POST INSPECTION MEMORANDUM
Director Approval: Chris Hoidal __________
Peer Review: Tom Finch __________
Senior Engineer: Dave Lykken __________
Inspector Approval: Al Jones __________
WUTC Docket No: PL-050199
Date: June 2, 2005
Operator Inspected:
ChevronTexaco Pipeline Company Opid: 2731 Region: Western
2811 Hayes Road
Houston, TX 77082
Unit Inspected: Headquarters
Unit ID.: 5145
Unit Type: Interstate Hazardous Liquids
Inspection Type: Team O&M Inspection
Record Location: Houston, TX
Inspection Dates: May 23 – 26, 2005
AFOD: 6
Contact: Randy Burke, ChevronTexaco DOT Specialist
Phone: 281 596 3569 Fax: 281 596 3626 Emergency: 800 762 3404
Facilities Inspected:
Reviewed O&M procedures that covered the entire ChevronTexaco pipeline system. This was
done at ChevronTexaco headquarters in Houston, TX.
Persons Interviewed:
Randy Burk, DOT Compliance Coordinator
Gary Saenz, DOT Compliance Coordinator
General Observations:
ChevronTexaco has expressed the intent to create a master reference manual called the Core
Corporate Liquids Manual. The intent is to have very general procedures in this document that
will provide references to the detailed procedure in the Maintenance and Inspection Procedures
(MIP). The following general observations were noted:
1. There are numerous references to natural gas regulations in the Liquids Corporate Manual.
The document needs to be reviewed and all references to Part 192 removed to ensure
personnel do not become confused and perform their duties to the wrong procedures.
2. ChevronTexaco expressed the intent to distribute this manual after this Manual Review and
provide training on the new manuals. Confusion could pose a threat to operations and
maintenance personnel as well as to the safe operations of the pipeline systems.
3. There appears to be confusion with regard to exactly where certain procedures were located.
ChevronTexaco should review the corporate liquid manual to ensure correct reference to
applicable MIPs to minimize contradictions and duplications between the core manual and
the MIPs.
Potential Issues Contained in Procedural Manual for
Operations, Maintenance and Emergencies:
1. '195.5 Conversion to Service:
Manual needs a reference to Maintenance and Inspection Procedures (MIP) manuals for
specific requirements if one or more of the variables required for the design equation in
195.1-6 is unknown.
2. '195.5 Supplemental Report:
Manual needs to include supplemental report within 30 days of substantial information
change or addition.
3. '195.120(a) Passage of ILI Devices:
Manual needs to reference the corporate manual procedure with their procedure in the
Emergency Research Technical Company (ERTC) pipeline manual Section 453 (design
manual). Also, as it pertains to this requirement define key terms, such as “line section.”
4. '195.228, 195.230, & 195.234 NDT Procedures:
The Corporate manual references Section 6 of API 1104. This section has changed to
Section 9 in the new referenced edition of API 1104.
5. '195.402(c)(11) Minimizing the Likelihood of Accidental Ignition in Areas
Identified Under 195.402(c)(4):
Procedures do not reference immediate response areas specifically. ChevronTexaco
needs to reference the appropriate sections of other manuals pertaining to “immediate
response areas” in their Core Liquids Manual for this requirement.
6. '195.402(e)(1) Emergency Procedures:
ChevronTexaco needs to have procedures for the classification of notices of events in
their corporate manual. Appendix H, which was referenced in this procedure, contained
the requirements for classifying natural gas leaks, which does not apply to the
requirements of Part 195.
7. '195.402(e)(5) Emergency Procedures:
ChevronTexaco needs to add crude oil, petroleum products and CO2 to the procedure
8.10 in their corporate manual.
8. '195.402(e)(8) Emergency Procedures:
Procedure states that field personnel responding to a HVL release should know the extent
of a vapor cloud from a worst-case release before arriving on the scene. ChevronTexaco
could demonstrate how they should establish the extent of the vapor cloud from a worse
case release on HVL lines.
9. '195.(a)(1)(i), (ii), and (iii) Maps & Records:
The corporate manual uses the term “Major Facilities” instead of breakout tanks, pump
stations, and scraper and sphere facilities. ChevronTexaco needs to define “Major
Facilities.”
10. '195.410(a)(2) Line Markers:
The corporate manual did not address the correct letter characteristics and warning
information requirements for line markers.
11. '195.430(c) Fire Equipment:
Company must add a reference to specific procedures for locating fire fighting equipment,
i.e., ERTC Fire Protection Manual Section 3738.
12. '195.432(b) Breakout Tank Procedures:
Company needs to spell out the tank inspection requirements of this code section in their
corporate manual.
13 '195.573(e) Corrosion Control Procedures:
Specific procedures are in MIP 501, Section 5.5.1. The procedure states remediation
when interference is discovered within 6 months. This needs to be more prompt and
comply with referenced Part 195.401(b) that states any condition that could adversely
affect the safe operation of a pipeline system, shall be corrected within a reasonable time.
Remediation for interference type of corrosion shall be addressed as soon as possible.
14. '195.577(b) Corrosion Control Procedures:
ChevronTexaco needs to demonstrate cathodic protection design requirements are in
place to minimize the effects of detrimental stray currents on adjacent metallic structures.
Comments:
O&M Inspection Team consisted of:
Jason Terry, OPS Southwest Region, Lead
Peter Katchmar, OPS Western Region
Buddy Sheets, OPS Southwest Region
Joe Mataich, OPS Southern Region
Al Jones, WUTC
Recommendations:
The above items that are required to be in the O&M manual should be verified.