{"operation":"document","citation":"CPF 520085040M","title":"PHILLIPS 66 PIPELINE LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-10-15","effective_on":null,"summary":"CLOSED notice of amendment citing 195.452(e)(1), 195.452(f)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085040m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085040m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085040m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520085040M","body":"Notice of Amendment involving PHILLIPS 66 PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.452(e)(1),  195.452(f)(3). The case was opened on 2008-10-15 and is reported as closed as of 2009-09-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520085040M_notice of amendment_10152008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085040M/520085040M_notice%20of%20amendment_10152008.pdf\n\n520085040m_notice of amendment_10152008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085040M/520085040m_notice%20of%20amendment_10152008_text.pdf\n\n520085040M_operator_response_08242009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085040M/520085040M_operator_response_08242009.pdf\n\n520085040m_notice of amendment_10152008_text.pdf\n\nU S. Department\nof Tf GrtspoftGtlon\nPmpslliine and\nHazardous Maternalls Safety\nAdmtnmstratilon\n12300 W Dakota Ave, Suite 110\nLakewood, CO 80228\nNOTICE OF AMKXBMKXT\nOctober 15, 2008\nMs Margaret A Yaege\nPresident\nConocoPhillips Pipelmes Inc\n600 North Dairy Ashford\nHouston, TX 77079\nCPF 5-2008-5040M\nDear Ms Yaege\nOn May 19-23 and June 2-5, 2008, representatives of the Pipehne and Hazardous Materials\nSafety Admmistration {PHMSA) and the Washington Utihties and Transportation\nComnnssion (WUTC), mspected the ConocoPhilhps Pipe Line Company's (CPPL)\nprocedures for their Integrity Management Program (IMP) in Ponca City, Oklahoma\nOn the basis of the inspection, PHMSA identified apparent inadequacies found within\nCPPL's plans or procedures, as described below\n\n\n\n(e) What are the nsk factors for establishing an assessment schedule (for both\nthe baseHne and continual integrity assessments) 7\n(I) An operator must establish an integrity assessment schedule that\nprioritizes pipehne segments for assessment (see paragraphs (d) (]I. ) and (j) (3)\nof this section). An operator must base the assessment schedule on aH nsk\nf'actors that reflect the risk conditions on the pipeline segment. The factors an\noperator must consider include, but are not limited to:\n(i) Results of the previous integnty assessment, defect type and size that the\nassessment method can detect, and defect gr owth rate;\n(H) Pipe size, material, manufactunng information, coating type and condition,\nand seam type;\n(Hi) l. eak history, repair history and cathodic protection history;\n(iv) Product transpor ted;\n(v) Operating stress level;\n(vi) Existing or projected activities in the area;\n(vh) l, ocal environmental factor s that could affect the pipehne (e. g. , corrosiivity\nof soil, subsidence, chmatic);\n(vhi) Geo-technical hazards; and (ix) Physical support of the segment such as\nby a cable suspension bndge.\n(2) Appendix C of this part provides further guidance on risk factors.\no item 1: $195 452 (e)(1)k(2)\nIt appears that pipeime susceptibshty to stress corrosion crackmg (SCC) was not\nappropriately cons&dered. CPPL needs to develop a more robust process and\nscreenmg tool for determmmg the potentsa1 for stress corrosion crackmg on each of\n&ts p&peime systems\n(f) What are the elements of an integrity management program'7 An integnty\nmanagement progrmn begins with the iniitial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions\ndrawn from results of the integrity assessments, and other maintenance and\nsurveiHance data, and evaluation of consequences of a failure on the high\nconsequence area. An operator must include, at minimum, each of the\nfoHowing elements in its written integnty management program:\n(3) An analysiis that integrates aH available information about the integrity of\nthe entire pipeline and the consequences of a failure (see paragraph (g) of this\nsection);\n(g) What is an information analysis~ Jn periodicaHy evaluating the integrity of\neach pipeline segment (paragraph (j) of this section), an operator must analyze\naH avaHable infor mation about the integrity of the entire pipehne and the\nconsequences of a f'ailure. This information includes:\n\n\n\n~ Item 2: )195. 452 (f)(3)k(g)\n2. A. The corrosion checkhst associated with the AP History and Planning\nDocument does not identify specific portions of the system that represents the\nhighest risk to each high consequence area\n2 B. The Process Hazards Analyses (PHA) performed to identify risks at your\nfacilities are based on consequences only. The analyses did not include an\nevaluation of the likelihood of a facihty release, or how a release could affect\nnearby high consequence areas (HCAs). In addition, no discussion of how\npreventative and mitigative measures could reduce risks was included in the PHA.\nRes onse to this Notice\nThis Notice is provided pursuant to 49 U. S C $ 60108(a) and 49 C F. R. ( 190 237\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline\nOperators in Comp&ance Proceedings Please refer to this document and note the\nresponse options Be advised that all material you submit in response to this enforcement\naction is subject to bemg made publicly available If you beheve that any portion of your\nresponsive material qualifies for confidential treatment under 5 U S C 552(b), along with\nthe complete original document you must provide a second copy of the document with the\nportions you believe quahfy for confidential treatment redacted and an explanation of why\nyou beheve the redacted information qualifies for confidential treatment under 5 U. S C\n552(b) If you do not respond within 30 days of receipt of this Notice, this constitutes a\nwaiver of your right to contest the allegations m this Notice and authorizes the Associate\nAdmimstrator for Pipelme Safety to find facts as alleged m this Notice without further\nnotice to you and to issue a Fmal Order\n\n\n\nIf, after opportumty for a hearmg, your plans or procedures are found inadequate as alleged\nm this Notice, you may be ordered to amend your plans or procedures to correct the\ninadequacies (49 C. F. R ( 190 237) lf you are not contesting this Notice, we propose that\nyou submit your amended procedures to my office within 30 days of receipt of this Notice\nThis period may be extended by written request for good cause Once the inadequacies\nidentified herein have been addressed in your amended procedures, this enforcement action\nwill be closed\nIn correspondence concermng this matter, please refer to CPI 5-2008-5040M and, for\neach document you submit, please provide a copy in electronic format whenever possible\nSmcerely,\nChris Hoidal\nDll ectol, Western Region\nPipehne and Hazardous Materials Safety Admmistration\ncc PHP-60 Compliance Registry\nPHP-500 H. Nguyen (4121862)\nEnclosure. Response Options for Pipehne Operators m Comp1iance Proceedings","truncated":false,"body_characters":6740}