{"operation":"document","citation":"CPF 520087001W","title":"UNION OIL COMPANY OF CALIFORNIA (UOCC) — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-05-07","effective_on":null,"summary":"CLOSED warning letter citing 195.452(i)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520087001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520087001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520087001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520087001W","body":"Warning Letter involving UNION OIL COMPANY OF CALIFORNIA (UOCC). PHMSA's enforcement data identifies the cited regulation as 195.452(i)(3). The case was opened on 2008-05-07 and is reported as closed as of 2008-05-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520087001W_warning letter_05072008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520087001W/520087001W_warning%20letter_05072008.pdf\n\n520087001w_warning letter_05072008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520087001W/520087001w_warning%20letter_05072008_text.pdf\n\n520087001w_warning letter_05072008_text.pdf\n\nO\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 RE UESTED\nMay 7, 2008\nMr. John Zager\nGeneral Manager\nUnion Oil Company of Cahfornia\n909 West 9th Avenue\nAnchorage, AK 99501\nCPF 5-2008-7001W\nDear Mr. Zager:\nBetween September 1 land 14, 2007, representatives of the Pipeline and Hazardous Materials\nSafety Admmistration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected\nyour procedures and records for Union Oil Company of Cahfornia's (UNOCAL) Integrity\nManagement Program in Anchorage, Alaska.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipehne Safety Regulations, Title 49, Code of Federal Regulations The item inspected and\nthe probable violation is\n$195. 452 (i) What preventive and mitigative measures must an operator take to\nprotect the high consequence area? (3) Leak detection. An operator must have a\nmeans to detect leaks on its pipeline system. An operator must evaluate the\ncapability of its leak detection means and modify, as necessary, to protect the high\nconsequence area. An operator's evaluation must, at least, consider the following\nfactors-length and size of the pipeline, type of product carried, the pipeline's\nproximity to high consequence area, the swiftness of leak detection, location of\nnearest response personnel, leak history, and risk assessment results.\n\n\n\nUNOCAL has not conducted an adequate analysis of its leak detection systems to\nevaluate the capability of its leak detection system, as necessary, to protect the high\nconsequence area. UNOCAL's leak detection evaluation must, at least, consider the\nfollowing factors: length and size of the pipeline, type of product carried, the pipehne's\nproximity to high consequence area, the swiftness of leak detection, location of nearest\nresponse personnel, leak history, and risk assessment results. UNOCAL initiated a\nreview of its leak detection capabihties m 2002, but did not adopt the recommendations\nof the draft proposal from the Vendor, due to the multi-phase flow of the pipehne.\nUNOCAL chose not to adopt the Vendor's proposal at that time and as a result,\nUNOCAL has not formally completed the leak detection study.\nUnder 49 United States Code, ) 60122, you are subject to a civil penalty not to exceed\n$100, 000 for each violation for each day the violation persists up to a maximum of $1, 000, 000\nfor any related series of violations. We have reviewed the circumstances and supporting\ndocuments mvolved in this case, and have decided not to conduct additional enforcement\naction or penalty assessment proceedings at this time. We advise you to correct the items\nidentified in this letter. Failure to do so will result in UNOCAL bemg subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2008-7001W. Be advised that all material you submit in response to this\nenforcement action is subject to being made pubhcly available. If you believe that any portion\nof your responsive material quahfies for confidential treatment under 5 U. S C 552(b), along\nwith the complete original document you must provide a second copy of the document with\nthe portions you beheve quahfy for confidential treatment redacted and an explanation of why\nyou beheve the redacted mformation quahfies for confidential treatment under 5 U. S. C\n552(b).\nSmcerely,\nChris oidal\nDirector, Western Region\nPipehne and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Strawn (¹119794)","truncated":false,"body_characters":4351}