CPF 320095024W
CPF 320095024W
320095024W_Warning Letter _11242009.pdf, page 1Official PDFU.S. Department of Transportation 901 Locust Street, Suite 462 Kansas City, MO 64106-2641 Pipeline and Hazardous Materials Safety Administratior WARNING LETTER CERTIFIED MAIL - RETURN RECEIPT REQUESTED November 24, 2009 Mr. Patrick T. Doolan, Vice President Southern Operations Manager ExxonMobil Pipeline Company 800 Bell Street PL-EMB-691H Houston, TX 77002 CPF 3-2009-5024W Dear Mr. Doolan: On November 21, 2008, and December 1-3, 2008, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your ExxonMobil Pipeline Company 30-inch diameter Mokena to Joliet refinery crude oil pipeline, the Lockport, IL refined products terminal and pipeline records, and the field facilities in Patoka and Lockport, Illinois. As a result of the inspection, it appears that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable violations are:. §195.404 Maps and Records. (a) ich de art teas hal following utormaman; and records of its pipeline systems (2) All crossings of public roads, railroads, rivers, buried utilities, and foreign pipelines. ExxonMobil Pipeline Company did not maintain current maps of its pipeline system. The 30-inch diameter crossing of the Alliance Pipeline east of the Joliet Refinery was not documented on maps at the last inspection in 2004. At that time, ExxonMobil indicated#
320095024W_Warning Letter _11242009.pdf, page 2that this crossing would be added to the map. During the 2008 inspection, the ExxonMobil maps were not updated or current as the crossing was only illustrated by a hand drawn redlined version of the Alliance crossing. §195.579 What must I do to mitigate internal corrosion? (c) Removing pipe. Whenever you remove pipe from a pipeline, you must inspect the internal surface of the pipe for evidence of corrosion. If you find internal corrosion requiring corrective action under Sec. 195.585, you must investigate circumferentially and longitudinally beyond the removed pipe (by visual examination, indirect method, or both) to determine whether additional corrosion requiring remedial action exists in the vicinity of the removed pipe. ExxonMobil Pipeline Company did not perform two internal inspections of their pipeline system. During the 2008 inspection, ExxonMobil Pipeline records did not have information or documentation to support that an internal inspection was performed on the 12-inch diameter Buckeye (Badger) Pipeline discharge valve in June 2008 and the 16- inch diameter scraper trap valve in the Lockport, IL Terminal in July 2008 when the valves were removed from the system. 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 items) identified in this letter. Failure to do so will result in ExxonMobil Pipeline Company 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 3-2009-5024W. 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, Uran U. Hint Ivan A. Huntoon Director, Central Region Pipeline and Hazardous Materials Safety Administration 2#
320095024W_Warning Letter_11242009_text.pdf, page 1Official PDFWARNING LETTER CERTIFIED MAIL - RETURN RECEIPT REQUESTED November 24, 2009 Mr. Patrick T. Doolan, Vice President Southern Operations Manager ExxonMobil Pipeline Company 800 Bell Street PL-EMB-691H Houston, TX 77002 CPF 3-2009-5024W Dear Mr. Doolan: On November 21, 2008, and December 1-3, 2008, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your ExxonMobil Pipeline Company 30-inch diameter Mokena to Joliet refinery crude oil pipeline, the Lockport, IL refined products terminal and pipeline records, and the field facilities in Patoka and Lockport, Illinois. As a result of the inspection, it appears that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable violations are: 1. §195.404 Maps and Records. (a) Each operator shall maintain current maps and records of its pipeline systems that include at least the following information; (2) All crossings of public roads, railroads, rivers, buried utilities, and foreign pipelines. ExxonMobil Pipeline Company did not maintain current maps of its pipeline system. The 30-inch diameter crossing of the Alliance Pipeline east of the Joliet Refinery was not documented on maps at the last inspection in 2004. At that time, ExxonMobil indicated#
320095024W_Warning Letter_11242009_text.pdf, page 2that this crossing would be added to the map. During the 2008 inspection, the ExxonMobil maps were not updated or current as the crossing was only illustrated by a hand drawn redlined version of the Alliance crossing. 2. §195.579 What must I do to mitigate internal corrosion? (c) Removing pipe. Whenever you remove pipe from a pipeline, you must inspect the internal surface of the pipe for evidence of corrosion. If you find internal corrosion requiring corrective action under Sec. 195.585, you must investigate circumferentially and longitudinally beyond the removed pipe (by visual examination, indirect method, or both) to determine whether additional corrosion requiring remedial action exists in the vicinity of the removed pipe. ExxonMobil Pipeline Company did not perform two internal inspections of their pipeline system. During the 2008 inspection, ExxonMobil Pipeline records did not have information or documentation to support that an internal inspection was performed on the 12-inch diameter Buckeye (Badger) Pipeline discharge valve in June 2008 and the 16- inch diameter scraper trap valve in the Lockport, IL Terminal in July 2008 when the valves were removed from the system. 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 ExxonMobil Pipeline Company 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 3-2009-5024W. 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, Ivan A. Huntoon Director, Central Region Pipeline and Hazardous Materials Safety Administration 2#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.