{"operation":"document","citation":"CPF 320025004M","title":"EXXONMOBIL PIPELINE CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2002-04-16","effective_on":null,"summary":"CLOSED notice of amendment citing 195.452(b)(6)(ii).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320025004m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320025004m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320025004m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320025004M","body":"Notice of Amendment involving EXXONMOBIL PIPELINE CO. PHMSA's enforcement data identifies the cited regulation as 195.452(b)(6)(ii). The case was opened on 2002-04-16 and is reported as closed as of 2004-08-24. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320025004M_Order Directing Amendment_12312002.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320025004M/320025004M_Order%20Directing%20Amendment_12312002.pdf\n\n320025004M_Order Directing Amendment_12312002.pdf\n\nJ.S. Department\n400 Seventh St.. S.W\nof Transportation\nWashington. D.C. 20590\nResearch and\nSpecial Programs\nAdministration\nDEC 3 1 2002\nMr. Andrew K. Turner\nVice President\nExxonMobil Pipeline Company\n600 Bell Street\nHouston, TX 77002\nRe: CPF No. 3-2002-5004M\nDear Mr. Turner:\nEnclosed is the Order Directing Amendment issued by the Associate Administrator for:\nPipeline Safety in the above-referenced case. It makes a finding of inadequate procedures and\nrequires that you amend your integrity management program procedures. When the terms of the\nOrder are completed, as determined by the Director, Central Region, OPS, this enforcement action\nwill be closed. Your receipt of the Order Directing Amendment constitutes service of that document\nunder 49 C.F.R. § 190.5.\nSincerely,\nfor Gwendolyn M. Hill\nPipeline Compliance Registry\nOffice of Pipeline Safety\nEnclosure\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\n\n\n\nDEPARTMENT OF TRANSPORTATION\nRESEARCH AND SPECIAL PROGRAMS ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON. DC 20590\nIn the Matter of\nExxonMobil Pipeline Company,\nRespondent.\nCPF No. 3-2002-5004M\nORDER DIRECTING AMENDMENT\nDuring,January l7-l8.and March |9-20,2002,representbtives of.the Central and Southern Regionsl r:., ,:.:.'. ;\nOffrce,of Pipeline Safety (OPS), inspected ExxonMobil Piiieline Company's (Respondent) irtegriw. ., r;, r\n' '\n,,\nmanagement program.at Respondent's facility inHouston;'lTexas,,A$,a.result of the inspection,.,the,:r,:'.',,i,,'\nCentral.Regional.Director,oPS,issuedtoRespondent,:by.\",letter.dated:April|6,2002,aNoticeof.'.\nArnendmentOIOA). TheNOAallegedinadequaciesinRespondenttsintegritymanagementprogram . i'1;, ;r'r\nand proposed to require amendment of Respondent'srprocedures to'comply with the requirements ,:\nof 49 C.F.R. $ l9s.4s2(b).\nRespondent responded to the NOA by letter dated May 17,2002. Respondent did not contest the\nallegations set forth in the NOA but requested a hearing to discuss the revisions Respondent planned\nto make to address the cited inadequacies. An informal hearing by telephone was held on June 19,\n2002. Respondent submitted further information on its segment identification procedures by letters\ndated July 8 and July 31,2002.\nFINDING\nThe NOA alleged that Respondent's segment identification procedures did not consider spill\nmigration via overland transports and transport by streams that run parallel to pipeline segments.\nThe NOA further alleged that the procedures did not provide adequate justification for using a buffer\nzone applicable for crude and product spills to segments transporting highly volatile liquids (HVL).\nIn its May 17 response Respondent explained that it had identified the need for conducting overland\nspill analyses and HVL modeling. Respondent further explained that it was going to incorporate a\ntopographic analysis of potential spill migration patterns, adjust the spill depth used in the model,\ninclude parallel streams in the analysis and use HVL modeling to determine vapor dispersion\ndistances.\n\n\n\nF\nt\nL\n2\nDuring the hearing, Respondent discussed in more detail the planned revisions to its segment\nidentification procedures. OPS requested clarification on Respondent's HVL vapor cloud dispersion\nmodeling and quality assurance process. In its July 8 letter, Respondent provided OPS with this\ninformation.\nIn its July 3 I letter, Respondent submitted revised segment identification procedures for its integrity\nmanagement program. Respondent explained that the revised procedures include improvements to\naddress the inadequacies cited in the NOA as well as others Respondent identified. The Central\nRegion reviewed the revised procedures.\nRespondent has made substantial progress in revising its procedures. However, the procedures need\nto contain detailed information detailing who has responsibility for each step of the process, how\neach step will be carried out and when each step is to be done. For example, in the revised paragraph\nonparallel waterways, theprocedure doesnot indicatewho is responsible fordeterminingthe lengths\nof pipe that have the potential to affect a high consequenc e area, when this should be done, and what\nis to be done once determined. Similarly, the section on HVLs does not detail who is responsi,ble\nfor performing the calculations, how the modeling will be carried out, and what is to be done once\nthe af,fected areas are identified. : ,i.r :. , .,.i.. i; ,\n:\n,, ., ,, .\nAccordingly, I find that Respondent's integrity management program.procedures are inadequate.to . ;,\n, ensuresafe,operationof itspipelinesystem. P.ursuant'.to,49'U;S.G$ 60108(a) and49 C.F.R''i;:i.1-r '\n9,190.2 7, Respondent,is ordered to make the following changes,to its integrity management,',',,'r:-,'\nprogram procedures. Respondent must\nl.\nAmend the procedures for identifi ing segments that could affect a hi gh consequence area\nto include a detailed process that assigns roles and responsibilities, defines inputs and\nsources to be used, provides analytical steps personnel must follow to ensure a repeatable\nlogical process, and transforms inputs and assumptions into outputs. In the procedures,\nRespondent must define the outputs so that they lead to conclusions or decisions. And\nRespondent must integrate the results of the segment identification determination back\ninto the risk analysis process to better understand the consequences of a failure and the\nrelative importance of the segment for establishing integrity assessment priorities.\nSubmit the amended procedures to the Regional Director, Central Region, OPS within\n30 days after receipt of this Order Directing Amendment.\n3.\nWith the revised procedures, submit an implementation schedule for completing the\nidentification process based on the revisions.\n4.\nThe Regional Director may extend the period for complying with the required items if\nthe Respondent requests an extension and justifies the reasons for the extension.\nThe terms and conditions of this Order Directing Amendment are effective upon receipt.\n\n\n\n.f\nr\n3\nFailure to comply with this Order may result in the assessment of civil penalties ofup to $25,000 per\nviolation per day, or in the referral of the case for judicial enforcement.\nDEC 3 i ;LI#\nDate Issued\n#\nStacey Gerard\nAssociate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":6815}