# PHILLIPS 66 PIPELINE LLC — Notice of Amendment - **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:** Not available - **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. Official case documents: 520155012M_closure letter_08112015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155012M/520155012M_closure%20letter_08112015.pdf 520155012M_closure letter_08112015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155012M/520155012M_closure%20letter_08112015_text.pdf 520155012M_notice of amendment_06162015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155012M/520155012M_notice%20of%20amendment_06162015.pdf 520155012M_notice of amendment_06162015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155012M/520155012M_notice%20of%20amendment_06162015_text.pdf 520155012M_Operator Response to Notice_07202015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155012M/520155012M_Operator%20Response%20to%20Notice_07202015.pdf 520155012M_notice of amendment_06162015_text.pdf NOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED June 16, 2015 Mr. Todd Denton President Phillips 66 Pipeline LLC 3010 Briarpark Drive PWC-7109 Houston, TX 77042 CPF 5-2015-5012M Dear Mr. Denton: Between March 2014 and December 2014, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Phillips 66 Pipeline LLC’s (Phillips 66) Glacier Crude Pipeline System in Montana. On the basis of the inspection, PHMSA has identified the apparent inadequacy found within Phillips 66’s plans or procedures, as described below: 1. §195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. This manual shall be reviewed at intervals not exceeding 15 months, but at least once each calendar year, and appropriate changes made as necessary to insure that the manual is effective. This manual shall be prepared before initial operations of a pipeline system commence, and appropriate parts shall be kept at locations where operations and maintenance activities are conducted. (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. Phillips 66 Pipeline LLC did not establish adequate written procedures for performing overpressure safety device inspections in according with Section 195.428(a). During the inspection, it was determined through discussion with various Phillips 66 operating personnel that the technicians performing overpressure safety device (OSD) inspections are required to check the Operating Data (OD) sheets to identify the correct set point for each OSD device and subsequently record that value on the appropriate OSD inspection form prior to performing the OSD inspections. It was then determined that the procedure and forms for inspecting OSDs were not clear in this regard. As a result, Phillips 66 must modify the following procedures and related inspection forms to clarify the steps necessary for a technician to identify the correct set point for each OSD and to include that set point information on the Phillips 66 OSD inspection forms: MPR 4216 Calibration and Maintenance of Pressure Switches MPR 4225 Inspection and Maintenance of Pressure Regulation Systems Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings. Please refer to this document and note the response options. Be advised that all material you submit in response to this enforcement action is subject to being made publicly available. If you believe that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original document you must provide a second copy of the document with the portions you believe qualify for confidential treatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue a Final Order. If, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 60 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that Phillips 66 Pipeline LLC maintain documentation of the 2 safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Chris Hoidal, Director, Western Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 5-2015-5012M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Chris Hoidal Director, Western Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings cc: PHP-60 Compliance Registry PHP-500 M. Petronis (#146290) 3 520155012M_closure letter_08112015_text.pdf CERTIFIED MAIL - RETURN RECEIPT REQUESTED August 11, 2015 Mr. Todd L. Tullio Manager, Regulatory Compliance Phillips 66 Pipe Line LLC 3010 Briarpark Drive P.O. Box 4428 Houston, TX 77042 CPF 5-2015-5012M Case Closure Dear Mr. Tullio: Between March 2014 and December 2014, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Phillips 66’s Glacier Crude Pipeline System in Montana. As a result of the inspection, Phillips 66 Pipeline LLC was issued a Notice of Amendment on June 16, 2015, which proposed amendment of your procedures. We received your amended procedures dated July 20, 2015. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in the Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Chris Hoidal Director, Western Region Pipeline and Hazardous Materials Safety Administration cc: PHP-60 Compliance Registry PHP-500 M. Petronis (#146290) - **truncated:** false - **body characters:** 7471