{"operation":"document","citation":"CPF 520105022W","title":"EXXONMOBIL PIPELINE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-07-20","effective_on":null,"summary":"CLOSED warning letter citing 195.116(e), 195.403(c), 195.404(a), 195.412(a), 195.420(a), 195.555, 195.583(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520105022w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520105022w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520105022w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520105022W","body":"Warning Letter involving EXXONMOBIL PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 195.116(e),  195.403(c),  195.404(a),  195.412(a),  195.420(a),  195.555,  195.583(c). The case was opened on 2010-07-20 and is reported as closed as of 2010-07-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520105022W_warning letter_07202010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105022W/520105022W_warning%20letter_07202010.pdf\n\n520105022W_warning letter_07202010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105022W/520105022W_warning%20letter_07202010_text.pdf\n\n520105022W_warning letter_07202010_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 20, 2010\nMr. Gary W. Pruessing\nPresident\nExxonMobil Pipeline Company\n800 Bell Street, Room 741D\nHouston, TX 77002\nCPF 5-2010-5022W\nDear Mr. Pruessing:\nOn July 27 to 30, 2009, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected\nExxonMobil’s Silvertip Pipeline from the Silvertip Basin in Southern Montana to the\nExxonMobil Refinery in Billings, Montana.\nAs a result of the inspection, it appears that ExxonMobil has committed probable violations of\nthe Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected\nand the probable violations are:\n1. §195.116 Valves.\nEach valve installed in a pipeline system must comply with the following:\n(e) Each valve other than a check valve must be equipped with a means for\nclearly indicating the position of the valve (open, closed, etc.).\nAt the Silvertip Station, the launcher bypass valves do not have a means for clearly indicating\nthe position of the valves. ExxonMobil is required to have valves with a device that will\nindicate the position of the valves.\n\n\n\n2. § 195.420 Valve maintenance.\n(a) Each operator shall maintain each valve that is necessary for the safe\noperation of its pipeline systems in good working order at all times.\nDuring the field inspection of the Silvertip Pipeline, it was noted that Valve 1060 and Valve\n1061 were leaking crude oil from the bonnets and/or stem packing as there was fresh crude oil\non the soil immediately adjacent the valves. ExxonMobil submitted documentation a few\nweeks after the inspection to indicate that the valves had been replaced with new valves and\nthat the crude oil had been cleaned up. ExxonMobil must ensure that each valve that is\nnecessary for the safe operation of the Silvertip Pipeline is in good working condition at all\ntimes.\n3. § 195.412 Inspection of rights-of-way and crossings under navigable waters.\n(a) Each operator shall, at intervals not exceeding 3 weeks, but at least 26 times\neach calendar year, inspect the surface conditions on or adjacent to each pipeline\nright-of-way. Methods of inspection include walking, driving, flying or other\nappropriate means of traversing the right-of-way.\nDuring the field inspection of the Silvertip Pipeline, it was noted that the pipeline right-of-way\non the south bank of the Clark’s Fork of the Yellowstone River was covered by excessive\nvegetation, and it appeared that it was not visible by aerial patrols. ExxonMobil submitted\ndocumentation a few weeks after the inspection documenting that this area had been cleared of\nvegetation for effective aerial patrols. ExxonMobil must ensure that all portions of the pipeline\nright-of-way are cleared of vegetation to ensure that it is visible to aerial patrols. If removal of\nthe vegetation along portions of the right-of-way is impractical, ExxonMobil must inspect\nthose portions of the right of way by other means, i.e. walking or driving.\n4. § 195.404 Maps and records.\n(a) Each operator shall maintain current maps and records of its pipeline systems\nthat include at least the following information:\n(1) Location and identification of the following pipeline facilities:\n(i) Breakout tanks;\n(ii) Pump stations;\n(iii) Scraper and sphere facilities;\n(iv) Pipeline valves;\n(v) Facilities to which §195.402(c)(9) applies;\n(vi) Rights-of-way; and\n(vii) Safety devices to which §195.428 applies.\n(2) All crossings of public roads, railroads, rivers, buried utilities, and foreign\npipelines.\n\n\n\n(3) The maximum operating pressure of each pipeline.\n(4) The diameter, grade, type, and nominal wall thickness of all pipe.\nDuring the review of the maps and drawings of the Silvertip Pipeline, it was noted that the\npipeline alignment drawings did not include information regarding the pipeline reconditioning\nproject that was conducted near Rock Creek from 1999 to 2001, and the pipeline relocation\nthat was performed along Interstate 90 near the Conoco Refinery in Billings several years ago.\nIn addition, a mainline valve shown on the map near the town of Bridger appears to no longer\nexist. ExxonMobil must update the alignment drawings of the Silvertip Pipeline to ensure that\nthe drawings accurately reflect the pipeline location and facilities installed as prescribed in\nsection 195.404.\n5. § 195.403 Emergency response training.\n(c) Each operator shall require and verify that its supervisors maintain a\nthorough knowledge of that portion of the emergency response procedures\nestablished under 195.402 for which they are responsible to ensure compliance.\nDuring the records review of the Silvertip Pipeline, it was noted that ExxonMobil relies solely\non a self certification process to verify supervisor knowledge of emergency response\nprocedures. ExxonMobil must develop a process that does not rely on self certification to\nensure that its supervisors maintain a thorough knowledge of that portion of the emergency\nresponse procedures established under 195.402 for which they are responsible.\n6. § 195.555 What are the qualifications for supervisors?\nYou must require and verify that supervisors maintain a thorough knowledge of\nthat portion of the corrosion control procedures established under §195.402(c)(3)\nfor which they are responsible for insuring compliance.\nDuring the records review of the Silvertip Pipeline, it was noted that ExxonMobil relies solely\non a self certification process to verify supervisor knowledge of corrosion control procedures.\nExxonMobil must develop a process that does not rely on self certification to ensure that its\nsupervisors maintain a thorough knowledge of that portion of the corrosion control procedures\nestablished under §195.402(c)(3) for which they are responsible.\n7. § 195.583 What must I do to monitor atmospheric corrosion control?\n(c) If you find atmospheric corrosion during an inspection, you must provide\nprotection against the corrosion as required by §195.581.\n\n\n\nDuring the records review of the Silvertip Pipeline, it was noted that ExxonMobil did not\nfollow up on atmospheric corrosion issues that were identified during their three (3) year\natmospheric corrosion surveys in a timely manner. ExxonMobil must provide protection\nagainst atmospheric corrosion identified on the Silvertip Pipeline in a timely manner.\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 violation. 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\nidentified in this letter. Failure to do so will result in ExxonMobil being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2010-5022W. 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 portion\nof your responsive material qualifies 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 believe qualify for confidential treatment redacted and an explanation of why\nyou believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 M. Petronis (#123899)","truncated":false,"body_characters":8473}