{"operation":"document","citation":"CPF 520085012M","title":"CHEVRON PRODUCTS COMPANY — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-06-04","effective_on":null,"summary":"CLOSED notice of amendment citing 195.452(e)(1), 195.452(i)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085012m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085012m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085012m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520085012M","body":"Notice of Amendment involving CHEVRON PRODUCTS COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.452(e)(1),  195.452(i)(1). The case was opened on 2008-06-04 and is reported as closed as of 2008-09-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520085012M_notice of amendment_06042008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085012M/520085012M_notice%20of%20amendment_06042008.pdf\n\n520085012M_Operator Response_09052008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085012M/520085012M_Operator%20Response_09052008.pdf\n\n520085012M_notice of amendment_06042008.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n12300 W. Dakota Ave.. Suite 110\nLakewood, CO 80228\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 4,2008\nMr. Peter Prather\nHES Manager\nChevron Products Company\n6001 Bollinger Canyon Road, Room L-2184\nSan Ramon, CA 94583-2324\nCPF 5-2008-5012M\nDear Mr. Prather:\nOn March 19,2008, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) and California State Fire Marshal (CSFM), pursuant to Chapter 601\nof 49 United States Code, inspected Chevron Products Company's (CPC) procedures for their\nIntegrity Management Program (IMP) in San Ramon, California.\nOn the basis of the inspection, PHMSA identified apparent inadequacies found within CPCYs\nplans or procedures, as described below:\n1. 5195.452 Pipeline integrity management in high consequence areas.\n(e) What are the risk factors for establishing an assessment schedule (for both the\nbaseline and continual integrity assessments)?\n(1) An operator must establish an integrity assessment schedule that prioritizes\npipeline segments for assessment (see paragraphs (d) (1) and (j) (3) of this section).\nAn operator must base the assessment schedule on all risk factors that reflect the\n\n\n\n2. risk conditions on the pipeline segment. The factors an operator must consider\ninclude, but are not limited to:\n(i) Results of the previous integrity assessment, defect type and size that the\nassessment method can detect, and defect growth rate;\n(ii) Pipe size, material, manufacturing information, coating type and condition, and\nseam type;\n(iii) Leak history, repair history and cathodic protection history;\n(iv) Product transported;\n(v) Operating stress level;\n(vi) Existing or projected activities in the area;\n(vii) Local environmental factors that could affect the pipeline (e.g., corrosivity of\nsoil, subsidence, climatic);\n(viii) Geo-technical hazards; and (ix) Physical support of the segment such as by a\ncable suspension bridge.\n(2) Appendix C of this part provides further guidance on risk factors.\nItem 1: $195.452 (e)(2)\nThe risk model did not consider likely risk factors and critical variables related to their\nLoss Prevention System (LPS) and API 653 inspection reports. CPC's integrity\nmanagement program does not have an adequate process to include these factor in their\nrisk model.\n5195.452 Pipeline integrity management in high consequence areas.\n(0 What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\nintegrity management program:\n(6) Identification of preventive and mitigative measures to protect the high\nconsequence area (see paragraph (i) of this section);\n(i) What preventive and mitigative measures must an operator take to protect the\nhigh consequence area?\n(1) General requirements. An operator must take measures to prevent and\nmitigate the consequences of a pipeline failure that could affect a high consequence\narea. These measures include conducting a risk analysis of the pipeline segment to\nidentify additional actions to enhance public safety or environmental protection.\nSuch actions may include, but are not limited to, implementing damage prevention\nbest practices, better monitoring of cathodic protection where corrosion is a\nconcern, establishing shorter inspection intervals, installing EFRDs on the pipeline\nsegment, modifying the systems that monitor pressure and detect leaks, providing\nadditional training to personnel on response procedures, conducting drills with\nlocal emergency responders and adopting other management controls.\n\n\n\nItem 2: 5 195.452 (i)(l) & 5 195.452 (g)(3)\nCPC did not have adequate procedures to take into account key information collected\nfrom their operations and maintenance activities into their risk model and their\npreventive and mitigative decision process. The primary examples of key information\nthat should be considered are Chevron's Loss Prevention System (LPS) and the API 653\ninspection reports.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. 5 60108(a) and 49 C.F.R. 9 190.237. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue a Final Order.\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the inadequacies\n(49 C.F.R. tj 190.237). If you are not contesting this Notice, we propose that you submit your\namended procedures to my office within 30 days of receipt of this Notice. This period may be\nextended by written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed.\nIn correspondence concerning this matter, please refer to CPF 5-2008-5012M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 H. Nguyen (#I2 1 192)\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings","truncated":false,"body_characters":7134}