{"operation":"document","citation":"CPF 42025029NOPV","title":"EXXONMOBIL PRODUCTION COMPANY, A DIVISION OF EXXON MOBIL CORPORATION — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-05-08","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.583(a), 195.583(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025029nopv.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025029nopv.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025029nopv","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42025029NOPV","body":"Notice of Probable Violation involving EXXONMOBIL PRODUCTION COMPANY, A DIVISION OF EXXON MOBIL CORPORATION. PHMSA's enforcement data identifies the cited regulations as 195.583(a),  195.583(b). The case was opened on 2025-05-08 and is reported as closed as of 2025-07-23. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42025029NOPV_Closure Letter_07232025_(24-296566).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025029NOPV/42025029NOPV_Closure%20Letter_07232025_(24-296566).pdf\n\n42025029NOPV_Closure Letter_07232025_(24-296566)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025029NOPV/42025029NOPV_Closure%20Letter_07232025_(24-296566)_text.pdf\n\n42025029NOPV_Final Order_07082025_(24-296566).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025029NOPV/42025029NOPV_Final%20Order_07082025_(24-296566).pdf\n\n42025029NOPV_Final Order_07082025_(24-296566)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025029NOPV/42025029NOPV_Final%20Order_07082025_(24-296566)_text.pdf\n\n42025029NOPV_Operator Response to Notice_05282025_(24-296566).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025029NOPV/42025029NOPV_Operator%20Response%20to%20Notice_05282025_(24-296566).pdf\n\n42025029NOPV_PCO_05082025_(24-296566).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025029NOPV/42025029NOPV_PCO_05082025_(24-296566).pdf\n\n42025029NOPV_PCO_05082025_(24-296566)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025029NOPV/42025029NOPV_PCO_05082025_(24-296566)_text.pdf\n\n42025029NOPV_Final Order_07082025_(24-296566)_text.pdf\n\nJuly 8, 2025\nVIA ELECTRONIC MAIL TO: dan.ammann@exxonmobil.com\nDan Ammann\nPresident, ExxonMobil Upstream Company\nExxonMobil Production Company\n22777 Springwoods Village Parkway, W3.6B.477\nSpring, Texas 77389\nRe: CPF No. 4-2025-029-NOPV\nDear Mr. Ammann:\nEnclosed please find the Final Order issued in the above-referenced case. It makes a finding of\nviolation and specifies actions that need to be taken to comply with the pipeline safety\nregulations. When the terms of the compliance order are completed, as determined by the\nDirector, Southwest Region, this enforcement action will be closed. Service of the Final Order\nby e-mail is effective upon the date of transmission and acknowledgement of receipt as provided\nunder 49 CFR § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nLinda Daugherty\nActing Associate Administrator\nfor Pipeline Safety\nEnclosures (Final Order and NOPV)\ncc: Bryan Lethcoe, Director, Southwest Region, Office of Pipeline Safety\nScott W. Gillis, Wyoming Safety, Security, Heath, and Environmental Supervisor,\n\n\n\nExxonMobil Upstream Oil & Gas, US Conventional\nAdolfo A. Calero, Regulatory Specialist, ExxonMobil Upstream Oil & Gas, US\nConventional\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nExxonMobil Production Company, ) CPF No. 4-2025-029-NOPV\n)\n)\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nOn May 8, 2025 pursuant to 49 CFR § 190.207, the Director, Southwest Region, Office of\nPipeline Safety (OPS), issued a Notice of Probable Violation (Notice) to ExxonMobil Production\nCompany (Respondent). The Notice proposed finding that Respondent had violated the pipeline\nsafety regulations in 49 CFR Part 195. The Notice also proposed certain measures to correct the\nviolation. Respondent did not contest the allegations of violation or corrective measures and\nstated it had submitted documentation demonstrating compliance with the proposed corrective\nmeasures.\nBased upon a review of all the evidence, pursuant to § 190.213, I find Respondent violated the\npipeline safety regulations listed below, as more fully described in the enclosed Notice, which is\nincorporated by reference:\n49 CFR § 195.583(b) (Item 1) ─ Respondent failed to inspect pipe under thermal\ninsulation for atmospheric corrosion at the Rock Springs metering station.\nThis finding of violation will be considered a prior offense in any subsequent enforcement action\ntaken against Respondent.\nCompliance Actions\nPursuant to 49 U.S.C. § 60118(b) and 49 CFR § 190.217, Respondent is ordered to take the\nactions proposed in the enclosed Notice to correct the violation. The Director may grant an\nextension of time to comply with any of the required items upon a written request timely\nsubmitted by the Respondent and demonstrating good cause for an extension. Upon completion\nof the ordered actions, Respondent may request that the Director close the case. Respondent\npreviously submitted evidence to show appropriate actions have been taken to correct the\nviolations. This evidence is currently under review by the Director. Failure to comply with this\nOrder may result in the assessment of civil penalties under 49 CFR § 190.223 or in referral to the\n\n\n\nAttorney General for appropriate relief in a district court of the United States.\nThe terms and conditions of this order are effective upon service in accordance with 49 CFR\n§ 190.5.\n___________________________________ _________________________\nLinda Daugherty Date Issued\nActing Associate Administrator\nfor Pipeline Safety\n\n\n\nNOTICE OF PROBABLE VIOLATION\nAND\nPROPOSED COMPLIANCE ORDER\nVIA ELECTRONIC MAIL TO: dan.ammann@exxonmobil.com\nMay 8, 2025\nDan Ammann\nPresident, ExxonMobil Upstream Company\nExxonMobil Production Company\n22777 Springwoods Village Parkway W3.6B.477\nSpring, Texas 77389\nCPF 4-2025-029-NOPV\nDear Mr. Ammann:\nFrom April 23 to June 14, 2024, of the on-site inspection, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant\nto Chapter 601 of 49 United States Code (U.S.C.), inspected ExxonMobil Production Company’s\n(ExxonMobil) carbon dioxide (CO2) transmission pipeline system in Wyoming.\nAs a result of the inspection, it is alleged that ExxonMobil has committed probable violations of\nthe Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items\ninspected and the probable violations are:\n1. § 195.583 What must I do to monitor atmospheric corrosion control?\n(a) You must inspect each pipeline or portion of pipeline that is\nexposed to the atmosphere for evidence of atmospheric corrosion, as\nfollows:\n\n\n\nIf the pipeline is\nThen the frequency of inspection is:\nlocated:\nOnshore\nAt least once every 3 calendar years, but with intervals not\nexceeding 39 months\nOffshore\nAt least once each calendar year, but with intervals not exceeding\n15 months\n(b) During inspections you must give particular attention to pipe at\nsoil-to-air interfaces, under thermal insulation, under disbonded\ncoatings, at pipe supports, in splash zones, at deck penetrations, and in\nspans over water.\nExxonMobil failed to inspect each pipeline or portion of the pipeline that is exposed to the\natmosphere for evidence of atmospheric corrosion at least once every 3 calendar years, but with\nintervals not exceeding 39 months, paying particular attention during inspections to pipe under\nthermal insulation in accordance with § 195.583(b) and its atmospheric corrosion procedures.\nSpecifically, ExxonMobil failed to inspect pipe under thermal insulation at the Rock Springs\nmetering station since the pipeline came into service.\nExxonMobil's procedure, Monitoring for Atmospheric Corrosion, in its Operation, Maintenance,\n& Emergency Manual for DOT Hazardous Liquid Pipelines (Rev. December 2023; Version 1),\nSection 38.3 Process, step 4, requires giving particular attention to pipe at soil-to-air interfaces,\nunder thermal insulation, under disbonded coatings, at pipe supports, in splash zones, at deck\npenetrations, and in spans over water. However, during PHMSA's inspection, ExxonMobil was\nunable to provide past atmospheric corrosion control records for the pipe under thermal\ninsulation at the Rock Springs Metering Station.\nTherefore, ExxonMobil failed to inspect each pipeline or portion of the pipeline that is exposed\nto the atmosphere for evidence of atmospheric corrosion at least once every 3 calendar years, but\nwith intervals not exceeding 39 months, paying particular attention to pipe under thermal\ninsulation in accordance with § 195.583(b) and its atmospheric corrosion inspection procedures.\n\n\n\nProposed Civil Penalty\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a\nrelated series of violations. For violation occurring on or after December 28, 2023 and before\nDecember 30, 2024, the maximum penalty may not exceed $266,015 per violation per day the\nviolation persists, up to a maximum of $2,660,135 for a related series of violations. For violation\noccurring on or after January 6, 2023 and before December 28, 2023, the maximum penalty may\nnot exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627\nfor a related series of violations. For violation occurring on or after March 21, 2022 and before\nJanuary 6, 2023, the maximum penalty may not exceed $239,142 per violation per day the\nviolation persists, up to a maximum of $2,391,412 for a related series of violations. For violation\noccurring on or after May 3, 2021 and before March 21, 2022, the maximum penalty may not\nexceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for\na related series of violations. For violation occurring on or after January 11, 2021 and before\nMay 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation\npersists, up to a maximum of $2,225,034 for a related series of violations. For violation\noccurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not\nexceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for\na related series of violations.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to propose a civil penalty assessment at this time.\nProposed Compliance Order\nWith respect to Item 1, pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials\nSafety Administration proposes to issue a Compliance Order to ExxonMobil Production\nCompany. Please refer to the Proposed Compliance Order, which is enclosed and made a part of\nthis Notice.\nResponse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators\nin Enforcement Proceedings. Please refer to this document and note the response options. All\nmaterial you submit in response to this enforcement action may be made publicly available. If\nyou believe that any portion of your responsive material qualifies for confidential treatment\nunder 5 U.S.C. § 552(b), along with the complete original document you must provide a second\ncopy of the document with the portions you believe qualify for confidential treatment redacted\nand an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. § 552(b).\nFollowing your receipt of this Notice, you have 30 days to respond as described in the enclosed\nResponse Options. If you do not respond within 30 days of receipt of this Notice, this constitutes\na waiver of your right to contest the allegations in this Notice and authorizes the Associate\nAdministrator for Pipeline Safety to find facts as alleged in this Notice without further notice to\nyou and to issue a Final Order. If you are responding to this Notice, we propose that you submit\n\n\n\nyour correspondence to my office within 30 days from receipt of this Notice. The Region\nDirector may extend the period for responding upon a written request timely submitted\ndemonstrating good cause for an extension.\nIn your correspondence on this matter, please refer to CPF 4-2025-029-NOPV and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Enforcement Proceedings\nCc: Kathleen Ash, General Manager, ExxonMobil Production Company,\nkathleen.d.ash@exxonmobil.com\n\n\n\nPROPOSED COMPLIANCE ORDER\nPursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) proposes to issue to ExxonMobil Production Company (ExxonMobil)\na Compliance Order incorporating the following remedial requirements to ensure the compliance\nof ExxonMobil with the pipeline safety regulations:\nA. B. In regard to Item 1 of the Notice pertaining to ExxonMobil’s failure to give\nparticular attention to pipe under thermal insulation during inspections,\nExxonMobil must identify all jurisdictional pipelines with thermal insulation for\nits Wyoming CO2 pipeline system. If a pipe segment is identified as having\nthermal insulation, ExxonMobil must provide the last two cycles of atmospheric\ncorrosion inspections for that pipe segment that details the condition of the pipe\nunderneath the insulation, and pictures showing that the pipeline can be inspected\nunderneath the insulation. If the insulated pipe cannot be inspected in accordance\nwith the requirements of § 195.583(b) and ExxonMobil’s atmospheric corrosion\ninspection procedures, ExxonMobil must modify or remove the insulation. After\nmodification or removal of the insulation, ExxonMobil must conduct atmospheric\ncorrosion inspections of those pipelines.\nExxonMobil must provide records identifying all jurisdictional pipelines, the last\ntwo cycles of atmospheric corrosion inspections for the identified pipelines,\npictures showing that the pipeline can be inspected underneath the insulation, and\natmospheric corrosion inspection records, including records of insulation\nmodifications or removals, of any pipelines determined to have insulation that\nrequired modification or removal, to the Director, Southwest Region, PHMSA\nwithin 60 days of receipt of the Final Order.\nIt is requested (not mandated) that ExxonMobil Production Company maintain\ndocumentation of the safety improvement costs associated with fulfilling this\nCompliance Order and submit the total to Bryan Lethcoe, Director, Southwest\nRegion, Pipeline and Hazardous Materials Safety Administration. It is requested\nthat these costs be reported in two categories: 1) total cost associated with\npreparation/revision of plans, procedures, studies and analyses, and 2) total cost\nassociated with replacements, additions and other changes to pipeline\ninfrastructure.\n\n42025029NOPV_Closure Letter_07232025_(24-296566)_text.pdf\n\nVIA ELECTRONIC MAIL TO: dan.ammann@exxonmobil.com\nJuly 23, 2025\nDan Ammann\nPresident, ExxonMobil Upstream Company\nExxonMobil Production Company\n22777 Springwoods Village Parkway, W3.6B.477\nSpring, Texas 77389\nRE: CPF No. 4-2025-029-NOPV\nDear Mr. Ammann:\nOn July 8, 2025, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to\nExxonMobil Production Company a Final Order. Based on our review of the documentation you\nprovided, it has been determined that you have complied with the terms of this Order.\nAccordingly, this case is now closed and no further action is necessary with respect to the matters\ninvolved in this case. Thank you for your cooperation in this matter.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Kathleen Ash, General Manager, ExxonMobil Production Company,\nkathleen.d.ash@exxonmobil.com\nScott W. Gillis, Wyoming Safety, Security, Heath, and Environmental Supervisor,\nExxonMobil Upstream Oil & Gas, US Conventional, scott.w.gillis@exxonmobil.com\nAdolfo A. Calero, Regulatory Specialist, ExxonMobil Upstream Oil & Gas, US\nConventional, adolfo.a.calero@exxonmobil.com","truncated":false,"body_characters":16051}