# MOBIL  PIPE  LINE COMPANY — Warning Letter

- **operation:** document
- **citation:** CPF 320095024W
- **title:** MOBIL  PIPE  LINE COMPANY — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2009-11-24
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.404(a)(2), 195.579(c).
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-320095024w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/320095024W
**body:**

Warning Letter involving MOBIL  PIPE  LINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.404(a)(2),  195.579(c). The case was opened on 2009-11-24 and is reported as closed as of 2009-11-24. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320095024W_Warning Letter _11242009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320095024W/320095024W_Warning%20Letter%20_11242009.pdf

320095024W_Warning Letter_11242009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320095024W/320095024W_Warning%20Letter_11242009_text.pdf

320095024W_Warning Letter _11242009.pdf

U.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



that 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

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:
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



that 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
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