{"operation":"document","citation":"CPF 520145015W","title":"PHILLIPS 66 PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-10-10","effective_on":null,"summary":"CLOSED warning letter citing 195.452(g)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520145015w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520145015w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520145015w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520145015W","body":"Warning Letter involving PHILLIPS 66 PIPELINE LLC. PHMSA's enforcement data identifies the cited regulation as 195.452(g)(4). The case was opened on 2014-10-10 and is reported as closed as of 2014-10-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520145015W_warning letter_10102014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520145015W/520145015W_warning%20letter_10102014.pdf\n\n520145015W_warning letter_10102014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520145015W/520145015W_warning%20letter_10102014_text.pdf\n\n520145015W_warning letter_10102014_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 10, 2014\nMr. Todd Denton\nPresident\nPhillips 66 Pipeline, LLC\n3010 Briarpark Drive\nPWC-7109\nHouston, TX, 77042\nCPF 5-2014-5015W\nDear Mr. Denton:\nFrom March 2013 through November 2013, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) and the Washington Utilities and Transportation\nCommission (WUTC), pursuant to Chapter 601 of 49 United States Code, inspected your\nYellowstone Pipeline System from Billings, Montana to Spokane, Washington.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violation is:\n\n\n\n1. §195.452 Pipeline integrity management in high consequence areas.\n(g) What is an information analysis? In periodically evaluating the integrity of each\npipeline segment (paragraph (j) of this section), an operator must analyze all\navailable information about the integrity of the entire pipeline and the consequences\nof a failure. This information includes:\n(4) Information about how a failure would affect the high consequence area, such as\nlocation of the water intake.\nAt the time of the inspection, Hauser Lake was not defined as an HCA. However, interviews\nwith Phillips 66 personnel concerning the potential impacts to the reservoir and recreational\nareas if a spill was to occur then the impact would be significant. Subsequently, Phillips has\nindicated that they have designated the area as an HCA and have reevaluated HCAs along the\nlength of the pipeline.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this letter.\nFailure to do so will result in Phillips 66 Pipeline, LLC being subject to additional enforcement\naction.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\n5-2014-5015W. 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 the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\n2\n\n\n\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 M. Petronis (#144046)\nWUTC\n3","truncated":false,"body_characters":3877}