# PHILLIPS 66 PIPELINE LLC — Warning Letter

- **operation:** document
- **citation:** CPF 520085028W
- **title:** PHILLIPS 66 PIPELINE LLC — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2008-09-08
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.412(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520085028w.json
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520085028W
**body:**

Warning Letter involving PHILLIPS 66 PIPELINE LLC. PHMSA's enforcement data identifies the cited regulation as 195.412(a). The case was opened on 2008-09-08 and is reported as closed as of 2008-09-08. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520085028W_warning letter_09082008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085028W/520085028W_warning%20letter_09082008.pdf

520085028w_warning letter_09082008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085028W/520085028w_warning%20letter_09082008_text.pdf

520085028w_warning letter_09082008_text.pdf

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U. S DePGrlment
of Tl G rlsPortGtlofl
Ptpslllns and
Hazardous Matermalls Safety
Admtnmstmtiion
12300 W Dakota Ave, Suite 110
Lakewood, CO 80228
WA~IXG KKTTKR
September 8, 2008
Ms Meg Yeage
President
Conoco/Philhps Pipe Line Company
600 North Dairy Ashford
Houston, TX 77079
CPF 5-2008-5028M
Dear Ms. Yeage.
On April 1, 2008 a representative of the Pipehne and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your
Borger Denver Products Pipehne in Commerce City, Colorado.
As a result of the inspection, it appears that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the
probable violation is:
(a) Each operator shaH, at intervals not exceeding 3 weeks, but at least 26 times
each calendar year, inspect the surface conditions on or adjacent to each pipeline
right-of-way. Methods of inspection include walking, driving, flying or other
appropriate mean of traversing the right-of-way.
The operator's procedure for documenting right-of-way inspections was niadequate and
resulted in some pipehne segments not being inspected at the correct time intervals



After spending considerable time reviewing two small samples of patrol records,
violations were discovered in both samplings From MP 336 to MP 342, the time
interval was 31 days between nispections. From MP 487 to MP 530, the interval was 23
days.
Under 49 United States Code, ( 60122, you are subject to a civil penalty not to exceed $100, 000
for each violation for each day the violation persists up to a maximum of $1, 000, 000 for any
related series of violations. We have reviewed the circumstances and suppoitmg 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 Pipe Line Company 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 5-ZOO8-5O28%. Be advised that all material you submit in response to this enforcement
action is subject to being made pubhcly available If you beheve that any portion of your
responsive material quahfies 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 beheve quahfy for confidential treatment redacted and an explanation of why you beheve
the redacted information qualifies for confidential treatment under 5 U. S. C, 552(b).
Sincerely,
Chris Hoidal
Director, Western Region
Pipehne and Hazardous Materials Safety Administration
cc. PHP-60 Comphance Registry
PHP-500 J. Haddow (4120728)
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