{"operation":"document","citation":"CPF 520135012W","title":"PHILLIPS 66 PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-09-03","effective_on":null,"summary":"CLOSED warning letter citing 195.110(a), 195.404(a)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520135012w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520135012w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520135012w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520135012W","body":"Warning Letter involving PHILLIPS 66 PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.110(a),  195.404(a)(1). The case was opened on 2013-09-03 and is reported as closed as of 2013-09-03. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520135012W_warning letter_09032013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520135012W/520135012W_warning%20letter_09032013.pdf\n\n520135012W_warning letter_09032013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520135012W/520135012W_warning%20letter_09032013_text.pdf\n\n520135012W_warning letter_09032013_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 3, 2013\nMr. Todd Denton\nPresident\nPhillips 66 Pipeline LLC\n3010 Briarpark Drive\nPWC-7109\nHouston, TX 77042\nCPF 5-2013-5012W\nDear Mr. Denton:\nFrom March 2012 through November 2012, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States\nCode, inspected the following Phillips 66 Pipeline systems in Montana:\n• Yellowstone Pipeline from Billings to Springdale (YP-01)\n• Suction lines associated with the Yellowstone Pipeline in Billings (YP-11, 12, 13)\n• Alkali Creek Diesel Pipeline from Billings to Laurel (YP-14)\n• Seminoe Pipeline from Billings to MP10 (SM-01)\n• Suction lines associated with the Seminoe Pipeline in Billings (SM-11, 12)\n• Glacier Pipeline from the Canadian Border to Billings (GL01, 03, 05, 07, 08, 09)\n• Transfer lines associated with the Glacier Pipeline in Billings (GL-11)\nAs a result of the inspections, it appears that Phillips 66 Pipeline LLC committed probable\nviolations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The\nitems inspected and the probable violations are:\n1. § 195.404 Maps and records.\n\n\n\n(a) Each operator shall maintain current maps and records of its pipeline\nsystems that include at least the following information:\n(1) Location and identification of the following pipeline facilities:\n(i) Breakout tanks;\n(ii) Pump stations;\n(iii) Scraper and sphere facilities;\n(iv) Pipeline valves;\n(v) Facilities to which §195.402(c) (9) applies;\n(vi) Rights-of-way; and\n(vii) Safety devices to which §195.428 applies.\n(2) All crossings of public roads, railroads, rivers, buried utilities, and foreign\npipelines.\n(3) The maximum operating pressure of each pipeline.\n(4) The diameter, grade, type, and nominal wall thickness of all pipe.\nDuring the review of the maps and drawings of the pipeline systems listed previously, it\nwas determined that many of the pump station drawings do not accurately reflect the field\ninstallations and have not been updated in many years. During the inspection, Phillips 66\nindicated that a process had been initiated to update all of the station drawings within\napproximately two years, however as of November 2012, none of the station drawings had\nbeen updated. Phillips 66 Pipeline must ensure that each of the pump station drawings are\nupdated in a timely manner to accurately reflect current field installations and that a\nprocess is developed and followed to ensure that the appropriate drawings are updated in a\ntimely manner anytime that changes to the field installations are made.\nIn addition, during a review of drawings at the Great Falls Field Office, it was determined\nthat many out of date alignment drawings were maintained in the office but field personnel\nwere not aware that they were out of date and did not seem to know how to obtain current\ndrawings from Phillips 66’s TranMap system. Phillips 66 Pipeline must remove all out of\ndate drawings from the Great Falls Field Office and instruct personnel in the Great Falls\nField Office how to obtain accurate alignment drawings from the Phillips 66 TranMap\nsystem.\n2\n\n\n\n2. § 195.110 External Loads\n(a) Anticipated external loads (e.g.), earthquakes, vibration, thermal\nexpansion, and contraction must be provided for in designing a pipeline\nsystem. In providing for expansion and flexibility, section 419 of ASME/ANSI\nB31.4 must be followed.\nThe Glacier Pipeline traverses areas in far northern Montana that are susceptible to\nlandslides during and after periods of heavy rain or rapid snowmelt, however as of\nNovember 2012, Phillips 66 did not have a landslide monitoring program in place for this\nsection of the pipeline. Phillips 66 needs to consider a landslide monitoring program for\nareas in northern Montana through which the Glacier Pipeline traverses that are susceptible\nto land movement and take appropriate actions to ensure that the pipeline is not damaged\ndue to land movement.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the\nmaximum penalty may not exceed $100,000 per violation per day, with a maximum\npenalty not to exceed $1,000,000 for a related series of violations. We have reviewed the\ncircumstances and supporting documents involved in this case, and have decided not to\nconduct additional enforcement action or penalty assessment proceedings at this time. We\nadvise you to correct the items identified in this letter. Failure to do so will result in\nPhillips 66 Pipeline LLC being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please\nrefer to CPF 5-2013-5012W. 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\ntreatment 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 M. Petronis (#138125, #138127, #138128, #138129)\n3","truncated":false,"body_characters":6283}