{"operation":"document","citation":"CPF 220085007","title":"BP WEST COAST PRODUCTS L.L.C. — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-06-19","effective_on":null,"summary":"CLOSED notice of probable violation citing 192.905(a), 192.905(c), 192.907(a), 192.917, 192.917(c), 192.917(e), 192.921(a), 192.933(d), 192.945(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220085007.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220085007.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220085007","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220085007","body":"Notice of Probable Violation involving BP WEST COAST PRODUCTS L.L.C.. PHMSA's enforcement data identifies the cited regulations as 192.905(a),  192.905(c),  192.907(a),  192.917,  192.917(c),  192.917(e),  192.921(a),  192.933(d),  192.945(a). The case was opened on 2008-06-19 and is reported as closed as of 2010-11-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220085007_closure letter_11262010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220085007/220085007_closure%20letter_11262010.pdf\n\n220085007_closure letter_11262010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220085007/220085007_closure%20letter_11262010_text.pdf\n\n220085007_Final Order_10062010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220085007/220085007_Final%20Order_10062010.pdf\n\n220085007_Final Order_10062010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220085007/220085007_Final%20Order_10062010_text.pdf\n\n220085007_NOPV PCO Letter_06192008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220085007/220085007_NOPV%20PCO%20Letter_06192008.pdf\n\n220085007_nopv pco letter_06192008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220085007/220085007_nopv%20pco%20letter_06192008_text.pdf\n\n220085007_operator response to notice_07222008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220085007/220085007_operator%20response%20to%20notice_07222008.pdf\n\n220085007_Final Order_10062010_text.pdf\n\nOCT 6 2010\nMr. Steve Pankhurst\nPresident\nBP Pipelines (North America), Inc.\n28100 Torch Parkway\nWarrenville, IL 60555\nRe: CPF No. 2-2008-5007\nDear Mr. Pankhurst:\nEnclosed please find the Final Order issued in the above-referenced case. It makes findings of\nviolation and specifies actions that need to be taken by BP Pipelines (North America), Inc., to\ncomply with the pipeline safety regulations. When the terms of the compliance order have been\ncompleted, as determined by the Director, Southern Region, this enforcement action will be\nclosed. Service of the Final Order by certified mail is deemed effective upon the date of mailing,\nor as otherwise provided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. Wayne Lemoi, Director, Southern Region, PHMSA\nMr. David O. Barnes, Manager DOT & Integrity, BP Pipelines (North America), Inc.\nCERTIFIED MAIL – RETURN RECEIPT REQUESTED [7005 1160 0001 0039 0812]\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nBP Pipelines (North America), Inc., ) CPF No. 2-2008-5007\n)\n)\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nOn October 9-12 and 22-24, 2007, pursuant to 49 U.S.C. § 60117, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS), conducted an on-site pipeline safety inspection of the facilities and records of BP\nPipelines (North America), Inc. (BPNA or Respondent), in Warrenville, Illinois. BPNA operates\napproximately 654 miles of natural gas transmission pipelines in the United States, along with\nother gas and hazardous liquid pipelines.\nAs a result of the inspection, the Director, Southern Region, OPS (Director), issued to\nRespondent, by letter dated June 19, 2008, a Notice of Probable Violation and Proposed\nCompliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed\nfinding that BPNA had committed various violations of 49 C.F.R. Part 192 and proposed\nordering Respondent to take certain measures to correct the alleged violations.\nRespondent responded to the Notice by letter dated July 22, 2008 (Response). BPNA contested\nseveral of the allegations and requested a hearing. An informal hearing was subsequently held\nvia teleconference on February 4, 2009, with Larry White, Attorney, PHMSA Office of Chief\nCounsel, presiding. At the hearing, Respondent was represented by counsel. After the hearing,\nRespondent provided additional written material for the record, by letter dated March 5, 2009.\nFINDING OF VIOLATION\nThe Notice alleged that Respondent violated 49 C.F.R. Part 192, as follows:\nItem 7: The Notice alleged that Respondent violated 49 C.F.R. § 192.917(c), which states in\nrelevant part:\n\n\n\n2\n§ 192.917 – How does an operator identify potential threats to\npipeline integrity and use the threat identification in its integrity\nprogram?\n(a) ….\n(c) Risk assessment. An operator must conduct a risk assessment\nthat follows ASME/ANSI B31.8S, section 5, and considers the identified\nthreats for each covered segment. An operator must use the risk\nassessment to prioritize the covered segments for the baseline and\ncontinual reassessments (§§192.919, 192.921, 192.937), and to\ndetermine what additional preventive and mitigative measures are\nneeded (§192.935) for the covered segment.\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.917(c) by failing to have a risk\nmodel for conducting its risk assessments that enabled Respondent to determine the need for\nadditional preventive and mitigative measures to minimize failure consequences for covered\nsegments. More specifically, Respondent’s risk model and assessment process failed to describe\nhow the risk assessment addressed the following:\n• Assessment of the benefits derived from mitigating actions.\n• Determination of the most effective mitigation measures for identified threats.\n• Assessment of the integrity impact from modified inspection intervals.\n• Assessment of the use of or need for alternative inspection methodologies.\n• More effective resource allocation.\n• Facilitation of decisions to address risks along a pipeline or within a facility.\nIn its Response and during the hearing, BPNA stated that it used a relativistic risk model and that\nits subject matter experts considered conditional threats and non-conditional threats in\nperforming its segment risk ranking. Respondent also noted that PHMSA did not conclude that\nits risk ranking results reflected an improper ranking of its covered segments. In its March 5,\n2009 correspondence, Respondent offered further description of the threats it had identified and\nstated that the nature of these threats and the condition of its pipelines gave it reason to believe\nthat further consideration of consequences was unnecessary.\nWe acknowledge that Respondent’s risk model included threat identification. A determination\nof the need for additional preventive and mitigative measures for covered segments, however, is\nan express requirement of the cited regulation. Respondent did not produce any documentation\nshowing that the risk modeling process it had in place during the relevant period included a\nmeans of determining the need for additional preventive and mitigative measures to minimize\nfailure consequences and accomplish the purpose of the regulation.\nAccordingly, after considering all of the evidence, I find that Respondent violated 49 C.F.R.\n§ 192.917(c) by failing to have a risk model for conducting its risk assessments that enabled the\ncompany to determine the need for additional preventive and mitigative measures to minimize\nfailure consequences for covered segments.\nThis finding of violation will be considered a prior offense in any subsequent enforcement action\ntaken against Respondent.\n\n\n\n3\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Item 7 in the Notice for violation of 49\nC.F.R. § 192.917(c). Under 49 U.S.C. § 60118(a), each person who engages in the\ntransportation of gas or who owns or operates a pipeline facility is required to comply with the\napplicable safety standards established under chapter 601. Pursuant to the authority of 49 U.S.C.\n§ 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following actions to\nensure compliance with the pipeline safety regulations applicable to its operations:\nWith respect to the violation of § 192.917(c) (Item 7), within 30 days following\nreceipt of this order:\na. Provide the Director with complete written procedures for conducting a risk\nassessment (likelihood and consequences) for all covered gas pipeline\nsegments that follows ASME/ANSI B31.8S, section 5, considers the identified\nthreats for each covered segment, and uses all available risk information;\nb. Provide the Director with a timeline for application of these procedures and\ncompletion of the risk assessment on all covered gas pipeline segments\nincluded in BPNA’s integrity management program.\nc. Maintain documentation of the safety improvement costs associated with\nfulfilling this Compliance Order and submit the total to the Director. Costs\nshall be reported in two categories: (1) total cost associated with\npreparation/revision of plans, procedures, studies and analyses; and (2) total\ncost associated with replacements, additions, and other changes to pipeline\ninfrastructure.\nThe Director may grant an extension of time to comply with any of the required items upon a\nwritten request timely submitted by the Respondent and demonstrating good cause for an\nextension.\nFailure to comply with this Order may result in the administrative assessment of civil penalties\nnot to exceed $100,000 for each violation for each day the violation continues or in referral to the\nAttorney General for appropriate relief in a district court of the United States.\nWARNING ITEMS\nWith respect to Items 1, 2, 3, 4, 5, 6, 8, and 9, the Notice alleged probable violations of Part 192\nbut did not propose a civil penalty or compliance order for these items. Therefore, these are\nconsidered to be warning items. The warnings were for:\n49 C.F.R. § 192.905(a) (Item 1) ─ Respondent’s alleged failure to identify all\nhigh consequence areas (HCAs) using appropriate methods;\n49 C.F.R. § 192.905(c) (Item 2) ─ Respondent’s alleged failure to have a\ndocumented process for annual or more frequent identification of newly identified\nHigh Consequence Areas;\n\n\n\n4\n49 C.F.R. § 192.907(a) (Item 3) ─ Respondent’s alleged failure to follow its\nsegment identification process for two offshore risers;\n49 C.F.R. § 192.921(a) (Item 4) ─ Respondent’s alleged failure to incorporate all\nassessment specifications and methods best suited to address the identified\nthreats;\n49 C.F.R. § 192.917(e) (Item 5) ─ Respondent’s alleged failure to use threat\nidentification information to monitor and address seam integrity risks on low\nfrequency electric-resistance welded pipe;\n49 C.F.R. § 192.917(b) (Item 6) ─ Respondent’s alleged failure to have a\ndocumented process for gathering and integrating available pipeline data to\nsupport threat analysis and risk determination;\n49 C.F.R. § 192.933(d) (Item 8) ─ Respondent’s alleged failure to omit pressure\nreduction from the allowable actions to be taken when an immediate repair\ncondition is identified on a gas pipeline operating at or below 30% SMYS;\n49 C.F.R. § 192.945(a) (Item 9) ─ Respondent’s alleged failure to use specified\nmetrics to evaluate the effectiveness of its integrity management program on a\nsemi-annual basis.\nBPNA presented information in its Response showing that it had taken certain actions to address\nthe cited items. Accordingly, having considered such information, I find, pursuant to 49 C.F.R.\n§ 190.205, that probable violations of 49 C.F.R. §§ 192.905(a), 192.905(c), 192.907(a),\n192.921(a), 192.917(e), 192.917(b), 192.933(d), and 192.945(a) have occurred as described\nabove and Respondent is hereby advised to correct such conditions. In the event that OPS finds\na violation of any of these items in a subsequent inspection, Respondent may be subject to future\nenforcement action.\nUnder 49 C.F.R. § 190.215, Respondent has a right to submit a petition for reconsideration of\nthis Final Order. Should Respondent elect to do so, the petition must be sent to: Associate\nAdministrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey Avenue, SE, East Building,\n2nd Floor, Washington, DC 20590, with a copy sent to the Office of Chief Counsel, PHMSA, at\nthe same address. PHMSA will accept petitions received no later than 20 days after receipt of\nservice of this Final Order by the Respondent, provided they contain a brief statement of the\nissue(s) and meet all other requirements of 49 C.F.R. § 190.215. Unless the Associate\nAdministrator, upon request, grants a stay, the terms and conditions of this Final Order are\neffective upon service in accordance with 49 C.F.R. § 190.5.\n___________________________________ __________________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n220085007_closure letter_11262010_text.pdf\n\nNovember 26, 2010\nMr. Steve Pankhurst\nPresident\nBP Pipelines (North America), Inc.\n28100 Torch Parkway\nWarrenville, IL 60555\nCPF 2-2008-5007\nDear Mr. Pankhurst:\nOn October 9-12, and October 22-24, 2007, a team of representatives from the Pipeline and\nHazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety conducted an\ninspection of the BP Pipelines (North America), Inc. (BPNA) gas integrity management\nprogram (IMP) in Warrenville, Illinois, pursuant to Chapter 601 of 49 United States Code.\nAs a result of the inspections, PHMSA issued a Final Order on October 6, 2010. The Final\nOrder included a Compliance Order (CO), which required BPNA to take certain actions to\nprotect the public and the environment.\nThe PHMSA Southern Region has reviewed your November 12, 2010, written response to the\nCO. We find that you have met the requirements specified in the CO. No further action is\nnecessary with regards to the Final Order and this case is now closed.\nPlease be advised that nothing herein states or implies that the above described gas integrity\nmanagement program meets the requirements of the federal pipeline safety regulations or that\nthe program is approved. The pipeline system and IMP remain subject to inspection by\nPHMSA.\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n\n220085007_nopv pco letter_06192008_text.pdf\n\nU. S. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n233 Peacntree Street Ste. 600\nAtlanta, GA 30303\nNOTICE OF PROBABLE VIOLATION\nand\nPROPOSED COMPLIANCE ORDER\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nJune 19, 2008\nMr. Jim Lamanna\nPresident\nBP Pipelines P1orth America), Inc.\n28100 Torch Parkway\nWarrenville, IL 60555\nCPF 2-2008-5007\nDear Mr. Lamanna:\nOn October 9-12 and 22-24, 2007, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nyour BP Pipelines (North America), Inc. procedures for Integrity Management in Warrenville,\nIllinois.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violation(s) are:\ntt192. 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 tt192. 903 to\nidentify a high consequence area.\n1) The BP IMP does not account for inaccuracies in the HCA mapping process when\nidentifying HCAs and HCA segment length. No buffer is applied to the Potential\nImpact Radius (PIR) and inaccuracies were stated to be as high as +/-50 to 100 It. in\nmeasurements obtained from aerial photography. Onshore pipelines, excluding LA\nBasin (Line 211) and HCL (Line 893) (both 100% HCA) will need to be reanalyzed\nto incorporate the stated accuracy.\n\n\n\n2) The initial effort to identify HCAs by 12/I'7/04 did not accurately account for\nidentified sites in the HCA segment identification process. Identified sites were\ndesignated by points on structures and HCA segment were established based on point\nlocation rather than a PIC sliding along the pipeline for the length of the structure at\nits closest points of impact. The current practice requires ail identified sites to be\ndigitized as polygons.\n2. t)192. 905 How does an operator identify a high consequence area?\n(c) Newly identified areas. When an operator has information that the area around a\npipeline segment not previously identified as a high consequence area could satisfy\nany of the definitions in t)192. 903, the operator must complete the evaluation using\nmethod (1) or (2).\nThe BP IMP does not provide a documented process for how new information is\nidentified and integrated with the integrity management program. Further, the IMP states\nthat HCA updates are to occur on a 3-year basis rather than on an annual or more\nfrequent basis. Changes were made to the BP IMP between weeks 1 and 2 of the\ninspection to address this issue.\n3. II192. 907 What must an operator do to implement this subpart?\n(a) General. No later than December 17, 2004, an operator of a covered pipeline\nsegment must and follow a written integrity management program that contains all\nthe elements described in II192. 911 and that addresses the risks on each covered\ntransmission pipeline segment.\nThe initial HCA segment identification process did not include the risers offshore that\ncould affect the platforms, Okeanos (Nakika) and Cleopatra (Mad Dog), which are\nidentified sites in the Mardi Gras System not identified by 12/17/04. Records indicated\nthat one segment operated on 11/30/03 and the other segment on 02/25/05.\n5192. 921 How is the baseline assessment to be conducted?\n(a) Assessment methods. An operator must assess the integrity of the line pipe in\neach covered segment by applying one or more of the following methods depending\non the threats to which the covered segment is susceptible. An operator must select\nthe method or methods best suited to address the threats identified to the covered\nsegment (See 11192. 917).\nThe BP IMP does not make appropriate use of references to other documents which\nimplement IMP activities. Examples include:\n\n\n\n~ Specification BPPL-STP 32-210 provides requirements for ensuring the\nreliability of ILI assessments, but this specification is not clearly referenced in\ncontext by the IMP.\n~ The procedure that controls hydro-testing to ensure Subpart I requirements are\nmet is not referenced by the IMP.\nChanges were made to the BP IMP between weeks 1 and 2 of the inspection to address\nthese issues.\nI'1192. 917 How does an operator identify potential threats to pipeline integrity and\nuse the threat identification in its integrity program?\n(e) Actions io address particular threats. If an operator identifies any of the following\nthreats, the operator must take the following actions to address the threat.\n(4) ER W pipe. If a covered pipeline segment contains low frequency electric\nresistance welded pipe (ERW), lap welded pipe or other pipe that satisfies the\nconditions specified in ASME/ANSI B31. S, Appendices A4. 3 and A4. 4, and any\ncovered or noncovered segment in the pipeline system with such pipe has\nexperienced seam failure, or operating pressure on the covered segment has\nincreased over the maximum operating pressure experienced during the preceding\nfive years, an operator must select an assessment technology or technologies with a\nproven application capable of assessing seam integrity and seam corrosion\nanomalies.\nThe BP IMP contains no provisions to monitor operating pressures experienced over the\npreceding 5-year period to ensure that seam conditions on LF ERW piping do not become\nunstable.\n11192. 917 How does an operator identify potential threats to pipeline integrity and\nuse the threat identification in its integrity program?\n(b) Data gathering and integration. To identify and evaluate the potential threats to a\ncovered pipeline segment, an operator must gather and integrate existing data and\ninformation on the entire pipeline that could be relevant to the covered segment. In\nperforming this data gathering and integration, an operator must follow the\nrequirements in ASME/ANSI B31. 8S, section 4.\nThe BP IMP includes no documented plan or process for the gathering and integration of\ndata to support threat analysis and risk determination. Data sources aud data elements in\naccordance with B31. 8S Tables 1 aud 2 are not identified. No provisions exist for\ntreatment of missing or suspect data. No procedures are provided which ensure timely\ntreatment of new data. No procedures exist to define the process for spatial integration of\ndata or to demonstrate integration of ILI results with encroachments or foreign line\ncrosslligs.\n\n\n\n7. $192. 917 How does an operator identify potential threats to pipeline integrity and\nuse the threat identification in its integrity program?\n(c) Risk assessment. An operator must conduct a risk assessment that follows\nASME/ANSI B31. 8S, section 5, and considers the identified threats for each covered\nsegment. An operator must use the risk assessment to prioritize the covered\nsegments for the baseline and continual reassessments (@192. 919, 192. 921, 192. 937),\nand to determine what additional preventive and mitigative measures are needed\n(t)192. 935) for the covered segment.\nThere has been no development of a risk model as part of the BP IMP. Threats have been\nanalyzed using a relativistic model and the model developed for liquid lines is stated to\nbe similar to that which will be developed for gas lines over the next two years, but there\nhas been no determination of risk (likelihood and consequences) for gas lines.\nAccordingly, there are no program procedures that describe the use of risk information as\npart of the Gas IMP.\nThe BP IMP does not address pipeline risk in a manner that enables:\n~ Assessment of the benefits derived from mitigating actions:\n~ Determination of the most effective mitigation measures for identified threats;\n~ Assessment of the integrity impact from modified inspection intervals;\n~ Assessment of the use of or need for alternative inspection methodologies;\n~ More effective resource allocation;\n~ Facilitation of decisions to address risks along a pipeline or within a facility.\nNo program documentation exists to describe how these objectives are met using risk\ndetermination. Further, no risk information exists to ensure appropriate ranking for\nconducting the BAP.\n(j192. 933 What actions must be taken to address integrity issues?\n(d) Special requirements for scheduling remediation. -(1) Immediate repair conditions.\nAn operator's evaluation and remediation schedule must follow ASME/ANSI\nB31. 8S, section 7 in providing for immediate repair conditions. To maintain safety,\nan operator must temporarily reduce operating pressure in accordance with\nparagraph (a) of this section or shut down the pipeline until the operator completes\nthe repair of these conditions.\n\n\n\nThe BP IMP states reduce pressure, shut down the line, or notify PHMSA if it discovers\nan immediate condition. If BP has a line operating at or below 30% SMYS they may\nsimply notify PHMSA of the condition, rather than reduce pressure. There is no direction\nto immediately take a pressure reduction. BP stated that this is done at the 40% level on\nthe liquid side, but changed to 30% to coincide with the gas Rule. This approach will be\ndiscussed internally with PHMSA management to determine if it meets the Rule intent.\nBP has not discovered any immediate condition in a HCA segment of its gas pipelines at\nthis time.\ntj192. 945 What methods must an operator use to measure program effectiveness?\n(a) General. An operator must include in its integrity management program\nmethods to measure, on a semi-annual basis, whether the program is effective in\nassessing and evaluating the integrity of each covered pipeline segment and in\nprotecting the high consequence areas.\nSection I of the BP IMP addresses the need to track threat specific metrics on a semi-\nannual basis. There is no documentation to demonstrate that these metrics are taken.\nChanges were made to the IMP between weeks I and 2 of the inspection to correct this\nissue.\nPro osed Com liance Order\nPursuant to 49 United States Code $ 60118, the Pipeline and Hazardous Materials Safety\nAdministration proposes to issue a Compliance Order to BP Pipelines (North America), Inc.\nPlease refer to the Proposed Compliance Order that is enclosed and made a part of this Notice.\n~Wlt\nWith respect to item(s): I, 2, 3, 4, 5, 6, 8 and 9, we have reviewed the circumstances and\nsupporting documents involved in this case and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to promptly\ncorrect these item(s). Be advised that failure to do so may result in BP Pipelines (North\nAmerica), Inc. being subject to additional enforcement action.\nRes onse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators\nin Compliance 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 for\nconfidential treatment under 5 U. S. C. 552(b), along with the complete original document you\nmust 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 days\n\n\n\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue a Final Order.\nIn your correspondence on this matter, please refer to CPF 2-2008-5007 and for each document\nyou submit, please provide a copy in electronic format whenever possible.\nSincerely,\nLinda Daugherty\nDirector, Southern\nPipeline and Hazardous Materials Safety Administration\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Compliance Proceedings\n\n\n\nPROPOSED COMPLIANCE ORDER\nPursuant to 49 United States Code ) 60118, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) proposes to issue to BP Pipelines (North America), Inc. a Compliance\nOrder incorporating the following remedial requirements to ensure the compliance of BP\nPipelines (North America), Inc. with the pipeline safety regulations:\nIn regard to Item Number 7 of the Notice pertaining to Risk Assessment, BP NA\nmust conduct a risk assessment that follows ASME/ANSI B31. 8S, section 5, and\nconsiders the identified threats for each covered segment. Threats have been\nanalyzed using a relativistic model and the model developed for liquid lines is\nstated to be similar to that which will be developed for gas lines over the next two\nyears. BP NA must determine the risk (likelihood and consequences) for the gas\nlines and provide program procedures that describe the use of risk information as\npart of the Gas IMP.\n2. BP NA must provide a timeline to PHMSA detailing the application of the Risk\nAssessment process to those pipeline segments included in BP NA's IMP.\nThis is to be accomplished within 30 days following receipt of the Final Order.\nBP NA shall maintain documentation of the safety improvement costs associated\nwith fulfilling this Compliance Order and submit the total to Linda Daugherty,\nDirector, Southern Region, Pipeline and Hazardous Materials Safety\nAdministration. Costs shall be reported in two categories: I) total cost associated\nwith preparation/revision of plans, procedures, studies and analyses, and 2) total\ncost associated with replacements, additions and other changes to pipeline\ninfrastructure.","truncated":false,"body_characters":28023}