{"operation":"document","citation":"CPF 520170024W","title":"CHEVRON PIPE LINE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-11-08","effective_on":null,"summary":"CLOSED warning letter citing 192.463(a), 192.465(a), 192.465(c), 192.481(b), 192.605(a), 192.615(c)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520170024w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520170024w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520170024w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520170024W","body":"Warning Letter involving CHEVRON PIPE LINE CO. PHMSA's enforcement data identifies the cited regulations as 192.463(a),  192.465(a),  192.465(c),  192.481(b),  192.605(a),  192.615(c)(1). The case was opened on 2017-11-08 and is reported as closed as of 2017-11-08. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520170024W_Warning Letter_11082017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170024W/520170024W_Warning%20Letter_11082017.pdf\n\n520170024W_Warning Letter_11082017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170024W/520170024W_Warning%20Letter_11082017_text.pdf\n\n520170024W_Warning Letter_11082017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL – RETURN RECEIPT REQUESTED\nNovember 8, 2017\nMr. Frank Cassulo\nPresident\nChevron Pipeline Company\n1400 Smith Street\nHouston, TX 77002\nCPF 5-2017-0024W\nDear Mr. Cassulo:\nOn March 20 through 24, and May 8 through 12, 2017, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.), inspected your Coalinga/McKittrick Gas Lines in Houston, Texas, and\nBakersfield, California.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items\ninspected and the probable violations are:\n1. §192.615 Emergency Plans.\n(c) Each operator shall establish and maintain liaison with appropriate fire,\npolice, and other public officials to:\n(1) Learn the responsibility and resources of each government organization that\nmay respond to a gas pipeline emergency.\n\n\n\nA review of the operator’s records for calendar years 2014 through 2016 indicated liaison\nrecords only for the operator’s liquid assets. No records were available for the natural gas\npipelines. The operator was not able to demonstrate through records that they have established\nand maintained liaisons with public officials, fire, or police, in accordance with\n§192.615(c)(1).\n2. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual\nof written procedures for conducting operations and maintenance activities and\nfor emergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed\nand updated by the operator at intervals not exceeding 15 months, but at least\nonce each calendar year. This manual must be prepared before operations of a\npipeline system commence. Appropriate parts of the manual must be kept at\nlocations where operations and maintenance activities are conducted.\nWhile reviewing the operator’s atmospheric corrosion records, it was determined that the\noperator is not following their written procedure for atmospheric corrosion inspections.\nThe operator’s written procedure (MIP 506) requires that the soil-to-air interface be carefully\ninspected above and below ground eighteen (18) inches. While interviewing the field staff\nwho performed these inspections, the field staff did not appear to be aware of the procedural\nrequirements.\n3. §192.481 Atmospheric corrosion control: Monitoring.\n(b) During inspections the operator must give particular attention to pipe at soil-\nto-air interfaces, under thermal insulation, under disbonded coatings, at pipe\nsupports, in splash zones, at deck penetrations, and in spans over water.\nThe operator’s documentation for atmospheric corrosion inspections failed to demonstrate\nthey are paying particular attention to the soil-to-air interfaces, in accordance with\n§192.481(b).\n4. §192.465 External corrosion control: Monitoring.\n(a) Each operator that is under cathodic protection must be tested at least once\neach calendar year, but with intervals not exceeding 15 months, to determine\nwhether the cathodic protection meets the requirements of §192.463. However, if\ntests at those intervals are impractical for separately protected short sections of\nmains or transmission lines, not in excess of 100 feet (30 meters), or separately\nprotected service lines, these pipelines may be surveyed on a sampling basis. At\nleast 10 percent of these protected structures, distributed over the entire system\nmust be surveyed each calendar year, with a different 10 percent checked each\nsubsequent year, so that the entire system is tested in each 10-year period.\n2\n\n\n\nThe operator was not able to provide records to demonstrate that cathodic protection\nmonitoring tests have occurred on the CAL 0601A pipeline. The operator stated that the\npipeline was abandoned and DOT compliance was no longer required. However, the operator\ncould not provide documentation to demonstrate abandonment of this pipeline. Therefore,\ncathodic protection monitoring is required, in accordance with §192.465(a).\n5. §192.465 External corrosion control: Monitoring.\n(c) Each reverse current switch, each diode, and each interference bond whose\nfailure would jeopardize structure protection must be electrically checked for\nproper performance six times each calendar year, but with intervals not\nexceeding 2 ½ months. Each other interference bond must be checked at least\nonce each calendar year, but with intervals not exceeding 15 months.\nThe operator’s records failed to demonstrate electrical checks in October and December,\n2014. The operator failed to perform electrical checks on the critical bond at MP00 (BComp –\nDrain to Station – Route Code CAL 0608), in accordance with §192.465(c).\n6. §192.463 External corrosion control: Cathodic protection.\n(a) Each cathodic protection system required by this subpart must provide a level\nof cathodic protection that complies with one or more of the applicable criteria\ncontained in appendix D of this part. If none of these criteria is applicable, the\ncathodic protection system must provide a level of cathodic protection at least\nequal to that provided by compliance with one or more of these criteria.\nThe operator is utilizing the Appendix D(I)(A)(1) criteria of a negative (cathodic) voltage of\nat least 0.85 volts (-850 mV) but fails to fully consider voltage (IR) drop, as required under\nsection II of Appendix D for a valid interpretation of the voltage measurement.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to\nexceed $209,002 per violation per day the violation persists up to a maximum of $2,090,022\nfor a 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 Pipeline Company being\nsubject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2017-0024W. 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\n3\n\n\n\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nKim West\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 D. Fehling (#155203)\n4","truncated":false,"body_characters":7731}