UNION OIL COMPANY OF CALIFORNIA (UOCC) — Warning Letter

520087001w_warning letter_05072008_text.pdf, page 1Official PDFO U. S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 12300 W Dakota Ave, Suite 110 Lakewood, CO 80228 WARNING LETTER CERTIFIED MAIL - RETURN RECEIPT RE UESTED May 7, 2008 Mr. John Zager General Manager Union Oil Company of Cahfornia 909 West 9th Avenue Anchorage, AK 99501 CPF 5-2008-7001W Dear Mr. Zager: Between September 1 land 14, 2007, representatives of the Pipeline and Hazardous Materials Safety Admmistration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your procedures and records for Union Oil Company of Cahfornia's (UNOCAL) Integrity Management Program in Anchorage, Alaska. 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 item inspected and the probable violation is $195. 452 (i) What preventive and mitigative measures must an operator take to protect the high consequence area? (3) Leak detection. An operator must have a means to detect leaks on its pipeline system. An operator must evaluate the capability of its leak detection means and modify, as necessary, to protect the high consequence area. An operator's evaluation must, at least, consider the following factors-length and size of the pipeline, type of product carried, the pipeline's proximity to high consequence area, the swiftness of leak detection, location of nearest response personnel, leak history, and risk assessment results.#

520087001w_warning letter_05072008_text.pdf, page 2UNOCAL has not conducted an adequate analysis of its leak detection systems to evaluate the capability of its leak detection system, as necessary, to protect the high consequence area. UNOCAL's leak detection evaluation must, at least, consider the following factors: length and size of the pipeline, type of product carried, the pipehne's proximity to high consequence area, the swiftness of leak detection, location of nearest response personnel, leak history, and risk assessment results. UNOCAL initiated a review of its leak detection capabihties m 2002, but did not adopt the recommendations of the draft proposal from the Vendor, due to the multi-phase flow of the pipehne. UNOCAL chose not to adopt the Vendor's proposal at that time and as a result, UNOCAL has not formally completed the leak detection study. 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 items identified in this letter. Failure to do so will result in UNOCAL bemg subject to additional enforcement action. No reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 5-2008-7001W. Be advised that all material you submit in response to this enforcement action is subject to being made pubhcly 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 beheve quahfy for confidential treatment redacted and an explanation of why you beheve the redacted mformation quahfies for confidential treatment under 5 U. S. C 552(b). Smcerely, Chris oidal Director, Western Region Pipehne and Hazardous Materials Safety Administration cc: PHP-60 Compliance Registry PHP-500 J. Strawn (¹119794)#