{"operation":"document","citation":"CPF 42021028NOA","title":"MOBIL  PIPE  LINE COMPANY — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-05-03","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(a), 195.402(c)(5), 195.402(c)(6), 195.452(i)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021028noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021028noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021028noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42021028NOA","body":"Notice of Amendment involving MOBIL  PIPE  LINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.402(c)(5),  195.402(c)(6),  195.452(i)(4). The case was opened on 2021-05-03 and is reported as closed as of 2021-10-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42021028NOA_Closure Letter_10152021_(20-172335).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021028NOA/42021028NOA_Closure%20Letter_10152021_(20-172335).pdf\n\n42021028NOA_Closure Letter_10152021_(20-172335)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021028NOA/42021028NOA_Closure%20Letter_10152021_(20-172335)_text.pdf\n\n42021028NOA_Notice of Amendment_05032021_(20-172335).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021028NOA/42021028NOA_Notice%20of%20Amendment_05032021_(20-172335).pdf\n\n42021028NOA_Notice of Amendment_05032021_(20-172335)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021028NOA/42021028NOA_Notice%20of%20Amendment_05032021_(20-172335)_text.pdf\n\n42021028NOA_Operator Response to Notice and Request Time Extension_07152021_(20-172335).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021028NOA/42021028NOA_Operator%20Response%20to%20Notice%20and%20Request%20Time%20Extension_07152021_(20-172335).pdf\n\n42021028NOA_Closure Letter_10152021_(20-172335)_text.pdf\n\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nOctober 15, 2021\nSteve Yatauro\nPresident & Chief Executive Officer\nExxonMobil Pipeline Company\n22777 Springwoods Village Parkway\nSpring, Texas 77389\nCPF 4-2021-028-NOA\nDear Mr. Yatauro:\nFrom June 15, 2020 through October 30, 2020, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.),\ninspected the DOT Liquids Manual and the Integrity Management Manual for ExxonMobil’s Central\nInspection System, operating under Mobil Pipeline Company, ExxonMobil Pipeline Company, and\nMustang Pipeline LLC (collectively, ExxonMobil Pipeline Company) located in and around Lockport,\nIllinois. As a result of the inspection, PHMSA issued a Notice of Amendment to ExxonMobil Pipeline\nCompany on May 3, 2021, which required amendments to its procedures.\nExxonMobil submitted its amended and supplementary procedures on July 15, 2021, and August\n31, 2021. PHMSA staff has reviewed these procedures, and it appears that the inadequacies\noutlined in the Notice of Amendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\ncc: Johnita D. Jones, Vice President and Southern Operations Manager, ExxonMobil\nPipeline Company, johnita.d.jones@exxonmobil.com\nRobert P. Spangenberg, Pipeline Safety Advisor, ExxonMobil Pipeline Company,\nRobert.p.spangenberg@exxonmobil.com\n\n42021028NOA_Notice of Amendment_05032021_(20-172335)_text.pdf\n\nNOTICE OF AMENDMENT\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nMay 3, 2021\nSteve Yatauro\nPresident & Chief Executive Officer\nExxonMobil Pipeline Company\n22777 Springwoods Village Parkway\nSpring, Texas 77389\nCPF 4-2021-028-NOA\nDear Mr. Yatauro:\nFrom June 15, 2020 through October 30, 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 the DOT Liquids Manual and the Integrity Management Manual for\nExxonMobil’s Central Inspection System, operating under Mobil Pipeline Company, ExxonMobil\nPipeline Company, and Mustang Pipeline LLC (collectively, ExxonMobil Pipeline Company)\nlocated in and around Lockport, Illinois.\nBased on the inspection, PHMSA has identified the apparent inadequacies found within\nExxonMobil Pipeline’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 manual\nof written procedures for conducting normal operations and maintenance activities\nand handling abnormal operations and emergencies. This manual shall be reviewed\nat intervals not exceeding 15 months, but at least once each calendar year, and\nappropriate changes made as necessary to insure that the manual is effective. This\nmanual shall be prepared before initial operations of a pipeline system commence,\nand appropriate parts shall be kept at locations where operations and maintenance\nactivities are conducted.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during\nmaintenance and normal operations:\n\n\n\n2\n(1) …\n(5) Analyzing pipeline accidents to determine their causes.\n(6) Minimizing the potential for hazards identified under paragraph (c)(4) of this\nsection and the possibility of recurrence of accidents analyzed under paragraph\n(c)(5) of this section.\nExxonMobil Pipeline's written DOT Liquids Manual, Section 5. Analyzing Pipeline Accidents\n– 195.402(c)(5) (Issued October 2002, Reviewed October 16, 2019) is inadequate to assure safe\noperation of its pipeline facilities because it does not include a process for analyzing pipeline\naccidents to determine their causes as required by § 195.402(c)(5). PHMSA reviewed Section\n5. Analyzing Pipeline Accidents – 195.402(c)(5) and found the procedure does not include\ndetailed analysis techniques or methods to analyze pipeline accidents to determine the root\ncause of an accident and does not include measures to prevent recurrence of an accident.\nExxonMobil Pipeline must amend Section 5 of its DOT Liquids Manual to include a process for\nanalyzing pipeline accidents to determine their causes, along with the timeframe for when the\nroot cause analysis will be conducted. Additionally, the procedures must be revised to include\nthe identification of which measures should be implemented to prevent a recurrence and the\ntimeframe for the completion of those identified measures.\n2. § 195. 452 Pipeline integrity management in high consequence areas.\n(a)…\n(i) What preventive and mitigative measures must an operator take to protect the\nhigh consequence area?\n(1) …\n(4) Emergency Flow Restricting Devices (EFRD). If an operator determines that an\nEFRD is needed on a pipeline segment to protect a high consequence area in the\nevent of a hazardous liquid pipeline release, an operator must install the EFRD. In\nmaking this determination, an operator must, at least, consider the following\nfactors—the swiftness of leak detection and pipeline shutdown capabilities, the\ntype of commodity carried, the rate of potential leakage, the volume that can be\nreleased, topography or pipeline profile, the potential for ignition, proximity to\npower sources, location of nearest response personnel, specific terrain between the\npipeline segment and the high consequence area, and benefits expected by reducing\nthe spill size.\nExxonMobil Pipeline’s Integrity Management Program Manual, Section 6.1 EFRD Evaluation\n(Dated April 2020, Version 2020.1) is inadequate to assure safe operation of its pipeline\nfacilities because it fails to set forth a process for documenting the determination for installation\nof and justification for not installing emergency flow restricting devices (EFRD). PHMSA\nreviewed Section 6.1 and found the procedure for determining whether to install an EFRD does\nnot include guidance for documenting the company’s decision-making process and does not\nprovide justification of what is considered significant.\n\n\n\n3\nExxonMobil Pipeline must amend its Integrity Management Program Manual, Section 6.1\nEFRD Evaluation, to include detailed guidance regarding documenting the determination for\ninstallation of and the justification for not installing EFRDs, as well as include guidance for what\nis considered significant in the making that determination.\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\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 Pipeline maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Mary L. McDaniel, Director, Southwest Region, Pipeline\nand Hazardous Materials Safety Administration. In correspondence concerning this matter, please\nrefer to CPF 4-2021-028-NOA and, for each document you submit, please provide a copy in\nelectronic format whenever possible.\nSincerely,\nMary L. McDaniel, PE\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosures: Response Options for Pipeline Operators in Enforcement Proceedings","truncated":false,"body_characters":10535}