” in accordance
with §192.727(g), which requires that operators file a report upon abandonment for each
abandoned offshore pipeline facility. Until the “Hunt Line” is abandoned, the
requirements of Part 192 still apply.



2. §192.477 Internal corrosion control: Monitoring.
If corrosive gas is being transported, coupons or other suitable means must be used
to determine the effectiveness of the steps taken to minimize internal corrosion.
Each coupon or other means of monitoring internal corrosion must be checked two
times each calendar year, but with interval not exceeding 7 1/2 months.
XOM did not check each coupon or other means of monitoring internal corrosion two
times each calendar year, but with interval not exceeding 7½ months. During the
inspection, records dating back to 2008 were reviewed. For Line MO-31-G, the “Hunt
Line,” there were no records indicating that XOM performed monitoring to determine the
effectiveness of the steps taken to minimize internal corrosion. XOM records show the
“Hunt line” as being shut-in since 1999. Until the “Hunt Line” is abandoned, the
requirements of Part 192 still apply.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
$100,000 for each violation for each day the violation persists up to a maximum of
$1,000,000 for any 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(s) identified in this letter. Failure to do so will result in XOM 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 2-2012-2001W. 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).
Sincerely,
Wayne T. Lemoi
Director, Office of Pipeline Safety
PHMSA Southern Region
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