{"operation":"document","citation":"CPF 520155012M","title":"PHILLIPS 66 PIPELINE LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-06-16","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-520155012m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520155012m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520155012m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520155012M","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 2015-06-16 and is reported as closed as of 2015-08-11. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520155012M_closure letter_08112015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155012M/520155012M_closure%20letter_08112015.pdf\n\n520155012M_closure letter_08112015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155012M/520155012M_closure%20letter_08112015_text.pdf\n\n520155012M_notice of amendment_06162015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155012M/520155012M_notice%20of%20amendment_06162015.pdf\n\n520155012M_notice of amendment_06162015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155012M/520155012M_notice%20of%20amendment_06162015_text.pdf\n\n520155012M_Operator Response to Notice_07202015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155012M/520155012M_Operator%20Response%20to%20Notice_07202015.pdf\n\n520155012M_notice of amendment_06162015_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 16, 2015\nMr. Todd Denton\nPresident\nPhillips 66 Pipeline LLC\n3010 Briarpark Drive\nPWC-7109\nHouston, TX 77042\nCPF 5-2015-5012M\nDear Mr. Denton:\nBetween March 2014 and December 2014, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States\nCode, inspected Phillips 66 Pipeline LLC’s (Phillips 66) Glacier Crude Pipeline System in\nMontana.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within\nPhillips 66’s plans or procedures, as described below:\n1. §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\nmaintenance activities and handling abnormal operations and emergencies. This\nmanual shall be reviewed at intervals not exceeding 15 months, but at least once\neach calendar year, and appropriate changes made as necessary to insure that\nthe manual is effective. This manual shall be prepared before initial operations of\n\n\n\na pipeline system commence, and appropriate parts shall be kept at locations\nwhere operations and maintenance activities are conducted.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis 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.\nPhillips 66 Pipeline LLC did not establish adequate written procedures for performing\noverpressure safety device inspections in according with Section 195.428(a). During the\ninspection, it was determined through discussion with various Phillips 66 operating personnel\nthat the technicians performing overpressure safety device (OSD) inspections are required to\ncheck the Operating Data (OD) sheets to identify the correct set point for each OSD device\nand subsequently record that value on the appropriate OSD inspection form prior to\nperforming the OSD inspections. It was then determined that the procedure and forms for\ninspecting OSDs were not clear in this regard. As a result, Phillips 66 must modify the\nfollowing procedures and related inspection forms to clarify the steps necessary for a\ntechnician to identify the correct set point for each OSD and to include that set point\ninformation on the Phillips 66 OSD inspection forms:\nMPR 4216 Calibration and Maintenance of Pressure Switches\nMPR 4225 Inspection and Maintenance of Pressure Regulation Systems\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond\nwithin 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the\nallegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to\nfind facts as alleged in this Notice without further notice to you and to issue a Final Order.\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in\nthis 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 60 days of receipt of this Notice.\nThis period may be extended by written request for good cause. Once the inadequacies\nidentified herein have been addressed in your amended procedures, this enforcement action\nwill be closed.\nIt is requested (not mandated) that Phillips 66 Pipeline LLC maintain documentation of the\n2\n\n\n\nsafety improvement 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 correspondence\nconcerning this matter, please refer to CPF 5-2015-5012M and, for each document you\nsubmit, 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 M. Petronis (#146290)\n3\n\n520155012M_closure letter_08112015_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 11, 2015\nMr. Todd L. Tullio\nManager, Regulatory Compliance\nPhillips 66 Pipe Line LLC\n3010 Briarpark Drive\nP.O. Box 4428\nHouston, TX 77042\nCPF 5-2015-5012M\nCase Closure\nDear Mr. Tullio:\nBetween March 2014 and December 2014, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\ninspected Phillips 66’s Glacier Crude Pipeline System in Montana. As a result of the\ninspection, Phillips 66 Pipeline LLC was issued a Notice of Amendment on June 16, 2015,\nwhich proposed amendment of your procedures.\nWe received your amended procedures dated July 20, 2015. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in the Notice of Amendment have\nbeen corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 M. Petronis (#146290)","truncated":false,"body_characters":7471}