PHILLIPS 66 PIPELINE LLC — Warning Letter

320075004W_Warning Letter_03052007.pdf, page 1Official PDFt4A:i a 7 2007 @ U.S. Deportment of Tronsportolion Plpetlne oncl Hozordous filqtedolr Sofety Admlnistrqtion 901 Locust Slreet, Suile 462 Kansas City, MO 6410G2641 WARNINGLETTER CERTIFIED MAIL - RETURN RECEIPT REOUESTED March 5, 2007 Ms. Margaret Yaege General Manager of Pipelines and Terminals ConocoPhillips Pipe Line Company 600 N. Dairy Ashford Houston, TX 74079 cPF 3-2007-5004W Dear Ms. Yaege: On October l6-20, October 30 - November 3, November 13-17 and December ll-15,2006, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected yourpipeline facilities in Illinois, Kansas, Missouri, and Indiana. As a result of the inspection, it appears that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable violations are: 1. S195.404 Maps and Records. (c) Each operator shall maintain the following records for the periods specified; (3) A record of each inspection and test required by this subpart shall be maintained for at least 2 years or until the next inspection or test is performed, whichever is longer. (a) ConocoPhillips failed to properly maintain the overpressure protection records for two pump stations. The "Pressure Protection Device Inspection and Test" records did not record the actual test pressure for the High Discharge Shutdown set point, nor the Control Valve set point. The inspection form's o'Required Pressure Setting" column#

320075004W_Warning Letter_03052007.pdf, page 2listed 4 - 20 mA and 0-1500 #. This data is the current in amperage output range of the transducer and the associated pressure rangeo not the actual test pressure shut down set point. The actual test pressures were not recorded on the test records for overpressure protection for the following pump stations on the dates listed: Syracuse Pump Station Blue a:rd Gold P/L May 15, 2006 December 2,2005 Mav26.2005 Rosebud Pump Station Gold P/L November 2'7,2006 May 8, 2006 November 28,2005 May20,2005 2. 5195.567 Which pipelines must have test leads and what must I do to install and maintain the leads? (c) Maintenance. You must maintain the test lead wires in a condition that enables you to obtain electrical measurements to determine whether cathodic protection complies with Sec. 195.571, ConocoPhillips did not maintdn the test lead wires on the Gold P,IL at MP 183 08+50 and MP 217 06+29. The test leads were determined to be defective during the 2005 annual corrosion control survey, but their repair was overlooked during your test lead repair prpgram in 2006 prior to the 2006 anaual survey. ConocoPhillips has reported that the test leads were repaired and that cathodic protection levels were adequate. Under 49 United States Code, g 60122, you are subject to a civil penalty not to exceed $ 100,000 for each violation for each day the violations persists up to a maximum of $ 1 ,000,000 for any related series of violations. We have reviewed the circumstances and supporting documents involved in this case, and have decided not to conduct additional enforcement action or penalty assessment proceedings at this time. We advise you to correct the items identified in this letter. Failure to do so will result in ConocoPhillips being subject to additional enforcement action. No reply to this letter is required. Ifyou choose to reply, in your correspondence please refer to CPF 3-2007-5004W. Be advised that all material you submit in response to this 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. 5520), 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 of why you believe the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b). Sincerelv. fl .// /.4x /) /ftewwt 4ffi722- ffivan A. Huntoon U Director. Central Region Pipeline and Hazardous Materials Safety Administration#