{"operation":"document","citation":"CPF 520085039W","title":"PHILLIPS 66 PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-10-15","effective_on":null,"summary":"CLOSED warning letter citing 195.452(f)(3), 195.452(f)(5), 195.452(f)(6), 195.452(f)(8).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085039w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085039w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085039w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520085039W","body":"Warning Letter involving PHILLIPS 66 PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.452(f)(3),  195.452(f)(5),  195.452(f)(6),  195.452(f)(8). The case was opened on 2008-10-15 and is reported as closed as of 2008-10-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520085039W_warning letter_10152008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085039W/520085039W_warning%20letter_10152008.pdf\n\n520085039w_warning letter_10152008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085039W/520085039w_warning%20letter_10152008_text.pdf\n\n520085039w_warning letter_10152008_text.pdf\n\nU. S Department\nof Transportahon\nPipelllne md\nHdzmdovs Mafertells Safety\nAdmtrtilsfjrefion\n12300 W Dakota Ave, Suite 110\nLakewood, CO 80228\nWA~IXG KKTTKR\nOctober 15, 2008\nMs. Margaret A Yaege\nPresident\nConocoPhilhps Pipehnes Inc\n600 North Dairy Ashford\nHouston, TX 77079\nCPF 5-2008-5039W\nDear Ms. Yaege\nOn May 19-23 and June 2-5, 2008, representatives of the Pipehne and Hazardous Materials\nSafety Administration (PHMSA) and the Washington Utihties and Transportation Commission\n(WUTC), pursuant to Chapter 601 of 49 United States Code, conducted an inspection of the\nConocoPhilhps Pipe Lme Company's (CPPL) Integrity Management Program (IMP) in Ponca\nCity, Oklahoma\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipehne Safety Regulations, Title 49, Code of Federal Regulations The items inspected and the\nprobable violations are\nfI What are the elements of an integrity management programs An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating expe~ience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\nope~ato~ must include, at minimum, each of the following elements in its written\nintegrity management program:\n\n\n\nThe CPPL evaluated one of their in-hne inspection (ILI) vendors using the quahfication\nrequirements of API 1163 (ASNT-ILI-PQ-2005) The supervisory personnel who review\nand evaluate integrity assessment results were assessed, however, the CPPL needs to\nreview the process in detail to ensure that all analysts grading ILI tool data meet the\nrequirements specified in API 1163 and ANST ILI-PQ-2005\n(f) What are the elements of an integrity management program~ An integrity\nmanagement program begins with the initial framework. An operator must.\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its wi itten\nintegrity management pr ogram:\n(3) An analysis that integrates all available information about the integrity of the\nentire pipehne and the consequences of a failure (see par agraph (g) of this section);\n(g) What is an information analysis?' 1n periodicaHy evaluating the integrity of each\npipeline segment (paragraph (j) of this section), an operator must analyze all\navailable information about the integrity of the entire pipeline and the consequences\nof a failure. This information includes:\n(1) 1nformation critical to determining the potential for, and preventing, damage\ndue to excavation, including current and planned damage prevention activities, and\ndevelopment or planned development along the pipehne segment;\n(2) Bata gathered through the integrity assessment required under this section;\n(3) Data gathered in conjunction with other inspections, tests, surveillance and\npatrols required by this Part, including, corrosion control monitoring and cathodic\nprotection surveys; and\n(4) 1nformation about how a failure wouM affect the high consequence area, such as\nlocation of the wate~ intake.\nThe CPPL needs to mtegrate and review the data from the previous ILI assessment tools\nto strengthen the CPPL integrity management performance and to measure the\neffectiveness of their damage prevention program,\n$195. 452 Pipehne integrity management in high consequence areas.\n\n\n\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the Following elements in its written\nintegrity management program:\n(6) Identification of preventive and mitigative measures to protect the high\nconsequence area (see paragraph (i) of this section);\n(i) What preventive and mitigative measures must an operator take to protect the\nhigh consequence areaP\n(t) General requirements. An operator must take measures to prevent and mitigate\nthe consequences of a pipehne failure that could affect a high consequence area.\nThese measures include conducting a nsk analysis of the pipehne segment to identify\nadditional actions to enhance pubhc safety or environmental protection. Such actions\nmay include, but are not Hmited to, implementing damage prevention best practices,\nbetter monitoring of cathodic protection where corrosion is a concern, estabHshing\nshorter inspection intervals, instalHng KF~s on the pipeHne segment, modifying the\nsystems that monitor pressure and detect leaks, prov~ding additional training to\npersonnel on response procedures, conducting drills with local emergency\nresponders and adopting other management controls.\n(2) Wsk analysis criteria. In identifying the need for additional preventive and\nmitigative measures, an operator must evaluate the hkeHhood of a pipeline release\noccurring and how a release could affect the high consequence area. This\ndetermination must consider all relevant risk factors, including, but not limited to:\n(i) Terrain surrounding the pipehne segment, including drainage systems such as\nsmall streams and othe~ smaller waterways that couM act as a conduit to the high\nconsequence areal\n(ii) Elevation profile;\n(iii) Characteristics of the product transported;\n(iv) Amount of product that couM be released;\n(v) Possibility of a spillage in a Farm field Following the drain tile into a waterway;\n(vi) Ditches along side a roadway the pipehne crosses;\n(vii) Physical support of the pipeline segment such as by a cable suspension bridge;\n(viii) Exposure of the pipehne to operating pressure exceeding estabhshed maximum\noperating pressure.\nThe decision process for implementing CPPL's Preventive and Mitigative Measures\n(PkMM) prospects should show how their IM prospects are integrated mto the risk model\n(PIRAMID) process The risk model does not appear to be sensitive to the\nimplementation of the PAMM prospects. In addition, the process for defining and rankrng\nPRMM for the facility is not well defined m the IMP This is important to ensure future\nPkMM decisions are made in a consistent, risk-based manner\n\n\n\ndata, and evaluation of consequences of a failuxe on the high consequence area. An\noperato~ must include, at minimum, each of the following elements in its written\nintegrity management program:\n(6) Identification of preventive and mitigative measuxes to pxotect the high\nconsequence area (see paragraph (i) of this section);\n(i) What preventive and mitigative measuxes must an operator take to protect the\nhigh consequence area~\n(3) I. eak detection. An opexator must have a means to detect leaks on its pipeline\nsystem. An operatox must evaluate the capability of its leak detection means and\nmodify, as necessary, to protect the high consequence area. An operator's evaluation\nmust, at least, considex, the foHowing factoxs — length and size of the pipeline, type of\npxoduct carried, the pipeHne's proximity to the high consequence axea, the swiftness\nof leak detection, location of nearest response personnel, leak history, and risk\nassessment results.\n(4) Emergency Flow Restricting Devices (KF~). If an operator determines that an\nKF~ is needed on a pipehne segment to protect a high consequence area in the\nevent of a hazardous Hquid pipeline release, an operator must install the KF~. In\nmaking this determination, an opexatox must, at least, consider the following\nfactors — the swiftness of leak detection and pipeline shutdown capabiHties, the type of\ncommodity carried, the rate of potential leakage, the volume that can be released,\ntopography or pipeline profile, the potential for ignition, proximity to power sources,\nlocation of nearest response pexsonnel, specific terrain between the pipehne segment\nand the high consequence Mea, and benefits expected by reducing the spill size.\nThe process for evaluating and identifying PkMM, leak detection capabihty, and\nemergency flow restricting devices (EFRD) is not fully implemented. It is expected at this\ntime that the required processes would be mature and the focus needs to be on the\nimplementation aspects to reduce both risk and release volume\n(f) What are the elements of an integrity management pxogxam~ An integrity\nmanagement pxogram begins with the initial framework. An opexator must\ncontinuaHy change the program to reflect operating experience, conclusions d~awn\nfrom results of the integrity assessxnents, and other maintenance and surveiHance\ndata, and evaluation of consequences of a failure on the hiigh consequence area. An\noperator must include, at minimum, each of the foHowing elements in its written\nintegrity management pxogram:\n(5) A continual process of assessxnent and evaluation to maintain a pipehne's\nintegrity (see par agx aph (j) of this section);\n(j) What is a continual process of evaluation and assessment to maintain a pipeHne's\nintegnty?'\n(]. ) General. After completing the basehne integrity assessment, an operato~ must\ncontinue to assess the hne pipe at specified intervals and pexiodicaHy evaluate the\nintegrity of each pipeline segment that could affect a high consequence area.\n\n\n\nCPPL must ensure and document that all niformation (for instance stress corrosion\ncrackIng) regarding a pipelme's mtegrity is being continually evaluated to determine\nimpacts on reassessment schedules, assessment methods, and other aspects of CPPL's\nIntegrity Management Program\nUnder 49 United States Code, ) 60122, you are subject to a civil penalty not to exceed $100, 000\nfor each violation for each day the violation persists up to a maximum of $1, 000, 000 for any\nrelated series of violations We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the items identified in this letter\nFailure to do so will result in ConocoPhilhps Pipe Line Company being subject to additional\nenforcement action\nNo reply to this letter is required If you choose to reply, m your correspondence please refer to\nCPP 5-ZOOS-5O39W Be advised that all material you submit m response to this enforcement\naction is sub]ect to being made pubhcly available. If you believe that any portion of your\nresponsive material quahfies 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 portions\nyou beheve quahfy for confidential treatment redacted and an explanation of why you beheve the\nredacted information quahfies for confidential treatment under 5 U. S. C 552(b)\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipehne and Hazardous Materials Safety Administration\ncc PHP-60 Compliance Registry\nPHP-500 H Nguyen (0121862)","truncated":false,"body_characters":11635}