# PHILLIPS 66 PIPELINE LLC — Notice of Amendment

- **operation:** document
- **citation:** CPF 520095014M
- **title:** PHILLIPS 66 PIPELINE LLC — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2009-03-17
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 195.452(h)(3).
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520095014m.md
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520095014M
**body:**

Notice of Amendment involving PHILLIPS 66 PIPELINE LLC. PHMSA's enforcement data identifies the cited regulation as 195.452(h)(3). The case was opened on 2009-03-17 and is reported as closed as of 2009-10-01. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520095014M_notice of amendment_03172009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095014M/520095014M_notice%20of%20amendment_03172009.pdf

520095014M_notice of amendment_03172009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095014M/520095014M_notice%20of%20amendment_03172009_text.pdf

520095014M_operator response_04152009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095014M/520095014M_operator%20response_04152009.pdf

520095014M_notice of amendment_03172009_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
March 17, 2009
Ms. Meg A. Yaege
General Manager of Pipelines and Terminals
ConocoPhillips Pipe Line Company
600 North Dairy Ashford St., TA 2010
Houston, TX 77079-1100
CPF 5-2009-5014M
Dear Ms. Yaege:
On October 31, 2008, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, met with your staff
to discuss pending repairs to the Denver-Chase pipeline system.
On the basis of this meeting and subsequent correspondence dated November 17, 2008 from
ConocoPhillips (CPPL) with regard to this matter, PHMSA has identified the apparent
inadequacy found within CPPL’s plans or procedures, as described below:
1. § 195.452 Pipeline integrity management in high consequence areas.
(h) What actions must an operator take to address integrity issues?
(3) Schedule for evaluation and remediation. An operator must complete
remediation of a condition according to a schedule prioritizing the conditions for
evaluation and remediation. If an operator cannot meet the schedule for any
condition, the operator must explain the reasons why it cannot meet the schedule



and how the changed schedule will not jeopardize public safety or environmental
protection.
CPPL procedures do not ensure that in the event an anomaly condition is not repaired
according to the schedule for the condition, and the operator is unable to reduce pressure,
that the operator explains the reasons why it cannot meet the schedule and how the
changed schedule will not jeopardize public safety or environmental protection. CPPL
procedures are not in compliance with § 195.452 (h)(3).
Response 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
Compliance 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 being
made publicly available. If you believe 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 qualify for
confidential treatment redacted and an explanation of why you believe 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 in this
Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in
this Notice without further notice to you and to issue a Final Order.
If, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in
this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies
(49 C.F.R. § 190.237). If 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 concerning this matter, please refer to CPF 5-2009-5014M and, for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
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