{"operation":"document","citation":"CPF 42025048NOA","title":"DCP MIDSTREAM, LP — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-05-21","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(1), 192.710(a), 192.710(f), 192.711(a), 192.711(c), 192.712(g)(1), 192.712(g)(19).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025048noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025048noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025048noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42025048NOA","body":"Notice of Amendment involving DCP MIDSTREAM, LP. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(1),  192.710(a),  192.710(f),  192.711(a),  192.711(c),  192.712(g)(1),  192.712(g)(19). The case was opened on 2025-05-21 and is reported as closed as of 2025-07-23. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42025048NOA_Closure Letter_07232025_(24-296557).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025048NOA/42025048NOA_Closure%20Letter_07232025_(24-296557).pdf\n\n42025048NOA_Closure Letter_07232025_(24-296557)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025048NOA/42025048NOA_Closure%20Letter_07232025_(24-296557)_text.pdf\n\n42025048NOA_Notice of Amendment_05212025_(24-296557).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025048NOA/42025048NOA_Notice%20of%20Amendment_05212025_(24-296557).pdf\n\n42025048NOA_Notice of Amendment_05212025_(24-296557)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025048NOA/42025048NOA_Notice%20of%20Amendment_05212025_(24-296557)_text.pdf\n\n42025048NOA_Operator Response to Notice_06162025_(24-296557).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025048NOA/42025048NOA_Operator%20Response%20to%20Notice_06162025_(24-296557).pdf\n\n42025048NOA_Notice of Amendment_05212025_(24-296557)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: bill.johnson@p66.com\nMay 21, 2025\nBill Johnson\nPresident\nPhillips 66\n2331 Citywest Blvd\nHouston, Texas 77042\nCPF 4-2025-048-NOA\nDear Mr. Johnson:\nFrom February 6 to May 22, 2024 of the on-site inspection, representatives of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.), inspected DCP Midstream’s1 (DCP) procedures for operations and\nmaintenance in Houston, Texas.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within DCP’s\nplans and procedures. The items inspected and the inadequacies are described below:\n1. § 192.605 Procedural manual for operations, maintenance, and\nemergencies.\n(a) . . . .\n(b) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the\nfollowing, if applicable, to provide safety during maintenance and\noperations.\n(1) Operating, maintaining, and repairing the pipeline in\naccordance with each of the requirements of this subpart and subpart\nM of this part.\n1 DCP Midstream is a subsidiary of Phillips 66.\n\n\n\n§ 192.710 Transmission lines: Assessments outside of high consequence areas.\n(a) Applicability. This section applies to onshore steel transmission\npipeline segments.\n(b) . . . .\n(f) Remediation. An operator must comply with the requirements\nin § 192.485, § 192.711, § 192.712, § 192.713, and § 192.714, where\napplicable, if a condition that could adversely affect the safe operation\nof a pipeline is discovered.\n§ 192.711 Transmission lines: General requirements for repair\nprocedures.\n(a) Temporary repairs.\n(b) ….\n(c) Welded patch. Except as provided in §192.717(b)(3), no operator may\nuse a welded patch as a means of repair.\nDCP’s written procedures for conducting operations and maintenance activities in accordance with\neach of the requirements of Subpart L and Subpart M were inadequate to provide for safety during\nnormal maintenance and operations in accordance with § 192.605(b)(1). Specifically, DCP’s\nprocedures, P66-TSD-3009 Pipeline Anomaly Worklist Selection Criteria (Rev. 4; Effective Sep.\n29, 2023) and Pipeline Repair and Lowering (Feb. 3, 2021) failed to include procedures for the\ngeneral repair requirements in § 192.711(c), if a condition that could adversely affect the safe\noperation of a pipeline is discovered, in accordance with § 192.710(f).\nAfter issuance of PHMSA’s Post-Inspection Written Preliminary Findings Report, DCP submitted\nupdated procedures P66-TSD-3009 Pipeline Anomaly Worklist Selection Criteria (Rev. 5;\nEffective June 28, 2024) on July 18, 2024, to PHMSA for review. It still did not include the general\nrepair requirement at § 192.711(c).\nTherefore, PHMSA proposes that DCP amend its procedures to include the requirements in §\n192.711(c), where applicable, if a condition that could adversely affect the safe operation of a\npipeline is discovered in accordance with § 192.710(f).\n2. § 192.605 Procedural manual for operations, maintenance, and\nemergencies.\n(a) . . . .\n(b) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the\nfollowing, if applicable, to provide safety during maintenance and\noperations.\n(1) Operating, maintaining, and repairing the pipeline in\naccordance with each of the requirements of this subpart and subpart\nM of this part.\n§ 192.712 Analysis of predicted failure pressure and critical strain level.\n\n\n\n(a) Applicability. Whenever required by this part,\n(b) . . . .\n(g) Records. An operator must keep for the life of the pipeline\nrecords of the investigations, analyses, and other actions taken in\naccordance with the requirements of this section. Records must\ndocument justifications, deviations, and determinations made for the\nfollowing, as applicable:\n(1) The technical approach used for the analysis;\n(2) ….\n……\n(19) Approval by responsible operator management personnel.\nDCP’s written procedures for conducting operations and maintenance activities in accordance with\neach of the requirements of Subpart L and Subpart M were inadequate to provide for safety during\nnormal maintenance and operations in accordance with § 192.605(b)(1). Specifically, DCP’s\nprocedure, Gas Pipeline O&M Manual M-04 DOT Record Keeping (Rev. Oct. 12, 2023), failed to\nrequire the retention of all records under paragraphs (1) to (19) of § 192.712(g).\nTherefore, PHMSA proposes that DCP amend its written procedures for requiring record keeping\nto include all required records to be maintained for the life of the pipeline in accordance with §\n192.712(g).\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. § 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 U.S.C. § 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 90 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\n\n\n\naction will be closed.\nIt is requested (not mandated) that DCP maintain documentation of the safety improvement costs\nassociated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures)\nand submit the total to Bryan Lethcoe, Director, Southwest Region, Pipeline and Hazardous\nMaterials Safety Administration. In correspondence concerning this matter, please refer to CPF 4-\n2025-048 and, for each document you submit, please provide a copy in electronic format whenever\npossible.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Doug B. Sauer, Manager, Pipeline Regulatory Affairs, Philips 66,\ndoug.b.sauer@p66.com\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n\n42025048NOA_Closure Letter_07232025_(24-296557)_text.pdf\n\nVIA ELECTRONIC MAIL TO: bill.johnson@p66.com\nJuly 23, 2025\nBill Johnson\nPresident\nPhillips 66\n2331 Citywest Blvd\nHouston, Texas 77042\nRE: CPF 4-2025-048-NOA\nDear Mr. Johnson:\nOn May 21, 2025, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued\nto DCP Midstream, LP (DCP), a Notice of Amendment (Notice) in the above-referenced case.\nDCP submitted its final version of the procedure for Items 1 and 2 on June 16, 2025. PHMSA\nstaff reviewed these procedures and documents. The inadequacies outlined in this Notice have\nbeen corrected.\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.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Doug B. Sauer, Vice President, Pipeline Regulatory Affairs, Philips 66,\ndoug.b.sauer@p66.com\nMichael Pavlak, Director, DOT Gas Operations Compliance, Phillips 66,\nMichael.Pavlak@p66.com","truncated":false,"body_characters":9721}