{"operation":"document","citation":"CPF 420185012W","title":"PHILLIPS 66 PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-11-16","effective_on":null,"summary":"CLOSED warning letter citing 195.567(c), 195.581.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420185012w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420185012w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420185012w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420185012W","body":"Warning Letter involving PHILLIPS 66 PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.567(c),  195.581. The case was opened on 2018-11-16 and is reported as closed as of 2018-11-16. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420185012W_Warning Letter_11162018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420185012W/420185012W_Warning%20Letter_11162018.pdf\n\n420185012W_Warning Letter_11162018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420185012W/420185012W_Warning%20Letter_11162018_text.pdf\n\n420185012W_Warning Letter_11162018_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 16, 2018\nTodd Denton\nPresident\nPhillips 66 Pipeline, LLC\n2331 City West Blvd.\nHouston, Texas 77042\nCPF 4-2018-5012W\nDear Mr. Denton:\nFrom January 16 to August 9, 2018, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49\nUnited States Code (U.S.C.) inspected Phillips 66 Pipeline LLC’s (Phillips 66) pipelines and\nfacilities in Kansas, New Mexico, Oklahoma and Texas.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. §195.567 Which pipelines must have test leads and what must I do to install and\nmaintain the leads?\n\n\n\n2. (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 §195.571.\nPhillips 66 failed to maintain test lead wires in a condition that would enable them to obtain\nelectrical measurements to determine whether cathodic protection complies with §195.71.\nPHMSA reviewed Phillips 66 cathodic protection annual survey records in their Alvin,\nTexas office. During the review, it was observed that two test leads on line ST-18 did not\nhave data for pipe-to-soil potential readings. There was no reading for the test lead at\nmilepost 27 3+3 for calendar years 2015, 2016, 2017 and there were no readings for the\ntest lead at milepost 58 13+3 for calendar years 2016, 2017. Phillips 66 stated the test\nleads had been damaged. The 2018 annual survey records indicated the test leads had been\nrepaired and the pipe-to-soil potential readings were adequate.\n§195.581 Which pipelines must I protect against atmospheric corrosion and what\ncoating material may I use?\n(a) You must clean and coat each pipeline or portion of pipeline that is exposed to the\natmosphere, except pipelines under paragraph (c) of this section.\n(b) Coating material must be suitable for the prevention of atmospheric corrosion.\n(c) Except portions of pipelines in offshore splash zones or soil-to-air interfaces, you\nneed not protect against atmospheric corrosion any pipeline for which you\ndemonstrate by test, investigation, or experience appropriate to the environment of\nthe pipeline that corrosion will—\n(1) Only be a light surface oxide; or\n(2) Not affect the safe operation of the pipeline before the next scheduled inspection.\nPhillips 66 failed to protect against atmospheric corrosion at soil-to-air interfaces on their\nfacilities at file locations.\nDuring the field review of Phillips 66 facilities, it was observed by PHMSA that there were\nareas of damaged coating at soil-to air interfaces or the coating did not adequately extend\nbeyond the ground surface and protect the soil-to-air interface. The following table lists\nthose facilities and the inadequacies.\nFacility Inadequacy\nPasadena Terminal Odessa Terminal\nA flange was partially buried and there\nwas no soil-to-air interface coating\nA flange connected to the WT-10 pump\nwas partially buried and there was no soil-\nto-air interface coating\n2\n\n\n\nBorger Terminal\nHighway 8 Block Valve Line MX-10 Jay Hawk Junction Line MX-10 The scraper trap soil-to-air interface\ncoating did not extend far enough beyond\nthe ground surface and non-coated pipe\nwas in contact with the ground.\nThe soil-to-air interface coating had been\ndamaged and needed repair.\nThe soil-to-air interface coating had been\ndamaged and needed repair.\nPrior to completion of the inspection, the damaged coating was repaired and soil was\nremoved from the area around the flanges and scraper trap pipe. Phillips 66 took\nphotographs of the repairs. The photographs were reviewed by PHMSA and the repairs\nwere found to be acceptable.\nProposed Civil Penalty\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$209,002 per violation per day the violation persists, up to a maximum of $2,090,022 for a related\nseries of violations. For violations occurring prior to November 2, 2015, the maximum penalty\nmay not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000\nfor a related 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 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 4-2018-5012W. 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 the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n3","truncated":false,"body_characters":6204}