PHILLIPS 66 PIPELINE LLC — Notice of Amendment

party submissionOfficial PDF320075014M_Operator_Response_to_Notice_04252007.pdf#

320075014M_Closure Letter_11182010_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED November 18, 2010 Mr. Todd L. Tullio Manager, Regulatory Compliance ConocoPhillips Pipe Line Company 600 North Dairy Ashford Road, #TA2010 Houston, Texas 77079 CPF 3-2007-5014M Dear Mr. Tullio: On June 20-24, July 18-22, August 1-5, September 8-9, and October 20, 2005, a representative from the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site pipeline safety inspection of ConocoPhillips Pipe Line Company (CPPL) procedures in Illinois, Kansas, and Missouri. As a result of the inspection, CPPL was issued a Notice of Amendment on March 16, 2007, which proposed amendment of your procedures. CPPL submitted its amended procedures on November 19, 2009. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, David Barrett Director, Central Region Pipeline and Hazardous Materials Safety Administration#

320075014M_Notice Of Amendment_03162007.pdf, page 1Official PDFU.S. Depofiment of Trqnsoortolion Plpellne qnd Hozordous trtoterlols sqtety Adminbtrolion 901 Locust Street, Suite 462 Kansas Citv, MO 64106-2641 NOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REOUESTEI) March 16.2007 Ms. Margaret Yaege General Manager of Pipelines and Terminals ConocoPhillips Pipe Line Company 600 N. Dairy Ashford Houston. TX 74079 cPF 3-2007-5014M Dear Ms. Yaege: On June 20-24,Iuly 18-22, Alg l-5, Sept. 9-8, October 20,2005, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your pipeline facilities in Illinois, Kansas, and Missouri. On the basis of the inspection, PHMSA has idenfified the apparent inadequacies found within ConocoPhillips Pipe Line Company's plans or procedures and are described below: 1. 5195.402 Procedural Manual for Operations, Maintenance and Emergencies. $195.402(a) requires that each operator shall prepare and follow for each pipeline system a manual of written procedures for.conducting normal operations and maintenance activities and handling abnormal operations and emergencies. $195.402(c) indicates that the manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part#

320075014M_Notice Of Amendment_03162007.pdf, page 2Review of the Operation and Maintenance (O&M) manual found thatthe following requirements were not adequately covered in the manual or needed to be expanded to provide additional guidance to your personnel. Item (a) is required to be included in the manual by $ 1es.a02(c)(3). 1.(a) $f95. 406 Maximum Operating Pressure. (b) No operator may permit the pressure in a pipeline during surges or other variations from normal operations to exceed 110 percent of the operating pressure limit established under paragraph (a) ofthis section. Each operator must provide adequate controls and protective equipment to control the pressure within this limit. ConocoPhillips O&M procedures for temporary pressure reductions do not assure an adequate level ofoverpressure protection for reductions that are in place longer than 30 days. ConocoPhillips allows the use of Administrative Controls for temporary pressure reduction. This allows the Control Center or location to achieve the pressure reduction by monitoring and maintaining an upstream and/or downstream set point or deviation alarm in the SCADA or local controls. From interviews with ConocoPhillips personnel, this means that a required pressure reduction can be achieved by setting an alarm in SCADA that woulil require the SCADA operator to take action to shut down the pipeline in an overpressure situation. Administrative Control relieves the operator from having to reset the actual field overpressue protection shutdowns. Per ConocoPhillips O&M, Administrative Controls are limited to a 90-day period - except, Integrtty Engineer & the Director of Pipeline Integrity can extend Administrative Control another 90 days. Administrative Controls should not be used beyond 30 days' Response to this Notice This Notice is proyided pursuant to 49 U.S.C. $ 60108(a) and 49 C.F.R. $ 190.237. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings. Please refer to this document and note the response options. Be advised that all material you submit in response to this enforcement action is subject to being made publicly available. If you believe that any portion of your 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 confrdential treatment under 5 U.S.C. 552(b). If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue a Final Order.#

320075014M_Notice Of Amendment_03162007.pdf, page 3If, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. $ 190.237). If you are not contesting this Notice, we propose that you submit your amended procedures to my offrce within 30 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. In correspondence concerning this matter, please refer to CPF 3-2007-5014M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerelv. Ivan A. Huntoon Director, Cenhal Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings#

320075014M_Notice Of Amendment_03162007.pdf, page 4Response Options for Pipeline Operators in Compliance Proceedings The requirements of 49 c.F.R. Part 190, Subpart B ($$ 190.201-190.237) govem response to Notices issued by a Regional Director, Pipeline and Hazardous Materials Safety Administration (PHMSA). Be advised that all material submitted by a respondent in response to an enforcement action is subject to being made publicly available. If you believe that any portion of your responsive material qualifies for confidential fieatrnent under 5 U.S.C. 552(b), along with the complete original document you must provide a second copy of the document with the portions you believe qualify for confidential ffeatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatrnent under 5 U.S.C. 552(b). Procedures for Resnondinq to a NOTICE OF PROBABLE VIOLATION: Within 30 days of receipt of a Notice of Probable Violation, the respondent shall respond to the Regional Director who issued the Notice in the following way: a. When the Notice contains a proposed CIVIL PENALTY* -- L Paythe proposed civil penalty and advise the Regional Director ofthe payment. This authorizes PHMSA to make findings and to close the case with prejudice to the respondent. Payment terms are outlined below; 2. Submit written explanations, information, or other materials in response to the allegations and/or seek elimination or mitigation of the proposed civil penalty. Refer to 49 C.F.R. S 190.225 for assessment considerations, which include the respondent's ability to pay and the effect on the respondent's ability to stay in business, upon which civil penalties are based; or 3. Request a hearing as described below to contest the allegations and/or proposed assessment of a civil penalty. b. When the Notice contains a proposed COMPLIANCE ORDER* -- l. Notiff the Regional Director that you intend to take the steps in the proposed compliance order; Submit written explanations, information, or other materials in answer to the allegations in the Notice and object to or seek clarification of the proposed oompliance order items in whole or in part; or 3, Request a hearing as described below to contest the allegations and/or proposed compliance order items; I of5#

320075014M_Notice Of Amendment_03162007.pdf, page 5il. c, When the Notice contains a WARMNG ITEM - No written response is required. The respondent is warned that if it does not take appropriate acttonto correct these items, enforcement action will be taken ifa subsequent inspection reveals a violation * Failure of the respondent to respond to the Notice within 30 days of receipt constitutes a waiver of the right to contest the allegations in the Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in the Notice without further notice to the respondent and to issue a Final Order. Procedures for Respondine to a NOTICE OF AMENDMENT*: Within 30 days of receipt of a Notice of Amendment, the respondent shall respond to the Regional Director who issued the Notice in the following way: a. Notify the Regional Director of your plans to address the inadequacies identified in the Notice: b. Submit written explanations, information, or other materials in answer to the allegations in the Notice and/or object to or seek clarification ofthe proposed amendment items in whole or in part; or Request a hearing as described below to contest the allegations in the Notice. * Failure of the respondent to respond to the Notice within 30 days of receipt constitutes a waiver of the right to contest the allegations in the Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in the Notice without further notice to the respondent and to issue a Final Order. Procedure for Requesting a Hearing A request for a hearing must be in writing and accompanied by a statement of the issues that the respondent intends to raise at the hearing. The issues may relate to the allegations, new informatior\ or to the proposed compliance order or proposed civil penalty amount. Refer to 49 C.F.R. $ 190.225 for assessment considerations upon which civil penalties are based. A respondent's failure to speciff an issue may result in waiver of the right to raise that issue at the hearing. The respondent's request.must also indicate whether or not respondent will be represented by counsel at the hearing. Failure to request a hearing in writing within 30 days of receipt of a Notice waives the right to a hearing, In addition, ifthe amount ofthe proposed civil penalty or the proposed corrective action is less than $10,000, the hearing will be held by telephone, unless the respondent submits a uritten request for an in-person hearing. Complete hearing procedures can be found at 49 C.F.R. $ 190.211. 2of5#

320075014M_Notice Of Amendment_03162007.pdf, page 6IV. V. VL Extensions of Time An extension of time to prepare an appropriate response to a Notice may be granted, at the agency's discretion, following submittal of a written request to the Regional Director. The request must indicate the amount of time needed and the reasons for the extension, The request must be submitted within 30 days of receipt of the Notice.' X'reedom of Information Act Any material prepared by PHMSA, including the violation report, the Notice, and any order issued in this case, and any material provided to PHMSA by the respondent, may be considered public information and subject to disclosure under the Freedom of Information Act (FOIA). If the information you provide is security sensitive, prMleged, confidential or may cause your company competitive disadvantages, please clearly identify the material and provide justification why the documents, or portions of a document should not be released under FOIA, If we receive a request for your material, we will noti$r you if PHMSA, after reviewing the materials and your provided justification, determines that withholding the materials does not meet any exemption provided under the FOIA. You may appeal the agency's decision to release material under the FOIA at that time. Your appeal will stay the release of those materials until a final decision is made. Small Business Requlatory Enforcement Fairness Act Information The Small Business and Agricultural Regulatory Enforcement Ombudsman and l0 Regional Faimess Boards were established to receive comments from small businesses about federal agency enforcement actions. The Ombudsman will annually evaluate the enforcement activities and rate each agency's responsiveness to small business. Ifyorr wish to comment on the enforcement actions of the Pipeline and Hazardous Materials Safety Adminishation, call 1-888-REG-FAIR (1-888-734-3247) or go to http ://www sba. gov/ombudsman/dsp_faq. html. 3 of 5#

320075014M_Notice Of Amendment_03162007.pdf, page 7VIL PAYMENT INSTRUCTIONS Civil Penalty Payments of Less Than 810,000 Payment ofa civil penalty ofless than $10,000 proposed or assessed, under Subpart B ofPart 190 of the Pipeline Safety Regulations san be made by certified check, money order or wire transfer. Payment by certifred check or money order (containing the CPF Number for this case) should be made payable to the "Department of Transporlation" and should be sent to: Federal Aviation Administration Mike Moruoney Aeronautical Center Financial Operations Division (AMZ-300) P.O. Box 25082 Oklahoma City, OK 73125'4915 Wire transfer payments of less than $10,000 may be made through the Federal Reserve Communications System (Fedwire) to the account of the U.S. Treasury. Detailed instructions are provided below. Questions conceming wire transfer should be directed to the Financial Operations Division at (405) 954-8893, or at the above address. Civil Penalty Payments of $10,000 or more Paymeht ofa civil penalty of$10,000 or more proposed or assessed under Subpart B ofPart 190 of the Pipeline Safety Regulations must be made wire transfer (49 C.F.R. $ 89.21 (bX3), through the Federal Reserve Communications System (Fedwire) to the account of the U,S. Treaswy. Detailed instructions are provided below. Questions concerning wire transfers should be directed to the Financial Operations Division at (405) 954-8893, or at the above address. INSTRUCTIONS FOR ELECTRONIC FT]ND TRANSFERS (I) RECEIVER ABA NO. 021030004 (2) TYPE/SUB-T\?E (Provided by sending bank) (3) SENpTNG BANKABANO. (Provided by ssnding bank) (4) SENpTNG BANK REF NO. (Provided by sending bank) (s)AMOUNT (6) SENDINGBANKNAME @rovided by sending bank) (7) RECEIVERNAME TREASNYC (8) PROpUCT COpE (Normally CTR, or as provided by sending bank) (9) BENEFICIAL (BND : AGENCY LOCATION CODE BNF = /ALC-69-14-0001 (10) REASONS FOR PA\MENT Example: PHMSA - CPF # / Ticket NumberlPipeline Assessment number 4 of5#

320075014M_Notice Of Amendment_03162007.pdf, page 8INSTRUCTIONS: You, as sender of the wire transfer, must provide the sending bank with the information for blocks (1), (5), (7), (9), and (10). The information provided in Blocks (l), (7), and (9) are constant and remain the same for all wire transfers to the Pipeline and Hazardous Materials Safety Administration, Departrnent of Transportation. Block #l - RECEIVER ABA NO. - "021030004". Ensure the sending bank enters this 9-digit identification number; it represents the routing symbol for the U.S. Treasury at the Federal Reserve Bank in New York. Block #5 - AMOLTNT - You as the sender provide the amount of the transfer. Please be sure the transfer amount is punctuated with commas and a decimal point. EXAMPLE: $10.000.00 Block#7 - RECEIVERNAME - "TREAS NYC". Ensure the sending bank enters this abbreviation. It must be used for all wire transfers to the Treasury Department, Block#9 - BENEFICI.A,L - AGENCY LOCATION CODE - "BNF=/ALC-69-14-0001". Ensure the sending bank enters this infotmation. This is the Agency Location Code for the Pipeline and Hazardous Materials Safety Administration, Department of Transportation. Btock #10 - REASON FOR PAYMENT - "AC-payment for PHMSA Case # / To ensure your wire transfer is credited properly, enter the case number/ticket number or Pipeline Assessment number, and country." NOTE: A wire transfer must comply with the format and instructions or the Department cannot accept the wire transfer. You as the sender can assist this process by notifying the Financial Operations Division (405) 954-8893 at the time you send the wire transfer. Februarv 2007 f or)#