UNION OIL COMPANY OF CALIFORNIA (UOCC) — Notice of Amendment

party submissionOfficial PDF520087004M_operator_response_10132008.pdf#

520087004m_notice of amendment_09102008_text.pdf, page 1Official PDFU. S. Department of Transportahon Plpelllns and Hazafrdous Materlells Safety Admlnlstrd Pion 12300 W Dakota Ave, Suite 110 Lakewood, CO S0228 NOTICE OF AMKXBMKXT September 10, 2008 Mr, John Zager Union Oil Company of Cahfornia 909 West 9'" Avenue Anchorage, AIZ 99501 CPF 5-2008-7004M Dear Mr. Zager: On March 24 through 27, 2008, representatives of the Pipehne and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Union Oil Company of California (UOCC) procedures for your Coolr. Inlet Petroleum Pipelines. Specifically, we reviewed the UOCC's "STANDARD OPERATING AND MAINTENANCE PROCEDURES MANUAL FOR HAZARDOUS LIQUID PIPELINES" at your office in Anchorage, Alaska. On the basis of the inspection, PHMSA identified the following inadequacies within UOCC's operating and maintenance (O&M) procedures, as described below: $195. 50 Reporting accidents. An accident report is required for each failure in a pipehne system subject to this part in whjlch there is a release of the hazardous squid or carbon dioxide transported resulting in any of the following:#

520087004m_notice of amendment_09102008_text.pdf, page 2UOCC's OAM Manual, page 7, Chart HL1. 01, states that an oil spill reporting criteria of fifty (50) barrels for incident reporting to DOT shall be used Chart HL1. 01 does not conforin to )195. 50 Reporting Accidents. This regulation requires reports for any release of five (5) gallons or more of hazardous hquid, except that no report is required for a release of 5 barrels resultmg from a pipehne mamtenance activity. The OAM Manual, Procedure HL 1. 01, page 6, does not specify that a supplemental report must be filed within thirty (30) days if new or additional information related to the release becomes known UOCC's OXM Manual, Table HL9. 01A, does not specify how internal corrosion will be mitigated. gjL95. 422 Pipeline Repairs. (a) Each operator shall, in repairing its pipehne systems, insure that the repairs are made in a safe manner and are made so as to prevent damage to persons or property. UOCC's OAM Manual, Table HL8 02A, page 110, does not require that industry standard ASME B316 be used to determine and hmit the pipehne pressure durmg excavation of corrosion defects, or 65% of the operating pressure, whichever is less. Res onse to this Notice This Notice is provided pursuant to 49 U. S. C. $ 60108(a) and 49 C. F. R ) 190. 237. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Comphance ProceeCings. Please refer to this document and note the response options. Be advised that all material you submit in response to this enforcement action is subject to being#

520087004m_notice of amendment_09102008_text.pdf, page 3made pubhcly available If you beheve 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) If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipehne Safety to find facts as alleged in this Notice without further notice to you and to issue a Final Order If, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C. F. R. ) 190. 237). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within [number of daysj days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. In correspondence concerning this matter, please refer to CPF 5-2008-7004M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Chris Hoidal Director, Western Region Pipehne and Hazardous Materials Safety Administration cc. PHP-60 Compliance Registry PHP-500 B. Flanders (0's 122013, 120665, 120666, 120667, 120668, 120669) Encl: Response Opttons for Ptpeltne Operators tn Compliance Proceedzngs#