{"operation":"document","citation":"CPF 52022035NOA","title":"PHILLIPS 66 PIPELINE LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-04-25","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(5), 192.605(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52022035noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52022035noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52022035noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52022035NOA","body":"Notice of Amendment involving PHILLIPS 66 PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(5),  192.605(e). The case was opened on 2022-04-25 and is reported as closed as of 2022-09-09. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52022035NOA_Closure Letter_09092022_(21-231738).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022035NOA/52022035NOA_Closure%20Letter_09092022_(21-231738).pdf\n\n52022035NOA_Closure Letter_09092022_(21-231738)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022035NOA/52022035NOA_Closure%20Letter_09092022_(21-231738)_text.pdf\n\n52022035NOA_Notice of Amendment_04252022_(21-231738).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022035NOA/52022035NOA_Notice%20of%20Amendment_04252022_(21-231738).pdf\n\n52022035NOA_Notice of Amendment_04252022_(21-231738)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022035NOA/52022035NOA_Notice%20of%20Amendment_04252022_(21-231738)_text.pdf\n\n52022035NOA_Notice of Amendment_04252022_(21-231738)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA E-MAIL TO MR. TODD DENTON\nApril 25, 2022\nMr. Todd Denton\nPresident\nPhillips 66 Pipeline, LLC\n3010 Briarpark Drive\nPWC-7109\nHouston, TX 77042\nCPF 5-2022-035-NOA\nDear Mr. Denton:\nFrom October 4 through October 8, 2021, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected\nPhillips 66’s written procedures for its California Gas Line in San Obispo, California.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nPhillips 66’s procedures, as described below:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(e) Surveillance, emergency response, and accident investigation. The procedures\nrequired by §§ 192.613(a), 192.615, and 192.617 must be included in the manual\nrequired by paragraph (a) of this section.\nPhillips 66 relies on its Integrated Contingency Plan (ICP), California Pipeline Response Zone\n(Revision August 2021) manual for emergency response procedures required under § 192.605(e) for\ntheir California Natural Gas Pipelines. This document, however, mainly includes Part 194\nrequirements. For example, Section I – Plan Introduction Elements, Page I-6, under the heading\n“DOT Plan Revisions” states:\n\n\n\nEach operator shall review its response Plan at intervals not exceeding 15\nmonths, but at least once each calendar year and modify the Plan to\naddress new or different operating conditions or information included in\nthe Plan.\nIf a new or different operating condition or information would\nsubstantially affect the implementation of a response Plan, the operator\nmust immediately modify its response Plan to address such a change and,\nwithin 30 days of making such a change, submit the change to PHMSA.\nThis manual, which includes requirements set forth in §194.121 of Part 194-Response Plans for\nOnshore Oil Pipelines, appears to be intended for liquid pipelines subject to Part 194, and not natural\ngas pipelines. Emergency response for natural gas pipelines is significantly different than that of\nliquid pipelines. As such, Phillips 66’s emergency response procedures required under § 192.605(e),\nand the timely review of such procedures, must be tailored to address gas pipelines.\n2. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide safety\nduring maintenance and operations.\n(1) …\n(5) Starting up and shutting down any part of the pipeline in a manner designed to\nassure operation within the MAOP limits prescribed by this part, plus the build-up\nallowed for operation of pressure-limiting and control devices.\nPhillips 66’s California Gas pipeline is a small gas system which ties into the SoCal Gas System. In\nthe event the pipeline would need to be shut down quickly, there is only one valve in which field\npersonnel could utilize to perform a shutdown.\nDuring the inspection, Phillips 66 directed PHMSA to their ICP, Emergency Shutdown and Pressure\nReduction Procedures, found in Section II-5.1 Release Detection, page II-45 for information on the\nshutting down of this system. However, this section is for liquid pipelines only and does not address\nthe California Gas pipeline.1\nPhillips 66 must amend or develop a procedure in their Operations & Maintenance or Emergency\nManual that clearly provides the location and process for shutting down the natural gas pipeline in\nthe event of an emergency, and for shutting down any part of the pipeline in a manner to assure\noperation with the MAOP limits, plus the build-up allowed for operation of pressure-limiting and\ncontrol devices pursuant to § 192.605(b)(5).\n1 It also includes reference to breakout tanks, terminal inspections, overfill, etc. and other matters that are specific to\nliquid pipelines and not gas pipelines.\n2\n\n\n\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as part\nof this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you submit\nin response to this enforcement action is subject to being made publicly available. If you believe that\nany portion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document with the\nportions you believe qualify for confidential treatment redacted and an explanation of why you\nbelieve the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice,\nwe propose that you submit your amended procedures to my office within sixty (60) days of receipt\nof this Notice. This 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 will be\nclosed.\nIt is requested (not mandated) that Phillips 66 Pipeline, LLC maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Dustin Hubbard, Director, Western Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please refer to\nCPF 5-2022-035-NOA and, for each document you submit, please provide a copy in electronic\nformat whenever possible.\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 D. Fehling (#21-231738)\n3\n\n52022035NOA_Closure Letter_09092022_(21-231738)_text.pdf\n\nVIA E-MAIL TO MR. DOUG SAUER\nSeptember 9, 2022\nMr. Doug Sauer\nVP Pipeline Regulatory Affairs\nPhillips 66 Pipeline, LLC\n2331 CityWest Blvd.\nHouston, TX 77042-2862\nCPF 5-2022-035 NOA\nClosure Letter\nDear Mr. Sauer:\nOn October 4 through October 8, 2021, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of Phillips 66’s procedures. As a result of the\ninspection, Phillips 66 was issued a Notice of Amendment on April 25, 2022, which proposed\namendment of your procedures.\nPhillips 66 submitted its amended procedures on September 1, 2022. My staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 D. Fehling (#21-228051)","truncated":false,"body_characters":8847}