{"operation":"document","citation":"CPF 520140005W","title":"CHEVRON PIPE LINE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-11-12","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520140005w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520140005w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520140005w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520140005W","body":"Warning Letter involving CHEVRON PIPE LINE CO. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2014-11-12 and is reported as closed as of 2014-11-12. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520140005W_warning letter_11122014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520140005W/520140005W_warning%20letter_11122014.pdf\n\n520140005W_warning letter_11122014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520140005W/520140005W_warning%20letter_11122014_text.pdf\n\n520140005W_warning letter_11122014_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 12, 2014\nMr. Randy Curry\nPresident\nChevron Pipe Line Co.\n4800 Fournace Place Rm. C382A\nBellaire, TX 77401-2324\nCPF 5-2014-0005W\nDear Mr. Curry:\nOn September 17-20, 2012, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your\nNorthern California Gas Lines in Pittsburg, California.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the\nprobable violation is:\n1. §192.605(a) Procedural manual for operations, maintenance, and emergencies\nEach operator shall include the following in its operating and maintenance plan:\n\n\n\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least one each\ncalendar year. This manual must be prepared before operations of a pipeline\nsystem commence. Appropriate parts of the manual must be kept at locations\nwhere operations and maintenance activities are conducted.\nChevron Pipe Line Company (Chevron) did not follow their procedure, Core Gas Pipeline\nOperating and Maintenance 9.0 Maintenance Procedures Section 9.3.4.2, on calibrating gas\ndetection instruments. The procedure stated that Chevron personnel were to “calibrate each leak\ndetection instrument in accordance with the manufacturer's recommended calibration\ninstructions” and also “on a regular schedule, considering the type of instrument and how the\ninstrument is used.” The procedure also reminded personnel to “check hydrogen flame ionization\n(HFI) systems and CGI instruments for calibration at least once each month while in use.”\nChevron was found to have insufficient documented evidence of periodic calibration of its gas\ndetection instruments. A single record of calibration for a DP4 instrument performed by Heath\nConsultants on October 28, 2009 was found during the inspection. No calibration records, as\nrequired by their leak survey procedures, were found from 2010 and 2011 to validate the 2010\nand 2011 annual leak surveys, in which a gas detection instrument was used. Chevron must\nfollow its procedures in accordance with 192.605(a), and conduct and document periodic\ncalibration of its gas detection instruments.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item identified in this letter.\nFailure to do so will result in Chevron Pipe Line Co. being subject to additional enforcement\naction.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2014-0005W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\n2\n\n\n\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 C. Ishikawa (#138142)\n3","truncated":false,"body_characters":4889}