{"operation":"document","citation":"CPF 420155007W","title":"PHILLIPS 66 PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-03-31","effective_on":null,"summary":"CLOSED warning letter citing 195.202, 195.214(a), 195.214(b), 195.228(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420155007w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420155007w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420155007w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420155007W","body":"Warning Letter involving PHILLIPS 66 PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.202,  195.214(a),  195.214(b),  195.228(a). The case was opened on 2015-03-31 and is reported as closed as of 2015-03-31. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420155007W_Operator Response to Notice_04242015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155007W/420155007W_Operator%20Response%20to%20Notice_04242015.pdf\n\n420155007W_Warning_03312015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155007W/420155007W_Warning_03312015.pdf\n\n420155007W_Warning_03312015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155007W/420155007W_Warning_03312015_text.pdf\n\n420155007W_Warning_03312015_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 31, 2015\nMr. Todd Denton\nPresident\nPhillips 66 Pipeline LLC\n3010 Briarpark Drive\nHouston, TX 77042\nCPF 4-2015-5007W\nDear Mr. Denton:\nOn February 9-12, 2015, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your\nconstruction on the Triple C Project in Pasadena, TX.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violation(s) are:\n1. §195.228 Welds and welding inspection: Standards of acceptability.\n(a) Each weld and welding must be inspected to insure compliance with the\nrequirements of this subpart. Visual inspection must be supplemented by\nnondestructive testing.\nPhillips 66 failed to visually inspect welds made during construction of the Triple C project as\nrequired by §195.228. During the PHMSA inspection, Phillips 66 was unable to produce any\n\n\n\nrecords or other documentation of visual inspection of the welds showing that they were found to\nhave met the requirements of Section 9 of API 1104 and the Phillips 66 welding procedures.\n2. §195.214 Welding procedures\n(a) Welding must be performed by a qualified welder in accordance with welding\nprocedures qualified under Section 5 of API Std 1104 or Section IX of the ASME\nBoiler and Pressure Vessel Code (ASME BPVC) (incorporated by reference, see\n§195.3). The quality of the test welds used to qualify the welding procedure shall be\ndetermined by destructive testing.\n(b) Each welding procedure must be recorded in detail, including the results of the\nqualifying tests. This record must be retained and followed whenever the procedure\nis used.\nPhillips 66 failed to confirm that welds made during construction of the Triple C project were\ndone according to the qualified welding procedure (WPS# P1D). During the PHMSA\ninspection, Phillips 66 was unable to produce any records or other documentation showing that\nthe welds were confirmed to have been made according to the essential variables and within the\nparameters of the qualified welding procedure (i.e., within the ranges of voltage, amperage,\ntravel speed, appropriate number of passes, and using the specified electrodes, etc.). The\nnondestructive examination (NDE) employed by Phillips 66 on the construction project can\ndetermine if the welders introduced a defect into the weld that would cause the weld to be\nrejected by the criteria in API 1104, Section 9. However, the NDE by itself cannot determine\nthat the weld was made within the parameters of the qualified welding procedure to ensure that\nthe weld has the same required strength and mechanical properties as the qualifying weld.\n3. §195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive\nwritten specifications or standards that are consistent with the requirements of this\npart.\nPhillips 66 failed to follow its specification, Welding Procedures and Welder Qualification,\nP66PL-MPR-4401 during the construction of the Triple C project. During the PHMSA\ninspection, Phillips 66 was unable to produce any records or other documentation showing that\nthe welding was performed according to the requirements of P66PL-MPR-4401, Section 8,\nProduction Welding. Paragraph 8.1.1 states, “Each weld must be thoroughly inspected to\nidentify any defect. All defects in the root pass must be repaired before welding is resumed\nbecause defects in the root pass can propagate through the entire finished weld.” Section 8\neffectively details nineteen additional items associated with the root bead pass, interpass welds,\nand the completed weld that must be inspected. Phillips 66 could not provide any records or\ndocumentation that these welding inspections had been performed.\n2\n\n\n\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\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 item(s) identified in this letter.\nFailure to do so will result in Phillips 66 being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2015-5007W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), 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\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nR.M. Seeley\nDirector, SW Region\nPipeline and Hazardous Materials Safety Administration\n3","truncated":false,"body_characters":6269}