{"operation":"document","citation":"CPF 120155007W","title":"PHILLIPS 66 PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-06-08","effective_on":null,"summary":"CLOSED warning letter citing 195.452(l)(1)(ii).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120155007w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120155007w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120155007w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120155007W","body":"Warning Letter involving PHILLIPS 66 PIPELINE LLC. PHMSA's enforcement data identifies the cited regulation as 195.452(l)(1)(ii). The case was opened on 2015-06-08 and is reported as closed as of 2015-06-08. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120155007W_Operator Response to Notice _07072015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120155007W/120155007W_Operator%20Response%20to%20Notice%20_07072015.pdf\n\n120155007W_Warning Letter_06082015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120155007W/120155007W_Warning%20Letter_06082015.pdf\n\n120155007W_Warning Letter_06082015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120155007W/120155007W_Warning%20Letter_06082015_text.pdf\n\n120155007W_Warning Letter_06082015_text.pdf\n\nU.S. Department Of Transportation Pipeline and 609.989.2171\nHazardous Materials\nSafety Administration\n820 Bear Tavern Road, Suite 103\nWest Trenton, NJ 08628\nWARNING LETTER\nEXPRESS OVERNIGHT DELIVERY\nJune 8, 2015\nMr. Todd Denton\nPresident\nPhillips 66 Pipeline, LLC\n3010 Briarpark Drive\nHouston, TX 77042\nCPF 1-2015-5007W\nDear Mr. Denton:\nFrom October 7 to October 10, 2014, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Office of Pipeline Safety, pursuant to Chapter 601 of 49\nUnited States Code inspected the Phillips 66 Pipeline LLC’s (Phillips) facility in Linden, New\nJersey.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the\nprobable violation is:\n1. §195.452 Pipeline integrity management in high consequence areas.\n(a) . . .\n(l) What records must be kept? (1) An operator must maintain for review during an\ninspection: . . .\n(ii) Documents to support the decisions and analyses, including any modifications,\njustifications, variances, deviations and determinations made, and actions taken, to\nimplement and evaluate each element of the integrity management program listed in\nparagraph (f) of this section. . . .1\n1 On January 5, 2015, PHMSA issued a final rule that, among other things, made non-substantive editorial\ncorrections clarifying regulatory language in certain provisions. See, 80 Fed. Reg. 168-188 (Jan. 5, 2015). Phillips\ncommitted a probable violation prior to the amendment to regulation §195.452(l)(1).\n\n\n\n1-2015-5007W\nPhillips integrity management records failed to demonstrate compliance per §195.452(l)(1)(ii)2\n.\nPhillips Field Anomaly Evaluation Report Doc. No. eForm 3933B, evaluation repair date\n11/15/2013, contained inaccurate information.\nDuring the inspection, the PHMSA inspector reviewed Phillips in-line inspection remediation\nprojects and anomaly reports. The Field Anomaly Evaluation Report eForm 3933B dated\n11/15/2013, indicated that the “[maximum operating pressure (MOP)] at Feature” was 678\npounds per square inch gauge (psig). Phillips stated that the MOP of the pipeline is 275 psig.\nPhillips could not produce any documentation or analysis which supported the “MOP at feature”\nindicated on the report. Phillips stated this “MOP at Feature” was incorrectly input or calculated\nby Phillips personnel.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item identified in this letter.\nFailure to do so will result in Phillips being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2015-5007W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nByron Coy, P.E.\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n2 Id.\n1-2015-5007W Page 2 of 2","truncated":false,"body_characters":4803}