{"operation":"document","citation":"CPF 520085011W","title":"EXXONMOBIL OIL CORPORATION-TERMINALS — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-05-29","effective_on":null,"summary":"CLOSED warning letter citing 195.565, 195.581.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085011w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085011w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085011w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520085011W","body":"Warning Letter involving EXXONMOBIL OIL CORPORATION-TERMINALS. PHMSA's enforcement data identifies the cited regulations as 195.565,  195.581. The case was opened on 2008-05-29 and is reported as closed as of 2008-05-29. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520085011W_operator response_08042008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085011W/520085011W_operator%20response_08042008.pdf\n\n520085011W_warning letter_05292008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085011W/520085011W_warning%20letter_05292008.pdf\n\n520085011W_warning letter_05292008.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials safety\nAdministration\n12300 W. Dakota Ave., Suite 11 0\nLakewood, CO 80228\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 29,2008\nMr. Jim Rose\nDirector\nExxon Mobil Pipeline Company\n12851 166'~ Street\nCerritos, CA 90703-21 03\nCPF 5-2008-501 1 W\nDear Mr. Rose:\nBetween August 20-23,2007 a representative of the Washington Utilities and Transportation\nCommission (WUTC) inspected your Spokane Terminal in Spokane, Washington, pursuant to\nChapter 601 of 49 United States Code. The WUTC is an authorized Interstate Agent and\nrepresentative for the Pipeline and Hazardous Materials Safety Administration (PHMSA).\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 and the\nprobable violations are:\n1. 8195.581 Which pipelines must I protect against atmospheric corrosion and what\ncoating material may I use?\n(a) You must clean and coat each pipeline or portion of pipeline that is exposed to\nthe atmosphere, except pipelines under paragraph (c) of this section.\n(b) Coating material must be suitable for the prevention of atmospheric corrosion.\n(c) Except portions of pipelines in offshore splash zones or soil-to-air interfaces,\nyou need not protect against atmospheric corrosion any pipeline for which you\n\n\n\ndemonstrate by test, investigation, or experience appropriate to the environment of\nthe 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.\nAtmospheric Corrosion Monitoring records were not found for two manifold areas. One\narea was the transfer manifold located next to the storage tanks. The second manifold is\nlocated adjacent to the Yellowstone Pipeline Facility. This manifold is owned by Exxon\nMobile but maintained by Yellowstone Pipeline. Neither Yellowstone nor Exxon\nproduced atmospheric corrosion monitoring records for this manifold equipment. It was\nnoted that atmospheric monitoring records were available for the storage tank areas.\n2. 5195.565 How do I install cathodic protection on breakout tanks?\nAfter October 2,2000, when you install cathodic protection under Sec. 195.563(a)\nto protect the bottom of an aboveground breakout tank of more than 500 barrels\n(79.5m3) capacity built to API Specification 12F, API Standard 620, or API\nStandard 650 (or its predecessor Standard 12C), you must install the system in\naccordance with API Recommended Practice 651. However, installation of the\nsystem need not comply with API Recommended Practice 651 on any tank for\nwhich you note in the corrosion control procedures established under Sec.\n195.402(~)(3) why compliance with all or certain provisions of API Recommended\nPractice 651 is not necessary for the safety of the tank.\nVoltage drop needs to be considered when interpreting corrosion data. Pipe to soil\nreadings were collected during the inspection. \"On\" potentials for tanks 502 and 508\nwere - 1.087 V(on) and - 1 .I85 (on) respectively. \"Off' readings were -0.6 1 8 V (off)\nand -0.626 V (off) respectively. Annual Corrosion Monitoring data consisted of \"on\"\nreadings only. IR drop was not properly considered in interpreting Corrosion Data.\nUnder 49 United States Code, 5 60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violation persists up to a maximum of $1,000,000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this\nletter. Failure to do so will result in Exxon Mobil Pipeline Company being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2008-5011W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\n\n\n\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 T. Finch (Activity ID: 1 18855)\nWUTC - Mr. Dave Lykken","truncated":false,"body_characters":5406}