UNION OIL COMPANY OF CALIFORNIA (UOCC) — Notice of Amendment

520082003m_notice of amendment_09102008_text.pdf, page 1Official PDFU. S. DSPGrtment of Tf'GflsPortGtlon Pmpslllns and Hazardous Matermalls Safety Admln~sttratmon 12300 W Dakota Ave, Suite 110 Lakewood, CO 80228 XQTIiL'K OF AMKXBMKXT September 10, 2008 Mr John Zager General Manager Union Oil Company of Cahfornia 909 West 9'" Avenue Anchorage, AIZ 99501 CPF 5-2008-2003M Dear Mr. Zager: On March 24-27, representatives of the Pipehne and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Union Oil Company of California (UOCC) procedures for your Cook Inlet Natural Gas Pipelme facihties. Specifically we reviewed UOCC's "STANDARD OPERATING AND MAINTENANCE PROCEDURES MANUAL FOR GAS PIPELINES" at your office in Anchorage, Alaska On the basis of the inspection, PHMSA identified the following inadequacies within UOCC's operating and maintenance procedures, as described below: 1. $192. 605 Procedural manual for operations, maintenance, and emergencies. Each operator shall jinclude the following in its operating and maintenance plan: (b) Maintenance and normal operations. Yhe manual reqmred by paragraph (a) of this section must include procedures for the following, if applicable, to provide safety during maintenance and operations.#

520082003m_notice of amendment_09102008_text.pdf, page 2A. The Pipehne Specific Operations Manual (PSOM) for Steelhead Platform's gas pipehnes A k B, designates that the pressure controllnig devices are the pressure rehef valves, H-PSV 2015 and H-PSV 4184, which are both set at 1760 psig. The Piping and Instrumentation Diagram (PAID) for Steelhead Platform designates that the pressure controlhng device is PSV 4148, which is set at 1480 psig During the field inspection, it was found that the pressure control device was the pressure rehef valve, PSV 2015 B, which is set at 1481 psig. The Operator needs to change the PSOM and P&ID to ensure that the procedures and supporting diagrams accurately reflect the pressure control devices that protect the facihties and their proper set point. B. The PSOM for Grayhng Platform's gas pipehne B states that when importing gas from the Trading Bay Production Facihty that the pressure controlhng device is the pressure rehef valve, PSV 210, which should be set at 840 psig. The PAID designates that the only pressure control device is rehef valve, PSV 210, which is set at 800 psig. The operator needs to reconcile the PSOM and PAID to ensure that the procedures and supporting diagrams reflect the appropriate set point. C. When gas is flownig to the Bruce Platform from Granite Point Tank Farm, the PSOM designates that the pressure controlhng devices are the pressure rehef valve, T-PSV 480 (set at 200 psig), and pressure relief valve, T-PSV 514 (which is set at 1400 psig). The PAID designates that the pressure control device is the only pressure rehef valve, T-PSV 514, which is set at 285 psi. In the field, the pressure controlhng device was found to be- the pressure rehef valve, PSV 1230, which is set at 285 psi. The operator needs to change the PSOM and PAID to ensure that the procedures and supporting diagrams reflect the pressure control devices that protect the facihty and their proper set points. 2. )192. 713 Transmission hnes: Permanent field repair of imperfections and damages. (b) Operating pressure must be at a safe level during Iepair operations. UOCC's OAM Manual, Table 68. 02A, page 112, does not require that industry standard ASME B316 be used to determine the pressure during excavation of corrosion defects, or 80% of the operating pressure, whichever is less. 3. $192. 717 Transmission hnes: Permanent field repan of leaks. (5) Apply a method that ~eliable engineering tests and analyses show can permanently restore the serviceabihty of the pipe. The OkM Manual, Table G9. 01A, does not specify how internally corroded pipe will be repaired. 4. $192. 727 Abandonment or deactivation of facilities. (b) Each pipeline abandoned in place must be disconnected from all sources and supphes of gas; purged of gas; in the case of offshore pipelines, fdled with wate~ or#

520082003m_notice of amendment_09102008_text.pdf, page 3UOCC's OkM Manual, Procedure 613. 01, page 165, stated that, "Offshore pipehnes should be filled with a non-hazardous liquid to maintain negative buoyancy " The code requires that this be done; therefore, their OkM Manual should be revised to indicate this is a mandatory requirement 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 past of this Notice is a document entitled Response Options for Pipeline Operators in Comphance ProceeCings. 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 bemg made publicly available. If you beheve 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 beheve quahfy for confidential treatment redacted and an explanation of why you believe the redacted information quahfies 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 Pipehne 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 inadequac&es (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 [number of days] 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. In correspondence concerning this matter, please refer to CPF 5-2008-2003M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Chris oidal Director, Western Region Pipehne and Hazardous Materials Safety Administration cc. PHP-60 Comphance Registry PHP-500 B. Flanders (0's 122013, 120665, 120666, 120667, 120668, 120669) Enclosure: Response Options for Pipeline Operators in Compliance Proceedings#