EXXONMOBIL PIPELINE CO — Notice of Probable Violation

520035006_final order_07012004_text.pdf, page 1Official PDFUS Deparfment of Transporfaf ton Research and Special Programs Administration Office of the Chief Counsel 400 Seventh St S W Washington 0 C 20590 Andrew K Turner Vice President, Operations ExxonMobil Pipelme Company 800 Bell Street Houston, TX 77002 Re CPF No 5-2003-5006 Dear Mr, Turner. Enclosed is the Final Order issued by the Associate Administrator for Pipehne Safety in the above-referenced case. It withdraws one of the allegations of violation and the associated compliance order and finds that you have addressed the inadequacies m your procedures that were cited. Therefore, you need not take any further action with respect to the matters m this case This enforcement action is now closed Your receipt of the Final Order constitutes service of that document under 49 C F R. ) 190. 5. Sincerely, James Reynolds Pipeline Compliance Registry Office of Pipehne Safety Enclosure cc Ms. Karen Bailor Manager, Operations Integrity Department ERTIFIED MAIL - RETURN RECEIPT RE UESTED#

520035006_final order_07012004_text.pdf, page 2DEPARTMENT OF TRANSPORTATION RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, DC 20590 In the Matter of ) ) ExxonMobil Pipehne Company, ) ) Respondent ) ) CPF No. 5-2003-5006 FINAL ORDER On October 8-10 and November 21, 2002, pursuant to 49 U S. C. ( 60117, a representative of the Office of Pipehne Safety (OPS) conducted an on-site pipeline safety inspection of ExxonMobil Pipehne Company's (Respondent's) facihties and records m Montana. As a result of the inspection, the Director, Western Region, OPS, issued to Respondent, by letter dated January 30, 2003 a Notice of Probable Violation, Proposed Compliance Order, and Notice of Amendment (Notice). In accordance with 49 C F. R. ( 190 207, the Notice proposed finding that Respondent committed violations of 49 C. F R. Part 195 and proposed that Respondent take certam measures to correct the alleged violations The Notice also alleged inadequacies m Respondent's operations, maintenance, and emergencies (OM&E) procedures and proposed m accordance with 49 C. F R. ( 190. 237 that Respondent amend its procedures. Respondent responded to the Notice by letter dated March 17, 2003 (Response). Respondent contested the allegations, offered information m explanation of the allegations, and requested a hearing. The hearing was held on September 21, 2003 m Denver, Colorado WITHDRAWAL OF ALLEGATION Item 3 of the Notice alleged that Respondent violated 49 C. F. R. ( 195 571 by faihng to consider voltage drops in determming the adequacy of the cathodic protection on its lines. The corrosion control provisions of the pipehne safety regulations incorporate NACE Standard RP0169-96 and require operators usmg the 850 mV negative cathodic potential criterion to correct for voltage drop m order to arrive at vahd mterpretations of their pipe-to-soil measurements. The value of the voltage drop and the methods of correcting for it must be determined by selecting and applying sound engineering methods, The universally accepted method is to interrupt the flow of current at the rectifier and measure the magmtude of the voltage drop usmg the "instant off" techmque. Once measured, the voltage drop may be used for correcting future pipe-to-soil measurements at the same location as well as other test pomts in the area provided conditions such as soil characteristics and coatmg quahty remam constant When the instant off method is impracticable or otherwise#

520035006_final order_07012004_text.pdf, page 3determined inappropriate for a particular pipeline or pipeline section, the use of extrapolation methods to determme the polarized potential of pipe structures and computerized survey techniques are also acceptable methods of accounting for voltage drop. In its response and at the hearing, Respondent demonstrated that its cathodic protection practices in effect accounted for voltage drops. Specifically, Respondent demonstrated that up-to-date close- interval electrical survey data for the entire pipehne and comprehensive information on the output levels of all impressed current rectifiers along with other corrosion control records were integrated with other relevant operational data and analyzed for the purpose of determming the adequacy o f the cathodic protection on its pipelines. Based on an extrapolation analysis of this data, Respondent's corrosion specialist concluded that if all environmental factors remained constant and the annual pipe-to-soil measurements and rectifier outputs maintained their current levels, a determination that voltage drops had been accounted for was warranted with respect to the subject pipeline. Havmg considered this information demonstrating substantial comphance with the regulation, I am withdrawmg this allegation of violation and the Proposed Comphance Order associated with it AMENDMENT OF PROCEDURES Item 2 of the Notice alleged that Respondent's written OM&E procedures were inadequate in that they failed to describe Respondent's method for considering voltage drops in interpreting its annual pipe-to-soil measurements and failed to indicate how it was to be implemented by its personnel. Under ) 195. 402, operators must have written procedures implementmg the OM&E requirements in Part 195 In its response, Respondent demonstrated that NACE Standard RP0169-96 was referenced in its OM&E manual. Respondent, however, failed to demonstrate that the manual being used by its field personnel at the time of the inspection described its process for considering voltage drops in a manner that would have permitted the OPS mspector to evaluate the capacity of this process to produce vahd results or determine whether it had been fully implemented and followed by the responsible personnel After the hearing, Respondent submitted documents demonstratmg that it had amended its OM&E manual to direct the systematic use of an extrapolation method to assess and momtor the polarized potential of pipe structures. Specifically, Respondent's revised procedures require annual pipe-to-soil measurements to be plotted against the measurements for the preceding three years and require any significant deviations to be investigated and corrected. The Director, Western Region, OPS has reviewed the revised procedures and accepted them as adequate in hght of the fact that Respondent's practice of performing comprehensive cathodic protection data collection and mtegration (see Item 3 discussion above) has demonstrated satisfactory results. Accordingly, I find that Respondent's original procedures as described in the Notice were inadequate to ensure the safe operation of its pipehne system, but that Respondent has corrected the identified inadequacies Because Respondent's actions have satisfied the proposed amendment of procedures, it is unnecessary to issue an order directing amendment of Respondent's procedures.#

520035006_final order_07012004_text.pdf, page 4WARNING ITEM The Notice did not propose a civil penalty or corrective action for Item 1. Therefore, it is considered a warnmg item. Respondent presented information its response and at the hearing showing that it has addressed the cited item. Respondent is again warned that if OPS finds a violation for this item in a subsequent inspection, enforcement action will be taken Under 49 C F. R. $ 190. 215, Respondent has a right to submit a petition for reconsideration of this Final Order The petition must be received within 20 days of Respondent's receipt of this Final Order and must contain a brief statement of the issue(s). The terms and conditions of this Final Order are effective on receipt. cey Gerard Associate Administrator for Pipehne Safety Date Issued#