# CHEVRON PIPE LINE CO — Warning Letter

- **operation:** document
- **citation:** CPF 420205003W
- **title:** CHEVRON PIPE LINE CO — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2020-01-13
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.446(d)(3).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-420205003w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-420205003w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-420205003w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420205003W
**body:**

Warning Letter involving CHEVRON PIPE LINE CO. PHMSA's enforcement data identifies the cited regulation as 195.446(d)(3). The case was opened on 2020-01-13 and is reported as closed as of 2020-01-13. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420205003W_Warning Letter_01132020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205003W/420205003W_Warning%20Letter_01132020.pdf

420205003W_Warning Letter_01132020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205003W/420205003W_Warning%20Letter_01132020_text.pdf

420205003W_Warning Letter_01132020_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
January 13, 2020
Allen Satterwhite
President
Chevron Pipeline Company
1400 Smith Street
Houston, Texas 77002
CPF 4-2020-5003W
Dear Mr. Satterwhite:
From September 23, 2019 to September 26, 2019, representatives of the Pipeline and Hazardous
Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code
(U.S.C.) inspected your Control Center in Houston, Texas.
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 item inspected and
the probable violation is:
1. §195.446 Control room management.
(d) Fatigue mitigation. Each operator must implement the following methods to reduce
the risk associated with controller fatigue that could inhibit a controller's ability to carry
out the roles and responsibilities the operator has defined:
(3) Train controllers and supervisors to recognize the effects of fatigue.
Chevron failed to fully train their controllers to recognize the effects of fatigue in 2018.
Chevron provided PHMSA inspectors with its fatigue training records for 2017-2019. The
inspectors noted that four controllers had failed to complete one of their two required training
courses in 2018.



Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related
series of violations. For violation occurring on or after November 27, 2018 and before July 31,
2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum
penalty not to exceed $2,132,679. For violation occurring on or after November 2, 2015 and
before November 27, 2018, the maximum penalty may not exceed $209,002 per violation per day,
with a maximum penalty not to exceed $2,090,022. 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 identified in this letter. Failure to do so will result in Chevron Pipeline Co 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 4-2020-5003W. 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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