CHEVRON PIPE LINE CO — Warning Letter

420085024w_warning_12192008_text.pdf, page 1Official PDFu. S. Deportment Ol Transportation Pipeline and Hazardous itrlaterlats Safety Administration it7ttt Souttr Geeeoer, Suite tttc Housioo, TX 77tt74 WARNING LETTER CERTIFIED MAIL - RETURN RECEIPT REQUESTED December 19, 2008 Mr. J. M. Balnum VP of HES, services & Standards Chevron Pipeline Company 4800 Fournace Place Bellaire, TX 77401-2324 CPF 4-2008-5024W Dear Mr. Balnum: During the week of May 19-23, 2008, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the Chevron Pipeline, West Texas LPG 4 unit. Records were reviewed in the Wortham, Texas office and then a field review was conducted. As a result of the inspection, it appears that you have committed a probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable violation(s) are: $195. 420 Valve maintenance. (a) Each operator shall maintain each valve that is necessary for the safe operation of its pipeline systems in good working order at all times. (b) Each operator shall, at intervals not exceeding 7 1/2 months, but at least twice each calendar year, inspect each mainline valve to determine that it is functioning properly. (c) Each operator shall provide protection for each valve from unauthorized operation and from vandalism. Per 195A20(b) vales must be inspected twice a year not to exceed 7 «/~ months. Records indicated that in 2006 several valve inspections exceeded the 7 l~ period. The 2007 records indicated this issue had been corrected internally. Conversation with your representative implies that your e-records system will not let this happen. This shows a review of the program should be done to prevent future re-occurences.#

420085024w_warning_12192008_text.pdf, page 2$1 95. 428 Overpressure safety devices and overfill protection systems (a) Except as provided in paragraph (b) of this section, each operator shall, at intervals not exceeding 15 months, but at least once each calendar year, or in the case of pipelines used to carry highly volatile liquids, at intervals not to exceed 7'h months, but at least twice each calendar year, inspect and test each pressure limiting device, relief valve, pressure regulator, or other item of pressure control equipment to determine that it is functioning properly, is in good mechanical condition, and is adequate from the standpoint of capacity and reliability of operation for the service in which it Is usecl. Per 195. 428(a) Overpressure safety devices, in the case of HVL's, at intervals not exceeding 7 % months, but at-least twice each calendar year be inspected and tested. Records indicated that 4 overpressure devices exceeded the 7 % month interval in 2006. Again, the 2007 records had corrected the issue. Under 49 United States Code, 560122, 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 identified in this letter. Failure to do so will result in Enterprise Products Operating LP 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 4-2008-5024W. 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). R, M. Seeley Director, Southwest Region Pipeline and Hazardous Materials Safety Administration#