# PHILLIPS 66 PIPELINE LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 520070005
- **title:** PHILLIPS 66 PIPELINE LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2007-03-02
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 192.14.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520070005.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520070005.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520070005
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520070005
**body:**

Notice of Probable Violation involving PHILLIPS 66 PIPELINE LLC. PHMSA's enforcement data identifies the cited regulation as 192.14. The case was opened on 2007-03-02 and is reported as closed as of 2009-09-22. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

5-2007-0005 ConocoPhillips NOPV PCO 3-2-07.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520070005/5-2007-0005%20ConocoPhillips%20NOPV%20PCO%203-2-07.pdf

5-2007-0005 conocophillips nopv pco 3-2-07_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520070005/5-2007-0005%20conocophillips%20nopv%20pco%203-2-07_text.pdf

520070005_operator_response_10052007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520070005/520070005_operator_response_10052007.pdf

5-2007-0005 conocophillips nopv pco 3-2-07_text.pdf

U. s. Department
of Transportation
Pipeline and
Hazardous Materials Safety
Administration
12300 W Dakota Ave, Suite 110
Lakewood, CO 80228
NOTICE OF PROBABLE VIOLATION
and
PROPOSED COMPLIANCE ORDER
CERTIFIED MAIL - RETURN RECEIPT RE UESTED
March 2, 2007
Ms. Margaret Yaege
ConocoPhillips Pipeline Company
600 North Dairy Ashford Road
Houston, TX 77079
CPF 5-2007-0005
Dear Ms. Yaege:
On March 20 — 24, 2006, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your
intrastate natural gas pipeline facilities in San Luis Obispo County, California.
As a result of the inspection, it appears that you have committed a probable violation of the
Pipehne Safety Regulations, Title 49, Code of Federal Regulations. The items inspected
and the probable violation(s) are:
$192. 14 Conversion to service subject to this part. (a) A steel pipeline
previously used in service not subject to this part qualifies for use under this
part if the operator prepares and follows a written procedure to carry out the
following requirements:
(1) The design, construction, operation, and maintenance history of the
pipeline must be reviewed and, where sufficient historical records are not



available, appropriate tests must be performed to determine if the pipeline is
in a satisfactory condition for safe operation.
(2) The pipeline right-of-way, all aboveground segments of the pipeline, and
appropriately selected underground segments must be visually inspected for
physical defects and operating conditions which reasonably could be expected
to impair the strength or tightness of the pipeline.
(3) All known unsafe defects and conditions must be corrected in accordance
with this part.
(4) The pipeline must be tested in accordance with subpart J of this part, to
substantiate the maximum allowable operating pressure permitted by subpart
L of this part.
(b) Each operator must keep for the life of the pipeline a record of the
investigations, tests, repairs, replacements, and alterations made under the
requirements of paragraph (a) of this section.
Records were unavailable at the time of the inspection to substantiate compliance with this
section. Many historical records were destroyed in a fire, and the previous operator did not
consider the pipelines to be in regulated service. Formal pipeline-specific conversion-to-
service procedures were not documented.
Pro osed Com liance Order
Pursuant to 49 United States Code ) 60118, the Pipeline and Hazardous Materials Safety
Administration proposes to issue a Compliance Order to ConocoPhillips Pipeline Company.
Please refer to the Proposed Compliance Order that is enclosed and made a part of this
Notice.
Res onse to this Notice
Enclosed as part of this Notice is a document entitled Response Options for Pipeline
Operators in Compliance Proceedings. Please refer to this document and note the response
options. 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). If you
do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your
right to contest the allegations in this Notice and authorizes the Associate Administrator for
Pipeline Safety to find facts as alleged in this Notice without further notice to you and to
issue a Final Order.



In your correspondence on this matter, please refer to CPF 5-2007-0005 and for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
l
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators tn Compliance Proceedtngs
cc: PHP-60 Compliance Registry
PHP-500 J. Stahoviak (4116699)



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code $ 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to ConocoPhillips Pipeline Company a
Compliance Order incorporating the following remedial requirements to ensure the
compliance of ConocoPhillips Pipeline Company with the pipeline safety regulations:
In regard to Item Number 1 of the Notice pertaining to failure to adequately
perform and document conversion to Part 192 service, ConocoPhillips
Pipeline Company must prepare, submit, and follow a written procedure,
including a proposed time table, to fulfill the requirements for conversion to
service.
Following receipt of a Final Order, ConocoPhillips Pipeline Company must
submit the conversion to service procedure and timetable within 60 days.
Implementation of the specific steps contained in the procedure must not
vary significantly from the timetable without formal notice to the PHMSA,
Western Region Absent such delays, periodic updates on progress at 90 day
intervals must be supplied in wnting until the conversion is complete.
Because of the lack of alternate energy supplies to the downstream facilities,
it is understood that the timing of certain required activities, such as hydro-
tests, may not be under the control of ConocoPhillips Pipeline Company.
However, it is expected that opportunities for performing required activities,
such as a refinery "turnaround" will not be missed, barring extraordinary
circumstances and notification to PHMSA, Western Region.
ConocoPhillips Pipeline Company shall maintain documentation of the
safety improvement costs associated with fulfilling this Compliance Order
and submit the total to Christopher Hoidal, Director, Western Region,
Pipeline and Hazardous Materials Safety Administration. Costs shall be
reported in two categories: 1) total cost associated with preparation/revision
of plans, procedures, studies and analyses, and 2) total cost associated with
replacements, additions and other changes to pipeline infrastructure.
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