{"operation":"document","citation":"CPF 520105006W","title":"CHEVRON PRODUCTS COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-03-02","effective_on":null,"summary":"CLOSED warning letter citing 195.406(b), 195.581, 195.583(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520105006w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520105006w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520105006w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520105006W","body":"Warning Letter involving CHEVRON PRODUCTS COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.406(b),  195.581,  195.583(a). The case was opened on 2010-03-02 and is reported as closed as of 2010-03-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520105006W_warning letter_03022010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105006W/520105006W_warning%20letter_03022010.pdf\n\n520105006W_warning letter_03022010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105006W/520105006W_warning%20letter_03022010_text.pdf\n\n520105006W_warning letter_03022010_text.pdf\n\nWARNING LETTER\nVIA FEDERAL EXPRESS (FEDEX) – 7984 3805 5087\nMarch 2, 2010\nMr. Dave Feiglstok\nGeneral Manager\nChevron USA, Inc.\n6001 Bollinger Canyon Rd.\nSan Ramon, CA 94583\nCPF 5-2010-5006W\nDear Mr. Feiglstok:\nOn November 19, 2009, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected\nChevron USA, Inc.’s (Chevron) facilities and records in Hilo, Hawaii.\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\nthe probable violations are:\n1. §195.406 Maximum operating pressure.\n(b) No operator may permit the pressure in a pipeline during surges or other\nvariations from normal operations to exceed 110 percent of the operating pressure\nlimit established under paragraph (a) of this section. Each operator must provide\nadequate controls and protective equipment to control the pressure within this limit.\nOn July 13, 2009, at 1530 hrs., Chevron overpressured the Hawaiian Electric Light Company’s\n(HELCO) pipeline to 588 PSI. The MOP of the HELCO pipeline is 522 PSI. This\noverpressure of the HELCO pipeline by 113% exceeds that required by 195.406 (b). Chevron\n\n\n\nsubmitted a Safety Related Condition Report on July 20, 2009, stating that “Pump 120\nrestarted unexpectedly and pressured the HELCO pipeline.”\n2. §195.581 Which pipelines must I protect against atmospheric corrosion and what\ncoating material may I use?\n(a) You must clean and coat each pipeline or portion of pipeline that is exposed to the\natmosphere, except pipelines under paragraph (c) of this section.\n(b) Coating material must be suitable for the prevention of atmospheric corrosion.\n(c) Except portions of pipelines in offshore splash zones or soil-to-air interfaces, you\nneed not protect against atmospheric corrosion any pipeline for which you\ndemonstrate by test, investigation, or experience appropriate to the environment of\nthe pipeline that corrosion will-\n(1) Only be a light surface oxide; or\n(2) Not affect the safe operation of the pipeline before the next scheduled inspection.\nChevron failed to clean and coat each pipeline or portion of pipeline that is exposed to the\natmosphere with a coating that is suitable for the prevention of atmospheric corrosion.\nSpecifically, the 250’ of 8” diameter above-ground regulated piping and pig launcher that is\ncontained within the Hilo Marine Terminal facility exhibits extensive atmospheric corrosion.\nFurther, Chevron provided no record or investigation to demonstrate that the corrosion is only\na light surface oxide or that the corrosion will not affect the safe operation of the pipeline\nbefore the next scheduled inspection.\n3. §195.583 What must I do to monitor atmospheric corrosion control?\n(a) You must inspect each pipeline or portion of pipeline that is exposed to the\natmosphere for evidence of atmospheric corrosion, as follows:\nIf the pipeline is\nlocated:\nThen the frequency of\ninspection is:\nOnshore………………. At least once every 3\ncalendar years, but with\nintervals not exceeding\n39 months.\n(c) If you find atmospheric corrosion during an inspection, you must provide\nprotection against the corrosion as required by Sec. 195.581.\nChevron failed to provide atmospheric corrosion monitoring records in accordance with\n195.581 (a).\n2\n\n\n\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 involved 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 item(s)\nidentified in this letter. Failure to do so will result in Chevron USA, Inc. being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2010-5006W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C.552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under 5\nU.S.C.552(b).\nSincerely,\nDennis Hinnah\nDeputy Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Strawn (#127266)\n3","truncated":false,"body_characters":5471}