{"operation":"document","citation":"CPF 32021026NOA","title":"EXXONMOBIL PIPELINE CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-04-08","effective_on":null,"summary":"CLOSED notice of amendment citing 195.446(a), 195.446(b)(5), 195.446(c)(2), 195.446(c)(3), 195.446(c)(5), 195.446(d)(4), 195.446(e)(2), 195.446(e)(4), 195.446(e)(5).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021026noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021026noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021026noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32021026NOA","body":"Notice of Amendment involving EXXONMOBIL PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 195.446(a),  195.446(b)(5),  195.446(c)(2),  195.446(c)(3),  195.446(c)(5),  195.446(d)(4),  195.446(e)(2),  195.446(e)(4),  195.446(e)(5). The case was opened on 2021-04-08 and is reported as closed as of 2021-12-23. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32021026NOA_Closure Letter_12232021_(20-187008).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021026NOA/32021026NOA_Closure%20Letter_12232021_(20-187008).pdf\n\n32021026NOA_Closure Letter_12232021_(20-187008)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021026NOA/32021026NOA_Closure%20Letter_12232021_(20-187008)_text.pdf\n\n32021026NOA_Notice of Amendment_04082021_(20-187008).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021026NOA/32021026NOA_Notice%20of%20Amendment_04082021_(20-187008).pdf\n\n32021026NOA_Notice of Amendment_04082021_(20-187008)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021026NOA/32021026NOA_Notice%20of%20Amendment_04082021_(20-187008)_text.pdf\n\n32021026NOA_Operator Hearing Request Withdrawn_12082021_(20-187008).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021026NOA/32021026NOA_Operator%20Hearing%20Request%20Withdrawn_12082021_(20-187008).pdf\n\n32021026NOA_Operator Pre-Hearing Submission_10252021_(20-187008).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021026NOA/32021026NOA_Operator%20Pre-Hearing%20Submission_10252021_(20-187008).pdf\n\n32021026NOA_Operator Response to Notice and Request for Hearing and Statement of Issues_07162021_(20-187008).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021026NOA/32021026NOA_Operator%20Response%20to%20Notice%20and%20Request%20for%20Hearing%20and%20Statement%20of%20Issues_07162021_(20-187008).pdf\n\n32021026NOA_PHC Hearing Rescheduled_10282021_(20-187008).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021026NOA/32021026NOA_PHC%20Hearing%20Rescheduled_10282021_(20-187008).pdf\n\n32021026NOA_PHC Hearing Rescheduled_10282021_(20-187008)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021026NOA/32021026NOA_PHC%20Hearing%20Rescheduled_10282021_(20-187008)_text.pdf\n\n32021026NOA_PHC Hearing Scheduled_07292021_(20-187008).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021026NOA/32021026NOA_PHC%20Hearing%20Scheduled_07292021_(20-187008).pdf\n\n32021026NOA_PHC Hearing Scheduled_07292021_(20-187008)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021026NOA/32021026NOA_PHC%20Hearing%20Scheduled_07292021_(20-187008)_text.pdf\n\n32021026NOA_PHC Hearing Scheduled_07292021_(20-187008)_text.pdf\n\nJuly 29, 2021\nVIA ELECTRONIC MAIL TO: rebekah.r.bennett@exxonmobil.com and\ngregory.ochs@dot.gov\nMs. Rebekah R. Bennett, Esq.\nGeneral Counsel\nExxonMobil Pipeline Company\n22777 Springwoods Village Parkway\nSpring, TX 77389\nMr. Gregory Ochs\nDirector, Central Region\nPipeline and Hazardous Materials Safety Administration\n901 Locust Street, Suite 480\nKansas City, MO 64106-2641\nRe: Notice of Hearing, ExxonMobil Pipeline Company\nCPF No. 3-2021-026-NOA\nDear Ms. Bennett and Mr. Ochs:\nIn accordance with 49 C.F.R. § 190.211, an informal hearing will be held regarding the Notice of\nAmendment issued by the Pipeline and Hazardous Materials Safety Administration in the above-\nreferenced case. The hearing will take place on November 2, 2021, beginning at 8:30 a.m. Central\nTime.\nThe hearing will be held via videoconference. I will provide the videoconference information prior\nto the hearing. At least 10 calendar days prior to the hearing (or by October 25, 2021), both parties\nmust submit and exchange any additional written materials they intend to present at the hearing and\nthe name and email address of each attendee. This information should be provided electronically.\nMaterials not submitted by this date may be excluded.\nIf you have any questions, please do not hesitate to contact me.\nSincerely,\nLarry White\nPresiding Official\ncc: Mr. Steven Yatauro, President, ExxonMobil Pipeline Company,\nsteven.a.yatauro@exxonmobil.com\nMr. Joseph Hainline, Counsel, Central Region, Office of Pipeline Safety,\njoseph.hainline@dot.gov\n\n32021026NOA_Closure Letter_12232021_(20-187008)_text.pdf\n\nVIA ELECTRONIC MAIL TO: Christina.s.philbrook@exxonmobil.com\nDecember 23, 2021\nSteven Yatauro\nPresident of Exxon Mobil Pipeline Company\nExxon Mobile\n22777 Springwoods Village PKWY\nSpring, TX 77389\nsteven.a.yatauro@exxonmobil.com, diana.r.skates@exxonmobil.com\nCPF 3-2021-026-NOA\nDear Mr. Yatauro:\nFrom July 27 through August 24, 2020, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of Exxon Mobil’s procedures in Springs, Texas.\nAs a result of the inspection, Exxon Mobil was issued a Notice of Amendment on April 8, 2021,\nwhich proposed amendment of your procedures.\nExxon Mobil submitted its amended procedures on December 21, 2021. My staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n\n32021026NOA_PHC Hearing Rescheduled_10282021_(20-187008)_text.pdf\n\nDate: October 28, 2021\nFrom: Larry White\nTo: File\nRe: Continuance of Hearing, ExxonMobil Pipeline Company\nCPF No. 3-2021-026-NOA\nBy electronic mail dated October 28, 2021, Daniel Brink, Counsel for ExxonMobil Pipeline\nCompany, and Joseph Hainline, Counsel for OPS Central Region, submitted a joint request for a\ncontinuance of the hearing previously scheduled for November 2, 2021. The request explained that\nExxonMobil needed additional time to amend its procedures and submit them for approval by the\nRegional Director which would make a hearing unnecessary.\nI granted the request for a continuance until December 10, 2021 which will be the new hearing date\nif for any reason the amendment of procedures is not completed by that time.\n\n32021026NOA_Notice of Amendment_04082021_(20-187008)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: darren.w.woods@exxonmobil.com Christina.s.philbrook@exxonmobil.com\nApril 8, 2021\nDarren W. Woods\nChairman and CEO\nExxon Mobile\n22777 Springwoods Village PKWY\nSpring, TX 77389\nCPF 3-2021-026-NOA\nDear Mr. Woods:\nFrom July 27 through August 24, 2020, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Exxon Mobil’s\n(Exxon) procedures for Control Room Operations in Spring, Texas.\nThis Notice is in response to PHMSA’s Control Room Management (CRM) Initiative, which is a national\nlevel program that includes inspectors from every region. As a result, you may have received this Notice\nfrom a different Regional Director than typical because the CRM Initiative inspections are currently\nseparate from the standard inspection program. Notices and correspondence from other types of\ninspections will remain unchanged.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within Exxon’s\nplans or procedures, as described below:\n1. § 195.446 Control room management.\n(a) General. This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline facility\nthrough a SCADA system. Each operator must have and follow written control room\nmanagement procedures that implement the requirements of this section. The procedures\nrequired by this section must be integrated, as appropriate, with the operator's written\nprocedures required by § 195.402. An operator must develop the procedures no later than\nAugust 1, 2011, and must implement the procedures according to the following schedule.\nThe procedures required by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this\nsection must be implemented no later than October 1, 2011. The procedures required by\nparagraphs (c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no later than\nAugust 1, 2012. The training procedures required by paragraph (h) must be implemented\nno later than August 1, 2012, except that any training required by another paragraph of\nthis section must be implemented no later than the deadline for that paragraph.\n\n\n\nExxon’s Control Room Management (CRM) plan, dated January 24, 2020, was inadequate because it did\nnot provide a process to determine if a facility is a control room. Exxon personnel stated that they review\nall facilities on an annual basis to determine if a facility is a control room by applying a matrix of\nquestions to each facility. Exxon completes this exercise each year, but does not have the process\ndeveloped in its CRM plan.\nExxon must amend its procedure to include a written process for how its personnel are to identify\nfacilities as control rooms.\n2. § 195.446 Control room management\n(a) . . . .\n(b) Roles and responsibilities. Each operator must define the roles and responsibilities of a\ncontroller during normal, abnormal, and emergency operating conditions. To provide for a\ncontroller’s prompt and appropriate response to operating conditions, and operator must\ndefine each of the following.\n(1) . . . .\n(5) The roles, responsibilities and qualifications of others who have the authority to direct\nor supersede the specific technical actions of controllers.\nExxon’s CRM Plan, dated January 24, 2020, was inadequate because it did not contain any statements\nrelated to either allowing or disallowing others to have authority to direct or superseded the specific\ntechnical actions of a controller. Exxon’s CRM plan includes statements in several sections of its plan\nthat controllers have the authority to shut down the pipeline. While this is an important aspect under\nRoles and Responsibilities of a controller, more is needed to have a procedure that is adequate to assure\nthe safe operation of Exxon’s pipelines that are operated by controllers\nThe procedure must be amended to clearly identify all the roles, responsibilities and qualifications of\nothers who have the authority to direct or supersede the specific technical actions of controllers. If Exxon\ndoes not allow others to have such authority, Exxon must amend its procedure to so state.\n3. § 195.446 Control room management\n(a) . . . .\n(c) Provide adequate information. Each operator must provide its controllers with the\ninformation, tools, processes and procedures necessary for the controllers to carry out the\nroles and responsibilities the operator has defined by performing each of the following:\n(1) . . . .\n(2) Conduct a point-to-point verification between SCADA displays and related field\nequipment when field equipment is added or moved and when other changes that affect\npipeline safety are made to field equipment or SCADA displays;\nExxon’s point-to-point (P2P) procedures inadequate to support a thorough evaluation of the point being\nmonitored and controlled from the control room. The procedure is vague in its description and guidance\non performing a thorough and accurate P2P verification test. Missing from the procedure was a\nrequirement to record the field value/status found, and the corresponding control room SCADA/HMI\nvalue/status, alarm limit set point and verification of alarming, alarm information (priority, color,\nmessage, correct audio etc.), and point presentation on all screens verified. Additional information related\nto the tag name, field device name, RTU/PLC address, general location identification as well as any other\nmapping information for the point to provide its location and that the correct point has been verified. It is\n2\n\n\n\nnot merely the endpoint value read correctly, but every aspect of that point was verified to be an accurate\nrepresentation with proper messaging to the controller. The procedure does not provide enough detail to\nverify mapping of the point through the SCADA system, alarm set points as well as point and alarm\nattributes. This lack of process can render inconsistent verification and incomplete records.\nExxon Mobil recently installed a new SCADA system and are designing a new tool for recording P2P\nverification. The new template for P2P was reviewed, but the template and procedure still not adequate to\nmeet the requirements of this section.\nExxon must amend its procedures to provide guidance and direction to support a thorough and consistent\nP2P verification between SCADA displays and related field equipment when field equipment is added or\nmoved and when other changes that affect pipeline safety are made to field equipment or SCADA\ndisplays.\n4. § 195.446 Control room management\n(a) . . . .\n(c) Provide adequate information. Each operator must provide its controllers with the\ninformation, tools, processes and procedures necessary for the controllers to carry out the\nroles and responsibilities the operator has defined by performing each of the following:\n(1) . . . .\n(3) Test and verify an internal communication plan to provide adequate means for manual\noperation of the pipeline safely, at least once each calendar year, but at intervals not to\nexceed 15 months;\nExxon’s Control Room Management (CRM) Plan, dated January 24, 2020, was inadequate because it did\nnot provide enough detail in the internal communication plan for the safe manual operation of the\npipeline. There were two conditions identified in the CRM Plan; a single point of failure, and a HUB\nProcedure. The single point failure indicates that the field or interconnects should monitor and call hourly\nto the controller, but it does not support how the controller is to document this information and\nincorporate it into the overall operation of the pipeline.\nThe HUB procedure enlists a field controls personnel to go to the communications hub point and test the\npoint with a SCADA technician. They never engage the controller except to notify them of the test. In a\nreal case scenario, if this option is employed, the controller has no procedure or guidance on what to do,\nhow to direct the actions of field personnel at the Hub, how to document the information being relayed\nbetween the control room and field, or how to incorporate that information to operate the system. While\nExxon tests the HUB procedure frequently, it has never been tested with a controller.\nExxon must amend its procedure to provide enough detail in the internal communication plan for the safe\nmanual operation of the pipeline to provide adequate means for the safe manual operation of the pipeline.\nThe procedure must include guidance for the controller to consistently document information, from the\nfield, related to the single point failure process. The procedure must also be amended to include the\ncontrol room in the HUB Test Procedure. Information should be relayed to the control room and the field\ntechnician should take direction from the controller. The procedure needs to support how this manual\ninformation requested and received, from the field to the controller, will be either incorporated as\nsupplemental information to SCADA information or as a stand-alone process of operating the system in\nfull manual mode (if required). The procedure also needs to include defining the official record when this\noccurs and where it will be maintained.\n3\n\n\n\n5. § 195.446 Control room Management\n(a) . . . .\n(c) Provide adequate information. Each operator must provide its controllers with the\ninformation, tools, processes and procedures necessary for the controllers to carry out the\nroles and responsibilities the operator has defined by performing each of the following:\n(1) . . . .\n(5) Implement section 5 of API RP 1168 (incorporated by reference, see § 195.3) to establish\nprocedures for when a different controller assumes responsibility, including the content of\ninformation to be exchanged.\nExxon's CRM plan, dated January 24, 2020, was inadequate because it did not require the outgoing and\noncoming controllers to sign the 12-hour Shift Log at the end of the shift turnover meeting. The\nprocedure states that \"the outgoing Controller is expected to have the oncoming Controller sign the 12-\nhour Shift Log documenting that it has been reviewed\". There is no date or time or acknowledgement by\nthe outgoing controller when the shift change occurred. Exxon Mobil indicated that when the oncoming\ncontroller signs in to SCADA, this is the official time and date stamp; however, the procedure does not\nstate this.\nAlso, the procedure does not adequately describe what Exxon considers the official documentation for\nshift change. The official shift change documentation, in practice, is called a \"packet\" that consists of\nthree separate documents: The Operations Control Center Controller Check List, EMPCo Controller 12\nHour Shift Log, and the upcoming Oil Plan. These three documents are all paper. Documents are\ngathered, stapled and maintained for records. The individual documents do not have administrative\ncontrols where, if separated, they could be matched back together. To be more specific, there is no\nconsistency of date, shift, console or controller, to align the documents together. This was evident during\nthe inspection because Exxon had to separate the documents and scan them to prepare for the\ninspection. When they were trying to provide the packet, it was difficult to discern, by all, they had the\nright record for that packet.\nA comparison review of the procedure shift change requirements to the requirements of API 1168 Section\n5 (incorporated by reference at § 195.446(c)(5)), it is difficult to verify that any of the items defined in\nAPI 1168 5.3.1 - 5.3.7 are incorporated into the shift turnover discussion. The checklist encompasses\nsome of the items, but these seem to be more of a checklist for the oncoming controller to orient\nthemselves to the console operations rather than a discussion check list.\nExxon must amend its procedure to adequately describe what must happen and be documented when a\ndifferent controller assumes responsibility, including the content of information to be exchanged. The\nprocedure should include at a minimum, the documents required for the complete turn over, expectations\nfor completion of all documents, consistent document formatting to assemble the packet and what the\nofficial time and date stamp is for when the shift turnover occurs; including the console and personnel\ninvolved in the exchange. It should also include clarification regarding the checklist, these are items (API\n1168 5.3.1 - 5.3.7) that are to be discussed and were discussed between controllers at the time of shift\nturnover.\n6. § 195.446 Control room management.\n(a) . . . .\n(d) Fatigue mitigation. Each operator must implement the following methods to reduce the\nrisk associated with controller fatigue that could inhibit a controller's ability to carry out\nthe roles and responsibilities the operator has defined:\n(1) . . . .\n4\n\n\n\n(4) Establish a maximum limit on controller hours-of-service, which may provide for an\nemergency deviation from the maximum limit if necessary for the safe operation of a\npipeline facility.\nExxon’s Control Room Management (CRM) Plan, dated January 24, 2020, was inadequate because it did\nnot provide information related to shift schedules and Hours of Service (HOS) for controllers who work\nunder 8-hour shifts. In a review of shift schedules, it was identified that there were HOS deviations for\ncontrollers who normally work 8 hour shifts. These individuals serve in roles that do not fill a regular\nconsole shift position. However, they are qualified and fill in periodically to cover shifts. During this\nreview, controller’s shift coverage hours of service violated working more than 5 shifts in a row, in some\ncases 7 shifts in a row, without the required time off. However, in these cases, they did not exceed the\nmaximum total hours worked (65 hours) because of the combination of 8-hour and 12-hour shifts. The\nHOS deviations are set up for 12-hour shifts and do not take in to account controllers working 8-hour\nshifts and 12-hours shifts. The procedure does not take into consideration maximum HOS in a rolling 7-\nday period, which can support monitoring HOS for multiple shifts workers as well as 12-hour shift\nworkers.\nExxon must amend its procedure(s) to include information related to the 8-hour shifts worked by qualified\ncontrollers in the control room, and provide HOS guidelines the encompass both 8-hour shifts and 12-hour\nshifts, especially since some controllers work both.\n7. § 195.446 Control room management\n(e) Alarm management. Each operator using a SCADA system must have a written alarm\nmanagement plan to provide for effective controller response to alarms. An operator’s plan\nmust include provisions to:\n(1)…\n(2) Identify at least once each calendar month points affecting safety that have been taken\noff scan in the SCADA host, have had alarms inhibited, generated false alarms, or that have\nhad forced or manual values for periods of exceeding that required for associated\nmaintenance or operating activities.\nExxon’s Control Room Management (CRM) plan, dated January 24, 2020, was inadequate because it did\nnot address the monthly identification, recording, review, and analysis of points that have been taken off\nscan, have had alarms inhibited, generated false alarms, or that have had forced or manual values for periods\nof time exceeding that required for associated maintenance or operating activities. While section 4.8.1 of\nthe CRM plan describes how to manage a point being taken off-scan, out of service or disabled, section\n4.8.4 addresses False Alarms, sections 4.8.2 and 4.9.1.5 address Inhibited Points, and Table 4 Alarm Metric\nReporting addresses Inhibited Alarms and Off-Scan (sic Point/Alarm) Review, the procedure lacks process\ndetail. There is no mention in the procedure about how Exxon manages or monitors forced or manual\nvalues in SCADA, which includes the monthly review.\nExxon’s CRM plan fails to provide specific guidance to address the requirements of this monthly\nrequirement. The procedure lacks how process for how to gather information, what is to be considered in\nthe review, who will perform the review, what information will be reported out from the review, and any\naction steps based on the findings of the review.\nThe procedure must be amended to include the requirements related to points affecting safety that have\nbeen taken off scan in the SCADA host, have had alarms inhibited, generated false alarms, or that have\nhad forced or manual values for periods of exceeding that required for associated maintenance or\noperating activities.\n5\n\n\n\n8. § 195.446 Control room management\n(a) . . . .\n(e) Alarm management. Each operator using a SCADA system must have a written alarm\nmanagement plan to provide for effective controller response to alarms. An operator’s plan\nmust include provisions to:\n(1) . . . .\n(4) Review the alarm management plan required by this paragraph at least once each\ncalendar year, but at intervals not exceeding 15 months, to determine the effectiveness of\nthe plan;\nExxon’s Control Room Management (CRM) Plan, dated January 24, 2020, was inadequate because it did\nnot state what criteria will be used for determination of effectiveness. Exxon explained that it reviews the\nyear end results of the Alarm Performance Metrics, and modifies the metrics for the following year.\nHowever, this process is not described in the procedure. The procedure discusses reviewing the alarm\nsystem, but does not explain what such a review should include. Deficiencies identified will be assigned\ncorrective action plans which are to be reviewed and documented. The documentation was a line item in\nthe Controls Catalogue, which also was not represented in the procedure.\nThe procedure must be amended to include the criteria and process for the review that would provide a\ndetermination of the alarm management plan’s effectiveness.\n9. § 195.446 Control room management\n(a) . . . .\n(e) Alarm management. Each operator using a SCADA system must have a written alarm\nmanagement plan to provide for effective controller response to alarms. An operator’s plan\nmust include provisions to:\n(1) . . . .\n(5) Monitor the content and volume of general activity being directed to and required of\neach controller at least once each calendar year, but at intervals not exceeding 15 months,\nthat will assure controllers have sufficient time to analyze and react to incoming alarms;\nExxon’s Control Room Management Plan, dated January 24, 2020, was inadequate because it did not\nhave criteria identified on how Exxon will determine that a controller has sufficient time to analyze and\nreact to incoming alarms. The procedure identifies various items that are considered, and data that is\ncollected and aggregated for the review. These items relate to the quantity of activity, such as number of\ntelephone calls or number of alarms per hour. However, there is no conversion of the quantity to time, or\na benchmark on what quantity is acceptable or too high for a controller to manage. The expectation is to\ndetermine if a controller has adequate time to be able to identify, verify and respond to alarms. Since\nExxon did not have a stated standard, there was no bench mark to verify compliance.\nExxon Mobil must amend the procedure to provide criteria and metrics that support the study results as to\nwhether controllers have sufficient time to analyze and react to incoming alarms. The procedure also\nneeds to provide recommendations to remedy deficiencies found in the analysis.\n6\n\n\n\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as part of\nthis Notice is a document entitled Response Options for Pipeline Operators in Enforcement\nProceedings. Please refer to this document and note the response options. Be advised that all material\nyou submit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C.\n552(b), along with the complete original document you must provide a second copy of the document with\nthe portions you believe qualify for confidential treatment redacted and an explanation of why you\nbelieve the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or\na request for a hearing under § 190.211. If you do not respond within 30 days of receipt of this Notice,\nthis constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate\nAdministrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and\nto issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R.\n§ 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures\nto my office within 30 days of receipt of this Notice. This period may be extended by written request for\ngood cause. Once the inadequacies identified herein have been addressed in your amended procedures,\nthis enforcement action will be closed.\nIt is requested (not mandated) that Exxon Mobil maintain documentation of the safety improvement costs\nassociated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and\nsubmit the total to Gregory A. Ochs, Director, Central Region, Pipeline and Hazardous Materials Safety\nAdministration. In correspondence concerning this matter, please refer to CPF 3-2021-026-NOA and, for\neach document you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\ncc: Christina Philbrook, Regulatory Compliance Supervisor Christina.s.philbrook@exxonmobil.com\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n7","truncated":false,"body_characters":28466}