{"operation":"document","citation":"CPF 520176031M","title":"CHEVRON PRODUCTS COMPANY — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-08-17","effective_on":null,"summary":"CLOSED notice of amendment citing 195.583(a), 195.583(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520176031m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520176031m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520176031m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520176031M","body":"Notice of Amendment involving CHEVRON PRODUCTS COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.583(a),  195.583(b). The case was opened on 2017-08-17 and is reported as closed as of 2017-11-09. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520176031M_Closure Letter_11092017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176031M/520176031M_Closure%20Letter_11092017.pdf\n\n520176031M_Closure Letter_11092017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176031M/520176031M_Closure%20Letter_11092017_text.pdf\n\n520176031M_Notice of Amendment_08172017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176031M/520176031M_Notice%20of%20Amendment_08172017.pdf\n\n520176031M_Notice of Amendment_08172017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176031M/520176031M_Notice%20of%20Amendment_08172017_text.pdf\n\n520176031M_Operator Response to Notice_09122017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176031M/520176031M_Operator%20Response%20to%20Notice_09122017.pdf\n\n520176031M_Closure Letter_11092017_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 9, 2017\nMr. John S. Watson\nChairman and Chief Executive Officer\nChevron Products Company\n6001 Bollinger Canyon Road\nSan Ramon, CA 94583\nCPF 5-2017-6031M\nClosure Letter\nDear Mr. Watson:\nOn July 25 through 29, 2016, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, conducted an\non-site pipeline safety inspection of Chevron Products Company’s procedures for the Willbridge\nFacilities in Portland, Oregon. As a result of the inspection, Chevron Products Company was\nissued a Notice of Amendment on August 17, 2017 which proposed amendment of your\nprocedures.\nChevron Products Company submitted its amended procedures on September 12, 2017. My staff\nreviewed the amended procedures, and it appears that the inadequacies outlined in the Notice of\nAmendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nKim West\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Owens (#152513 & #152514)\n\n520176031M_Notice of Amendment_08172017_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 17, 2017\nMr. John S. Watson\nChairman and Chief Executive Officer\nChevron Products Company\n6001 Bollinger Canyon Road\nSan Ramon, CA 94583\nCPF 5-2017-6031M\nDear Mr. Watson:\nOn July 25 through 29, 2016, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected\nChevron Products Company’s procedures for the Willbridge Facilities in Portland, Oregon.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within\nChevron Products Company’s Willbridge Facilities plans or procedures, as described below:\n1. §195.583 What must I do to monitor atmospheric corrosion control?\n(a) You must inspect each pipeline or portion of pipeline that is exposed to the\natmosphere for evidence of atmospheric corrosion, as follows: If the pipeline is\nlocated Onshore then the frequency of inspection is: At least once every 3\ncalendar years, but with intervals not exceeding 39 months…\n(b) During inspections you must give particular attention to pipe at soil-to-air\ninterfaces, under thermal insulation, under disbonded coatings, at pipe supports,\nin splash zones, at deck penetrations, and in spans over water…\n\n\n\nThe operator produced procedures (Chevron Distribution Terminals O&M Manual, Procedure\n(604.1 Exposed Pipe Coatings) that require atmospheric corrosion inspections “not to exceed\n39 months.” Atmospheric corrosion regulation §195.583(a) requires inspections “[a]t least\nonce every 3 calendar years, but with intervals not exceeding 39 months.” The requirement\nthat atmospheric inspections be at least once every 3 calendar months is missing from the\noperator’s procedure. Additionally, no language in the provided procedure addressed the\nfacility areas slated for particular attention during the inspection as required by §195.583(b).\nMr. Jerry Henderson stated that there are weekly, monthly, and 5-year (API) inspections that\nsatisfy regulations requiring atmospheric corrosion inspection every 3 calendar years within\n39 months. However, nothing in the produced procedures ties the weekly, monthly, and 5-\nyear checks to the satisfaction of the atmospheric corrosion inspection procedures regulations.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in\nthis Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as\nalleged in this Notice without further notice to you and to issue an Order Directing\nAmendment. If your plans or procedures are found inadequate as alleged in this Notice, you\nmay be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. §\n190.206). If you are not contesting this Notice, we propose that you submit your amended\nprocedures to my office within 30 days of receipt of this Notice. This period may be extended\nby written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that Chevron Products Company maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Kim West, Acting Director,\nWestern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\n2\n\n\n\nconcerning this matter, please refer to CPF 5-2017-6031M and, for each document you\nsubmit, please provide a copy in electronic format whenever possible.\nSincerely,\nKim West\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 J. Owens (#152513 & #152514)\n3","truncated":false,"body_characters":7283}