{"operation":"document","citation":"CPF 320195014W","title":"MOBIL  PIPE  LINE COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-03-15","effective_on":null,"summary":"CLOSED warning letter citing 195.452(f)(3), 195.452(g), 195.452(i)(4), 195.571.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320195014w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320195014w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320195014w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320195014W","body":"Warning Letter involving MOBIL  PIPE  LINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.452(f)(3),  195.452(g),  195.452(i)(4),  195.571. The case was opened on 2019-03-15 and is reported as closed as of 2019-03-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320195014W_Warning Letter_03152019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320195014W/320195014W_Warning%20Letter_03152019.pdf\n\n320195014W_Warning Letter_03152019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320195014W/320195014W_Warning%20Letter_03152019_text.pdf\n\n320195014W_Warning Letter_03152019_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 15, 2019\nMr. Gerald S. Frey\nPresident\nExxonMobil Pipeline Company\nP.O. Box 2220\nHouston, Texas 77252-2220\n3-2019-5014W\nDear Mr. Frey:\nOn July 31st through August 4th and November 27th through December 1st 2017, a\nrepresentative of the Pipeline and Hazardous Materials Safety Administration (PHMSA)\npursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected your Lockport Products\nTerminal, Mokena-Joliet Refinery 30”(MOJO) pipeline and Mustang pipeline in central\nIllinois.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items\ninspected and the probable violation(s) are:\n\n\n\n1. 195.452 Pipeline integrity management in high consequence areas.\n(a) . . . .\n(f) What are the elements of an integrity management program?\nAn integrity management program begins with the initial framework. An operator\nmust continually change the program to reflect operating experience, conclusions\ndrawn from results of the integrity assessments, and other maintenance and\nsurveillance data, and evaluation of consequences of a failure on the high\nconsequence area. An operator must include, at minimum, each of the following\nelements in its written integrity management program:\n(1) . . . .\n(3) An analysis that integrates all available information about the integrity of the\nentire pipeline and the consequences of a failure (see paragraph (g) of this section);\n§195.452(g) What is an information analysis? In periodically evaluating the integrity\nof each pipeline segment (paragraph (j) of this section), an operator must analyze all\navailable information about the integrity of the entire pipeline and the consequences\nof a failure. This information includes:\n(1) Information critical to determining the potential for, and preventing, damage\ndue to excavation, including current and planned damage prevention activities, and\ndevelopment or planned development along the pipeline segment;\n(2) Data gathered through the integrity assessment required under this section;\n(3) Data gathered in conjunction with other inspections, tests, surveillance and\npatrols required by this Part, including, corrosion control monitoring and cathodic\nprotection surveys; and\n(4) Information about how a failure would affect the high consequence area, such as\nlocation of the water intake.\nUnits 43163 and 64233:\nExxonMobil’s integrity management program (IMP) does not include an analysis that\nintegrates all available information about the integrity of pipeline facilities and the\nconsequences of a failure. ExxonMobil performed several facility integrity management\nactivities such as: Facility Risk Assessment (FRA) for critical control devices, a review of\noverfill protection systems, and API 570 inspections of select pipeline and storage facilities.\nHowever, ExxonMobil has not developed an information analysis for each facility or a\ncomprehensive facility integrity risk analysis to consistently identify and evaluate risks in\naccordance with 195.452(g).\n2. §195.571 What criteria must I use to determine the adequacy of cathodic\nprotection? Cathodic protection required by this Subpart must comply with one or\nmore of the applicable criteria and other considerations for cathodic protection\ncontained in paragraphs 6.2 and 6.3 of NACE SP 0169 (incorporated by reference,\nsee § 195.3).\n2\n\n\n\nUnit 87704:\nExxonMobil failed to comply with one or more of the applicable criteria and other\nconsiderations for cathodic protection contained in paragraphs 6.2 and 6.3 of NACE SP 0169.\nPermanent reference electrodes (both zinc & copper copper-sulfate types) have been installed\nbetween the double tank bottoms on breakout tanks 902, 904, 905, 907, 909 at Lockport\nterminal. Based on the cathodic protection survey data, the tank-to-soil potential readings\ntaken using the permanent reference electrodes installed between the tank bottoms is suspect.\nThere is no other method in place for testing the cathodic protection (CP) effectiveness on the\nprimary containment tank bottom.\n3. §195.571 What criteria must I use to determine the adequacy of cathodic\nprotection? Cathodic protection required by this Subpart must comply with one or\nmore of the applicable criteria and other considerations for cathodic protection\ncontained in paragraphs 6.2 and 6.3 of NACE SP 0169 (incorporated by reference,\nsee § 195.3).\nUnits 43163 and 64233:\nExxonMobil has not adequately considered IR drop in the determination of adequate cathodic\nprotection in accordance with NACE criteria. ExxonMobil uses “ON” pipe-to-soil-potential\nmeasurements to determine adequacy of cathodic protection which does not consider IR drop.\n4. §195.452 Pipeline integrity management in high consequence areas.\n(a) . . . .\n(i) What preventive and mitigative measures must an operator take to protect the\nhigh consequence area ?\n(1) . . . .\n(4) Emergency Flow Restricting Devices (EFRD ). If an operator determines that an\nEFRD is needed on a pipeline segment to protect a high consequence area in the\nevent of a hazardous liquid pipeline release, an operator must install the EFRD. In\nmaking this determination, an operator must, at least, consider the following factors\n- the swiftness of leak detection and pipeline shutdown capabilities, the type of\ncommodity carried, the rate of potential leakage, the volume that can be released,\ntopography or pipeline profile, the potential for ignition, proximity to power\nsources, location of nearest response personnel, specific terrain between the pipeline\nsegment and the high consequence area, and benefits expected by reducing the spill\nsize.\nUnits 64233:\n3\n\n\n\nExxonMobil performed a study of its 18” Mustang pipeline in 2014 that identified a potential\nEFRD location at MP 24.22. The type of EFRD considered was a remotely operated valve\n(ROV). Per ExxonMobil’s IM process, the potential EFRD candidate was submitted to their\nLRMT (Local Risk Management Team) for consideration. ExxonMobil used Form 6.2\n(Ver.2013) to document the data reviewed and the results of their EFRD evaluation for this site\n(EMPCo 2017 CRA EFRD Lockport to Patoka 001). The LMRT review determined that the\ninstallation of a ROV would not provide significant risk reduction and the descision was made\nnot to install the ROV. However, section 7 of form 6.2 for this site had several variables listed\nas N/A including Risk Reduction Score, Segment Risk Matrix, Threat Classification and\nConsequence. The Significant Change box was also left unchecked which indicates whether\nthe EFRD should be considered as a possible risk reduction strategy. In addition, comments\nwithin the form did not adequately document or describe the decision why not to install an\nEFRD device at MP 24.22.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to\nexceed $213,268 per violation per day the violation persists, up to a maximum of $2,132,679\nfor a related series of violations. For violation occurring on or after November 2, 2015 and\nbefore November 27, 2018, the maximum penalty may not exceed $209,002 per violation per\nday, with a maximum penalty not to exceed $2,090,022. For violations occurring prior to\nNovember 2, 2015, the maximum penalty may not exceed $200,000 per violation per day, with\na maximum penalty not to exceed $2,000,000 for a related series of violations. We have\nreviewed the circumstances and supporting documents involved in this case, and have decided\nnot to conduct additional enforcement action or penalty assessment proceedings at this time.\nWe advise you to correct the item(s) identified in this letter. Failure to do so will result in\nExxonMobil Pipeline Company being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto 3-2019-5014W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nAllan C. Beshore, P.E.\nDirector, Central Region\nPipeline and Hazardous Materials Safety Administration\n4","truncated":false,"body_characters":9273}