# EXXONMOBIL PRODUCTION COMPANY, A DIVISION OF EXXON MOBIL CORPORATION — Warning Letter

- **operation:** document
- **citation:** CPF 420092001W
- **title:** EXXONMOBIL PRODUCTION COMPANY, A DIVISION OF EXXON MOBIL CORPORATION — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2009-01-26
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.465(a), 192.481(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-420092001w.json
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-420092001w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420092001W
**body:**

Warning Letter involving EXXONMOBIL PRODUCTION COMPANY, A DIVISION OF EXXON MOBIL CORPORATION. PHMSA's enforcement data identifies the cited regulations as 192.465(a),  192.481(a). The case was opened on 2009-01-26 and is reported as closed as of 2009-01-26. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420092001W_Warning_01262009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420092001W/420092001W_Warning_01262009.pdf

420092001W_Warning_01262009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420092001W/420092001W_Warning_01262009_text.pdf

420092001W_Warning_01262009_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
January 26, 2009
Mr. Randy Cleveland
US Production Manager
ExxonMobil US Production, a Division of Exxon Mobil Corporation
14950 Heathrow Forest Parkway, MI-3004B
Houston, TX 77032
CPF 4-2009-2001W
Dear Mr. Cleveland:
On November 4-6, 2007, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your Offshore
Gas pipeline system in Grand Isle, TX and the Gulf of Mexico.
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
violation(s) are:
1. §192.465 External corrosion control: Monitoring.
(a) Each pipeline that is under cathodic protection must be tested at least once each
calendar year, but with intervals not exceeding 15 months, to determine whether the
cathodic protection meets the requirements of §192.463.
At the time of the inspection, records indicated that the operator failed to test each pipeline that is
under cathodic protection within the required 15 month interval. As demonstrated in the operator’s
records of the Offshore Gas Unit, the annual pipe to soil survey from May 20, 2006 to October 11,
2007 exceeded the 15 month requirement.



2. §192.481 Atmospheric corrosion control: Monitoring.
(A) Each operator must inspect each pipeline or portion of pipeline that is exposed to
the atmosphere for evidence of atmospheric corrosion, as follows:
If the
pipeline is
located:
Then the frequency of inspection
is:
Onshore At least once every 3 calendar
years, but with intervals not
exceeding 39 months
Offshore At least once each calendar
year, but with intervals not
exceeding 15 months
At the time of the inspection, records indicated that the operator failed to conduct the required
inspections for atmospheric corrosion within the 15 month interval for the offshore portion of the Unit.
As indicated in the operator’s records of the Offshore Gas Unit, the Atmospheric Corrosion Surveys
from May 20, 2006 to October 11, 2007 exceeded the 15 month requirement.
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 US Production 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
4-2009-2001W. 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,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous
Materials Safety Administration
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