{"operation":"document","citation":"CPF 520035006","title":"EXXONMOBIL PIPELINE CO — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2003-01-30","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.402(a), 195.402(c)(3), 195.571.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520035006.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520035006.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520035006","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520035006","body":"Notice of Probable Violation involving EXXONMOBIL PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 195,  195.402(a),  195.402(c)(3),  195.571. The case was opened on 2003-01-30 and is reported as closed as of 2004-07-01. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520035006_Final Order_07012004.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520035006/520035006_Final%20Order_07012004.pdf\n\n520035006_final order_07012004_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520035006/520035006_final%20order_07012004_text.pdf\n\n520035006_final order_07012004_text.pdf\n\nUS Deparfment\nof Transporfaf ton\nResearch and\nSpecial Programs\nAdministration\nOffice of the\nChief Counsel\n400 Seventh St S W\nWashington 0 C 20590\nAndrew K Turner\nVice President, Operations\nExxonMobil Pipelme Company\n800 Bell Street\nHouston, TX 77002\nRe CPF No 5-2003-5006\nDear Mr, Turner.\nEnclosed is the Final Order issued by the Associate Administrator for Pipehne Safety in the\nabove-referenced case. It withdraws one of the allegations of violation and the associated\ncompliance order and finds that you have addressed the inadequacies m your procedures that were\ncited. Therefore, you need not take any further action with respect to the matters m this case This\nenforcement action is now closed Your receipt of the Final Order constitutes service of that\ndocument under 49 C F R. ) 190. 5.\nSincerely,\nJames Reynolds\nPipeline Compliance Registry\nOffice of Pipehne Safety\nEnclosure\ncc Ms. Karen Bailor\nManager, Operations Integrity Department\nERTIFIED MAIL - RETURN RECEIPT RE UESTED\n\n\n\nDEPARTMENT OF TRANSPORTATION\nRESEARCH AND SPECIAL PROGRAMS ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, DC 20590\nIn the Matter of\n)\n)\nExxonMobil Pipehne Company, )\n)\nRespondent\n)\n)\nCPF No. 5-2003-5006\nFINAL ORDER\nOn October 8-10 and November 21, 2002, pursuant to 49 U S. C. ( 60117, a representative of the\nOffice of Pipehne Safety (OPS) conducted an on-site pipeline safety inspection of ExxonMobil\nPipehne Company's (Respondent's) facihties and records m Montana. As a result of the inspection,\nthe Director, Western Region, OPS, issued to Respondent, by letter dated January 30, 2003 a Notice\nof Probable Violation, Proposed Compliance Order, and Notice of Amendment (Notice). In\naccordance with 49 C F. R. ( 190 207, the Notice proposed finding that Respondent committed\nviolations of 49 C. F R. Part 195 and proposed that Respondent take certam measures to correct the\nalleged violations The Notice also alleged inadequacies m Respondent's operations, maintenance,\nand emergencies (OM&E) procedures and proposed m accordance with 49 C. F R. ( 190. 237 that\nRespondent amend its procedures.\nRespondent responded to the Notice by letter dated March 17, 2003 (Response). Respondent\ncontested the allegations, offered information m explanation of the allegations, and requested a\nhearing. The hearing was held on September 21, 2003 m Denver, Colorado\nWITHDRAWAL OF ALLEGATION\nItem 3 of the Notice alleged that Respondent violated 49 C. F. R. ( 195 571 by faihng to consider\nvoltage drops in determming the adequacy of the cathodic protection on its lines. The corrosion\ncontrol provisions of the pipehne safety regulations incorporate NACE Standard RP0169-96 and\nrequire operators usmg the 850 mV negative cathodic potential criterion to correct for voltage drop\nm order to arrive at vahd mterpretations of their pipe-to-soil measurements. The value of the voltage\ndrop and the methods of correcting for it must be determined by selecting and applying sound\nengineering methods, The universally accepted method is to interrupt the flow of current at the\nrectifier and measure the magmtude of the voltage drop usmg the \"instant off\" techmque. Once\nmeasured, the voltage drop may be used for correcting future pipe-to-soil measurements at the same\nlocation as well as other test pomts in the area provided conditions such as soil characteristics and\ncoatmg quahty remam constant When the instant off method is impracticable or otherwise\n\n\n\ndetermined inappropriate for a particular pipeline or pipeline section, the use of extrapolation\nmethods to determme the polarized potential of pipe structures and computerized survey techniques\nare also acceptable methods of accounting for voltage drop.\nIn its response and at the hearing, Respondent demonstrated that its cathodic protection practices in\neffect accounted for voltage drops. Specifically, Respondent demonstrated that up-to-date close-\ninterval electrical survey data for the entire pipehne and comprehensive information on the output\nlevels of all impressed current rectifiers along with other corrosion control records were integrated\nwith other relevant operational data and analyzed for the purpose of determming the adequacy o f the\ncathodic protection on its pipelines. Based on an extrapolation analysis of this data, Respondent's\ncorrosion specialist concluded that if all environmental factors remained constant and the annual\npipe-to-soil measurements and rectifier outputs maintained their current levels, a determination that\nvoltage drops had been accounted for was warranted with respect to the subject pipeline. Havmg\nconsidered this information demonstrating substantial comphance with the regulation, I am\nwithdrawmg this allegation of violation and the Proposed Comphance Order associated with it\nAMENDMENT OF PROCEDURES\nItem 2 of the Notice alleged that Respondent's written OM&E procedures were inadequate in that\nthey failed to describe Respondent's method for considering voltage drops in interpreting its annual\npipe-to-soil measurements and failed to indicate how it was to be implemented by its personnel.\nUnder ) 195. 402, operators must have written procedures implementmg the OM&E requirements\nin Part 195 In its response, Respondent demonstrated that NACE Standard RP0169-96 was\nreferenced in its OM&E manual. Respondent, however, failed to demonstrate that the manual being\nused by its field personnel at the time of the inspection described its process for considering voltage\ndrops in a manner that would have permitted the OPS mspector to evaluate the capacity of this\nprocess to produce vahd results or determine whether it had been fully implemented and followed\nby the responsible personnel After the hearing, Respondent submitted documents demonstratmg\nthat it had amended its OM&E manual to direct the systematic use of an extrapolation method to\nassess and momtor the polarized potential of pipe structures. Specifically, Respondent's revised\nprocedures require annual pipe-to-soil measurements to be plotted against the measurements for the\npreceding three years and require any significant deviations to be investigated and corrected. The\nDirector, Western Region, OPS has reviewed the revised procedures and accepted them as adequate\nin hght of the fact that Respondent's practice of performing comprehensive cathodic protection data\ncollection and mtegration (see Item 3 discussion above) has demonstrated satisfactory results.\nAccordingly, I find that Respondent's original procedures as described in the Notice were inadequate\nto ensure the safe operation of its pipehne system, but that Respondent has corrected the identified\ninadequacies Because Respondent's actions have satisfied the proposed amendment of procedures,\nit is unnecessary to issue an order directing amendment of Respondent's procedures.\n\n\n\nWARNING ITEM\nThe Notice did not propose a civil penalty or corrective action for Item 1. Therefore, it is considered\na warnmg item. Respondent presented information its response and at the hearing showing that it\nhas addressed the cited item. Respondent is again warned that if OPS finds a violation for this item\nin a subsequent inspection, enforcement action will be taken\nUnder 49 C F. R. $ 190. 215, Respondent has a right to submit a petition for reconsideration of this\nFinal Order The petition must be received within 20 days of Respondent's receipt of this Final\nOrder and must contain a brief statement of the issue(s). The terms and conditions of this Final\nOrder are effective on receipt.\ncey Gerard\nAssociate Administrator\nfor Pipehne Safety\nDate Issued","truncated":false,"body_characters":8256}