# PHILLIPS 66 PIPELINE LLC — Notice of Amendment

**Citation:** CPF 320075015M  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2007-03-16

CLOSED notice of amendment citing 195.505.

## Document text

Notice of Amendment involving PHILLIPS 66 PIPELINE LLC. PHMSA's enforcement data identifies the cited regulation as 195.505. The case was opened on 2007-03-16 and is reported as closed as of 2007-07-19. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320075015M_Notice Of Amendment_03162007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320075015M/320075015M_Notice%20Of%20Amendment_03162007.pdf

320075015M_Operator Response_04252007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320075015M/320075015M_Operator%20Response_04252007.pdf

320075015M_Notice Of Amendment_03162007.pdf

@
U.S. Deportment
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901 Locusl Street, Suite 462
Kansas City, MO 64106-2641
}J|AR 2 3 ?007
NOTICE OF AMENDMENT
CERTIX'IED MAIL - RETURN RDCEIPT REOUESTED
March16,2007
Ms. Margaret Yaege
General Manager of Pipelines and Terminals
ConocoPhillips Pipe Line Company
600 N. Dairy Ashford
Houston, TX 74079
cPx'3-2007-5015M
Dear Ms. Yaege:
On October 16-20, October 30 - November 3, November 13-17 and December 71-15,2006,a
representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to
Chapter 601 of 49 United States Code inspected yoru pipeline facilities in Illinois, Kansas, Missouri,
and Indiana.
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
ConocoPhillips Pipe Line Company's plans or procedures and are described below:
1. 5195.402 Procedural Manual for Operations, Maintenance and Emergencies.
$195.a02(a) requires that each operator shall prepare and follow for each pipeline
system a manual of written procedures for conducting normal operations and
maintenance activities and handling abnormal operations and emergencies.
$195.a02(c) indicates that the manual required by paragraph (a) of this section must
include procedures for the following to provide safety during maintenance and normal
operations:



(3) Operating, maintaining, and repairing the pipeline system in accordance with each
of the requirements of this subpart and subpart H of this part.
Review of the Operation and Maintenance (O&M) manual found that the fpllowing
requirements were not adequately covered in the manual or needed to be expanded to provide
additional guidance to your personnel. Item (a) is required to be included in the manual by
$ les.a02(c)(3).
1.(a) $195.505Qualificationprogram.
Each operator shall have and follow a written qualification program.
The program shall include provisions to:
(") Identify covered tasks;
(b) Ensure through evaluation that individuals performing
covered tasks are qualified;
The Operator Qualification Program's evaluation forms did not provide sufficient
information to evaluate an individual's performance of a covered task to ensure
they were qualified. ConocoPhillips' evaluation checklist form for "Field
Inspection and Testing of Overfill Protective Devices On Aboveground Breakout
Tanks/Vessels" did not adequately address appropriate actions to be taken for the
different overfrll mechanisms used.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. $ 60108(a) and 49 C.F.R. $ 190.237. 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 qualihes for
confidential treatment under 5 U.S.C. 552(b), along with the complete original document you
must provide a second copy bf the document with the portions you believe qualiS 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). lf 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 a Final Order.
If, after opportunity for a hearing, 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. $ 190.237). 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 witten request for good cause. Once the inadequacies identified herein have been
addressed in your amended procedures, this enforcement action will be closed.
In correspondence conceming this matter, please refer to CPn.3-2007-5015M and, for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
q.** 1/r/,,ffi'-
Ivan A. Huntoon
Director, Central Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings



Response Options for Pipeline Operators in Compliance Proceedings
The requirements of 49 C.F.R. Part 190, Subpart B ($$ 190.201-190.237) govem response to
Notices issued by a Regional Director, Pipeline and Hazardous Materials Safety Administration
(PHMSA).
Be advised that all material submitted by a respondent in response to an enforcement action is
subject to being made publicly available. Ifyou believe that any portion ofyour 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 ofwhy you believe the
redacted information qualifies for confidential treatrnent under 5 U.S.C. 552(b).
Procedures for Resnondins to a NOTICD OF PROBABLE VIOLATION:
Within 30 days of receip of a Notice of Probable Violation, the respondent shall respond
to the Regional Director who issued the Notice in the following way:
a. When the Notice cgntains a proposed CIVIL PENALTY*::
l. Pay the proposed civil penalty and advise the Regional Director of the
payment. This authorizes PHMSA to make findings and to close the case
with prejudice to the respondent. Payment terms are outlined below;
2. Submit written explanations, information, or other materials in response to
the allegations and/or seek elimination or mitigation of the proposed civil
penalty. Refer to 49 C.F.R. $ 190.225 for assessment considerations,
which include the respondent's ability to pay and the effsct on the
respondent's ability to stay in business, upon which civil penalties are
based; or
3. Request a hearing as described below to contest the allegations and/or
proposed assessment ofa civil penalty.
b. When the Notice contains a proposed COMPLIANCE ORDER* -
1. Notiff the Regional Director that you intend to take the steps in the
proposed compliance order;
Submit written explanations, information, or other materials in answer to
the allegations in the Notice and object to or seek clarification of the
proposed compliance order items in whole or in part; or
J .
Request a hearing as described below to contest the allegations and/or
proposed compliance order items;
I of5



II.
m,
c. When the Notice contains a WARNING ITEM -
No written rcsponse is required. The respondent is wamed that if it does not
take appropriate action to correct these items, enforcement action will be
taken ifa subsequent inspection reveals a violation.
* Failure of the respondent to respond to the Notice within 30 days of receipt
constitutes a waiver of the right to contest the allegations in the Notice and authorizes
the Associate Administrator for Pipeline Safety to find facts as alleged in the Notice
without further notice to the respondent and to issue a Final Order.
Procedures for Resnondine to a NOTICE OF'AMENDMENT*--
Within 30 days of receipt of a Notice of Amendment, the respondent shall respond to the
Regional Director who issued the Notice in the following way:
a. Notifu the Regional Director of your plans to address the inadequacies
identified in the Notice:
b. Submit written explanations, information, or other materials in answer to the
allegations in the Notice and/or object to or seek clarification ofthe proposed
amendment items in whole or in part; or
Request a hearing as described below to contest the allegations in the Notice.
* Failure of the respondent to respond to the Notice within 30 days of receipt
constitutes a waiver of the right to contest the allegations in the Notice and authorizes
the Associate Adminishator for Pipeline Safety to find facts as alleged in the Notice
without fi.rther notice to the respondent and to issue a Final Order.
Procedure for Requesting a Hearins
A request for a hearing must be in writing and accompanied by a statement of the issues
that the respondent intends to raise at the hearing. The issues rnay relate to the
allegations, new information, or to the proposed compliance order or proposed civil
penalty amoult. Refer to 49 C.F.R. $ 190.225 for assessment considerations upon which
civil penalties are based. A respondent's failure to specify an issue may result in waiver
ofthe right to raise that issue at the hearing. The respondent's request must also indicate
whether or not respondent will be represented by counsel at the hearing. Failure to
request a hearing in writing within 30 days of receipt of a Notice waives the right to a
hearing, In addition, if the amount of the proposed civil penalty or the proposed
corrective action is less than $10,000, the hearing will be held by telephone, unless the
respondent submits a written request for an in-person hearing. Complete hearing
procedures can be found at 49 C.F.R. $ 190.211.
2 of5



IV.
V.
vI.
Extensions of Time
An extension of time to preparc an appropriate response to a Notice may be granted, at
the agency's discretion, following submittal of a written request to the Regional Director.
The request must indicate the amount of time needed and the reasons for the extension.
The request must be submitted within 30 days of receipt of the Notice.'
Freedom of Information Act
Any material prepared by PHMSA, including the violation report, the Notice, and any
order issued in this case, and any material provided to PHMSA by the respondent, may
be considered public information and subject to disclosure under the Freedom of
Information Act (FOIA). If the information you provide is security sensitive, privileged,
confidential or may cause your company competitive disadvantages, please cleady
identify the material and provide justification why the documents, or portions of a
document, should not be released under FOIA. If we receive a request for your material,
we will noti$' you if PHMSA, after reviewing the materials and your provided
justificatioq determines that withholding the materials does not meet any exemption
provided under the FOIA. You may appeal the agency's decision to release material
under the FOIA at that time. Your appeal will stay the release of those materials until a
final decision is made.
Small Business Resulatorv Enforcement Fairness Act Information
The Small Business and Agricultural Regulatory Enforcement Ombudsman and 10
Regional Faimess Boards were established to receive comments from small businesses
about federal agency enforcement actions. The Ombudsman will annually evaluate the
enforcement activities and rate eaoh agency's responsiveness to small business. If you
wish to comment on the enforcement actions of the Pipeline and Hazardous Materials
Safety Administration, call 1-888-REG-FAIR (l-888-734-3247) or go to
h@ :/iwww. sba, gov/ombudsman/dsp_faq.html.
3 of 5



vII. PAYMENT INSTRUCTIONS
Civil Penalty Payments of Less Than $10,000
Palirnent of a civil penalty of less than $ 10,000 proposed or assessed, under Subpart B ofPart
190 of the Pipeline Safety Regulations can be made by certified check, money order or wire
transfer. Payment by certified check or money order (containing the CPF Number for this case)
should be made payable to the "Deparhnent of Transportation" and should be sent to:
Federal Aviation Administration
Mike Monroney Aeronautical Center
Financial Operations Division (AMZ-300) P.O. Box 25082
Oklahoma City, OK 7 3 125 -4915
Wire transfer payments of less than $10,000 may be made through the Federal Reserve
Communications System (Fedwire) to the account of the U.S. Treasury. Detailed instructions are
provided below. Quesfions concerning wire transfer should be directed to the Financial
Operations Division at (405) 954-8893, or at the above address.
Civil Penalty Payments of $10,000 or more
Payment ofa civil penalty of$10,000 or more proposed or assessed under Subpart B ofPart 190
of the Pipeline Safety Regulations must be made wire transfer (49 C.F.R. $ 89.21 (bX3),
through the Federal Reserve Communications System (Fedwire) to the account of the U.S.
Treasury. Detailed instructions are provided below. Questions conceming wire transfers should
be directed to the Financial Operations Division at (405) 954-8893, or at the above address.
INSTRUCTIONS FOR ELECTRONIC FTJND TRA}ISFERS
(I) RECEIVER ABA NO.
02r030004
(2) TYPE/SUB-TYPE
(Provided by sending bank)
(3) SENpTNGBANKABANO.
(Provided by sending bank) (4) SENpTNGBANKREFNO.
(Provided by sending bank)
(s) AMOUNT (6) SENDING BANKNAME
(Provided by sending bank)
(7) RECEIVERNAME
TREASNYC
(8) PROpUCT COpE
(Normally CTR, or as provided by sending
bank)
(9) BENEFICIAL (BNN : AGENCY
LOCATION CODE
BNF =/ALC-69-14-0001
(10) REASONS FOR PAYMENT
Example: PHMSA - CPF # / Ticket
Number/Pipeline Assessment number
4 of 5



INSTRUCTIONS: You, as sender of the wire transfer, must provide the sending bank with the
information for blocks (1), (5), (7), (9), and (10). The information provided in Blocks (1), (7),
and (9) are constant and remain the same for all wire transfers to the Pipeline and Hazardous
Materials Safety Administration, Department of Transportation.
Block#l - RECEIVER ABA NO. - "021030004". Ensure the sending bank enters this 9-digit
identification number; it represents the routing symbol for the U.S. Treasury at the Federal
Reserve Bank inNew York.
Block #5 - AMOUNT - You as the sender provide the amount of the transfer. Please be sure the
transf€r amount is punctuated with commas and a decimal point. EXAMPLE: $10.000.00
Block #7 - RECEIVERNAME - "TREAS NYC". Ensure the sending bank enters this
abbreviation. It must be used for all wire transfers to the Treasury Department.
Block#9 - BENEFICI.A.L - AGENCY LOCATION CODE - I'BNF=/ALC-69-14-0001". Ensure
the sending bank enters this information. This is the Agency Location Code for the Pipeline and
Hazardous Materials Safety Administration, Deparbnent of Transportation.
Block #10 - REASON FOR PAYMENT - 6'AC-payment for PHMSA Case # / To ensure your
wire transfer is credited properly, enter the case number/ticket number or Pipeline Assessment number,
and country."
NOTE: A wire transfer must comply with the format and instructions or the Department cannot
accept the wire transfer. You as the sender can assist this process by notifying the Financial
Operations Division (405) 954-8893 at the time you send the wire transfer.
February 2007
5 of5

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/320075015M>
- Source ID: `phmsa-enforcement`
- SHA-256: `2030855a48803775b9c029159ca1b693101ac26d99ee87e82736cc2d548e858a`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T09:47:55.230Z
- Document slug: `phmsa-enforcement-320075015m`

### Source metadata

```json
{
  "cpf": "320075015M",
  "operator": "PHILLIPS 66 PIPELINE LLC",
  "region": "Central",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.505"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
    {
      "name": "320075015M_Notice Of Amendment_03162007.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/320075015M/320075015M_Notice%20Of%20Amendment_03162007.pdf",
      "bytes": 352758,
      "category": "agency_document"
    },
    {
      "name": "320075015M_Operator Response_04252007.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/320075015M/320075015M_Operator%20Response_04252007.pdf",
      "bytes": 286581,
      "category": "party_submission"
    }
  ],
  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "PHILLIPS 66 PIPELINE LLC"
}
```
