# CHEVRON PIPE LINE CO — Notice of Amendment

- **operation:** document
- **citation:** CPF 520105026M
- **title:** CHEVRON PIPE LINE CO — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2010-09-21
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 195.230(a), 195.308, 195.402(c)(6), 195.55.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520105026m.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520105026m.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520105026m
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520105026M
**body:**

Notice of Amendment involving CHEVRON PIPE LINE CO. PHMSA's enforcement data identifies the cited regulations as 195.230(a),  195.308,  195.402(c)(6),  195.55. The case was opened on 2010-09-21 and is reported as closed as of 2011-01-10. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520105026M_closure letter_01102011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105026M/520105026M_closure%20letter_01102011.pdf

520105026M_closure letter_01102011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105026M/520105026M_closure%20letter_01102011_text.pdf

520105026M_notice of amendment_09212010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105026M/520105026M_notice%20of%20amendment_09212010.pdf

520105026M_notice of amendment_09212010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105026M/520105026M_notice%20of%20amendment_09212010_text.pdf

520105026M_notice of amendment_09212010_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
September 21, 2010
Ms. Rebecca Roberts
President
Chevron Pipe Line Company
2811 Hayes Road
Houston, TX 77082
CPF 5-2010-5026M
Dear Ms. Roberts:
On June 8-11, 2010, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) and the Washington Utilities and Transportation Commission
(WUTC), pursuant to Chapter 601 of 49 United States Code, inspected Chevron Pipe Line
Company’s procedures for operations, maintenance, and emergency response in Lakewood,
Colorado.
On the basis of the inspection, PHMSA identified the apparent inadequacies found within
Chevron Pipe Line Company’s plans or procedures, as described below:
1. §195.55 Reporting safety-related condition reports.
(b) A report is not required for any safety-related condition that –
(3) Is corrected by repair or replacement in accordance with applicable safety
standards before the deadline for filing the safety-related condition report, except
that reports are required for all conditions under paragraph (a)(1) of this section
other than localized corrosion pitting on an effectively coated and cathodically
protected pipeline.



Chevron Pipe Line Company’s Operations and Maintenance (O&M) Procedural
Manual pertaining to the safety-related condition report is inadequate because
Chevron’s Pipe Line Company’s procedure MIP 102 refers to “ineffective” coating.
That is not consistent with the requirement of § 195.55(b)(3) of Subpart B.
2. §195.230 Welds: Repair or removal of defects.
(a) Each weld that is unacceptable under §195.228 must be removed or repaired.
Except for welds on an offshore pipeline being installed from a pipelay vessel, a
weld must be removed if it has a crack that is more than 8 percent of the weld
length.
Chevron Pipe Line Company O&M Procedural Manual pertaining to repair or removal
of defects is inadequate because Chevron Pipe Line Company’s procedure 5.10.4
allows repair of cracks greater than 8 percent. Per § 195.230(a), a weld must be
removed if it has a crack that is more than 8 percent of the weld length.
3. §195.308 Testing of tie-ins.
Pipe associated with tie-ins must be pressure tested, either with the section to be
tied in or separately.
Chevron Pipe Line Company’s O&M Procedural Manual did not include a provision in
their manual to address tie-ins. Chevron’s O&M Procedural Manual is inadequate
because they did not clearly describe how pipe associated with tie-ins must be pressure
tested as required by §195.308 of Subpart E.
On Saturday, June 12, 2010, Chevron discovered a failure on its crude system pipeline in Salt
Lake City, Utah. According to the results of the accident investigation, the failure had
occurred the previous evening. The investigation also revealed that a fault current imparted
from an electrical transmission facility located directly over the pipeline caused the failure by
creating a hole in the pipeline. That electrical facility had been constructed over the pipeline
during the early 1980s. The probable violations associated with this failure are being
addressed in a separate letter, but the circumstances of the failure indicate that Chevron Pipe
Line Company has inadequacies with their O&M procedures, specifically:
4. §195.402 Procedural Manual for operations, maintenance, and emergency
response.
… (c)(6) Minimizing the potential for hazards identified under paragraph (c)(4) of
this section and the possibility of recurrence of accidents under paragraph (c)(5)
of this section.
Chevron must revise its current patrolling procedures to ensure that their personnel
conducting patrols can properly inspect the surface conditions on or adjacent to each
pipeline right-of-way per the requirements of §195.402 Inspection of rights-of-way and
crossing under navigable waters. The June 12th release reveal that the current aerial2



patrol procedures are inadequate in certain situations, such as patrolling areas with
difficult flying conditions, heavy vegetation, or congested development. The patrolling
method must be adequate to allow discovery of not only new development or other
changed conditions along the ROW, but also any pre-existing conditions that pose a
hazard to the pipeline or are capable of causing a recurrence of past accidents.
Response 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
Compliance Proceedings. 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
made publicly available. If you believe that any portion of your responsive material qualifies
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 believe qualify for
confidential treatment redacted and an explanation of why you believe the redacted
information qualifies 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 Pipeline 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 30 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 5-2010-5026M and, for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
cc: PHP-60 Compliance Registry
PHP-500 J. Stahoviak (#129239)
3

520105026M_closure letter_01102011_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
January 10, 2011
Ms. Rebecca Roberts
President
Chevron Pipe Line Company
4800 Fournace Place
Bellaire, TX 77401
CPF 5-2010-5026M
Dear Ms. Roberts:
On June 8 – 11, 2010, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) and the Washington Utilities and Transportation Commission
(WUTC), pursuant to Chapter 601 of 49 United States Code, inspected Chevron Pipe Line
Company’s procedures for operations, maintenance, and emergency response in Lakewood,
Colorado. As a result of the inspection, Chevron was issued a Notice of Amendment on
September 21, 2010, which proposed amendment of your procedures.
Chevron submitted its amended procedures on December 2, 2010. My staff reviewed the
amended procedures, and it appears that the inadequacies outlined in this Notice of
Amendment have been corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank
you for your cooperation.
Sincerely,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 J. Stahoviak (#129239)
- **truncated:** false
- **body characters:** 8615
