{"operation":"document","citation":"CPF 220085006M","title":"BP WEST COAST PRODUCTS L.L.C. — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-06-18","effective_on":null,"summary":"CLOSED notice of amendment citing 192.7(a), 192.905(a), 192.905(b)(1), 192.909(a), 192.911(l), 192.911(m), 192.911(o), 192.917(a), 192.917(e)(1), 192.935(a), 192.935(c), 192.937(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220085006m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220085006m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220085006m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220085006M","body":"Notice of Amendment involving BP WEST COAST PRODUCTS L.L.C.. PHMSA's enforcement data identifies the cited regulations as 192.7(a),  192.905(a),  192.905(b)(1),  192.909(a),  192.911(l),  192.911(m),  192.911(o),  192.917(a),  192.917(e)(1),  192.935(a),  192.935(c),  192.937(b). The case was opened on 2008-06-18 and is reported as closed as of 2008-09-24. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220085006M_Notice of Amendment_06182008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220085006M/220085006M_Notice%20of%20Amendment_06182008.pdf\n\n220085006m_notice of amendment_06182008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220085006M/220085006m_notice%20of%20amendment_06182008_text.pdf\n\n220085006M_operator response to notice_07222008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220085006M/220085006M_operator%20response%20to%20notice_07222008.pdf\n\n220085006m_notice of amendment_06182008_text.pdf\n\nU. S. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n233 Peachtree Street Ste. 600\nAtlanta, GA 30303\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nJune 18, 2008\nMr. Jim Lamanna\nPresident\nBP Pipelines (North America), Inc.\n28100 Torch Parkway\nWarrenville, IL 60555\nCPF 2-2008-5006M\nDear Mr. Lamanna:\nOn October 9-12 and 22-24, 2007, representatives of the Pipeline aud Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nBP Pipelines (North America), Inc. procedures for Integrity Management in Warrenville,\nIllinois.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nBP Pipelines +orth America), Inc. procedures, as described below:\n1. 11192. 905 How does an operator identify a high consequence area?\n(a) General. To determine which segments of an operator's transmission pipeline\nsystem are covered by Subpart 0, an operator must identify the high consequence\nareas. An operator must use method (1) or (2) from the definition in I1192. 903 to\nidentify a high consequence area.\n\n\n\nI) The BP Integrity Management Plan (IMP) does not provide sufficient detail on how\nthe determination of HCA segments is accomplished. BP proposed additions to the\nIMP between weeks I and 2 of the inspection. The additions represent a more\nthorough process, however additional modifications are needed before the program\nprovides adequate directions, e. g. , specifics with respect to BP NA pipeline and the\nBP Alaska pipeline, better description of the objective of QA/QC activities.\n2) The BP IMP does not require that the method used to determine HCAs for each\nportion of the pipeline system be documented.\n2. ('l192. 905 How does an operator identify a high consequence area?\n(b)(1) Identified sites. An operator must identify an identified site, for purposes of\nthis subpart, from information the operator has obtained from routine operation\nand maintenance activities and from public officials with safety or emergency\nresponse or planning responsibilities who indicate to the operator that they know\nof locations that meet the identified site criteria. These public officials could\ninclude officials on a local emergency planning commission or relevant Native\nAmerican tribal officials.\nI) The BP IMP does not provide procedures that describe how identified sites are\ndetermined (number of people at a site, who contacted, etc). Contractors have been\nused to perform the HCA segment identification, but inadequate guidance was given\nto the contractors to ensure a quality effort was conducted. As a result, the\ndocumentation of the basis for identified site determination is lacking and there is\nno repeatable process described for future evaluation of potential HCAs.\n2) The BP IMP did not require contacting local government authorities or emergency\ncontacts for the determination of identified sites in the process of determining HCAs\nthat was conducted from program inception until 2006.\n3. ('l192. 911 What are the elements of an integrity management program?\n(o) Procedures for ensuring that each integrity assessment is being conducted in a\nmanner that minimizes environmental and safety risks.\nProcedures that provide protection for environmental and safety risks are not referenced\nby the IMP.\n(I192. 917 How does an operator, identify potential threats to pipeline integrity and\nuse the threat identification in its integrity program?\n(a) Threat identification. An operator must identify and evaluate all potential\nthreats to each covered pipeline segment. Potential threats that an operator must\nconsider include, but are not limited to, the threats listed in AMSE/ANSI B31. 8S\n(ibr, see (l192. 7), section 2.\n\n\n\n1) 'l'he HP lMP does not provide a documented process that describes how threats are\nanalyzed. The upper-tier requirement and the results of the analysis were provided,\nbut there is no information describing how threat scores and segment ranking are\ndetermined.\n2) The BP IMP has no documented process for evaluating interactive threats and threat\ninteraction has not been considered in evaluations conducted to date.\n5. t't192. 917 How does an operator, identify potential threats to pipeline integrity and\nuse the threat identification in its integrity program?\n(e)(1) Third party damage. An operator must utilized the data integration required\nin paragraph (b) of this section and AMSE/ANSI B31. 8S, Appendix A7 to\ndetermine the susceptibility of each covered segment to the threat of third party\ndamage. If an operator identifies the threat of third party damage, the operator\nmust implement comprehensive additional preventive measures in accordance\nwith (t192. 935 and monitor the effectiveness of the preventive measures.\nThe BP IMP does not contain a documented process for integrating data from various\nsources, such as the Dig Track database, to insure that comprehensive preventive\nmeasures are implemented for the threat of third party damage.\ntt192. 937 What is a continual process of evaluation and assessment to maintain a\npipeline's integrity?\n(b) Evaluation. An operator must conduct a periodic evaluation as frequently as\nneeded to assure the integrity of each covered segment. The periodic evaluation\nmust be based on a data integration and risk assessment of the entire pipeline as\nspecified in tt192. 917.\nThe BP IMP does not provide procedures for the performance and documentation of a\nperiodic evaluation based on data integration and risk assessment that includes:\n~ Past and present assessment results;\n~ Data integration and risk assessment information;\n~ Decisions about remediation; and\n~ Additional preventive and mitigative actions.\n$192. 935 What additional preventive and mitigative measures must an operator\ntake?\n(a) General requirements. An operator must take additional measures beyond those\nalready required by Part 192 to prevent a pipeline failure and to mitigate the\nconsequences of a pipeline failure in a high consequences area. An operator must\nbase the additional measures on the threats the operator has identified to each\npipeline segment. (See It192. 917)\n\n\n\nI) The BP IMP does not contain a documented process for identifying additional\nmeasures needed to prevent pipeline failure on HCA segments that is based on\nidentified threats and risk analysis.\n2) The BP IMP does not include a documented process that considers a spectrum of\nadditional measures to prevent failure of the pipeline or to mitigate consequences\nresulting from the pipeline's failure.\n3) The BP IMP does not make appropriate use of references to other documents which\nimplement activities. Examples include;\n~ The Damage Prevention Program identified in procedure P-192. 614,\n~ The BP \"Hurricane Plan\", the \"Earthquake Response Plan\", and the efforts\nconducted to detect and remediate concerns cause by \"strudel erosion\" on\noffshore pipeline in Alaska.\n4) The BP IMP has no documented procedures for a decision-making process that\ndetermines which P&M measures are to be implemented, and requires input from\naffected organizations.\n5) The BP IMP has no decision-making process for the determination of appropriate\nP&M measures that includes both likelihood and consequences of pipeline failures.\nThis includes an absence of a documented process as well as an absence of the\nconsequence component of evaluations performed to date.\n6) The BP IMP includes no process for identifying and documenting the\nimplementation of additional P&M measures or scheduling necessary measures for\nimplementation.\n8. II192. 935 What additional preventive and mitigative measures must an operator\ntake?\n(c) Automatic sit ut-off valves (AS V) or Remote control valves (RCV) If an operator\ndetermines, based on a risk analysis, that an ASV or RCV would be an efficient\nmeans of adding protection to a high consequence area in the event of a gas\nrelease, an operator must install the ASV or ACV.\nBP has not performed a risk-based analysis to determine if automatic shut-off valves or\nremote control valves should be added to protect its HCA segments and no documented\nprocess exists for the performance of this analysis.\n9. $192. 909 How can an operator change its integrity management program?\n(a) General. An operator must document any change to its program and the\nreasons for the change before implementing the change.\nThe BP IMP does not include a documented process that requires the reason for IMP\nchanges to be documented prior to implementation of the changes.\n10. II192. 911 What are the elements of an integrity management program?\n(I) A quality assurance process as outlined in ASME/ANSI B31. 8S, section 12.\n\n\n\n1) Section L. Quality Assurance (QA) of the BP IMP does not address or describe how\nASME B31. 8S, Section 12 requirements are met and how the IMP is to be reviewed\non a periodic basis, nor is there any process for addressing recommendations for\nIMP program improvements.\n2) The BP IMP neither contains nor references a documented corrective action process\nto ensure that corrections to the IMP or the QA process are documented and\nmonitored for effectiveness.\n3) The BP IMP does not contain a documented process that specifies how contracted\nresource suppliers are examined for implementation of an adequate quality\nassurance process to assure that IMP activities are conducted in a quality manner,\n11. I'1192. 7 Incorporation by references.\n(a) Any documents or portions there-of incorporated by reference in this part are\nincluded in this part as though set out in full. When only a portion of a document is\nreferenced, the remainder is not incorporated in this part.\nThe BP IMP does not address how \"should\" statements in referenced standards are\nconsidered within the IMP, nor does it identify how alternative implementation methods\nor the basis for not implementing the \"should\" statements are to be documented.\n12. I'1192. 911 What are the elements of an integrity management program?\n(m) A communication plan that includes the elements of ASME/AiqSI B31. SS,\nsection 10, and that includes procedures for addressing safety concerns raised by—\n(1) OPS; and\n(2) A State or local pipeline safety authority when a covered segment is\nlocated in a State where OPS has an interstate agent agreement.\n1) The BP IMP does not fully document how internal communications of integrity\nmanagement are to be conducted within the organization to ensure that\nunderstanding and support for the program are established. This plan should uot\nonly include management, but other personnel that conduct IMP-related activities.\n2) The BP IMP does not include a documented process for addressing safety concerns\nraised by PHIMS, State, or Local pipeline authorities.\n\n\n\nRes onse to this Notice\nThis Notice is provided pursuant to 49 U, S. C. ( 60108(a) and 49 C. F. R. tj 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 information\nqualifies for confidential treatment under 5 U. S. C. 552(b). If you do not respond within 30\ndays of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in\nthis Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as\nalleged 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 inadequacies\n(49 C. F. R. $ 190. 237). If you are not contesting this Notice, we propose that you submit your\namended procedures to my office within 45 days of receipt of this Notice. This period may be\nextended by written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed.\nIn correspondence concerning this matter, please refer to CPF 2-2008-5006M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nLinda Daugherty\nDirector, Southern\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings","truncated":false,"body_characters":13791}