PHILLIPS 66 PIPELINE LLC — Notice of Amendment

party submissionOfficial PDF520085040M_operator_response_08242009.pdf#

520085040m_notice of amendment_10152008_text.pdf, page 1Official PDFU S. Department of Tf GrtspoftGtlon Pmpslliine and Hazardous Maternalls Safety Admtnmstratilon 12300 W Dakota Ave, Suite 110 Lakewood, CO 80228 NOTICE OF AMKXBMKXT October 15, 2008 Ms Margaret A Yaege President ConocoPhillips Pipelmes Inc 600 North Dairy Ashford Houston, TX 77079 CPF 5-2008-5040M Dear Ms Yaege On May 19-23 and June 2-5, 2008, representatives of the Pipehne and Hazardous Materials Safety Admmistration {PHMSA) and the Washington Utihties and Transportation Comnnssion (WUTC), mspected the ConocoPhilhps Pipe Line Company's (CPPL) procedures for their Integrity Management Program (IMP) in Ponca City, Oklahoma On the basis of the inspection, PHMSA identified apparent inadequacies found within CPPL's plans or procedures, as described below#

520085040m_notice of amendment_10152008_text.pdf, page 2(e) What are the nsk factors for establishing an assessment schedule (for both the baseHne and continual integrity assessments) 7 (I) An operator must establish an integrity assessment schedule that prioritizes pipehne segments for assessment (see paragraphs (d) (]I. ) and (j) (3) of this section). An operator must base the assessment schedule on aH nsk f'actors that reflect the risk conditions on the pipeline segment. The factors an operator must consider include, but are not limited to: (i) Results of the previous integnty assessment, defect type and size that the assessment method can detect, and defect gr owth rate; (H) Pipe size, material, manufactunng information, coating type and condition, and seam type; (Hi) l. eak history, repair history and cathodic protection history; (iv) Product transpor ted; (v) Operating stress level; (vi) Existing or projected activities in the area; (vh) l, ocal environmental factor s that could affect the pipehne (e. g. , corrosiivity of soil, subsidence, chmatic); (vhi) Geo-technical hazards; and (ix) Physical support of the segment such as by a cable suspension bndge. (2) Appendix C of this part provides further guidance on risk factors. o item 1: $195 452 (e)(1)k(2) It appears that pipeime susceptibshty to stress corrosion crackmg (SCC) was not appropriately cons&dered. CPPL needs to develop a more robust process and screenmg tool for determmmg the potentsa1 for stress corrosion crackmg on each of &ts p&peime systems (f) What are the elements of an integrity management program'7 An integnty management progrmn begins with the iniitial framework. An operator must continually change the program to reflect operating experience, conclusions drawn from results of the integrity assessments, and other maintenance and surveiHance data, and evaluation of consequences of a failure on the high consequence area. An operator must include, at minimum, each of the foHowing elements in its written integnty management program: (3) An analysiis that integrates aH available information about the integrity of the entire pipeline and the consequences of a failure (see paragraph (g) of this section); (g) What is an information analysis~ Jn periodicaHy evaluating the integrity of each pipeline segment (paragraph (j) of this section), an operator must analyze aH avaHable infor mation about the integrity of the entire pipehne and the consequences of a f'ailure. This information includes:#

520085040m_notice of amendment_10152008_text.pdf, page 3~ Item 2: )195. 452 (f)(3)k(g) 2. A. The corrosion checkhst associated with the AP History and Planning Document does not identify specific portions of the system that represents the highest risk to each high consequence area 2 B. The Process Hazards Analyses (PHA) performed to identify risks at your facilities are based on consequences only. The analyses did not include an evaluation of the likelihood of a facihty release, or how a release could affect nearby high consequence areas (HCAs). In addition, no discussion of how preventative and mitigative measures could reduce risks was included in the PHA. Res onse to this Notice This Notice is provided pursuant to 49 U. S C $ 60108(a) and 49 C F. R. ( 190 237 Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Comp&ance 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 bemg made publicly available If you beheve 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 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) If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations m this Notice and authorizes the Associate Admimstrator for Pipelme Safety to find facts as alleged m this Notice without further notice to you and to issue a Fmal Order#

520085040m_notice of amendment_10152008_text.pdf, page 4If, after opportumty for a hearmg, your plans or procedures are found inadequate as alleged m this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C. F. R ( 190 237) lf you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 days of receipt of this Notice This period may be extended by written request for good cause Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed In correspondence concermng this matter, please refer to CPI 5-2008-5040M and, for each document you submit, please provide a copy in electronic format whenever possible Smcerely, Chris Hoidal Dll ectol, Western Region Pipehne and Hazardous Materials Safety Admmistration cc PHP-60 Compliance Registry PHP-500 H. Nguyen (4121862) Enclosure. Response Options for Pipehne Operators m Comp1iance Proceedings#