{"operation":"document","citation":"CPF 320075004W","title":"PHILLIPS 66 PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-03-05","effective_on":null,"summary":"CLOSED warning letter citing 195.404(c)(3), 195.567(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320075004w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320075004w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320075004w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320075004W","body":"Warning Letter involving PHILLIPS 66 PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.404(c)(3),  195.567(c). The case was opened on 2007-03-05 and is reported as closed as of 2007-03-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320075004W_Warning Letter_03052007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320075004W/320075004W_Warning%20Letter_03052007.pdf\n\n320075004W_Warning Letter_03052007.pdf\n\nt4A:i a 7 2007\n@\nU.S. Deportment\nof Tronsportolion\nPlpetlne oncl\nHozordous filqtedolr Sofety\nAdmlnistrqtion\n901 Locust Slreet, Suile 462\nKansas City, MO 6410G2641\nWARNINGLETTER\nCERTIFIED MAIL - RETURN RECEIPT REOUESTED\nMarch 5, 2007\nMs. Margaret Yaege\nGeneral Manager of Pipelines and Terminals\nConocoPhillips Pipe Line Company\n600 N. Dairy Ashford\nHouston, TX 74079\ncPF 3-2007-5004W\nDear Ms. Yaege:\nOn October l6-20, October 30 - November 3, November 13-17 and December ll-15,2006, a\nrepresentative of the Pipeline and Hazardous Materials Safety Administration (PHMSA)\npursuant to Chapter 601 of 49 United States Code inspected yourpipeline facilities in Illinois,\nKansas, Missouri, and Indiana.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violations are:\n1. S195.404 Maps and Records.\n(c) Each operator shall maintain the following records for the periods specified;\n(3) A record of each inspection and test required by this subpart shall be\nmaintained for at least 2 years or until the next inspection or test is\nperformed, whichever is longer.\n(a) ConocoPhillips failed to properly maintain the overpressure protection records for two\npump stations. The \"Pressure Protection Device Inspection and Test\" records did not\nrecord the actual test pressure for the High Discharge Shutdown set point, nor the\nControl Valve set point. The inspection form's o'Required Pressure Setting\" column\n\n\n\nlisted 4 - 20 mA and 0-1500 #. This data is the current in amperage output range of\nthe transducer and the associated pressure rangeo not the actual test pressure shut down\nset point. The actual test pressures were not recorded on the test records for\noverpressure protection for the following pump stations on the dates listed:\nSyracuse Pump Station Blue a:rd Gold P/L May 15, 2006\nDecember 2,2005\nMav26.2005\nRosebud Pump Station Gold P/L November 2'7,2006\nMay 8, 2006\nNovember 28,2005\nMay20,2005\n2. 5195.567 Which pipelines must have test leads and what must I do to install and\nmaintain the leads?\n(c) Maintenance. You must maintain the test lead wires in a condition that enables\nyou to obtain electrical measurements to determine whether cathodic protection\ncomplies with Sec. 195.571,\nConocoPhillips did not maintdn the test lead wires on the Gold P,IL at MP 183 08+50 and\nMP 217 06+29. The test leads were determined to be defective during the 2005 annual\ncorrosion control survey, but their repair was overlooked during your test lead repair\nprpgram in 2006 prior to the 2006 anaual survey. ConocoPhillips has reported that the\ntest leads were repaired and that cathodic protection levels were adequate.\nUnder 49 United States Code, g 60122, you are subject to a civil penalty not to exceed $ 100,000\nfor each violation for each day the violations persists up to a maximum of $ 1 ,000,000 for any\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 items identified in this letter.\nFailure to do so will result in ConocoPhillips being subject to additional enforcement action.\nNo reply to this letter is required. Ifyou choose to reply, in your correspondence please refer to\nCPF 3-2007-5004W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. Ifyou believe that any portion ofyour\nresponsive material qualifies for confidential treatment under 5 U.S.C. 5520), 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 the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerelv.\nfl .// /.4x\n/) /ftewwt 4ffi722-\nffivan A. Huntoon\nU Director. Central Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":4631}