CPF 520105033W
CPF 520105033W
520105033W_Warning Letter_12142010_text.pdf, page 1Official PDFWARNING 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.#
520105033W_Warning Letter_12142010_text.pdf, page 2The 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) 2#
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