# PHILLIPS 66 PIPELINE LLC — Warning Letter

- **operation:** document
- **citation:** CPF 520105033W
- **title:** PHILLIPS 66 PIPELINE LLC — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2010-12-14
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 191.25(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520105033w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520105033w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520105033w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520105033W
**body:**

Warning Letter involving PHILLIPS 66 PIPELINE LLC. PHMSA's enforcement data identifies the cited regulation as 191.25(a). The case was opened on 2010-12-14 and is reported as closed as of 2010-12-14. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520105033W_Warning Letter_12142010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105033W/520105033W_Warning%20Letter_12142010.pdf

520105033W_Warning Letter_12142010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105033W/520105033W_Warning%20Letter_12142010_text.pdf

520105033W_Warning Letter_12142010_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
December 14, 2010
Mr. Brian Coffman
President
ConocoPhillips Pipe Line Company
600 North Dairy Ashford Road
TA 2010
Houston, TX 77079
CPF 5-2010-5033W
Dear Mr. Coffman:
On November 30, 2010, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, received and
reviewed two Safety Related Condition Reports. The two reports were for similar conditions
occurring at two discrete locations on the Seminoe Pipeline (Mile Post 245.5) near Casper,
Natrona County, State of Wyoming.
As a result of reviewing these reports, it appears that you have committed a probable violation
of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The probable
violation is:
1. §191.25 Filing safety-related condition reports.
(a) Each report of a safety related condition under 191.23(a) must be filed
(received by the Associate Administrator, OPS) in writing within five working
days (not including Saturday, Sunday, or Federal Holidays) after the day a
representative of the operator first determines that the condition exists, but not
later than 10 working days after the day a representative of the operator discovers
the condition. Separate conditions may be described in a single report if they are
closely related. Reports may be transmitted by facsimile at (202) 366-7128.



The filings of both reports indicate a date of first discovery and date of determination of each
Safety Related Condition (SRC) to be November 15, 2010. However, both SRC reports were
dated and received by PHMSA on November 30, 2010, five (5) days after the mandated
reporting deadline.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
$100,000 for each violation for each day the violation persists up to a maximum of $1,000,000
for any related series of violations. We have reviewed the circumstances and supporting
documents involved in this case, and have decided not to conduct additional enforcement
action or penalty assessment proceedings at this time. We advise you to correct the item(s)
identified in this letter. Failure to do so will result in ConocoPhillips being subject to
additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer
to CPF 5-2010-5033W. 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).
Sincerely,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 J. Kenerson (#132407)
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