# PHILLIPS 66 PIPELINE LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 320035007
- **title:** PHILLIPS 66 PIPELINE LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2003-03-13
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.401(b), 195.402, 195.402(d), 195.404(b), 195.406(b), 195.416, 195.428(b).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/320035007
**body:**

Notice of Probable Violation involving PHILLIPS 66 PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.401(b),  195.402,  195.402(d),  195.404(b),  195.406(b),  195.416,  195.428(b). The case was opened on 2003-03-13 and is reported as closed as of 2010-01-22. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320035007_Final Order_01092007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320035007/320035007_Final%20Order_01092007.pdf

320035007_final order_01092007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320035007/320035007_final%20order_01092007_text.pdf

320035007_final order_01092007_text.pdf

O
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



DEPARTMENT 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



2
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



3
(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



2 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
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