{"operation":"document","citation":"CPF 42021012NOA","title":"EXXONMOBIL PRODUCTION COMPANY, A DIVISION OF EXXON MOBIL CORPORATION — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-02-05","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(a), 195.402(e)(1), 195.573(a)(2), 195.58(a), 195.58(d).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021012noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021012noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021012noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42021012NOA","body":"Notice of Amendment involving EXXONMOBIL PRODUCTION COMPANY, A DIVISION OF EXXON MOBIL CORPORATION. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.402(e)(1),  195.573(a)(2),  195.58(a),  195.58(d). The case was opened on 2021-02-05 and is reported as closed as of 2021-03-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42021012NOA_Closure Letter_03192021_(20-172153).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021012NOA/42021012NOA_Closure%20Letter_03192021_(20-172153).pdf\n\n42021012NOA_Closure Letter_03192021_(20-172153)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021012NOA/42021012NOA_Closure%20Letter_03192021_(20-172153)_text.pdf\n\n42021012NOA_Notice of Amendment_02052021_(20-172153).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021012NOA/42021012NOA_Notice%20of%20Amendment_02052021_(20-172153).pdf\n\n42021012NOA_Notice of Amendment_02052021_(20-172153)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021012NOA/42021012NOA_Notice%20of%20Amendment_02052021_(20-172153)_text.pdf\n\n42021012NOA_Operator Response to Notice_03042021_(20-172153).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021012NOA/42021012NOA_Operator%20Response%20to%20Notice_03042021_(20-172153).pdf\n\n42021012NOA_Closure Letter_03192021_(20-172153)_text.pdf\n\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nMarch 19, 2021\nLiam Mallon\nPresident\nExxonMobil Upstream Oil & Gas Company\nExxonMobil Production Company, A Division of Exxon Mobil Corporation\n22777 Springwoods Village Parkway\nSpring, Texas 77389\nCPF 4-2021-012-NOA\nDear Mr. Mallon:\nFrom July 7, 2020 through September 25, 2020, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\nconducted a virtual pipeline safety inspection of ExxonMobil Production Company’s\n(ExxonMobil) procedures for its Santa Ynez Unit offshore facility located in Santa Barbara,\nCalifornia. As a result of the inspection, ExxonMobil was issued a Notice of Amendment on\nFebruary 5, 2021, which proposed an amendment of ExxonMobil’s procedures.\nExxonMobil submitted its amended procedures on March 5, 2021. PHMSA staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation in this matter.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\ncc: Kathleen D. Ash, General Manager, U.S. Conventional Upstream Oil and Gas Company\nkathleen.d.ash@exxonmobil.com\n\n42021012NOA_Notice of Amendment_02052021_(20-172153)_text.pdf\n\nNOTICE OF AMENDMENT\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nFebruary 5, 2021\nLiam Mallon\nPresident\nExxonMobil Upstream Oil & Gas Company\nExxonMobil Production Company, A Division of Exxon Mobil Corporation\n22777 Springwoods Village Parkway\nSpring, Texas 77389\nCPF 4-2021-012-NOA\nDear Mr. Mallon:\nFrom July 7, 2020 through September 25, 2020, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) inspected ExxonMobil Production Company’s (ExxonMobil) operations, maintenance,\nand integrity management records for its Santa Ynez Unit offshore facilities located in Santa\nBarbara, California.\nOn the basis of the inspection, PHMSA identified the apparent inadequacies found within\nExxonMobil’s plans or procedures as described below:\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\nmaintenance activities and handling abnormal operations and emergencies.…\n(e) Emergencies. The manual required by paragraph (a) of this section must\ninclude procedures for the following to provide safety when an emergency\ncondition occurs:\n(1) Receiving, identifying, and classifying notices of events which need immediate\nresponse by the operator or notice to fire, police, or other appropriate public\nofficials and communicating this information to appropriate operator\npersonnel for corrective action.\nExxonMobil's Operations, Maintenance, & Emergency Manual (OME Manual)\n12/20/2019 hazardous liquid pipelines, “Section 2.1.2 Emergency Operation” under\n“Section 2.1 Requirements for Abnormal and Emergency Operations Procedures” is\n\n\n\n2. 3. 2\ninadequate to assure safe operation of a pipeline. Specifically, Section 2.1 does not provide\nadequate guidance for receiving, identifying, and classifying notices of events, which need\nimmediate response by the operator or notice to fire, police, or other appropriate public\nofficials and communicating this information to appropriate operator personnel for\ncorrective action as required by § 195.402(e)(1).\nWhile ExxonMobil’s OME Manual references § 195.402(e)(1), it does not have written\nprocedures describing the process for how the operator will achieve the code\nrequirement. ExxonMobil must amend its procedures and manual to address this\ninadequacy.\n§ 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\nmaintenance activities and handling abnormal operations and emergencies.…\n§ 195.573 - What must I do to monitor external corrosion control?\n(a) Protected pipelines. You must do the following to determine whether cathodic\nprotection required by this subpart complies with §195.571:\n(1) …\n(2) Identify not more than 2 years after cathodic protection is installed, the\ncircumstances in which a close-interval survey or comparable technology is\npracticable and necessary to accomplish the objectives of paragraph 10.1.1.3\nof NACE SP 0169 (incorporated by reference, see § 195.3).\nExxonMobil’s OME Manual, “Section 3.4.2 Cathodic Protection Systems - Operation,\nSurveillance, and Maintenance” is inadequate as it is not in accordance with requirements\nin § 195.573(a)(2). The procedure does not include the requirement to identify, not more\nthan 2 years after cathodic protection is installed, the circumstances in which a close-\ninterval survey or comparable technology is practicable and necessary to accomplish the\nobjectives of paragraph 10.1.1.3 of NACE SP 0169.\nExxonMobil must amend its procedures to include provisions for determining the\ncircumstances in which a close interval survey is practicable and necessary as required in\n§ 195.573(a)(2).\n§ 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\nmaintenance activities and handling abnormal operations and emergencies.…\n\n\n\n3\n§ 195.58 - Report submission requirements.\n(a) General. Except as provided in paragraphs (b) and (e) of this section, an\noperator must submit each report required by this part electronically to\nPHMSA at http://opsweb.phmsa.dot.gov unless an alternative reporting\nmethod is authorized in accordance with paragraph (d) of this section.\n(b) …\n(d) Alternate Reporting Method. If electronic reporting imposes an undue burden\nand hardship, the operator may submit a written request for an alternative\nreporting method to the Information Resources Manager, Office of Pipeline\nSafety, Pipeline and Hazardous Materials Safety Administration, PHP-20,\n1200 New Jersey Avenue, SE., Washington DC 20590. The request must\ndescribe the undue burden and hardship. PHMSA will review the request and\nmay authorize, in writing, an alternative reporting method. An authorization\nwill state the period for which it is valid, which may be indefinite. An operator\nmust contact PHMSA at 202-366-8075, or electronically to\n“informationresourcesmanager@dot.gov” to make arrangements for\nsubmitting a report that is due after a request for alternative reporting is\nsubmitted but before an authorization or denial is received.\nExxonMobil’s OME Manual, “Section 2.3.6.3 Safety-Related Conditions” is inadequate\nbecause it does not provide guidance for submitting safety related condition (SRC) reports\nas required by § 195.58. ExxonMobil’s OME Manual does not describe where and how to\nsubmit an SRC report to PHMSA. Although the manual requires ExxonMobil personnel\nto complete a DOT Form 3: DOT Facility Event Record for each potential SRC, neither\nthe manual nor DOT Form 3 include at a minimum the portal website, or the alternate email\naddress or the mailing address, for submitting SRC reports to PHMSA.\nExxonMobil must amend its procedure to provide adequate guidance for submitting SRC\nreports in accordance with the requirement of § 195.58.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document, you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\n\n\n\n4\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 30 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that ExxonMobil Production Company maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Mary L. McDaniel, P.E.,\nDirector, Southwest Region, Pipeline and Hazardous Materials Safety Administration. In\ncorrespondence concerning this matter, please refer to CPF 4-2021-012-NOA, and for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":11434}