{"operation":"document","citation":"CPF 520075038W","title":"CHEVRON PRODUCTS COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-10-19","effective_on":null,"summary":"CLOSED warning letter citing 195.432, 195.581.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520075038w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520075038w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520075038w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520075038W","body":"Warning Letter involving CHEVRON PRODUCTS COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.432,  195.581. The case was opened on 2007-10-19 and is reported as closed as of 2007-10-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520075038W_warning letter_10192007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075038W/520075038W_warning%20letter_10192007_text.pdf\n\n520075038W_warning_letter_10192007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075038W/520075038W_warning_letter_10192007.pdf\n\n520075038W_warning_letter_10192007.pdf\n\n5. Departme\nTransportati\n12300 W. Dakota Ave., Suite 1\nakewood, CO 802:\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 19, 2007\nMr. Gene Ketcham\nChevron Texaco Products Company\nHES Specialist, NA Logistics\n5924 NW Front Avenue\nPortland, OR 97210\nCPF 5-2007-5038W\nDear Mr. Ketcham:\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected\nOn March 12, 2007, a representative of the Pipeline and Hazardous Materials Safety\nyour Portland Breakout Tanks in Portland, Oregon.\nPipe resus to the gicion, tap ar that you have omited probable vidation of the\nand the probable violations are:\n1.\n§195.581 Atmospheric Corrosion\n(2) You rote an and rear cap pieliac or por an or petin that is\n\n\n\n(c) Except portions of pipelines in offshore splash zones or soil-to-air\ninterfaces, you need not protect against atmospheric corrosion any pipeline\nthe environment of the pipeline that corrosion will -\nfor which you demonstrate by test, investigation, or experience appropriate to\n(2) Not affect the safe operation of the pipeline before the next scheduled\n(1) Only be a light surface oxide; or\ninspection.\ninvolving substantial atmospheric corrosion, lack of dielectric interface between\nVisual examination of tank farm facilities revealed unsatisfactory conditions\nstation piping and support structures, and above-ground paint failure and pitting\nthese conditions have existed for many years.\nwithin many areas of horizontal piping. Visual evidence further suggests that\n2.\n$195.432 Breakout tanks.\n(b) Each operator shall inspect the physical integrity of in-service\nsection 4 of API Standard 653. However, if structural conditions prevent\natmospheric and low-pressure steel aboveground breakout tanks according to\nplan included in the operations and maintenance manual under\naccess to the tank bottom, the bottom integrity may be assessed according to a\n§195.402(c)(3).\nField reviews showed advanced exterior paint failure, pitting, and atmospheric\ncorrosion on most storage tanks and horizontal piping.\nmaintain its facilities free of visible paint failure, pitting, and atmospheric\nAn operator has the responsibility under the Code of Federal Regulations to\nof future paint failure, pitting, and corrosion mitigation efforts.\ncorrosion, and to keep a maintenance schedule that projects an estimated timetable\n$100,000 for each violation for each day the violation persists up to a maximum of\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\nsupporting documents involved in this case, and have decided not to conduct additional\n$1,000,000 for any related series of violations. We have reviewed the circumstances and\ncorrect the items) identified in this letter. Failure to do so will result in ChevronTexaco\nenforcement action or penalty assessment proceedings at this time. We advise you to\nProducts Company being subject to additional enforcement action.\nrefer to CPF 5-2007-5038W. Be advised that all material you submit in response to this\nNo reply to this letter is required. If you choose to reply, in your correspondence please\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C.\nenforcement action is subject to being made publicly available. If you believe that any\n552(b), along with the complete original document you must provide a second copy of the\n2\n\n\n\nexplanation of why you believe the redacted information qualifies for confidential\ndocument with the portions you believe qualify for confidential treatment redacted and an\ntreatment under 5 U.S.C. 552(b).\nSincerely,\nChris Hoidal\nDirector, Western Regior\nPipeline and Hazardous Materials Safety Administratior\nCC:\nPHP-60 Compliance Registry\nPHP-500 J. Kenerson (#118892)\n3\n\n520075038W_warning letter_10192007_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 19, 2007\nMr. Gene Ketcham\nHES Specialist, NA Logistics\nChevronTexaco Products Company\n5924 NW Front Avenue\nPortland, OR 97210\nCPF 5-2007-5038W\nDear Mr. Ketcham:\nOn March 12, 2007, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected\nyour Portland Breakout Tanks in Portland, Oregon.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected\nand the probable violations are:\n1. §195.581 Atmospheric Corrosion\n(a) Your must clean and coat each pipeline or portion of pipeline that is\nexposed to the atmosphere, except pipelines under paragraph (c) of this\nsection.\n\n\n\n(c) Except portions of pipelines in offshore splash zones or soil-to-air\ninterfaces, you need not protect against atmospheric corrosion any pipeline\nfor which you demonstrate by test, investigation, or experience appropriate to\nthe environment of the pipeline that corrosion will –\n(1) Only be a light surface oxide; or\n(2) Not affect the safe operation of the pipeline before the next scheduled\ninspection.\nVisual examination of tank farm facilities revealed unsatisfactory conditions\ninvolving substantial atmospheric corrosion, lack of dielectric interface between\nstation piping and support structures, and above-ground paint failure and pitting\nwithin many areas of horizontal piping. Visual evidence further suggests that\nthese conditions have existed for many years.\n2. §195.432 Breakout tanks.\n(b) Each operator shall inspect the physical integrity of in-service\natmospheric and low-pressure steel aboveground breakout tanks according to\nsection 4 of API Standard 653. However, if structural conditions prevent\naccess to the tank bottom, the bottom integrity may be assessed according to a\nplan included in the operations and maintenance manual under\n§195.402(c)(3).\nField reviews showed advanced exterior paint failure, pitting, and atmospheric\ncorrosion on most storage tanks and horizontal piping.\nAn operator has the responsibility under the Code of Federal Regulations to\nmaintain its facilities free of visible paint failure, pitting, and atmospheric\ncorrosion, and to keep a maintenance schedule that projects an estimated timetable\nof future paint failure, pitting, and corrosion mitigation efforts.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of\n$1,000,000 for any related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to\ncorrect the item(s) identified in this letter. Failure to do so will result in ChevronTexaco\nProducts Company being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please\nrefer to CPF 5-2007-5038W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C.\n552(b), along with the complete original document you must provide a second copy of the\n2\n\n\n\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Kenerson (#118892)\n3","truncated":false,"body_characters":8325}