# PHILLIPS 66 PIPELINE LLC — Notice of Probable Violation

**Citation:** CPF 420055037  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2005-10-11

CLOSED notice of probable violation citing 195.452(f), 195.452(h)(2).

## Document text

Notice of Probable Violation involving PHILLIPS 66 PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.452(f),  195.452(h)(2). The case was opened on 2005-10-11 and is reported as closed as of 2007-02-09. Proposed civil penalty: $200,000. Assessed civil penalty: $200,000. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420055037_Final Order_01092007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420055037/420055037_Final%20Order_01092007.pdf

420055037_Notice_Letter_10112005.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420055037/420055037_Notice_Letter_10112005.pdf

CPF_NO_4-2005-5037.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420055037/CPF_NO_4-2005-5037.pdf

420055037_Final Order_01092007.pdf

U.S. Department 400 Seventh Street, S.W.
of Transportation Washington, D.C. 20590
Pipeline and Hazardous
Materials Safety Administration
JAEI - 9 2007
Ms. Margaret Yaege
President
ConocoPhillips Pipe Line Company
600 N Dairy Ashford St
Houston, TX 77079- 1 100
Re: CPF No. 4-2005-5037
Dear Ms. Yaege:
Enclosed is the Final Order issued by the Acting Associate Administrator for Pipeline Safety
in the above-referenced case. It makes findings of violation and assesses a civil penalty of
$200,000. The penalty payment terms are set forth in the Final Order. This enforcement action
closes automatically upon payment. Your receipt of the Final Order constitutes service under 49
C.F.R. 8 190.5.
Sincerely,
V
James Reynolds
Pipeline ~ o m ~ l i a n c e Registry
Office of Pipeline Safety
Enclosure
VIA CERTIFIED MAIL -RETURN RECEIPT REQUESTED



DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, DC 20590
In the Matter of
ConocoPhillips Pipe Line Company, ) CPF NO. 4-2005-5037
Respondent
) 1
1
)
)
FINAL ORDER
On June 7-10 and 20-24, 2005, pursuant to 49 U.S.C. 5 601 17, representatives of the Pipeline
and Hazardous Materials Safety Administration conducted an on-site pipeline safety inspection
of Respondent's written integrity management program in Ponca City, Oklahoma. As a result of
the inspection, the Director, Southwest Region, issued to Respondent, by letter dated October 11,
2005, a Notice of Probable Violation and Proposed Civil Penalty (Notice). In accordance with
49 C.F.R. $ 190.207, the Notice proposed finding that Respondent had committed violations
of 49 C.F.R. 5 195.452 and proposed assessing a civil penalty of $200,000 for the alleged
violations.
Respondent responded to the Notice by letter dated November 16,2005 (Response). Respondent
contested the allegations of violation, offered information in explanation of the allegations and
requested that the proposed civil penalty be reduced or eliminated. Respondent did not request a
hearing, and therefore has waived its right to one.
FINDINGS OF VIOLATION
Item 1 in the Notice alleged that Respondent violated 49 C.F.R. 5 195.452(f)(4) and (h)(l) by
failing to reduce operating pressure after Respondent discovered 12 immediate repair conditions.
In its Response, Respondent argued that it had determined the anomalous conditions were
actually 180-day conditions based on Respondent's experience from excavating similarly
reported anomalies.
Section 195.452(f)(4) requires each hazardous liquid pipeline operator to have an integrity
management program that includes criteria for addressing anomalous conditions discovered
through integrity assessments. Section 195.452(h)(l) requires operators to take prompt action to
address all anomalous conditions discovered through an integrity assessment. Specific
remediation requirements are prescribed in subsection (h)(4) for certain conditions-for
example, subsection (h)(4)(i) requires operators to temporarily reduce operating pressure or shut



down a pipeline until "immediate repair conditions" are repaired. An immediate repair condition
is, among other things, a dent located on the top of the pipeline with a depth greater than 6% of
the nominal pipe diameter. Subsection (h)(4)(iii) requires operators to schedule evaluation and
remediation of "180-day conditions" within 180 days of discovery of the condition. A 180-day
condition is, among other things, a dent located on the bottom of the pipeline with a depth
greater than 6% of the nominal pipe diameter.
In July 2003, Respondent performed an integrity assessment on the Villa Ridge to E. St. Louis
section of its pipeline using a caliper geometry tool. The single channel caliper tool was capable
of detecting dents and the depths of those dents, but could not provide the orientation (o'clock
position) of the anomalies. Shortly after the July 2003 tool run, Respondent received a
preliminary report from the tool vendor that identified 12 dents with a depth of greater than 6%
of nominal pipe diameter. Since the orientation of the dents was unknown, Respondent
categorized the dents as immediate repair conditions (top-side orientation) and reduced operating
pressure until the conditions were repaired. When Respondent excavated the conditions,
Respondent found that their orientation was on the bottom side of the pipe.
In August 2003, Respondent received the final report for the tool run. Respondent did not
anticipate that the report would include additional immediate repair conditions, so the report was
placed in a queue to be evaluated later. In December 2003, Respondent discovered that the final
report identified 12 additional dents of greater than 6% depth with unknown orientations. Based
on its experience with the previous 12 dents, Respondent believed the newly-reported dents were
also bottom side dents and treated them as 180-day conditions. Accordingly, Respondent did not
take an immediate pressure reduction. Respondent has stated that the conditions were
remediated within the applicable 180-day time frame.'
The Notice alleged Respondent violated 5 195.452(f)(4) and (h)(l) by failing to address the
newly-reported dents as immediate repair conditions. Since the depths of the dents were greater
than 6% of nominal pipe diameter and the orientation was unknown, the Notice alleged
Respondent was required to treat the dents as immediate repair conditions and take a pressure
reduction until the conditions were repaired. In its Response, Respondent argued that it had
determined the newly-reported dents were 180-day conditions based on its experience from
excavating the first 12 reported conditions. "Based on actual conditions found" that showed the
first set of conditions were bottom-side, Respondent believed the newly-reported conditions were
also bottom side dents.2 Respondent asserted that the regulations provide latitude for operators
to determine when adequate information exists about a defect and to determine the priority for
repair. Otherwise, Respondent stated, operators would not be Pemitted to use knowledge of
their systems when evaluating conditions and prioritizing repairs.
Each pipeline operator's integrity management program is tailor-made to address integrity issues
based on that operator's experience and knowledge of their particular pipeline system. Decisions
concerning the program must necessarily be based on sufficient factual data. In this case,
- - -
I Response, p.3. Respondent also stated that it confirmed the newly-reported dents were bottom-
side when the conditions were repaired.
2
- Id.
3 Response, p.2.



Respondent decided that newly-reported anomalies were sufficiently similar to those previously
reported and excavated that the dents would necessarily have the same orientation. While there
may be some situations where characteristics of one anomaly can be deduced by comparing tool
run data of two like-anomalies with the excavation information from just one, that practice
would require enough intelligent tool run data to justify the initial inference that the anomalies
are sufficiently similar. Respondent did not have enough intelligent tool run data to justify the
inference that the unexcavated anomalies have the same orientation as those that had been
excavated. The caliper tool reported only the existence of dents and their depth, but did not
provide any information concerning orientation. Respondent has not shown how the previous
excavations provided any information concerning the similarity of the unexcavated conditions.
Although Respondent stated in its Response that the two sets of dents were "similarly reported,"
Respondent did not explain how this conclusion was reached or the facts that formed the basis
for this concl~sion.~
The protection of pipeline integrity from identified anomalous conditions is a chief objective of
the integrity management regulations. Where orientation data is missing, and it is the
determinative factor in categorizing a dent as an immediate repair condition, Respondent must
treat the unknown variable as "worst case" (top-side) unless there is sufficient factual
information to justify a different decision. In this case, Respondent did not have enough factual
data, or at least none was provided to PHMSA, to support Respondent's decision that the 12
unexcavated conditions were bottom-side dents. Accordingly, Respondent was required to treat
the dents with unknown orientation and depths of greater than 6% as immediate repair conditions
and reduce operating pressure until the dents were repaired.
Respondent acknowledged that it did not reduce operating pressure upon discovery of the 12
newly-reported conditions. Accordingly, 1 find Respondent violated 49 C.F.R. 5 195.452(0(4)
and (h)(l) by failing to reduce operating pressure upon discovery of 12 immediate repair
conditions.
Item 2 in the Notice alleged Respondent violated 49 C.F.R. 5 195.452(0(4) and (h)(2) by failing
to discover anomalous conditions promptly and no later than 180 days after an integrity
assessment. Section 195.452(0(4) requires operators to have an integrity management program
that includes criteria for addressing anomalous conditions discovered through integrity
assessment. Subsection (h)(2) specifies that operators must obtain sufficient information
following an integrity assessment to discover each anomalous condition and to classify each
condition in accordance with the time periods for remediation prescribed in subsection (h)(4).
Discovery must be made promptly, but not later than 180 days after an integrity assessment.
The Notice alleged that Respondent failed to promptly discover anomalous conditions identified
by several inline inspection (ILI) integrity assessments, despite having sufficient information
well before the end of the 180-day deadline for discovery. The Notice listed 23 specific ILI tool
runs from which Respondent's discovery of conditions was close to or exceeding the 180-day
deadline despite Respondent's receipt of the final ILI reports months earlier. In its Response,
Respondent acknowledged that it failed to meet the 180-day deadline in some instances, but
argued that it met the deadline for most of the ILI runs listed in the Notice, noting that those
- -
4Response, p.2.



discovery dates were recorded within 180 days of the assessments. Respondent explained that
operators need to be permitted to use the full 180 days for evaluation, because "discovery may
require analysis [and] integration of information from various source^."^ Respondent objected to
any "generalized finding that receipt of a Final report provides adequate information [for
discovery]."6
Depending on the nature of the conditions reported and other circumstances, the final (and
oftentimes preliminary) ILI reports will provide an operator with sufficient information to enable
discovery of anomalous conditions.' During the June 2005 inspection, PHMSA found particular
ILI reports provided Respondent sufficient information to discover anomalous conditions well-
before Respondent actually declared discovery. In each case, Respondent's discovery of the
conditions was close to or exceeding the 180-day deadline, which in turn delayed the regulatory
deadline for remediation of the condition^.^ Although Respondent correctly stated that discovery
sometimes requires the gathering and integration of information from other sources, Respondent
did not specifically claim that it needed to gather and integrate information from sources other
than the ILI reports listed in the Notice. Respondent did not provide any evidence that
contradicted the allegation in the Notice that Respondent had sufficient information from the ILI
reports to enable earlier discovery of the conditions.
In its Response, Respondent stated that it has modified its process so that it will discover
conditions within 180 days of each integrity assessment. Respondent also explained that
whenever a deadline had been missed, Respondent reduced the time allowed for remediation to
ensure that repairs would not also be delayed. Respondent's actions are noted, but they do not
demonstrate compliance with respect to the alleged violation. Accordingly, I find Respondent
violated 49 C.F.R. tj 195.452(f)(4) and (h)(2) by failing to discover anomalous conditions
promptly and no later than 180 days after ILI tool assessments.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
5 Response, p.4.
6 Id.-
7 PHMSA has communicated this and other informal guidance concerning compliance with the
integrity management regulations on PHMSA's Implementing Integrity Management for Hazardous
Liquid Operators web site at htt~://vrimis.~hmsa.dot.gov/iim. Specifically, Frequently Asked Question
(FAQ) 7.3 states: "What constitutes 'discovery of a condition'? Discovery of a condition occurs when an
operator has adequate information about the condition to determine that it presents a potential threat to the
integrity of the pipeline. Depending on circumstances, an operator may have adequate information when
the operator receives the preliminary internal inspection report, gathers and integrates information from
other inspections, or when an operator receives the final internal inspection report. Operators are required
to obtain sufficient information about a condition to make this determination no later than 180 days after
an integrity assessment, unless the operator can demonstrate that the 180-day period is impractical."
(Revised February 18, 2003). While answers to FAQs are not rules, they provide informal guidance to
the regulated community about how to implement their integrity management programs in accordance
with the requirements of 49 C.F.R. part 195.
8The Notice listed 23 1L1runs where Respondent recorded the discovery of conditions from 175 to
228 days after the date of the integrity assessment. Of the discoveries dated before the 180-day deadline
had expired, most were recorded on the 179th and 180th day after the assessment.



ASSESSMENT OF PENALTY
Under 49 U.S.C. 5 60122, Respondent is subject to a civil penalty not to exceed $100,000 per
violation for each day of the violation up to a maximum of $1,000,000 for any related series of
violations. The Notice proposed a total civil penalty of $200,000 for the violations.
49 U.S.C. 9 60122 and 49 C.F.R. tj 190.225 require that, in determining the amount of the civil
penalty, I consider the following criteria: nature, circumstances, and gravity of the violation,
degree of Respondent's culpability, history of Respondent's prior offenses, Respondent's ability
to pay the penalty, good faith by Respondent in attempting to achieve compliance, the effect on
Respondent's ability to continue in business, and such other matters as justice may require.
Item 1 in the Notice proposed a civil penalty of $50,000 for violating 49 C.F.R. 9 195.452(f)(4)
and (h)(l). Respondent failed to reduce operating pressure when it discovered 12 dents of
greater than 6% depth and unknown orientation. Without sufficient information concerning the
orientation of the reported dents, Respondent was required to treat the unknown orientation as
worst case or top-side, which due to the depth of the dents required a pressure reduction until the
conditions were repaired. Respondent's failure to reduce operating pressure upon discovery of
immediate repair conditions threatened the integrity of the pipeline and high consequence areas
that could be affected. Respondent has not submitted information that warrants reducing the
proposed civil penalty for this violation. Respondent has previously been found in violation of
the integrity management and other hazardous liquid pipeline safety regulations. Accordingly,
having reviewed the record and considered the assessment criteria, I assess Respondent a civil
penalty of $50,000 for violating 49 C.F.R. 5 195.452(f)(4) and (h)(l).
Item 2 in the Notice proposed a civil penalty of $150,000 for violating 49 C.F.R. 5 195.452(0(4)
and (h)(2). Respondent failed to discover anomalous conditions promptly and no later than 180
days after 23 specific ILI tool assessments, despite having sufficient information from ILI reports
several months prior. Respondent's failure to promptly discover and categorize conditions
identified by integrity assessments deferred the regulatory deadlines for remediation of
anomalous conditions, which posed a potential threat to the integrity of pipelines that could
affect a high consequence area. Respondent has previously been found in violation of the
integrity management and other hazardous liquid pipeline safety regulations.
In its Response, Respondent noted that where the 180-day deadline was missed, Respondent
reduced its own deadline for remediation of the conditions to ensure that repairs were not also
delayed. Respondent also indicated that it has modified its process for discovery to ensure that
future discoveries will be made no later than 180 days from the date of an integrity assessment.
Respondent's actions are noted; but Respondent must also ensure that discoveries are made
promptly when sufficient information is available, even when that information is available well
before the end of the 180-day deadline. Respondent has not submitted information that warrants
reducing the proposed civil penalty amount for this item. Accordingly, having reviewed the
record and considered the assessment criteria, I assess Respondent a civil penalty of $150,000 for
the violation of 49 C.F.R. 9 195,452(0(4) and (h)(2).



Having reviewed the record and considered the assessment criteria, I assess Respondent a total
civil penalty of $200,000. Respondent has the ability to pay the assessed penalty without
adversely affecting its ability to continue in business.
Payment of the civil penalty must be made within 20 days of service. Federal regulations (49
C.F.R. 5 89.21(b)(3)) require this payment be made by wire transfer, through the Federal
Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed
instructions are contained in the enclosure. Questions concerning wire transfers should be
directed to: Financial Operations Division (AMZ-300), Federal Aviation Administration, Mike
Monroney Aeronautical Center, P.O. Box 25082, Oklahoma City, OK 73 125; (405) 954-8893.
Failure to pay the $200,000 civil penalty will result in accrual of interest at the current annual
rate in accordance with 31 U.S.C. 5 3717, 31 C.F.R. 5 901.9, and 49 C.F.R. 5 89.23. Pursuant to
those same authorities, a late penalty charge of six percent (6%) per annum will be charged if
payment is not made within 110 days of service. Furthermore, failure to pay the civil penalty
may result in referral of the matter to the Attorney General for appropriate action in a United
States District Court.
Under 49 C.F.R. 5 190.215, Respondent has a right to submit a Petition for Reconsideration of
this Final Order. The petition must be received within 20 days of Respondent's receipt of this
Final Order and must contain a brief statement of the issue(s). The filing of the petition
automatically stays the payment of any civil penalty assessed. However, if Respondent submits
payment for the civil penalty, the Final Order becomes the final administrative action and the
right to petition for reconsideration is waived. The terms and conditions of this Final Order are
effective on receipt.
JAN - 9 2007
Date Issued
ssociate Administrator

420055037_Notice_Letter_10112005.pdf

U.S. Department
of Transportation
8701 S. Gessner, Suite 1110
Houston, TX 77074
Pipeline and
Hazardous Materials
Safety Administration
NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
AND
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
October 11, 2005
President
Ms. Margaret Yaege
ConocoPhillips Pipe Line Company
600 North Dairy Ashford
Houston, TX 77079
CPF No. 4-2005-5037
Dear Ms. Yaege:
On June 7-10 and 20-24, 2005, representatives of the Pipeline and Hazardous Materials Safety
Administration's Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States
Code, conducted an inspection of ConocoPhillips Pipe Line Company (CPPL) Integrity
Management Program (IMP) in Ponca City, OK.
As a result of this inspection, it appears that you have committed probable violations, as noted
below, of the pipeline safety regulations, Title 49, Code of Federal Regulations, Part 195. The
probable violations are:
§195.452 Pipeline integrity management in high consequence areas.
(t) What are the elements of an integrity management program? An integrity
management program begins with the initial framework. An operator must
continually change the program to reflect operating experience, conclusions drawn
trom results of the integrity assessments, and other maintenance and surveillance
data, and evaluation of consequences of a failure on the high consequence area.
megay management program
An operator must include, at minimum, each of the following elements in its written



(4) Criteria for remedial actions to address integrity issues raised by the
section)
assessment methods and information analysis (see paragraph (h) of this
(h) What actions must an operator take to address integrity issues?
(1) General requirements. An operator must take prompt action to address
all anomalous conditions that the operator discovers through the integrity
operator must evaluate all anomalous conditions and remediate those that
assessment or information analysis. In addressing all conditions, an
could reduce a pipeline's integrity. An operator must be able to demonstrate
that the remediation of the condition will ensure that the condition is unlikely
to pose a threat to the long-term integrity of the pipeline. A reduction in
operating pressure cannot exceed 365 days without an operator taking
further remedial action to ensure the safety of the pipeline. An operator must
comply with §195.422 when making a repair.
The OPS inspection of ILl results and associated repair records identified
some issues with
respect to the completion of repairs of anomalies. The IM rule requires an operator to take
prompt action to address all anomalous conditions that the operator discovers through the
integrity assessment or information analysis. On 7/23/2003, the Villa Ridge to E. St. Louis
pipeline section was assessed using a geometry tool; and the deformation too! measured depth,
but it could not give orientation.
Twenty-four anomalies ranging from 6.31% to 25.9%
deformation were reported in the ILl Vendor's Final Report, dated 08/12/2003. Discovery was on
12/30/03, which is the date on which CPPL issued the transmittal letter reporting the assessment.
findings and defining required repairs. As of 12/30/03, twelve anomalies remained un-evaluated
and not remediated. Since the orientation was unknown and all anomalies were reported above
reduction taken until all of the anomalies could be evaluated. No evidence that a pressure
6% deformation, the anomalies should have been treated as immediate repairs and a pressure
reduction was taken in the remediation of these defects was provided to OPS at the time of the
inspection.
2.
§195.452 Pipeline integrity management in high consequence areas.
(f) (4) (see above)
(h) What actions must an operator take to address integrity issues?
(2) Discovery of condition. Discovery of a condition occurs when an operator
has adequate information about the condition to determine that the
condition presents a potential threat to the integrity of the pipeline. An
operator must promptly, but no later than 180 days after an integrity
assessment, obtain sufficient information about a condition to make that
is impracticable.
determination, unless the operator can demonstrate that the 180-day period
The OPS inspection of ILl results and associated repair records identified some issues with
categorize an anomaly within 180 days after completing an assessment. On a significant
respect to the timeliness of "discovery" of anomalies.
The IM rule requires an operator to
percentage of their assessments, CPPL is taking the full 180 days to categorize anomalies as 60



and 180 day conditions and declare discovery, even when the vendor's final report has been
received well in advance of that discovery date; and adequate information was available to CPPL
to declare discovery in the form of the ILI Vendor's final report.
Specific examples of
assessments where discovery was declared well after receipt of the ILl Vendor's Final Report and
near or exceeding the end of the maximum 180 day discovery period are detailed in the table
below. The transmittal letter date indicates when the ILI Integrity Worklist Spreadsheet was sent
to the field to initiate repairs or evaluations and when discovery of conditions was declared by
Pipeline Segment
IL Tool
Final Report
180 Day
Transmittal Letter
Run Date
Date
Discovery
Date and Discovery
Deadline
Declared
Hardtner to MP271
12/14/03
01/05/04
6/11/04
7/9/04
Leeton to
07/28/04
09/21/04
1/24/05
1/24/05
Harrisonville
Rosebud to
07/28/04
9/27/04
1/24/05
1/24/05
Jefferson City
Harrisonville to Paola
07/28/04
10/5/04
1/25/05
1/24/05
Villa Ridge to
07/28/04
9/7/04
1/24/05
1/24/05
Rosebud
Jefferson City to
07/17/04
9/15/04
1/13/05
1/11/05
Syracuse
Kankakee to East
12/05/03
1/5/04
6/2/04
5/28/04
Chicago
Chocolate Bayou to
09/01/04
11/1/04
3/1/05
3/1/05
Webster
Austin to LaGrange
09/02/04
12/13/04
3/1/05
2/28/05
Brookshire to
09/03/04
11/16/04
3/2/05
3/1/05
Sweeney
Fredericksburg to
09/02/04
11/29/04
3/1/05
2/28/05
Austin
MP50 to Laverne
10/15/04
1/3/05
4/13/05
4/13/05
Villa Ridge to E. St.
06/23/04
7/30/04
12/20/04
12/16/04
Louis
Coalinga to Rodeo
08/29/04
12/23/04
2/25/05
4/14/05
Falls Terminal
Archer #1 to Wichita
11/21/03
3/1/04
6/6/04
6/6/04
Sneed to Borger
10/26/04
1/3/05
Borger to Skellytown
4/24/05
5/2/05
Rock Creek to
10/28/04
1/3/05
4/26/05
5/16/05
10/23/03
12/3/03
4/20/04
4/19/04
Paola to Kansas City
Borger
12/20/03
1/27/04
6/18/04
7/21/04
Douglas to
Wheatland
10/21/04
1/3/05
4/19/05
4/26/05
Sweeney to
12/08/03
1/5/04
6/5/04
6/11/04
Pasadena
Odessa to Gaines
11/18/03
12/15/03
5/16/04
5/13/04
Canyon to MP250
10/29/03
1/15/04
4/26/04
4/27/04



Under 49 United States Code §60122, you are subject to a civil penalty not to exceed $100,000
for each violation for each day the violation persists up to a maximum of $1,000,000 tor any
related series of violations.
The Compliance Officer has reviewed the circumstances and
supporting documentation involved in the above probable violation and it is recommended that
you be preliminarily assessed a civil penalty of $200,000 ($50,000 for Item 1 and $150,000 for
Item 2).
Enclosed with this Notice of Probable Violation is a description of the courses of action available
to you in responding to this Notice. Please note that regardless of the course of action you elect
to follow, you must respond within 30 days of your receipt of this Notice. Your failure to respond
within 30 days will result in referral to the Associate Administrator, Office of Pipeline Safety, to
find the facts to be as alleged herein and order a civil penalty.
Please refer to CPF No. 4-2005-5037 for any correspondence on this matter.
Sincerely,
R. M. Seeley
Director, Southwest Region
Enclosure

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/420055037>
- Source ID: `phmsa-enforcement`
- SHA-256: `ee4277884e5013f4d1fc03fdd0c5f8ce592f6c43dd7d38c8123216c3b0007b1b`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T21:55:13.043Z
- Document slug: `phmsa-enforcement-420055037`

### Source metadata

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  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
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    "195.452(h)(2)"
  ],
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}
```