# PHILLIPS 66 PIPELINE LLC — Notice of Amendment - **operation:** document - **citation:** CPF 320205027M - **title:** PHILLIPS 66 PIPELINE LLC — Notice of Amendment - **source type:** enforcement - **agency:** Pipeline and Hazardous Materials Safety Administration - **status:** historical - **official:** true - **published on:** 2020-11-05 - **effective on:** Not available - **summary:** CLOSED notice of amendment citing 195.402(c)(13). - **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-320205027m.json - **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-320205027m.md - **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-320205027m - **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/320205027M **body:** Notice of Amendment involving PHILLIPS 66 PIPELINE LLC. PHMSA's enforcement data identifies the cited regulation as 195.402(c)(13). The case was opened on 2020-11-05 and is reported as closed as of 2021-02-26. Open the official case record for notices, responses, orders, and the latest status. Official case documents: 320205027M_Closure Letter_02262021.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320205027M/320205027M_Closure%20Letter_02262021.pdf 320205027M_Closure Letter_02262021_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320205027M/320205027M_Closure%20Letter_02262021_text.pdf 320205027M_Notice of Amendment_11052020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320205027M/320205027M_Notice%20of%20Amendment_11052020.pdf 320205027M_Notice of Amendment_11052020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320205027M/320205027M_Notice%20of%20Amendment_11052020_text.pdf 320205027M_Notice of Amendment_11052020_text.pdf NOTICE OF AMENDMENT VIA ELECTRONIC MAIL TO: Todd.Denton@p66.com and Jeff.M.Blatchford@p66.com November 5, 2020 Mr. Todd Denton President, Phillips 66 Pipeline LLC 2331 Citywest Blvd Houston, TX 77042 CPF 3-2020-5027M Dear Mr. Denton: On March 25 – 29 and September 9 - 13, 2019, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Phillips 66 Pipeline LLC’s (Phillips 66) procedures for an Integrated Inspection in Houston, Texas and Keene, North Dakota. On the basis of the inspection, PHMSA has identified the apparent inadequacy found within Phillips 66’s plans or procedures, as described below: 1. §195.402 Procedural manual for operations, maintenance, and emergencies. (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (13) Periodically reviewing the work done by operator personnel to determine the effectiveness of the procedures used in normal operation and maintenance and taking corrective action where deficiencies are found. Phillip 66's Operation and Maintenance (O&M) manual is inadequate because it did not sufficiently address periodically reviewing the work done by operator personnel to determine the effectiveness of the procedures used in normal operation and maintenance and take corrective action where deficiencies are found. Procedure "P66-TSD-0103 Personnel Knowledge Verification & Emergency Response Training" was shown to PHMSA in response to an inquiry regarding this regulatory requirement. Accompanying the procedure is form “P66-TSD-0103A Annual Review Checklist for Field Employees.” Phillips 66 uses this procedure and form to demonstrate personnel knowledge, proficiency, and ability to perform operating and maintenance functions rather than reviewing the work done by operator personnel to determine the effectiveness of the procedures as required by §195.402(c)(13). Specifically, the procedure did not clearly state how often an effectiveness review will occur for each procedure used in normal operation and maintenance activities. Also, the procedure did not provide clear direction on how the review of work done by personnel will be performed to determine the effectiveness of the procedures. Phillips 66 must amend its procedures to address the inadequacies identified above in order to ensure the procedure adequately meets the requirements of §195.402(c)(13). Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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. 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 treatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. 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 an Order Directing Amendment. If 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. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office 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. It is requested (not mandated) that Phillips 66 Pipeline LLC maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment 2 (preparation/revision of plans, procedures) and submit the total to Allan C. Beshore, Director, Central Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 3-2020-5027M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Gregory A. Ochs Director, Central Region, OPS Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings cc: Jeff Blatchford, DOT Coordinator, Jeff.M.Blatchford@p66.com 3 320205027M_Closure Letter_02262021_text.pdf VIA ELECTRONIC MAIL TO: Todd.Denton@p66.com and Jeff.M.Blatchford@p66.com February 26, 2021 Mr. Todd Denton President, Phillips 66 Pipeline LLC 2331 Citywest Blvd Houston, TX 77042 Re: CPF 3-2020-5027M Dear Mr. Denton: On March 25 – 29 and September 9 - 13, 2019, representatives 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 Phillips 66 Pipeline LLC’s (Phillips 66) procedures in Houston, Texas and Keene, North Dakota. As a result of the inspection, Phillips 66 was issued a Notice of Amendment on November 5, 2020, which proposed amendment of your procedures. Phillips 66 submitted its amended procedures on Febuary 5, 2021. 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, Gregory A. Ochs Director, Central Region, OPS Pipeline and Hazardous Materials Safety Administration - **truncated:** false - **body characters:** 7283