{"operation":"document","citation":"CPF 520175014W","title":"PHILLIPS 66 PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-06-27","effective_on":null,"summary":"CLOSED warning letter citing 195.404(c)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520175014w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520175014w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520175014w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520175014W","body":"Warning Letter involving PHILLIPS 66 PIPELINE LLC. PHMSA's enforcement data identifies the cited regulation as 195.404(c)(3). The case was opened on 2017-06-27 and is reported as closed as of 2017-06-27. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520175014W_Operator Response To Notice_09052017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175014W/520175014W_Operator%20Response%20To%20Notice_09052017.pdf\n\n520175014W_Warning Letter_06272017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175014W/520175014W_Warning%20Letter_06272017.pdf\n\n520175014W_Warning Letter_06272017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175014W/520175014W_Warning%20Letter_06272017_text.pdf\n\n520175014W_Warning Letter_06272017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 27, 2017\nMr. Todd Denton\nPresident\nPhillips 66 Pipeline LLC\n2331 Citywest Blvd.\nHouston, TX 77042\nCPF 5-2017-5014W\nDear Mr. Denton:\nBetween August 10, 2016 and August 25, 2016, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\ninspected your Powder River HVL pipeline system from Douglas, Wyoming to Borger, Texas.\nAs a result of the inspection, it is alleged 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:\n1. §195.404 Maps and records.\n(c) Each operator shall maintain the following records for the periods specified:\n(3) A record of each inspection and test required by this subpart shall be maintained\nfor at least 2 years or until the next inspection or test is performed, whichever is\nlonger.\n\n\n\nDuring the records review of the Power River HVL pipeline system, Phillips 66’s (P66’s)\noverpressure protection records failed to demonstrate that they are in compliance with\n§195.428(a). It was noted that the maximum discharge and the maximum operating pressure\n(MOP) for the CO Pump Station is 1315 psig. However, the September 2015 overpressure\nprotection record for CO Pump Station Discharge Controller calibration indicated 1315 psig “as\nfound” and 1355 psig “as left”. Inteviews P66 personnel revealed that the “as left” pressure for\nthe CO Pump Station was 1315 psig, and this was confirmed with the March 2016 inspection\nrecord.\nIn addition, the Pressure/Temperature Device Inspections for the KE (HVL) Station were\nperformed on March 9, 2016 for six (6) devices. In accordance with P66PL-GPL-122 procedure,\nthe overpressure safety devices include the Discharge Transmitter, Hi Discharge Shutdown, Max\nDischarge Setpoint, Discharge Switch, Suction Transmitter, and Control Valve. During the\nrecords review of the overpressure safety devices for KE Station, six (6) overpressure device\ninspection records were not completed in their entirety, i.e. Product Service HVL, Non-HVL, or\nGas; \"Block Valves Sealed Open (Y, N, N/A)\"; and \"Operational & Mechanical Condition.\"\nAs of April 27, 2017, under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil\npenalty not to exceed $209,002 per violation per day the violation persists up to a maximum of\n$2,090,022 for a related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement action\nor penalty assessment proceedings at this time. We advise you to correct the item(s) identified in\nthis letter. Failure to do so will result in Phillips 66 Pipeline LLC being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2016-5014W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe 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).\nSincerely,\nDustin Hubbard\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 C. Allen/T. Jez (#152706 and #152708)","truncated":false,"body_characters":4518}