{"operation":"document","citation":"CPF 420185018W","title":"EXXONMOBIL PIPELINE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-10-04","effective_on":null,"summary":"CLOSED warning letter citing 195.402(a), 195.420(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420185018w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420185018w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420185018w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420185018W","body":"Warning Letter involving EXXONMOBIL PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.420(a). The case was opened on 2018-10-04 and is reported as closed as of 2018-10-04. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420185018W_Warning Letter_10042018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420185018W/420185018W_Warning%20Letter_10042018.pdf\n\n420185018W_Warning Letter_10042018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420185018W/420185018W_Warning%20Letter_10042018_text.pdf\n\n420185018W_Warning Letter_10042018_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 4, 2018\nGeoffrey Craft\nVice President, Operations\nExxonMobil Pipeline Company\n22777 Springwoods Village Parkway, E3.5A.385\nSpring, Texas 77389\nCPF 4-2018-5018W\nDear Mr. Craft:\nOn March 6, 2017 to July 14, 2017, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nyour ExxonMobil Pipeline Company (EMPCo) procedures and records at the EMPCo campus in\nThe Woodlands, TX, and pipeline facilities throughout Texas and Louisiana.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violation is:\n\n\n\n1. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall be\nreviewed at intervals not exceeding 15 months, but at least once each calendar year,\nand appropriate changes made as necessary to insure that the manual is effective.\nThis manual shall be prepared before initial operations of a pipeline system\ncommence, and appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\n§ 195.420 Valve Maintenance.\n(a) Each operator shall maintain each valve that is necessary for the safe operation of\nits pipeline systems in good working order at all times.\nEMPCo failed to follow their written maintenance procedure, PL731A DOT Mainline\nValve Inspection and Maintenance. The procedure states, “A full valve closure of 100% is\nrecommended, but is not required to meet DOT requirements, however the valve MUST\nbe operated a minimum of 15%” for motor operated and manual operated valves. EMPCo\ndid not partially operate each valve as required by their written procedure.\nDuring the valve maintenance records inspection of EMPCo facilities in the states of Texas,\nand Louisiana, EMPCo provided records documenting DOT/Mainline valve inspections.\nThe records showed the inspections for the years between 2014 and 2017, indicate they\nfailed to perform the partial operation of four valves during the valve inspections.\nValve Date of Inspection Percentage Operated\nVLV 17510-6093 July 28, 2015\nJanuary 28, 2016\n0%\n0%\nMOV-C917328-8579 March 31, 2017 0%\nESDV-17105-2338\nMarch 19, 2014\nSeptember 26, 2014\nMarch 13, 2015\nOctober 1, 2015\nMarch 4, 2016\nSeptember 2, 2016\n0%\n0%\n0%\n0%\n0%\n0%\nESDV-17109-2333\nMarch 19, 2014\nMarch 13, 2015\nOctober 2, 2015\nMarch 4, 2016\n0%\n0%\n0%\n0%\n2\n\n\n\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$209,002 per violation per day the violation persists, up to a maximum of $2,090,022 for a related\nseries of violations. For violations occurring prior to November 2, 2015, the maximum penalty\nmay not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000\nfor a related series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this letter.\nFailure to do so will result in EMPCo being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2018-5018W. 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 the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n3","truncated":false,"body_characters":4977}