{"operation":"document","citation":"CPF 520125010W","title":"PHILLIPS 66 PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-04-24","effective_on":null,"summary":"CLOSED warning letter citing 195.202, 195.204, 195.589.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520125010w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520125010w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520125010w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520125010W","body":"Warning Letter involving PHILLIPS 66 PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.202,  195.204,  195.589. The case was opened on 2012-04-24 and is reported as closed as of 2012-04-24. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520125010W_Operator Response _05142012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520125010W/520125010W_Operator%20Response%20_05142012.pdf\n\n520125010W_warning letter_04242012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520125010W/520125010W_warning%20letter_04242012.pdf\n\n520125010W_warning letter_04242012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520125010W/520125010W_warning%20letter_04242012_text.pdf\n\n520125010W_warning letter_04242012_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 24, 2012\nMs. Deborah Adams\nPresident\nConocoPhillips Pipeline Company\n600 N. Dairy Ashford\nHouston, TX 77079\nCPF 5-2012-5010W\nDear Ms. Adams:\nOn March 7 through April 3, 2012, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\ncompleted multiple field inspections on your Yellowstone pipeline horizontal directional drill\nproject under the Clark Fork River at MP 319.1, near the community of Turah, Montana.\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\nthe probable violations are:\n1. §195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive\nwritten specifications or standards that are consistent with the requirements of\nthis part.\n\n\n\nConocoPhillips Pipeline Company (CPPL) failed to have comprehensive written\nspecifications or standards for all aspects of the Yellowstone pipeline horizontal directional\ndrill (HDD) at MP 319.1. Though CPPL had procedures for welding and non-destructive\ntesting (NDT) and manufacturer’s recommended application practices for coating, other key\nconstruction specifications were not available to our inspector. After numerous requests,\nConocoPhillips could not provide specifications or standards for all aspects of construction\ninspection including coating, specifications for field bending of pipe, and documentation\nrequirements for coating application inspection.\n2. §195.204 Inspection - General.\nInspection must be provided to ensure the installation of pipe or pipeline systems\nin accordance with the requirements of this subpart. No person may be used to\nperform inspections unless that person has been trained and is qualified in the\nphase of construction to be inspected.\nCPPL failed to use a trained inspector to inspect the pipe welding process during their\nYellowstone pipeline HDD at MP 319.1. The CPPL inspector who was responsible for the\ninspection of the welding process had not been trained in the inspection of welding\nprocesses. Though this individual was a qualified non-destructive tester and was\nexperienced in welding, he did not have records showing that he had been trained in the\ninspection of the welding process. Furthermore, this inspector had no tools for checking the\nwelding parameters of volts, amps and travel speed during welding. He only checked for\npreheat requirements.\nThough all welds passed NDT requirements, one cannot be assured that the welding\nprocedure was followed because welding the parameters of volts, amps, and travel speed\nwere not periodically checked. Because a weld passes NDT does not mean that a procedure\nwas followed. If the procedure is not followed it is possible for the welder to affect the\nmetallurgical properties of the pipe and the weld in ways that may jeopardize the integrity of\nthe pipeline.\n3. §195.589 What corrosion control information do I have to maintain?\n(c) You must maintain a record of each analysis, check, demonstration,\nexamination, inspection, investigation, review, survey, and test required by this\nsubpart in sufficient detail to demonstrate the adequacy of corrosion control\nmeasures or that corrosion requiring control measures does not exist. You must\nretain these records for at least 5 years, except that records related to Secs.\n195.569, 195.573(a) and (b), and 195.579(b)(3) and (c) must be retained for as\nlong as the pipeline remains in service.\nCPPL did not maintain a record of coating prep, application, and pre-installation inspections\nof their Yellowstone pipeline HDD at MP 319.1. Coating preparation and coating\napplication inspections are required to insure the coating meets the requirements of §\n195.559. An operator must inspect their pipe’s coating just prior to its installing it and they\nmust repair all defects that are found in accordance with 195.561. Inspections that occurred\n\n\n\nbut were not documented included, surface prep profile checks, pipe temperature checks, wet\nsurface film thickness, dry film thickness, “Jeeping including voltage used and repairs made\nto coating. An operator is required to maintain records of this nature for at least 5 years to\ndemonstrate the adequacy of corrosion control measures in accordance with Subpart H.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of\n$1,000,000 for any related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct\nthe items identified in this letter. Failure to do so will result in ConocoPhillips Pipeline\nCompany being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2012-5010W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C.\n552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 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 (#138648)","truncated":false,"body_characters":6682}