CHEVRON PIPE LINE CO — Warning Letter

party submissionOfficial PDF520085037W_operator response_10272008.pdf#

520085037w_warning letter_10152008_text.pdf, page 1Official PDFU. S. Department of TrGnsportGtlon PmpeDne and HaxardoLts Matermalls Safety Admtntsfrafmon 12300 W Dakota Ave, Suite 110 Lakewood, CQ 80228 WA~ING EKTTKR October 15, 2008 Ms. Rebecca B. Robert President Chevron Pipe Lme Co 4800 Fournace Place Bellaire, TX 77401-2324 CPF 5-2008-5037M Dear Ms Robert From May 6 to 8, 2008, a representative of the Washington Utihties and Transportation Commission (WUTC) inspected your refined product terminals in Pasco and Spokane, Washington, pursuant to Chapter 601 of 49 United States Code The WUTC is an authorized Interstate Agent and representative for the Pipehne and Hazardous Materials Safety Administration (PHMSA) As a result of the inspection, it appears that you have committed probable violations of the Pipehne Safety Regulations, Title 49, Code of Federal Regulations The items mspected and the probable violations are. (b) Each ope~ato~ shaD inspect the physical integi ity of in-service atmospheric and low-pressure steel aboveground breakout tanks according to section 4 of AP1 Standard 653. However, jtf structur al 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).#

520085037w_warning letter_10152008_text.pdf, page 2Inspections conducted m accordance with Section 4 of API Standard 653 found the madequacies detailed below Durmg the field mspection of the Pasco terminal, it was found that there were isolated areas of paint failure on the tank shell for breakout tanks T-11, T-13 and T-17 Also, during the field inspection of the Pasco terminal, it was found that the valve packing for 8" outgoing hne valve, 8" barge hne valve and 1" level alarm valve for tank T-16 showed signs of leaking. The manhole blind flange also showed signs of leakmg Similar leaks were also found in other tanks. A number of tell-tale holes have steel plugs installed to seal the holes Those steel plugs must be removed as per API 650 requirement. Under 49 United States Code, ) 60122, you are subject to a civil penalty not to exceed $100, 000 for each violation for each day the violation persists up to a maximum of $1, 000, 000 for any related series of violations We have reviewed the circumstances and supporting documents mvolved in this case, and have decided not to conduct additional enforcement action or penalty assessment proceedings at this time. We advise you to correct the item(s) identified m this letter. Failure to do so will result in Chevron Pipehne Company being subject to additional enforcement action. No reply to this letter is required If you choose to reply, in your correspondence please refer to CPP 5-2OO8-5O37W, 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 quahfies 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 beheve the redacted information qualifies for confidential treatment under 5 U. S C 552(b) Sincerely, Chris Hoidal Director, Western Region Pipeline and Hazardous Materials Safety Administration cc PHP-60 Comphance Registry PHP-500 T. Finch (¹120771) WUTC — Mr. Dave Lykken#