{"operation":"document","citation":"CPF 520125002M","title":"PHILLIPS 66 PIPELINE LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-02-21","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(a), 195.402(c)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520125002m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520125002m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520125002m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520125002M","body":"Notice of Amendment involving PHILLIPS 66 PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.402(c)(3). The case was opened on 2012-02-21 and is reported as closed as of 2012-11-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520125002M_Closure letter_11152012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520125002M/520125002M_Closure%20letter_11152012.pdf\n\n520125002M_Closure letter_11152012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520125002M/520125002M_Closure%20letter_11152012_text.pdf\n\n520125002M_notice of amendment_02212012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520125002M/520125002M_notice%20of%20amendment_02212012.pdf\n\n520125002M_notice of amendment_02212012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520125002M/520125002M_notice%20of%20amendment_02212012_text.pdf\n\n520125002M_Operator Response_05092012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520125002M/520125002M_Operator%20Response_05092012.pdf\n\n520125002M_Closure letter_11152012_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 15, 2012\nDennis Smith,\nManager of Pipelines\nConocoPhillips\n600 North Dairy Ashford Road\nHouston, TX 77079 Closure Letter\nCPF 5-2012-5002M\nDear Mr. Smith:\nOn June 13-17, 2011, representatives from the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), the State of Washington Utilities and Transportation Commission, and\nthe California State Fire Marshal’s office, pursuant to chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of ConocoPhillips operations and maintenance\nprocedures in Houston, TX. As a result of the inspection, ConocoPhillips was issued a Notice of\nAmendment on February 21, 2012, which proposed amendment of your procedures.\nConocoPhillips submitted its amended procedures on May 9, 2012. My staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 B. Brown (#13398)\n\n520125002M_notice of amendment_02212012_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 21, 2012\nMr. Terry D. Roby\nManager of Pipelines\nConocoPhillips Pipe Line Company\n600 North Dairy Ashford Road\nHouston, TX 77079\nCPF 5-2012-5002M\nDear Mr. Roby:\nOn June 13-17, 2011, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Washington State Utilities and Transportation Commission, and\nthe California State Fire Marshal office, pursuant to Chapter 601 of 49 United States Code,\ninspected ConocoPhillips’s procedures for operations, maintenance, and emergency\nresponse at your company’s facility at 600 North Dairy Ashford Rd., Houston, Texas.\nOn the basis of the inspection, PHMSA staff identified the apparent inadequacies found\nwithin ConocoPhillips’s plans or procedures, as described below:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a)\nof this section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n\n\n\nThe Operations and Maintenance (O&M) manual is required to include written pipeline\nrepair procedures that comply with §195.422. This section requires that each repair be\nmade in a safe manner. At the time of the inspection, there was no procedure requiring a\nwritten Non-Destructive Testing procedure when welds are nondestructively tested as\nrequired by §195.234(c), when using x-ray or gamma rays for the inspection of pipeline\nrepairs.\n2. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies.\nAt the time of the inspection, the ConocoPhillips procedures addressing perimeter security\nfor facilities were ambiguous and confusing. Procedure CPPL-MPR-2001-WD2 (Security\nand Signs) Rev. 2- Effective Date: 2011-03-23, Section 6.1 did not state who is responsible\nfor determining the type of perimeter security required at a given site, guidelines for\ndetermining security for various types of sites, and who is responsible for maintaining the\nlevel of security established as required by §195.436.\nResponse 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 Compliance Proceedings. Please refer to this document and note the response\noptions. Be advised that all material you submit in response to this enforcement action is\nsubject to being made publicly available. If you believe that any portion of your responsive\nmaterial qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete\noriginal document you must provide a second copy of the document with the portions you\nbelieve 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). If you\ndo not respond within 30 days of receipt of this Notice, this constitutes a waiver of your\nright to contest the allegations in this Notice and authorizes the Associate Administrator for\nPipeline Safety to find facts as alleged in this Notice without further notice to you and to\nissue a Final Order.\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged\nin this Notice, you may be ordered to amend your plans or procedures to correct the\ninadequacies (49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that\nyou submit your amended procedures to my office within ninety days of receipt of this\nNotice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this\nenforcement action will be closed.\n\n\n\nIt is requested (not mandated) that ConocoPhillips maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Chris Hoidal, Director,\nWestern Region, Pipeline and Hazardous Materials Safety Administration. In\ncorrespondence concerning this matter, please refer to CPF 5-2012-5002M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 B. Brown (#13398)","truncated":false,"body_characters":7310}