{"operation":"document","citation":"CPF 520095018W","title":"PHILLIPS 66 PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2009-03-20","effective_on":null,"summary":"CLOSED warning letter citing 195.403(b)(1), 195.569, 195.573(c), 195.583(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520095018w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520095018w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520095018w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520095018W","body":"Warning Letter involving PHILLIPS 66 PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.403(b)(1),  195.569,  195.573(c),  195.583(a). The case was opened on 2009-03-20 and is reported as closed as of 2009-03-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520095018W_warning letter_03202009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095018W/520095018W_warning%20letter_03202009.pdf\n\n520095018W_warning letter_03202009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095018W/520095018W_warning%20letter_03202009_text.pdf\n\n520095018W_warning letter_03202009_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 20, 2009\nMs. Meg Yeage\nPresident\nConocoPhillips Pipeline Company\n600 North Dairy Ashford, TA 2010\nHouston, TX 77079\nCPF 5-2009-5018W\nDear Ms. Yeage:\nOn August 5 to 7, 2008, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\nYellowstone Pipeline (YPL) in Montana and Idaho.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n1. §195.403 Emergency Response Training.\n(b) At the intervals not exceeding 15 months, but at least once each calendar year,\neach operator shall:\n(1) Review with personnel their performance in meeting the objectives of the\nemergency response training program set forth in paragraph (a) of this section; and\n\n\n\nThree ConocoPhillips Pipeline (CPPL) employees in Billings did not have their\nperformance in meeting the objectives of the emergency response training program\nreviewed in 2007. CPPL records indicate that reviews were done in December 2006 and\nthen again on January 4, 2008 thereby missing their review in calendar year of 2007.\n2. §195.569 Do I have to examine exposed portions of buried pipelines?\nWhenever you have knowledge that any portion of a buried pipeline is exposed, you\nmust examine the exposed portion for evidence of external corrosion if the pipe is\nbare, or if the coating is deteriorated. If you find external corrosion requiring\ncorrective action under Sec. 195.585, you must investigate circumferentially and\nlongitudinally beyond the exposed portion (by visual examination, indirect method,\nor both) to determine whether additional corrosion requiring remedial action exists\nin the vicinity of the exposed portion.\nCPPL failed to evaluate the condition of the coating on their buried pipeline when it was\nexposed. The CPPL Pipeline Maintenance and Leak Report (PMLR) No. YP01-69-GRS-\n08-002 completed for a foreign line crossing at YPL Station 5853+31 does not indicate\nthe condition of the exposed pipe coating.\n3. §195.573 What must I do to monitor external corrosion control?\n(c) Rectifiers and other devices. You must electrically check for proper\nperformance each device in the first column at the frequency stated in the second\ncolumn.\nDevice Check frequency\nRectifier.................................\nReverse current switch\nDiode\nInterference bond whose failure\nwould jeopardize structural\nprotection\nAt least six times each calendar year, but\nwith intervals not exceeding 2 ½ months\nOther interference bond\n.......................\nAt least once each calendar year, but with\nintervals not exceeding 15 months.\nCPPL failed to electrically check their interference bond at YPL MP 290. CPPL records\nshow that the bond of YPL at MP 290 with a Northwestern natural gas pipeline that was\ninstalled in 2004 was not monitored in 2006. This is a non-critical bond so it should have\nbeen checked once each calendar year not to exceed 15 months.\n4. §195.583 What must I do to monitor atmospheric corrosion control?\n(a) You must inspect each pipeline or portion of pipeline that is exposed to the\natmosphere for evidence of atmospheric corrosion, as follows:\n2\n\n\n\nIf the pipeline is located: Then the frequency of inspection is:\nOnshore At least once every 3 calendar years, but\nwith intervals not exceeding 39 months\nOffshore At least once each calendar year, but with\nintervals not exceeding 15 months\n(b) During inspections you must give particular attention to pipe at soil-to-air\ninterfaces, under thermal insulation, under disbonded coatings, at pipe supports, in\nsplash zones, at deck penetrations, and in spans over water.\nIt appears that CPPL failed to perform an atmospheric corrosion inspection on the Clarks\nFork River pipeline suspension bridge pipe soil-to-air interface on the right bank looking\ndownstream. During this inspection, it was observed that this soil-to-air interface was in\npoor condition. The poor coating has since been corrected but only after it was noted\nduring our PHMSA field inspection.\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 CPPL being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2009-5018W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies 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 believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 G. Davis (#120781)\n3","truncated":false,"body_characters":6265}