CHEVRON PRODUCTS COMPANY — Notice of Amendment

party submissionOfficial PDF520176031M_Operator Response to Notice_09122017.pdf#

520176031M_Closure Letter_11092017_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED November 9, 2017 Mr. John S. Watson Chairman and Chief Executive Officer Chevron Products Company 6001 Bollinger Canyon Road San Ramon, CA 94583 CPF 5-2017-6031M Closure Letter Dear Mr. Watson: On July 25 through 29, 2016, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, conducted an on-site pipeline safety inspection of Chevron Products Company’s procedures for the Willbridge Facilities in Portland, Oregon. As a result of the inspection, Chevron Products Company was issued a Notice of Amendment on August 17, 2017 which proposed amendment of your procedures. Chevron Products Company submitted its amended procedures on September 12, 2017. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in the 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, Kim West Acting Director, Western Region Pipeline and Hazardous Materials Safety Administration cc: PHP-60 Compliance Registry PHP-500 J. Owens (#152513 & #152514)#

520176031M_Notice of Amendment_08172017_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED August 17, 2017 Mr. John S. Watson Chairman and Chief Executive Officer Chevron Products Company 6001 Bollinger Canyon Road San Ramon, CA 94583 CPF 5-2017-6031M Dear Mr. Watson: On July 25 through 29, 2016, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Chevron Products Company’s procedures for the Willbridge Facilities in Portland, Oregon. On the basis of the inspection, PHMSA has identified the apparent inadequacy found within Chevron Products Company’s Willbridge Facilities plans or procedures, as described below: 1. §195.583 What must I do to monitor atmospheric corrosion control? (a) You must inspect each pipeline or portion of pipeline that is exposed to the atmosphere for evidence of atmospheric corrosion, as follows: If the pipeline is located Onshore then the frequency of inspection is: At least once every 3 calendar years, but with intervals not exceeding 39 months… (b) During inspections you must give particular attention to pipe at soil-to-air interfaces, under thermal insulation, under disbonded coatings, at pipe supports, in splash zones, at deck penetrations, and in spans over water…#

520176031M_Notice of Amendment_08172017_text.pdf, page 2The operator produced procedures (Chevron Distribution Terminals O&M Manual, Procedure (604.1 Exposed Pipe Coatings) that require atmospheric corrosion inspections “not to exceed 39 months.” Atmospheric corrosion regulation §195.583(a) requires inspections “[a]t least once every 3 calendar years, but with intervals not exceeding 39 months.” The requirement that atmospheric inspections be at least once every 3 calendar months is missing from the operator’s procedure. Additionally, no language in the provided procedure addressed the facility areas slated for particular attention during the inspection as required by §195.583(b). Mr. Jerry Henderson stated that there are weekly, monthly, and 5-year (API) inspections that satisfy regulations requiring atmospheric corrosion inspection every 3 calendar years within 39 months. However, nothing in the produced procedures ties the weekly, monthly, and 5- year checks to the satisfaction of the atmospheric corrosion inspection procedures regulations. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. 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 an Order Directing Amendment. If 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. § 190.206). 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. It is requested (not mandated) that Chevron Products Company maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Kim West, Acting Director, Western Region, Pipeline and Hazardous Materials Safety Administration. In correspondence 2#

520176031M_Notice of Amendment_08172017_text.pdf, page 3concerning this matter, please refer to CPF 5-2017-6031M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Kim West Acting 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. Owens (#152513 & #152514) 3#