{"operation":"document","citation":"CPF 420195015H","title":"PHILLIPS 66 PIPELINE LLC — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-07-16","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420195015h.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420195015h.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420195015h","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420195015H","body":"Corrective Action Order involving PHILLIPS 66 PIPELINE LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2019-07-16 and is reported as closed as of 2022-12-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420195015H_Closure Letter_12202022_(19-166263S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195015H/420195015H_Closure%20Letter_12202022_(19-166263S).pdf\n\n420195015H_Closure Letter_12202022_(19-166263S)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195015H/420195015H_Closure%20Letter_12202022_(19-166263S)_text.pdf\n\n420195015H_Corrective Action Order_07162019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195015H/420195015H_Corrective%20Action%20Order_07162019.pdf\n\n420195015H_Corrective Action Order_07162019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195015H/420195015H_Corrective%20Action%20Order_07162019_text.pdf\n\n420195015H_Closure Letter_12202022_(19-166263S)_text.pdf\n\nVIA ELECTRONIC MAIL\nDecember 20, 2022\nManny Cortez\nPresident\nPhillips 66 Pipeline, LLC\n2331 City West Blvd.\nHouston, Texas 77042\nCPF 4-2019-5015H\nDear Mr. Cortez:\nOn July 16, 2019, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued\na Corrective Action Order (CAO) to Phillips 66 Pipeline, LLC (Phillips 66) for the Line OK-01\nrupture that occurred on July 10, 2019, near Thornberry, Texas. Line OK-01 transports crude oil\nbetween Wichita Falls, Texas and Ponca City, Oklahoma.\nOn November 2, 2022, Phillips 66 notified the Southwest Region office of completion of the\nRemedial Work Plan and requested closure of the CAO and restoring the pipeline to its pre-failure\noperating pressure. PHMSA monitored the actions taken within the Remedial Work Plan and\nreviewed records submitted by Phillips 66. PHMSA has determined that the operator has\nsubstantially completed the requirements of the CAO and that the pipe can safely be returned to\npre-failure operating pressures.\nAccordingly, this case is now closed, and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\ncc: Doug Sauer, doug.b.sauer@p66.com\n\n420195015H_Corrective Action Order_07162019_text.pdf\n\nJuly 16, 2019\nVIA CERTIFIED MAIL AND EMAIL TO:\nTodd Denton\nPresident\nPhillips 66 Pipeline, LLC\n2331 CityWest Blvd.\nHouston, Texas 77042\nCPF No. 4-2019-5015H\nDear Mr. Denton:\nEnclosed please find a Corrective Action Order (CAO) issued by the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), in the above-\nreferenced case. It requires Phillips 66 Pipeline, LLC, to take certain corrective actions with\nrespect to a crude oil release north of Wichita Falls, Texas, on July 10, 2019, from its 12.75-inch\nOK-01 pipeline.\nService of this CAO is being made by certified mail and facsimile. Service of the CAO by\nelectronic transmission is deemed complete upon transmission and acknowledgement of receipt,\nor as otherwise provided under 49 C.F.R. § 190.5. The terms and conditions of this Order are\neffective upon completion of service.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure: CAO\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS\nMs. Mary McDaniel, Director, Southwestern Region, OPS\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n_______________________________________________\nIn the Matter of )\nPhillips 66 Pipeline, LLC, )\nRespondent. )\n)\n)\n)\n) CPF No. 4-2019-5015H\n_______________________________________________ )\nCORRECTIVE ACTION ORDER\nPurpose and Background:\nThis Corrective Action Order (CAO or Order) is being issued under the authority of 49 U.S.C.\n§ 60112 to require Phillips 66 Pipeline, LLC (P66 or Respondent), to take the necessary\ncorrective actions to protect the public, property, and the environment from potential hazards\nassociated with the July 10, 2019 release from its 12.75-inch OK-01 crude oil pipeline north of\nWichita Falls, Texas (Accident).\nOn the afternoon of July 10, 2019, the P66 control room observed indications of a potential\nrelease on its 12.75-inch OK-01 crude oil pipeline north of Wichita Falls, Texas, when a\npumping unit shut down on low-suction pressure, with a corresponding indication of high flow\nrate. At the time of the initial report, P66 did not have confirmation of a leak and planned to\nprovide aerial patrol to search for the leak. A follow-up report from P66 confirmed a release at\napproximately Mile Post (MP) 204.5, in a rural agricultural area, with an impacted area\nestimated 60 yards long by 80 yards wide, including a landowner’s pond (Failure Site). The site\nis identified as a could affect area for drinking water sources as well as ecological impact.\nP66 reported no injuries or fatalities as a result of the Accident, and there were no reported fires\nor explosions. The cause of the Accident appears to be related to the pipe’s Pre 1970 ERW\nseam. Pursuant to 49 U.S.C. § 60117, PHMSA, Office of Pipeline Safety (OPS), has initiated an\ninvestigation of the Accident. The preliminary findings of the agency’s ongoing investigation\nare as follows:\nPreliminary Findings:\n P66, a wholly-owned subsidiary of Phillips 66, operates more than 12,000 miles of\npipeline and associated facilities in the United States that transport both crude oil and\n\n\n\nCPF No. 4-2019-5015H\nPage 2\nrefined petroleum products.1\n The OK-01 crude oil system is a 12.75-inch pipeline running from Wichita Falls,\nTexas, to South Tank Farm in Ponca City, Oklahoma. The line is 217.24 miles in\nlength and was built in 1955. The pipeline is part of a larger P66 unit with a total of\n452.57 miles.\nUpon discovery of the potential release, P66 shut the system in and held pressure on\nthe pipeline north of the Red River, indicating the potential release was located\nsomewhere between Wichita Falls, Texas, and the Texas/Oklahoma state line. P66\ndispatched a patrol plane and confirmed the Failure Site as being located at\napproximately MP 204.5, roughly two miles east of Thornberry, Texas. P66\nmobilized its Oil Spill Removal Organization and company staff to respond to the\nFailure Site. It also placed booms in the landowner stock pond to contain the spilled\noil and began recovery operations.\n It is estimated that 1200 barrels of crude oil was released.\n Line OK-01, between Wichita Falls, Texas, and Ponca City, Oklahoma, was\nconstructed of 12.75-inch OD x 0.250-inch wall thickness, low-frequency electric\nresistance welded (LF ERW) pipe manufactured in 1955 by an unknown\nmanufacturer. Pipes manufactured prior to 1970 with LF ERW longitudinal seams are\na known threat to pipeline integrity under certain conditions. A visual inspection of\nthe failed pipe by the PHMSA personnel on-site appeared to show longitudinal seam\nfailure as a probable cause of the failure.\n On July 13, 2019, the Director approved P66’s written restart plan, and operation was\nrestarted on July 14, 2019.\n The rupture opening appears to be a longitudinal seam failure 7 feet long by 1 inch at\nthe widest point. The failure appears to be in the middle of a 47-foot section of\npipeline (between girth welds).\n The Maximum Operating Pressure is 1168 pounds per square inch (psig) at the leak\nlocation. The discharge at the Wichita Falls Pump Station (MP 217) was recorded at\n865 psig. The pump station is located approximately 13 miles upstream of the point\nof failure.\n There are portions of the approximate 217-mile OK-01 pipeline that traverse High\nConsequence Areas that could potentially affect the life and property of those\n1 See https://www.phillips66.com/about/ (last accessed July 15, 2019).\n\n\n\nCPF No. 4-2019-5015H\nPage 3\nsurrounded by the pipeline. The pipeline originates in the city of Wichita Falls, Texas.\nThe nature of the LF ERW pipeline may make a release more likely prior to\nadditional testing and evaluation.\n The pipeline crosses environmentally sensitive areas as the crude oil is shipped from\nWichita Falls, Texas, to Ponca City, Oklahoma. Some of the areas could affect areas\nand drinking water sources. Approximately 6.8 miles downstream of the Failure Site,\nthe pipeline crosses the Red River and there is a drinking water source between\nThornberry and the Failure Site to the southwest.\n There have been two reportable accidents on this pipeline between 2002 and the\npresent. The first was in September 2011 in Temple, Oklahoma, which was the result\nof an unknown cause as it was 25 feet under the Red River. P66 replaced the river\ncrossing in 2011. The second was in December 2013 in Ponca City, Oklahoma, which\nwas caused by third-party damage. The only reported seam failure was during a\nhydrotest performed in 2004.\n The operator reported that it performed an UT-CD (Crack Detection Tool) in-line\ninspection (ILI) run in July 2018 and an MFL/DEF ILI in March 2016. The closest\nanomalies that were previously investigated in 2010 and 2011 were due to external\ncorrosion.\n PHMSA has issued Advisory Bulletins on the heightened safety risks of Low-\nFrequency Welded ERW and Flash-Welded Pipe manufactured prior to 1970. It also\nissued Alert Notice, ALN-88-01, in January 1988, advising owners and operators of\nnatural gas and hazardous liquids pipelines to consider the threat from ERW pipe\nmanufactured prior to 1970. Operators were advised to determine whether their\npipelines were susceptible to ERW seam failures and address the potential impact on\npipeline integrity.\nDetermination of Necessity for Corrective Action Order and Right to Hearing:\nSection 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action\nOrder, after reasonable notice and the opportunity for a hearing, requiring corrective action,\nwhich may include the suspended or restricted use of a pipeline facility, physical inspection,\ntesting, repair, replacement, or other action, as appropriate. The basis for making the\ndetermination that a pipeline facility is hazardous and requiring corrective action is set forth both\nin the above-referenced statute and 49 C.F.R.§ 190.233.\nSection 60112, and the regulations promulgated thereunder, provide for the issuance of a\nCorrective Action Order without prior opportunity for notice and hearing upon a finding that\nfailure to issue the Order expeditiously will likely result in serious harm to life, property or the\nenvironment. In such cases, an opportunity for a hearing will be provided as soon as practicable\n\n\n\nCPF No. 4-2019-5015H\nPage 4\nafter the issuance of the Order.\nP66 is governed by Section 60101 of Title 49, United States Code, as detailed in 49 C.F.R.\nSection 195.\nAfter evaluating the foregoing preliminary findings of fact and considering the ongoing\ninvestigation of the Accident, I find that the continued operation of the Affected Segment\nwithout corrective measures is or would be hazardous to life, property and the environment.\nGiven the increased likelihood that there are other locations along the pipe that are subject to the\nsame operational cycles and fatigue, and given that this is a pre-1970 ERW pipe, there is a\nheightened risk of imminent failures along the pipe. Additionally, after considering the facts and\nthe ongoing investigation of the Accident, I find that a failure to issue this Order expeditiously to\nrequire immediate corrective action would result in likely serious harm to life, property, and the\nenvironment.\nAccordingly, this Corrective Action Order mandating immediate corrective action is issued\nwithout prior notice and opportunity for a hearing. The terms and conditions of this Order are\neffective upon receipt.\nWithin 10 days of receipt of this Order, Respondent may request a hearing, to be held as soon as\npracticable, by notifying the Associate Administrator for Pipeline Safety in writing, with a copy\nto the Director, Southwest Region, PHMSA (Director). If a hearing is requested, it will be held\ntelephonically or in-person in Houston, Texas, unless a different location is expressly agreed to\nin writing by the Director.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective measures that need to be taken. Respondent will be notified of any\nadditional measures required and, if appropriate, PHMSA will consider amending this Order. To\nthe extent consistent with safety, Respondent will be afforded notice and an opportunity for a\nhearing prior to the imposition of any additional corrective measures.\nRequired Corrective Actions:\nDefinitions:\nAffected Segment – Means the approximately 217 miles of P66’s 12.75-inch line OK-01\nfrom Wichita Falls, Texas, to Ponca City, Oklahoma.\nIsolated Segment- Means approximately the 33-mile segment of P66’s 12.75-inch line\nOK-01 from Waurika Lake (MP 184) and Wichita Falls (MP 217). It is the portion of the\n“Affected Segment” that was shut-in after the Accident on July 10, 2019, by closing main\nline valves (upstream and downstream of the Failure Site) and that remained shut-in until\nthe restart plan was approved by the Director.\n\n\n\nCPF No. 4-2019-5015H\nPage 5\nDirector – Means the Director, Southwest Region, PHMSA, Office of Pipeline Safety.\nPursuant to 49 U.S.C. 60112, I hereby order P66 to immediately take the following corrective\nactions for the Affected Segment:\n1. 2. 3. 4. 5. Return to Service. P66 obtained approval from the Director to resume operation.\nRestart Plan. P66 developed and submitted a written restart plan, and received approval\nfrom of the Director, Southwest Region. The Restart Plan provided for adequate\npatrolling of the Isolated Segment during the restart process and included measures to\nconfirm the integrity of the pipeline facilities that were damaged or are suspected of\nbeing damaged as a result of the Accident. The Restart Plan specified a daylight restart\nand provided for advance communications with local emergency response officials.\nMetallurgical Testing. Within 45 days of receipt of this Order, complete mechanical and\nmetallurgical testing and failure analysis of the failed pipe by an independent testing\nlaboratory. Complete the testing and analysis as follows:\nA. Document the chain-of-custody when handling and transporting the failed pipe\nsection and other evidence from the Failure Site;\nB. Within 10 days of receipt of this Order, develop and submit to the Director the\ntesting protocol, including selection of the testing laboratory, for prior approval;\nC. Prior to commencing the mechanical and metallurgical testing, provide the\nDirector with the scheduled date, time, and location of the testing to allow a\nPHMSA representative to witness the testing; and\nD. Ensure that the testing laboratory distributes all resulting reports in their entirety\n(including all media), whether draft or final, to the Director at the same time as\nthey are made available to Respondent.\nRoot Cause Failure Analysis. Within 90 days following receipt of this Order, complete a\nroot cause failure analysis (RCFA) and submit a final report of the RCFA to the Director.\nThe RCFA must be supplemented/facilitated by an independent third-party acceptable to\nthe Director and must document the decision-making process and all factors contributing\nto the failure. The final report must include findings and lessons learned. The RCFA must\nalso include a discussion of whether the findings and lessons learned are applicable to other\nlocations within P66’s pipeline system.\nRemedial Work Plan. Within 90 days after completing the metallurgical testing and\nanalysis, submit a remedial work plan (Remedial Work Plan) to the Director for approval.\nThe Remedial Work Plan must provide for the verification of the integrity of the Affected\nSegment and must address all factors known or suspected in the Accident, including, but\n\n\n\n6. 7. 8. CPF No. 4-2019-5015H\nPage 6\nnot limited to, the following:\nA. The integration of the results of the failure analyses and other actions required by\nthis Order with all relevant operating data, including all historical repair\ninformation, results of past in-line inspections, construction, operating,\nmaintenance, testing, metallurgical analysis or other third-party consultation\ninformation, and assessment data for the Affected Segment;\nB. The performance of additional field testing, inspections, and evaluations to\ndetermine whether and to what extent the conditions associated with the Accident\nor any other integrity-threatening conditions are present elsewhere on the\nAffected Segment. The results of the inspections, field excavations, and\nevaluations must be made available to PHMSA or its representative;\nC. The performance of repairs or other corrective measures that fully remediate the\nidentified risk conditions associated with the Accident and any other integrity-\nthreatening condition everywhere along the Affected Segment. Based on the\nknown history and condition of the pipeline, the plans for repairs must include\ncontinuing long-term periodic testing and integrity verification measures to ensure\nthe ongoing safe operation of the pipeline, considering the results of the analyses,\ninspections, and corrective measures undertaken pursuant to the Order; and\nD. A proposed schedule for completion of Items A−C.\nThe Remedial Work Plan will be incorporated by reference into this Order. Respondent\nmust revise the Remedial Work Plan as necessary to incorporate the results of actions\nundertaken pursuant to this Order and whenever necessary to incorporate new\ninformation obtained during P66’s failure investigation and remedial activities. Submit\nany such plan revisions to the Director for prior approval. The Director may approve\nplan elements incrementally.\nImplement the Remedial Work Plan as approved by the Director, including any revisions\nto the plan.\nPressure Restriction. After receiving approval from the Director to restart the Affected\nand Isolated Segments, the pressure for both segments is not to exceed 80% of the actual\noperating pressure in effect immediately prior to the Accident. P66 provided data to\nsupport the pressure derating from each of their stations along the pipeline. This pressure\nreduction requires that any relevant remote or local alarm limits, software programming\nset-points or control points, and mechanical over-pressure devices be adjusted\naccordingly. This pressure restriction will remain in effect until written approval to\nincrease the pressure or return the pipeline to its pre-failure operating pressure is obtained\nfrom the Director.\n\n\n\nCPF No. 4-2019-5015H\nPage 7\n9. 2. 3. Removal of Pressure Restriction. The Director may allow the removal or modification of\nthe pressure restriction upon a written request from Respondent demonstrating that\nrestoring the Affected Segment to its pre-failure operating pressure is justified based on a\nreliable engineering analysis showing that the pressure increase is safe considering all\nknown defects, anomalies and operating parameters of the pipeline.\nOther Requirements:\n1. Reporting. Submit quarterly reports to the Director that: (1) include all available data and\nresults of the testing and evaluations required by this Order; and (2) describe the progress\nof the repairs or other remedial actions being undertaken. The first quarterly report is due\non September 30, 2019. The Director may change the interval for the submission of\nthese reports.\nDocumentation of the Costs. It is requested but not required that Respondent maintain\ndocumentation of the costs associated with implementation of this Corrective Action\nOrder. Include in each monthly report submitted, the to-date total costs associated with:\n(1) preparation and revision of procedures, studies and analyses; (2) physical changes to\npipeline infrastructure, including repairs, replacements and other modifications; and (3)\nenvironmental remediation, if applicable.\nApprovals. With respect to each submission that under this Order requires the approval\nof the Director, the Director may: (a) approve, in whole or part, the submission; (b)\napprove the submission on specified conditions; (c) modify the submission to cure any\ndeficiencies; (d) disapprove in whole or in part, the submission, directing that Respondent\nmodify the submission, or (e) any combination of the above. In the event of approval,\napproval upon conditions, or modification by the Director, Respondent shall proceed to\ntake all action required by the submission as approved or modified by the Director. If the\nDirector disapproves all or any portion of the submission, Respondent must correct all\ndeficiencies within the time specified by the Director, and resubmit it for approval.\nExtensions of Time. The Director may grant an extension of time for compliance with\nany of the terms of this Order upon a written request timely submitted demonstrating\ngood cause for an extension.\nBe advised that all material you submit in response to this enforcement action is subject\nto being made publicly available. If you believe that any portion of your responsive\nmaterial 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\nportions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under 5\nU.S.C. § 552(b).\nIn your correspondence on this matter, please refer to “CPF No. 4-2019-5015H” and for each\n4. 5.\n\n\n\nCPF No. 4-2019-5015H\nPage 8\ndocument you submit, please provide a copy in electronic format whenever possible. The\nactions required by this Order are in addition to and do not waive any requirements that apply to\nRespondent’s pipeline system under 49 C.F.R. Parts 190 through 199, under any other order\nissued to Respondent under authority of 49 U.S.C. Chapter 601, or under any other provision of\nFederal or State law.\nRespondent may appeal any decision of the Director to the Associate Administrator for Pipeline\nSafety. Decisions of the Associate Administrator shall be final.\nFailure to comply with this Order may result in the assessment of civil penalties and in referral to\nthe Attorney General for appropriate relief in United States District Court pursuant to\n49 U.S.C. § 60120.\nThe terms and conditions of this Order are effective upon service in accordance with 49 C.F.R.\n§ 190.5.\nJuly 16, 2019\n_________________________________ ________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":22770}