CHEVRON PIPE LINE CO — Notice of Amendment

party submissionOfficial PDF420205004M_Operator Response to Notice_02062020.pdf#

420205004M_Notice of Amendment_01142020_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED January 14, 2020 Allen Satterwhite President Chevron Pipeline Company 1400 Smith Street Houston, Texas 77002 CPF 4-2020-5004M 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 inspected Chevron Pipeline Company’s (Chevron) procedures for Control Room Management in Houston, Texas. On the basis of the inspection, PHMSA has identified the apparent inadequacies found within Chevron’s plans or procedures, as described below: 1. §195.446 Control room management. (b) Roles and responsibilities. Each operator must define the roles and responsibilities of a controller during normal, abnormal, and emergency operating conditions. To provide for a controller's prompt and appropriate response to operating conditions, an operator must define each of the following: (4) A method of recording controller shift-changes and any hand-over of responsibility between controllers.#

420205004M_Notice of Amendment_01142020_text.pdf, page 2Chevron’s procedures fail to properly define the roles and responsibilities of a controller during abnormal and emergency operating conditions. At the time of the inspection, Chevron provided PHMSA inspectors with their procedure titled CRM - 101 Roles and Responsibilities. Section 4.7 (page 3) states: 4.7 In the event a Console becomes unattended for any reason (on duty Controller is unable to perform his or her duties; unfit for duty; because of illness, fatigue, car trouble or other issues) the following procedure shall be initiated: 4.7.3 Until an off-duty Controller arrives, the Console Supervisor can select a Controller from the current on duty Controllers whose workload allows him or her to monitor the unattended console and their regular AOR. 4.7.4 If controlling actions are required to maintain the console in a “Safe and Controlled” state of operations, the Controller who is monitoring the unattended console can take direction from a qualified Controller for that console via telephone. This procedure makes selection of a controller to monitor the console optional, giving the Console Supervisor the option to leave the pipeline running in an unmonitored state. Chevron’s above procedure must be revised to make this selection mandatory, or specify another method to ensure the pipeline is kept in a “Safe and Controlled” state. 2. §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: (4) Establish a maximum limit on controller hours-of-service, which may provide for an emergency deviation from the maximum limit if necessary for the safe operation of a pipeline facility. Chevron’s procedures fail to establish an appropriate maximum limit on controller hours-of- service. Chevron provided PHMSA inspectors with their procedure titled CRM - 109 Fatigue Risk Management System. Section 6.10.4 (page 12) states: 6.10.4 The maximum number of hours worked in any seven (7) day period shall be 84, and shall be followed by at least 35 hours of off-duty time. Chevron regularly schedules their controllers for 84 hours in a seven-day period, with up to 30 minutes allowed for shift handover. The combination of the shift handover and the schedule shift controllers result in regular exceeding the 84-hour limit. Chevron’s procedure must be revised to establish an appropriate maximum number of hours worked, or the controllers’ schedule must be changed to work within the existing procedure. 2#

420205004M_Notice of Amendment_01142020_text.pdf, page 3Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings. Please refer to this document and note the response options. 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). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 60 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that Chevron Pipeline Company maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Mary L. McDaniel, Director, Southwest Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 4-2020-5004M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Mary L. McDaniel, P.E. Director, Southwest Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings 3#

420205004M_Closure Letter_03052020_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED March 5, 2020 Allen Satterwhite President Chevron Pipeline Company 1400 Smith Street Houston, Texas 77002 CPF 4-2020-5004M Dear Mr. Satterwhite: From September 23, 2019 to September 26, 2019, representatives from the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, conducted an on-site pipeline safety inspection of Chevron Pipeline Company’s (Chevron) procedures in Houston, Texas. As a result of the inspection, Chevron was issued a Notice of Amendment on January 15, 2020, which proposed amendment of your procedures. Chevron submitted its amended procedures on February 6, 2020. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Mary L. McDaniel P.E. Director, Southwest Region Pipeline and Hazardous Materials Safety Administration#