# EXXONMOBIL PIPELINE CO — Warning Letter

- **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:** Not available
- **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.

Official case documents:

420185018W_Warning Letter_10042018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420185018W/420185018W_Warning%20Letter_10042018.pdf

420185018W_Warning Letter_10042018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420185018W/420185018W_Warning%20Letter_10042018_text.pdf

420185018W_Warning Letter_10042018_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
October 4, 2018
Geoffrey Craft
Vice President, Operations
ExxonMobil Pipeline Company
22777 Springwoods Village Parkway, E3.5A.385
Spring, Texas 77389
CPF 4-2018-5018W
Dear Mr. Craft:
On March 6, 2017 to July 14, 2017, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected
your ExxonMobil Pipeline Company (EMPCo) procedures and records at the EMPCo campus in
The Woodlands, TX, and pipeline facilities throughout Texas and Louisiana.
As a result of the inspection, it is alleged that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected
and the probable violation is:



1. § 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a
manual of written procedures for conducting normal operations and maintenance
activities and handling abnormal operations and emergencies. This manual shall be
reviewed at intervals not exceeding 15 months, but at least once each calendar year,
and appropriate changes made as necessary to insure that the manual is effective.
This manual shall be prepared before initial operations of a pipeline system
commence, and appropriate parts shall be kept at locations where operations and
maintenance activities are conducted.
§ 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.
EMPCo failed to follow their written maintenance procedure, PL731A DOT Mainline
Valve Inspection and Maintenance. The procedure states, “A full valve closure of 100% is
recommended, but is not required to meet DOT requirements, however the valve MUST
be operated a minimum of 15%” for motor operated and manual operated valves. EMPCo
did not partially operate each valve as required by their written procedure.
During the valve maintenance records inspection of EMPCo facilities in the states of Texas,
and Louisiana, EMPCo provided records documenting DOT/Mainline valve inspections.
The records showed the inspections for the years between 2014 and 2017, indicate they
failed to perform the partial operation of four valves during the valve inspections.
Valve Date of Inspection Percentage Operated
VLV 17510-6093 July 28, 2015
January 28, 2016
0%
0%
MOV-C917328-8579 March 31, 2017 0%
ESDV-17105-2338
March 19, 2014
September 26, 2014
March 13, 2015
October 1, 2015
March 4, 2016
September 2, 2016
0%
0%
0%
0%
0%
0%
ESDV-17109-2333
March 19, 2014
March 13, 2015
October 2, 2015
March 4, 2016
0%
0%
0%
0%
2



Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$209,002 per violation per day the violation persists, up to a maximum of $2,090,022 for a related
series of violations. For violations occurring prior to November 2, 2015, the maximum penalty
may not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000
for a 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 EMPCo 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 4-2018-5018W. 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,
Mary L. McDaniel, P.E.
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
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