PHILLIPS 66 PIPELINE LLC — Notice of Probable Violation

320035007_final order_01092007_text.pdf, page 1Official PDFO U 5 Department of Transportation Pipeline and Hazardous Materials Safety Administration 400 Seventh Street, S W Washington, D C 20590 JAlr — 9 2007 Ms Meg Yeage President ConocoPhillips, Inc 600 North Dairy Ashford Houston, TX 77079 Re CPF No 3-2003-5007 Dear Ms Yeage 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 specifies actions to be taken to comply with the pipehne safety regulations The Final Order also makes a finding of inadequate procedures and requires amendment of certain of your operating and maintenance procedures When the terms of the comphance order and the amendment of procedures are completed, as determined by the Director, Central Regton, OPS, this enforcement action will be closed Your receipt of this Final Order constitutes service of that document under 49 C F R. tJ 190 5 Sincerely, James Reynolds Pipehne Compliance Registry Office of Pipeline Safety Enclosure cc Ivan Huntoon, Director, Central Region, OPS CERTIFIED MAIL — RETURN RECEIPT RE UESTED#

320035007_final order_01092007_text.pdf, page 2DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D. C. 20590 In the Matter of ConocoPhillips, Inc. Respondent CPF No. 3-2003-5007 , FINAL ORDER On May 1-5, May 15-19, May 22-26, and July 31-August 4, 2000, pursuant to 49 U S C $ 60117, a representative of the Pipehne and Hazardous Materials Safety Administration (PHMSA), Office of Pipehne Safety conducted an on-site pipehne safety inspection of Respondent's facihties and records in Bartlesville, Oklahoma and additional facihties in Kansas, Missouri, Ilhnois, and Indiana As a result of the inspection, the Director, Central Region, PHMSA, issued to Respondent. by letter dated March 13, 2003, a Notice of Probable Violation, Proposed Comphance Order, and Notice of Amendment (Notice) In accordance with 49 C F R $ 190 207, the Notice proposed findmg that Respondent had committed violations of 49 C F R Part 195 and proposed ordenng Respondent to take certain measures to correct the alleged violations The Notice also proposed, in accordance with 49 C F R ) 190 237, that Respondent amend its operating and maintenance procedures Respondent responded to the Notice by letter dated Apnl 21, 2003 (Response) Respondent did not contest the allegations of violation Respondent provided information concerning the corrective actions it has taken submitted copies of its revised procedures, and sought clanfication of certain comphance terms Respondent did not request a heanng, and therefore has waived its nght to one FINDINGS OF VIOLATION In its Response, Respondent did not contest the alleged violations in the Notice Accordingly, I find that Respondent violated the following sections of 49 C F R Part 195, as more fully descnbed in the Notice#

320035007_final order_01092007_text.pdf, page 32 49 C F R I) 195 401(b) (Notice Item I) — fathng to timely correct adverse conditions involving external loads on spans along the Gold Line and the Blue Line, 49 C F R l') 195 404(b) (Notice Item 3a) — fathng to maintain daily records indicating the discharge pressure at the Decatur pump station, and 49 C F R I) 195 416(t) (Notice Item 5) — fathng to maintain protection agamst 1 atmosphenc corroston on all components exposed to the atmosphere These findings of violation will be considered prior offenses tn any subsequent enforcement action taken agtunst Respondent COMPLIANCE ORDER The Nonce proposed a compliance order with respect to Items I, 3a, and 5 Under 49 U S C t) 60118(a), each person who engages tn the transportation of hazardous liquids or who owns or operates a pipehne facihty is required to comply with the apphcable safety standards estabhshed under chapter 601 With respect to Item 3a, Respondent provided information in its response demonstratmg that it had installed a discharge recorder at the specified location Since compliance has been actueved with respect to this item, it is unnecessary to include compliance terms for it in this Order With respect to Items I and 5, respondent has not demonstrated that comphance has been achieved Accordingly, pursuant to the authonty of49 U S C l) 60118(b) and 49 C F R I) 190 217, Respondent is ordered to take the following actions to ensure compliance with the pipeline safety regulations apphcable to its operations I Wtth respect to Notice Item I (a) Review the criteria for span/exposed pipe assessments to identify conditions which could allow the loadtng to exceed 90% of SMYS for combined internal and external stresses Any features exceeding the estabhshed cntena shall be further analyzed and remedial action taken All features such as dents, buckles, metal loss, etc, identified dunng the inspection shall be remedtated m accordance with ConocoPhillips' repiur cntena, (b) Withm 60 days following receipt of this Order, develop and submit a wntten plan and a proposed schedule for addressing the removal of debus from each affected span or other conditions described in Item I The necessary remedial measures shall be completed within one year following your receipt of this Order, and ' 49 C F R tt 195 416(i) (2001) This requirement is now found at 49 C F R I 195 581#

320035007_final order_01092007_text.pdf, page 43 (c) Upon completion of the actions specified in paragraphs (a) and (b), submit records and documentation demonstrating their completion to the Director, Central Region, PHMSA, 901 Locust Street, Suite 462, Kansas City, Missoun 64106-2641 2 With respect to Notice Item 5 (a) Review the condition of the coating at each span to determine which spans require remediation of the coating to prevent atmosphenc corrosion, (b) Wit)un 60 days following receipt of this Order, develop and submit a wntten plan and a proposed schedule for addressing the remediation of the spans The necessary remedial measures shall be completed within one year following your receipt of this Order, and (c) Upon completion of the actions specified in paragraphs (a) and (b), submit records and documentation demonstrating their completion to the Director, Central Region, PHMSA, 901 Locust Street, Suite 462, Kansas City, Missoun 64106-2641 The Director may grant an extension of time to comply with any of the required items upon a wntten request timely submitted by the Respondent demonstrating good cause for an extension Failure to comply with this Order may result in the assessment of civil penalties of up to $100, 000 per violation per day, or in the referral of the case for )udtcial enforcement AMENDMENT OF PROCEDURES Item 2 in the Notice alleged inadequacies in Respondent's operating and maintenance procedures and proposed to require amendment of Respondent's procedures to comply with the requirements of 49 C F R Part 195 With respect to Item 2a, Respondent submitted copies of its amended procedures with its response The Director reviewed the amended procedures and determmed that they now identify the operation of a safety device as an abnormal operation requinng a documented evaluation Accordingly, I find that Respondent's onginal procedures as descnbed m the Notice were inadequate to ensure safe operation of its pipehne system, but that Respondent has corrected the specified inadequacy With respect to Item 2b, Respondent did not submit revised procedures addressing the inadequacy identified in the Notice Accordmgly, I find that Respondent's procedures are madequate to assure safe operation of its pipehne system Pursuant to 49 U S C $ 60108(a) and 49 C F R $ 190 237, Respondent is ordered to make the following changes to its operating and maintenance procedures I Revise the procedures to address the capture of abnormal discharge pressure between maximum operating pressure (MOP) and the supervisory control and data acquisition system high pressure alarm set up to 10 pounds per square inch above MOP#

320035007_final order_01092007_text.pdf, page 52 Within 30 days following receipt of this order, submit the amended procedures to the Director, Central Region, PHMSA, 901 Locust Street, Suite 462, Kansas City, Missoun 64106-2641 The Regional Director may grant an extension of time to comply with any of the required items upon a wntten request timely submitted by the Respondent demonstrating good cause for an extension Failure to comply with this Order may result in the assessment of civil penalnes of up to $100, 000 per violation per day, or in the referral of the case for) udicial enforcement WARNING ITEMS The Notice did not propose a civil penalty or corrective action for Items 3b, 4, or 6 m the Notice Therefore, these are considered to be warning items The wammgs were for 49 C F R tl 195 404(b) — faihng to maintain records documenting the specified abnormal operating condition, 49 C F R tl 195 406((b) — faihng to control the pressure on the Conway line within the maximum hmit dunng the specified penod, and 49 C F R tt 195 428(b) — fathng to timely inspect the pressure rehef valves on the specified tanks at the Decatur terminal Respondent is warned that if it does not take appropnate action to correct these items, enforcement action will be taken if a subsequent inspection reveals a violation Under 49 C F R ) 190 215, Respondent has a nght to submit a petinon for reconsideration of this Final Order Should Respondent elect to do so, the petinon must be received within 20 days of Respondent's receipt of this Final Order and must contain a bnef statement of the issue(s) The terms of this Order, including any required corrective action and amendment of procedures, remain in full effect unless the Associate Administrator, upon wntten request, grants a stay The terms and conditions of this Final Order are effective on receipt JAN - 9 Z01 Date Issued Willk re e Ac g ssociate Admmistrator fo P eline Safety#