PHILLIPS 66 PIPELINE LLC — Warning Letter

520085028w_warning letter_09082008_text.pdf, page 1Official PDF~3 (5 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#

520085028w_warning letter_09082008_text.pdf, page 2After 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)#