# EXXONMOBIL PIPELINE CO — Notice of Amendment

- **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:** Not available
- **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.

Official case documents:

320025004M_Order Directing Amendment_12312002.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320025004M/320025004M_Order%20Directing%20Amendment_12312002.pdf

320025004M_Order Directing Amendment_12312002.pdf

J.S. Department
400 Seventh St.. S.W
of Transportation
Washington. D.C. 20590
Research and
Special Programs
Administration
DEC 3 1 2002
Mr. Andrew K. Turner
Vice President
ExxonMobil Pipeline Company
600 Bell Street
Houston, TX 77002
Re: CPF No. 3-2002-5004M
Dear Mr. Turner:
Enclosed is the Order Directing Amendment issued by the Associate Administrator for:
Pipeline Safety in the above-referenced case. It makes a finding of inadequate procedures and
requires that you amend your integrity management program procedures. When the terms of the
Order are completed, as determined by the Director, Central Region, OPS, this enforcement action
will be closed. Your receipt of the Order Directing Amendment constitutes service of that document
under 49 C.F.R. § 190.5.
Sincerely,
for Gwendolyn M. Hill
Pipeline Compliance Registry
Office of Pipeline Safety
Enclosure
CERTIFIED MAIL - RETURN RECEIPT REQUESTED



DEPARTMENT OF TRANSPORTATION
RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON. DC 20590
In the Matter of
ExxonMobil Pipeline Company,
Respondent.
CPF No. 3-2002-5004M
ORDER DIRECTING AMENDMENT
During,January l7-l8.and March |9-20,2002,representbtives of.the Central and Southern Regionsl r:., ,:.:.'. ;
Offrce,of Pipeline Safety (OPS), inspected ExxonMobil Piiieline Company's (Respondent) irtegriw. ., r;, r
' '
,,
management program.at Respondent's facility inHouston;'lTexas,,A$,a.result of the inspection,.,the,:r,:'.',,i,,'
Central.Regional.Director,oPS,issuedtoRespondent,:by.",letter.dated:April|6,2002,aNoticeof.'.
ArnendmentOIOA). TheNOAallegedinadequaciesinRespondenttsintegritymanagementprogram . i'1;, ;r'r
and proposed to require amendment of Respondent'srprocedures to'comply with the requirements ,:
of 49 C.F.R. $ l9s.4s2(b).
Respondent responded to the NOA by letter dated May 17,2002. Respondent did not contest the
allegations set forth in the NOA but requested a hearing to discuss the revisions Respondent planned
to make to address the cited inadequacies. An informal hearing by telephone was held on June 19,
2002. Respondent submitted further information on its segment identification procedures by letters
dated July 8 and July 31,2002.
FINDING
The NOA alleged that Respondent's segment identification procedures did not consider spill
migration via overland transports and transport by streams that run parallel to pipeline segments.
The NOA further alleged that the procedures did not provide adequate justification for using a buffer
zone applicable for crude and product spills to segments transporting highly volatile liquids (HVL).
In its May 17 response Respondent explained that it had identified the need for conducting overland
spill analyses and HVL modeling. Respondent further explained that it was going to incorporate a
topographic analysis of potential spill migration patterns, adjust the spill depth used in the model,
include parallel streams in the analysis and use HVL modeling to determine vapor dispersion
distances.



F
t
L
2
During the hearing, Respondent discussed in more detail the planned revisions to its segment
identification procedures. OPS requested clarification on Respondent's HVL vapor cloud dispersion
modeling and quality assurance process. In its July 8 letter, Respondent provided OPS with this
information.
In its July 3 I letter, Respondent submitted revised segment identification procedures for its integrity
management program. Respondent explained that the revised procedures include improvements to
address the inadequacies cited in the NOA as well as others Respondent identified. The Central
Region reviewed the revised procedures.
Respondent has made substantial progress in revising its procedures. However, the procedures need
to contain detailed information detailing who has responsibility for each step of the process, how
each step will be carried out and when each step is to be done. For example, in the revised paragraph
onparallel waterways, theprocedure doesnot indicatewho is responsible fordeterminingthe lengths
of pipe that have the potential to affect a high consequenc e area, when this should be done, and what
is to be done once determined. Similarly, the section on HVLs does not detail who is responsi,ble
for performing the calculations, how the modeling will be carried out, and what is to be done once
the af,fected areas are identified. : ,i.r :. , .,.i.. i; ,
:
,, ., ,, .
Accordingly, I find that Respondent's integrity management program.procedures are inadequate.to . ;,
, ensuresafe,operationof itspipelinesystem. P.ursuant'.to,49'U;S.G$ 60108(a) and49 C.F.R''i;:i.1-r '
9,190.2 7, Respondent,is ordered to make the following changes,to its integrity management,',',,'r:-,'
program procedures. Respondent must
l.
Amend the procedures for identifi ing segments that could affect a hi gh consequence area
to include a detailed process that assigns roles and responsibilities, defines inputs and
sources to be used, provides analytical steps personnel must follow to ensure a repeatable
logical process, and transforms inputs and assumptions into outputs. In the procedures,
Respondent must define the outputs so that they lead to conclusions or decisions. And
Respondent must integrate the results of the segment identification determination back
into the risk analysis process to better understand the consequences of a failure and the
relative importance of the segment for establishing integrity assessment priorities.
Submit the amended procedures to the Regional Director, Central Region, OPS within
30 days after receipt of this Order Directing Amendment.
3.
With the revised procedures, submit an implementation schedule for completing the
identification process based on the revisions.
4.
The Regional Director may extend the period for complying with the required items if
the Respondent requests an extension and justifies the reasons for the extension.
The terms and conditions of this Order Directing Amendment are effective upon receipt.



.f
r
3
Failure to comply with this Order may result in the assessment of civil penalties ofup to $25,000 per
violation per day, or in the referral of the case for judicial enforcement.
DEC 3 i ;LI#
Date Issued
#
Stacey Gerard
Associate Administrator
for Pipeline Safety
- **truncated:** false
- **body characters:** 6815