{"operation":"document","citation":"CPF 520085013W","title":"CHEVRON PRODUCTS COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-06-04","effective_on":null,"summary":"CLOSED warning letter citing 195.452(f)(1), 195.452(f)(6), 195.452(i)(1), 195.452(i)(3), 195.452(k).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085013w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085013w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085013w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520085013W","body":"Warning Letter involving CHEVRON PRODUCTS COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.452(f)(1),  195.452(f)(6),  195.452(i)(1),  195.452(i)(3),  195.452(k). The case was opened on 2008-06-04 and is reported as closed as of 2008-06-04. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520085013W_warning letter_06042008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085013W/520085013W_warning%20letter_06042008.pdf\n\n520085013W_warning letter_06042008.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n12300 W. Dakota Ave., Suite 110\nLakewood, CO 80228\nWARNING LETTER\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 5-2008-5013W\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) Integrity Management\nProgram in San Ramon, California.\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. 9195.452 Pipeline integrity management in high consequence areas.\nf) 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\n\n\n\n2. 3. operator must include, at minimum, each of the following elements in its written\nintegrity management program:\n(1) A process for identifying which pipeline segments could affect a high\nconsequence area;\nCPC did not complete an annual HCA review using their \"facility form\" as part of their\nsegment identification to determine could affect an HCA.\n9195.452 Pipeline integrity management in high consequence areas.\n(f) 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.\nCPC did not conduct an evaluation of their preventive and mitigative measures in a\ntimely manner. The target dates to implement an appropriate preventive and mitigative\nmeasures outlined in the IMP would not be completed for several years.\n9195.452 Pipeline integrity management in high consequence areas.\n(f) 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\n\n\n\n4. operator 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(3) Leak detection. An operator must have a means to detect leaks on its pipeline\nsystem. An operator must evaluate the capability of its leak detection means and\nmodify, as necessary, to protect the high consequence area. An operator's\nevaluation must, at least, consider, the following factors-length and size of the\npipeline, type of product carried, the pipeline's proximity to the high consequence\narea, the swiftness of leak detection, location of nearest response personnel, leak\nhistory, and risk assessment results.\nCPC did not produce any documentation to show that an evaluation of the leak detection\ncapability of their breakout tank facilities was performed and completed.\n8195.452 Pipeline integrity management in high consequence areas.\n(f) 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(7) Methods to measure the program's effectiveness (see paragraph (k) of this\nsection);\n(k) What methods to measure program effectiveness must be used? An operator's\nprogram must include methods to measure whether the program is effective in\nassessing and evaluating the integrity of each pipeline segment and in protecting\nthe high consequence areas. See Appendix C of this part for guidance on methods\nthat can be used to evaluate a program's effectiveness.\nCPC has not yet implemented their program evaluation.\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 items identified in this letter.\nFailure to do so will result in Chevron Products Company being subject to additional\nenforcement action.\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPP 5-2008-5013W. 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\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: PWP-60 Compliance Registry\nPHP-500 H. Nguyen (#I21 192)","truncated":false,"body_characters":8041}