CHEVRON PRODUCTS COMPANY — Notice of Amendment

party submissionOfficial PDF520075040M_operator response to notice_12182007.pdf#

520075040m_notice of amendment_11152007_text.pdf, page 1Official PDFKEN'I r& r ( x]vi. tA&ir i= Ri-. G1s" Y Hdt ticopv 1' 'oct& opliutJQ of C„p, „, (, 1-&, „c ti~tyl 12300 W Dakota Ave, Sutte 110 Lakewood, CO 80228 U. S. Department of Transportation Pipeline and Hazardous Materials Satety Administration NOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT RE UESTED November 15, 2007 Mr. Gene Ketcham HES Specialist, NA Logistics ChevronTexaco Products Company 5924 NW Front Avenue Portland, OR 97210 CPF 5-2007-5040M Dear Mr. Ketcham: On March 12, 2007, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your Portland Breakout Tanks in Portland, Oregon. On the basis of the inspection, PHMSA has identified the apparent inadequacies found within ChevronTexaco's Operation and Maintenance Procedures, as described below: $195. 405 Protection against Ignition and safe access/egress involving floating roofs. (a) After October 2, 2000, protection provided against ignitions arising out of static electricity, lightning, and stray currents during operation and maintenance activities involving aboveground breakout tanks must be in accordance with API Recommended Practice 2003, unless the operator notes in the procedural manual ($195. 402(c)) why compliance with all or certain provisions of API Recommended Practice 2003 is not necessary for the safety of a particular breakout tank. (b) The hazards associated with access/egress onto floating roofs of in-service aboveground breakout tanks to perform inspection, service, maintenance or repair activities (other than specified general considerations, specified routine tasks or entering tanks removed from service for cleaning) are addressed in API Publication 2026. After October 2, 2000, the operator must review and consider the potentially hazardous conditions, safety practices and procedures in API Publication 2026 for inclusion in the procedure manual ($195. 402(c)).#

520075040m_notice of amendment_11152007_text.pdf, page 21A. At the time of the inspection, ChevronTexaco's OBcM Manual did not address the requirement to protect against ignitions arising out of static electricity, lightning, and stray currents during operation and maintenance activities involving aboveground breakout tanks, and does not note in procedures why compliance with API 2003 is not necessary for tank safety. 2A. At the time of the inspection, Chevron Texaco's OEM Manual did not address the requirement that an operator must review and consider the potentially hazardous conditions, safety practices and procedures outlined in API 2026 (Safe Access/Egress Involving Floating Roofs of Storage Tanks in Petroleum Service) for inclusion in Chevron Texaco's procedure manual. 2. $195. 432 Inspection of in-service breakout tanks. (b) Each operator shall inspect the physical integrity of in-service atmospheric and low-pressure steel aboveground breakout tanks according to section 4 of API Standard 653. However, if structural conditions prevent access to the tank bottom, the bottom integrity may be assessed according to a plan included in the operations and maintenance manual under $195. 402(c)(3). Chevron Texaco's 08cM Manual does not clearly address how inspection of the physical integrity of in-service atmospheric and low-pressure steel aboveground breakout tanks will be accomplished according to the requirements of Section 4 of API Standard 653. Res onse to this Notice This Notice is provided pursuant to 49 U. S. C. $ 60108(a) and 49 C. F. R. $ 190. 237. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings. Please refer to this document and note the response options. Be advised that all material you submit in response to this enforcement action is subject to being made publicly available. If you believe that any portion of your responsive material qualifies for confidential treatment under 5 U. S. C. 552(b), along with the complete original document you must provide a second copy of the document with the portions you believe qualify for confidential treatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatment under 5 U. S. C. 552(b). If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue a Final Order. If, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C. F. R. $ 190. 237). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed.#

520075040m_notice of amendment_11152007_text.pdf, page 3In correspondence concerning this matter, please refer to CPF 5-2007-5040M and, for each document you submit, please provide a copy in electronic format whenever possible. )) Chris Ho& al Director, Western Region Pipeline and Hazardous Materials Safety Administration cc: PHP-60 Compliance Registry PHP-500 J. Kenerson {411892) i s%M~ Enclosure: Response Options for Pipeline Operators in Compliance Proceedings#