# ConocoPhillips (E&P - L-48) — Warning Letter

- **operation:** document
- **citation:** CPF 420171004W
- **title:** ConocoPhillips (E&P - L-48) — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2017-02-09
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 191.22(c)(2)(iii).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-420171004w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-420171004w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-420171004w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420171004W
**body:**

Warning Letter involving ConocoPhillips (E&P - L-48). PHMSA's enforcement data identifies the cited regulation as 191.22(c)(2)(iii). The case was opened on 2017-02-09 and is reported as closed as of 2017-02-09. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420171004W_Warning Letter_02092017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420171004W/420171004W_Warning%20Letter_02092017.pdf

420171004W_Warning Letter_02092017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420171004W/420171004W_Warning%20Letter_02092017_text.pdf

420171004W_Warning Letter_02092017_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
February 9, 2017
Oracio Estrada
Regulatory Specialist
Conoco Phillips (E&P-L-48)
P.O. BOX 2197
Houston, Texas 77252
CPF 4-2017-1004W
Dear Mr. Estrada:
In December 2016, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code reviewed the
notification reports filed electronically by Conoco Phillips. As a result of this review, it appears
that you have committed a probable violation of the Pipeline Safety Regulations, Title 49, Code
of Federal Regulations. The item reviewed and the probable violation is:
1. §191.22 National Registry of Pipeline and LNG Operators.
(c) Changes. Each operator must notify PHMSA electronically through the
National Registry of Pipeline and LNG Operators at http://opsweb.phmsa.dot.gov,
of certain events.
(2) An operator must notify PHMSA of any following event not later than 60
days after the event occurs:
(iii) A change in the entity (e.g., company, municipality) responsible
for an existing pipeline, pipeline segment, pipeline facility,
underground natural gas storage facility, or LNG facility;



Conoco Phillips failed to file notification of divestiture for 30.23 miles of gas transmission
pipeline no later than 60 days following the divestiture. Conoco Phillips submitted an Operator
Registry Notification Type D for 30.23 miles of Onshore, Intrastate pipeline, located in Brazoria
County, TX. According to the information submitted, the divestiture was completed on April 1,
2016, and the notification was not received until July 25, 2016 (114 days). This notification was
required by June 1, 2016.
For future filings, please be aware that the notification required for the divestiture of less than 50
miles would be a Type B. Attached for your convenience is a copy of the “Instructions (rev 5-
2015) for Form PHMSA F 1000.2 (rev 5-2015) OPERATOR REGISTRY NOTIFICATION” to
submit the correct notification type.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $205,638
per violation per day the violation persists up to a maximum of $2,056,380 for a related series of
violations. For violation occurring between January 4, 2012 to August 1, 2016, the maximum
penalty may not exceed $200,000 per violation per day, with a maximum penalty not to exceed
$2,000,000 for a related series of violations. For violations occurring prior to January 4, 2012,
the maximum penalty may not exceed $100,000 per violation per day, with a maximum penalty
not to exceed $1,000,000 for a 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 item identified in this letter. Failure to do so will result in Conoco Phillips (E&P-L-
48) being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 4-2017-1004W. 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).
Sincerely,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
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