LETTER OF CONCERN

August 7, 2001

CERTIFIED MAIL - RETURN RECEIPT REQUESTED

Mr. B.F. Ference
Vice President, Operations
Exxon Mobil Pipeline Company
800 Bell Street
Houston, TX 77002

CPF No. 3-2001-5016C

Dear Mr. Ference:

On June 26 - 28, July 17 - 20 and July 24 - 26, 2001, a representative of the Central Region, Office of Pipeline Safety, pursuant to Chapter 601 of 49 United States Code, conducted an onsite pipeline safety inspection of your records at the Dallas, TX, Patoka, IL and Doniphan, MO locations and field facilities located within the states of Illinois, and Missouri.

The inspection disclosed the following items of concern. Please give these items your attention.

1. Mobil Pipe Line existing procedures concerning the monitoring of pipeline casings that are shorted and impracticable to clear, are inadequate. Present procedures allows the vents on shorted casings to be monitored by aerial patrol and the pipe/casing to soil annual survey. We were informed that a new ExxonMobil Facilities Inspection and Maintenance Management System document on "Shorted Casing Program" is about to be implemented. This new procedure includes many improvements to the old procedures including acceptable monitoring techniques of shorted casings. We encourage you to implement this new program in the near future.
2. Mobil Pipe Line existing procedures concerning remedial actions required relative to the evaluation of internal corrosion coupons are inadequate. Present procedures do not provide direction to employees regarding when remedial actions are required for initiating corrective actions following the evaluation of internal coupons. We were informed that a new ExxonMobil Facilities Inspection and Maintenance Management System document on "Internal Corrosion Control" is about to be implemented. This new procedure provides for many improvements to the internal corrosion program and will include the above referenced remedial actions. We encourage you to implement this new program in the near future.
3. The MOP for discharge pressure of Yount, Missouri Pump Station was listed at the time of our inspection as 820 psi. A review of discharge records at this location indicated that you had not been operating at the 820 psi. Documentation supporting the MOP determination indicated that the MOP should be 819 psi. We were informed that the MOP for discharge pressure of Yount Pump Station has been corrected and other related over-pressure protection devices set at the correct set points. We were encouraged by your prompt attention to this matter

These items were discussed with your representatives during the inspection. They indicated that the items would receive attention.

The Office of Pipeline Safety appreciates your attention in this matter and good faith efforts to promote continued safety in your organization.

If we can answer any questions or be of any assistance, please contact us at (816) 329-3800. Thank you for your staff's cooperation during this scheduled inspection.

Sincerely,

Ivan A. Huntoon

Director, Central Region

Office of Pipeline Safety