# EXXONMOBIL PIPELINE CO — Notice of Amendment

- **operation:** document
- **citation:** CPF 42021017NOA
- **title:** EXXONMOBIL PIPELINE CO — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2021-04-27
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 195.402(a), 195.402(c)(3), 195.54(b), 195.573(e).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-42021017noa.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-42021017noa.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-42021017noa
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/42021017NOA
**body:**

Notice of Amendment involving EXXONMOBIL PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.402(c)(3),  195.54(b),  195.573(e). The case was opened on 2021-04-27 and is reported as closed as of 2021-08-25. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

42021017NOA_Closure Letter_08252021_(20-172158).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021017NOA/42021017NOA_Closure%20Letter_08252021_(20-172158).pdf

42021017NOA_Closure Letter_08252021_(20-172158)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021017NOA/42021017NOA_Closure%20Letter_08252021_(20-172158)_text.pdf

42021017NOA_Notice of Amendment_04272021_(20-172158).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021017NOA/42021017NOA_Notice%20of%20Amendment_04272021_(20-172158).pdf

42021017NOA_Notice of Amendment_04272021_(20-172158)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021017NOA/42021017NOA_Notice%20of%20Amendment_04272021_(20-172158)_text.pdf

42021017NOA_Operator Response to Notice_07082021_(20-172158).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021017NOA/42021017NOA_Operator%20Response%20to%20Notice_07082021_(20-172158).pdf

42021017NOA_Closure Letter_08252021_(20-172158)_text.pdf

ELECTRONIC MAIL - RETURN RECEIPT REQUESTED
August 25, 2021
Steve Yatauro
President
ExxonMobil Pipeline Company
22777 Springwoods Village Parkway
Spring, Texas 77389
CPF 4-2021-017-NOA
Dear Mr. Yatauro:
From September 14, 2020 through October 30, 2020, a representative from the Pipeline and
Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United
States Code (U.S.C.), inspected the plans and procedures of ExxonMobil Pipeline Company
(ExxonMobil) for its hazardous liquid pipeline systems located in Texas, Louisiana, and the Gulf
of Mexico. As a result of the inspection, ExxonMobil was issued a Notice of Amendment (Notice)
on April 27, 2021, which proposed amendments to ExxonMobil’s procedures.
After being granted a time extension for its response deadline, ExxonMobil submitted its amended
and supplementary procedures on July 8, 2021. PHMSA staff reviewed these procedures, and it
appears that the inadequacies outlined in the 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
cc: Johnita D. Jones, Vice Presidence and Southern Operations Manager, ExxonMobil
Pipeline Company, johnita.d.jones@exxonmobil.com
Robert P. Spangenberg, Pipeline Safety Advisor, ExxonMobil Pipeline Company,
Robert.p.spangenberg@exxonmobil.com

42021017NOA_Notice of Amendment_04272021_(20-172158)_text.pdf

NOTICE OF AMENDMENT
ELECTRONIC MAIL - RETURN RECEIPT REQUESTED
April 27, 2021
Steve Yatauro
President
ExxonMobil Pipeline Company
22777 Springwoods Village Parkway
Spring, Texas 77389
CPF 4-2021-017-NOA
Dear Mr. Yatauro:
From September 14, 2020 through October 30, 2020, a representative of the Pipeline and
Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States
Code (U.S.C.) inspected the plans and procedures of ExxonMobil Pipeline Company
(ExxonMobil) for its hazardous liquid pipeline systems located in Texas, Louisiana, and the Gulf
of Mexico. The inspection was conducted virtually due to COVID-19 travel restrictions.
Based on the inspection, PHMSA identified the apparent inadequacies found within ExxonMobil’s
plans or procedures, as described below:
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.
§ 195.54 - Accident reports.
(a) …
(b) Whenever an operator receives any changes in the information reported or
additions to the original report on DOT Form 7000-1, it shall file a supplemental
report within 30 days.



2. 2
ExxonMobil’s written Operations and Maintenance manual titled, DOT Liquids Manual,
(Revision October 16, 2019) Section 195.54 Accident Reports, is inadequate because it
does not include the 30-day requirement to file a supplemental report after changes have
been identified as required by §195.54.
ExxonMobil must amend its written procedure to require that whenever an operator
receives any changes in the information reported to the original report on DOT Form 7000-
1, the operator shall file a supplemental report within 30 days.
§ 195.402 - Procedural manual for operations, maintenance, and emergencies.
(a) …
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during
maintenance and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in accordance with
each of the requirements of this subpart and subpart H of this part.
§ 195.573 - What must I do to monitor external corrosion control?
(a) …
(e) Corrective action. You must correct any identified deficiency in corrosion control
as required by § 195.401(b). However, if the deficiency involves a pipeline in an
integrity management program under § 195.452, you must correct the deficiency as
required by § 195.452(h).
ExxonMobil’s written procedure Facilities Inspection and Maintenance Management
System, Cathodic Protection Program (Revision 16.0 dated 9/29/2020) is inadequate
because it does not include guidance to correct identified deficiencies in its corrosion
control or provide a timeframe for making those corrections to its cathodic protection
system.
ExxonMobil must amend its written procedure to include detailed guidance on correcting
identified deficiencies in corrosion control as required by § 195.401(b). ExxonMobil must
also provide a timeframe for when it should correct all identified corrosion control
deficiencies to ensure the adequacy of corrosion control protection, including an
appropriate timeframe for repairing or replacing test lead stations and test lead wires when
they are found to be damaged.



3
Response 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 30 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 ExxonMobil 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 4-2021-017-NOA, 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
cc: Jeb Montgomery, Pipeline Safety Advisor, ExxonMobil Pipeline Company,
Jason.j.montgomery@exxonmobil.com
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