STATOIL OIL & GAS LP — Notice of Probable Violation

party submissionOfficial PDF320176009_Operator Response To Notice_11032017.pdf#

320176009_Final Order_05142018_text.pdf, page 1Official PDFMay 14, 2018 Mr. Eldar Sætre President and Chief Executive Officer Statoil ASA Forusbeen 50 4035 Stavanger, Norway Re: CPF No. 3-2017-6009 Dear Mr. Sætre: Enclosed please find the Final Order issued in the above-referenced case. It makes findings of violation, assesses a civil penalty of $73,700, and specifies actions that need to be taken by Statoil Pipelines, LLC, a subsidiary of Statoil ASA, to comply with the pipeline safety regulations. The penalty payment terms are set forth in the Final Order. When the civil penalty has been paid and the terms of the compliance order completed, as determined by the Director, Central Region, this enforcement action will be closed. Service of the Final Order by certified mail is effective upon the date of mailing as provided under 49 C.F.R. § 190.5. Thank you for your cooperation in this matter. Sincerely, Alan K. Mayberry Associate Administrator for Pipeline Safety Enclosure cc: Mr. Allan C. Beshore, Director, Central Region, Office of Pipeline Safety, PHMSA Mr. Frederick Beck, Senior VP DPUSA, 6300 Bridge Point Parkway, Bldg 2, Suite 100, Austin, TX 78730 Mr. Charles O’Brien, Managing Counsel, Statoil Pipelines LLC, 120 Long Ridge Road Suite 3EO1, Stamford, CT 06905 Mr. Ronnie Speer, Principal DOT Pipeline Compliance, DPUSA SSU SRC REG, 6300 Bridge Point Parkway, Bldg 2, Suite 100, Austin TX 78730 CERTIFIED MAIL - RETURN RECEIPT REQUESTED#

320176009_Final Order_05142018_text.pdf, page 2U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 ____________________________________ In the Matter of ) Statoil Pipelines, LLC, ) CPF No. 3-2017-6009 a subsidiary of Statoil ASA, ) ) ) ) Respondent. ) ____________________________________) FINAL ORDER On March 22-24 and May 3-5, 2016, pursuant to 49 U.S.C. § 60117, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), conducted an on-site pipeline safety inspection of the facilities and records of Statoil Pipelines, LLC’s (Statoil or Respondent) North Dakota pipeline unit in Williston, North Dakota. Statoil ASA, the parent company of Statoil, is a Norwegian multinational oil and gas company headquartered in Stavanger, Norway, with operations in 36 countries, including the United States.1 As a result of the inspection, the Director, Central Region, OPS (Director), issued to Respondent, by letter dated September 29, 2017, a Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Statoil had committed five violations of 49 C.F.R. Part 195 and proposed assessing a civil penalty of $73,700 for the alleged violations. The Notice also proposed ordering Respondent to take certain measures to correct the alleged violations. Statoil responded to the Notice by letter dated November 3, 2017 (Response). The company did not contest the allegations of violation and agreed to pay the proposed penalty amount and perform the terms of the proposed compliance order upon receipt of this Final Order. Respondent did not request a hearing and therefore has waived its right to one. FINDINGS OF VIOLATION In its Response, Statoil did not contest the allegations in the Notice that it violated 49 C.F.R. Part 195, as follows: 1 Statoil’s website, available at https://www.statoil.com/ (last accessed January 16, 2018).#

320176009_Final Order_05142018_text.pdf, page 3CPF No. 3-2017-6009 Page 2 Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.266, which states: § 195.266 Construction records. A complete record that shows the following must be maintained by the operator involved for the life of each pipeline facility: (a) The total number of girth welds and the number nondestructively tested, including the number rejected and the disposition of each rejected weld. (b) The amount, location; and cover of each size of pipe installed. (c) The location of each crossing of another pipeline. (d) The location of each buried utility crossing. (e) The location of each overhead crossing. (f) The location of each valve and corrosion test station. The Notice alleged that Respondent violated 49 C.F.R. § 195.266 by failing to maintain complete records showing the amount, location, and depth of cover of each size of pipe installed, the location of each crossing of another pipe, the location of each buried utility crossing, the location of each overhead crossing, and the location of each valve and corrosion test station. Specifically, the Notice alleged that Statoil did not have records containing information on the depth of cover at the time of installation (except for bored sections), pipeline location, utility or overhead crossings, or valves and corrosion test stations for the Lougheed section of its pipeline. Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.266 by failing to have the requisite construction records for the Lougheed section of its pipeline. Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(c)(12), which states: § 195.402 Procedural manual for operations, maintenance, and emergencies. (a) . . . . (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: (1) . . . . (12) Establishing and maintaining liaison with fire, police, and other appropriate public officials to learn the responsibility and resources of each government organization that may respond to a hazardous liquid or pipeline emergency and acquaint the officials with the operator’s ability in responding to a hazardous liquid or carbon dioxide pipeline emergency and means of communication. The Notice alleged that Respondent violated 49 C.F.R. § 195.402(c)(12) by failing to follow for each pipeline system a manual of written procedures that included procedures for establishing liaison with fire, police, and other appropriate public officials to learn the responsibility and resources of each organization that may respond to a hazardous liquid or pipeline emergency and#

320176009_Final Order_05142018_text.pdf, page 4CPF No. 3-2017-6009 Page 3 acquaint these officials with Statoil’s response capabilities. Specifically, the Notice alleged that Statoil was unable to produce records evidencing liaison efforts with fire and police departments for the City of Willison and the City of Alexander. It also failed to produce records evidencing liaison efforts with the emergency-management and sheriff’s departments for Williams and McKenzie Counties. Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.402(c)(12) by failing to follow procedures to establish and maintain liaison with fire, police, and other appropriate public officials pursuant to a manual of written procedures to provide safety during maintenance and normal operations. Item 3: The Notice alleged that Respondent violated 49 C.F.R. § 195.410(a)(2)(ii), which states: § 195.410 Line markers. (a) Except as provided in paragraph (b) of this section, each operator shall place and maintain line markers over each buried pipeline in accordance with the following: (1) . . . . (2) The marker must state at least the following on a background of sharply contrasting color: (i) . . . . (ii) The name of the operator and a telephone number (including area code) where the operator can be reached at all times. The Notice alleged that Respondent violated 49 C.F.R. § 195.410(a)(2)(ii) by failing to place and maintain a line marker that included a telephone number where the operator could be reached at all times. Specifically, the Notice alleged that Statoil failed to have a marker that listed a telephone number where a person could be reached at all hours. When the inspector called the number listed, there was no response. Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.410(a)(2)(ii) by failing to place and maintain a line marker that included a telephone number where the operator could be reached at all times. Item 4: The Notice alleged that Respondent violated 49 C.F.R. § 195.452(b)(1), which states: § 195.452 Pipeline integrity management in high consequence areas. (a) . . . . (b) What program and practices must operators use to manage pipeline integrity? Each operator of a pipeline covered by this section must: (1) Develop a written integrity management program that addresses the risks on each segment of pipeline in the first column of the following table not later than the date in the second column:#

320176009_Final Order_05142018_text.pdf, page 5CPF No. 3-2017-6009 Page 4 Pipeline Date Category 1 . . . . . . . . . . . Category 2 . . . . . . . . . . . Category 3 . . . . . . . . . . . March 31, 2002. February 18, 2003. 1 year after the date the pipeline begins operation. The Notice alleged that Respondent violated 49 C.F.R. § 195.452(b)(1) by failing to develop an integrity management program (IMP) for a pipeline operating in a High Consequence Area (HCA) within the requisite time period. Specifically, the Notice alleged that Statoil failed to develop an IMP for a Category 3 pipeline (commissioned in 2013) until three years after it began operation, instead of the required one year. Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.452(b)(1) by failing to develop an IMP not later than one year after the date the pipeline began operation. Item 5: The Notice alleged that Respondent violated 49 C.F.R. § 195.509(a), which states: § 195.509 General. (a) Operators must have a written qualification program by April 27, 2001. The program must be available for review by the Administrator or by a state agency participating under 49 U.S.C. Chapter 601 if the program is under the authority of that state agency. The Notice alleged that Respondent violated 49 C.F.R. § 195.509(a) by failing to have a written qualification program in place during operation. Specifically, the Notice alleged that Statoil failed to have its written operator qualification (OQ) program in place from the time when operations began in February 2013 through October 2015. Prior to October 2015, there were employees and contractors performing covered tasks even though Statoil did not have an OQ program in place. Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.509(a) by failing to have a written qualification program in place during operation. These findings of violation will be considered prior offenses in any subsequent enforcement action taken against Respondent. ASSESSMENT OF PENALTY Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed $200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any#

320176009_Final Order_05142018_text.pdf, page 6CPF No. 3-2017-6009 Page 5 related series of violations.2 In determining the amount of a civil penalty under 49 U.S.C. § 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature, circumstances, and gravity of the violation, including adverse impact on the environment; the degree of Respondent’s culpability; the history of Respondent’s prior offenses; and any effect that the penalty may have on its ability to continue doing business; and the good faith of Respondent in attempting to comply with the pipeline safety regulations. In addition, I may consider the economic benefit gained from the violation without any reduction because of subsequent damages, and such other matters as justice may require. The Notice proposed a total civil penalty of $73,700 for the violations cited above. Item 1: The Notice proposed a civil penalty of $16,900 for Respondent’s violation of 49 C.F.R. § 195.266, by failing to maintain complete records showing the amount, location, and depth of cover of each size of pipe installed, the location of each crossing of another pipe, the location of each buried utility crossing, the location of each overhead crossing, and the location of each valve and corrosion test station. Statoil neither contested the allegation nor presented any evidence or argument justifying a reduction or elimination of the proposed penalty. I find that Statoil failed to comply with a requirement that was clearly applicable and offered no reasonable justification for its noncompliance. Accordingly, having reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of $16,900 for violation of 49 C.F.R. § 195.266. Item 3: The Notice proposed a civil penalty of $22,400 for Respondent’s violation of 49 C.F.R. § 195.410(a)(2)(ii) by failing to place and maintain a line marker that included a telephone number where the operator could be reached at all times. Statoil neither contested the allegation nor presented any evidence or argument justifying a reduction or elimination of the proposed penalty. Statoil failed to comply with a requirement that was clearly applicable and offered no reasonable justification for its noncompliance. Accordingly, having reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of $22,400 for violation of 49 C.F.R. § 195.410(a)(2)(ii). Item 4: The Notice proposed a civil penalty of $17,200 for Respondent’s violation of 49 C.F.R. § 195.452(b)(1) by failing to develop an IMP for a Category 3 pipeline operating in an HCA within one year of operation. Statoil neither contested the allegation nor presented any evidence or argument justifying a reduction or elimination of the proposed penalty. The proposed penalty took into consideration the fact that Statoil found the noncompliance, which occurred within an HCA, and took documented action to correct it prior to the PHMSA inspection. Accordingly, having reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of $17,200 for violation of 49 C.F.R. § 195.452(b)(1). Item 5: The Notice proposed a civil penalty of $17,200 for Respondent’s violation of 49 C.F.R. 49 C.F.R. § 195.509(a) by failing to have a written qualification program in place during operation. Statoil neither contested the allegation nor presented any evidence or argument justifying a reduction or elimination of the proposed penalty. The proposed penalty amount took 2 These amounts are adjusted annually for inflation. See, e.g., Pipeline Safety: Inflation Adjustment of Maximum Civil Penalties, 82 Fed. Reg. 19325 (April 27, 2017).#

320176009_Final Order_05142018_text.pdf, page 7CPF No. 3-2017-6009 Page 6 into consideration that Statoil found the noncompliance, which occurred within an HCA, and took documented action to correct it prior to the PHMSA inspection. Accordingly, having reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of $17,200 for violation of 49 C.F.R. § 195.509(a). In summary, having reviewed the record and considered the assessment criteria for each of the Items cited above, I assess Respondent a total civil penalty of $73,700. Payment of the civil penalty must be made within 20 days of service of this Final Order. Payment may be made by sending a certified check or money order (containing the CPF Number for this case), made payable to “U.S. Department of Transportation,” to the Federal Aviation Administration, Mike Monroney Aeronautical Center, Financial Operations Division (AMK- 325), 6500 S MacArthur Blvd, Oklahoma City, Oklahoma 79169. Federal regulations (49 C.F.R. § 89.21(b)(3)) also permit payment to be made by wire transfer through the Federal Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed instructions are contained in the enclosure. Questions concerning wire transfers should be directed to: Financial Operations Division (AMK-325), Federal Aviation Administration, Mike Monroney Aeronautical Center, 6500 S MacArthur Blvd, Oklahoma City, Oklahoma 79169. The Financial Operations Division telephone number is (405) 954-8845. Failure to pay the $73,700 civil penalty will result in accrual of interest at the current annual rate in accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to those same authorities, a late penalty charge of six percent (6%) per annum will be charged if payment is not made within 110 days of service. Furthermore, failure to pay the civil penalty may result in referral of the matter to the Attorney General for appropriate action in a district court of the United States. COMPLIANCE ORDER The Notice proposed a compliance order with respect to Item 2 in the Notice, for violation of 49 C.F.R. § 195.402(c)(12). Under 49 U.S.C. § 60118(a), each person who engages in the transportation of hazardous liquids or who owns or operates a pipeline facility is required to comply with the applicable safety standards established under chapter 601. Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following actions to ensure compliance with the pipeline safety regulations applicable to its operations: 1. With respect to the violation of § 195.402(c)(12) (Item 2), Respondent must locate all missing records and send them to Allan C. Beshore, Director, Central Region, OPS, PHMSA within 90 days of receipt of this Final Order. The Director may grant an extension of time to comply with any of the required items upon a written request timely submitted by the Respondent and demonstrating good cause for an extension.#

320176009_Final Order_05142018_text.pdf, page 8CPF No. 3-2017-6009 Page 7 It is requested (not mandated) that Respondent maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to the Director. It is requested that these costs be reported in two categories: (1) total cost associated with preparation/revision of plans, procedures, studies and analyses; and (2) total cost associated with replacements, additions and other changes to pipeline infrastructure. Failure to comply with this Order may result in the administrative assessment of civil penalties not to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), for each violation for each day the violation continues or in referral to the Attorney General for appropriate relief in a district court of the United States. Under 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this Final Order to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address, no later than 20 days after receipt of service of this Final Order by Respondent. Any petition submitted must contain a statement of the issue(s) and meet all other requirements of 49 C.F.R. § 190.243. The filing of a petition automatically stays the payment of any civil penalty assessed. The other terms of the order, including corrective action, remain in effect unless the Associate Administrator, upon request, grants a stay. The terms and conditions of this Final Order are effective upon service in accordance with 49 C.F.R. § 190.5. May 14, 2018 ___________________________________ __________________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety#

320176009_Closure Letter_09132018_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED September 13, 2018 Mr. Eldar Saetre President and Chief Executive Officer Statoil ASA Forusbeen 50 4035 Stavanger, Norway CPF 3-2017-6009 Dear Mr. Saetre: On May 14, 2018, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to Statoil Pipelines, LLC a subsidiary of Statoil ASA a Final Order in the above- referenced case. This Order included a Compliance Order and Civil Penalty assessment. Based on our review of the documentation you provided and confirmation of payment of the civil penalty, it has been determined that you have complied with the terms of this Order. Accordingly, this case is now closed and no further action is contemplated with respect to the matters involved in this case. Thank you for your cooperation in this matter. Sincerely, Allan C. Beshore Director, Central Region, OPS Pipeline and Hazardous Materials Safety Administration#

320176009_NOPV PCP PCO_09292017_text.pdf, page 1Official PDFNOTICE OF PROBABLE VIOLATION PROPOSED CIVIL PENALTY and PROPOSED COMPLIANCE ORDER CERTIFIED MAIL - RETURN RECEIPT REQUESTED September 29, 2017 Mr. Frederick Beck, Senior Vice President DPUSA Statoil Oil & Gas LP 6300 Bridge Point Parkway, Bldg. 2, Suite 100 Austin, TX 78730 CPF 3-2017-6009 Dear Mr. Beck: On March 22-24 and May 3-5, 2016, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code inspected your North Dakota pipeline unit in Williston, North Dakota. As a result of the inspection, it is alleged that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable violation(s) are: 1. §195.266 Construction Records A complete record that shows the following must be maintained by the operator involved for the life of each pipeline facility:#

320176009_NOPV PCP PCO_09292017_text.pdf, page 22. (a) The total number of girth welds and the number nondestructively tested, including the number rejected and the disposition of each rejected weld. (b) The amount, location; and cover of each size of pipe installed. (c) The location of each crossing of another pipeline. (d) The location of each buried utility crossing. (e) The location of each overhead crossing. (f) The location of each valve and corrosion test station. Statoil Oil & Gas LP (Statoil) failed to demonstrate that complete records which show the amount, location, depth of cover of each size of pipe installed and location of each crossing of another pipeline, location of each buried utility crossing, location of each overhead crossing, and location of each valve and corrosion test station are being maintained for each pipe segment. The Lougheed section was reviewed for Welds, UT Inspection, Rejections, Cut-outs, Repairs and Pipeline Component and Crossing Locations. No record was produced for this line on depth of cover at the time of the pipeline’s installation except on the bored sections. No record was produced indicating locations of pipeline, utility or overhead crossings, valves and corrosion test stations. §195.402 Procedural manual for operations, maintenance, and emergencies. (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: (12) Establishing and maintaining liaison with fire, police, and other appropriate public officials to learn the responsibility and resources of each government organization that may respond to a hazardous liquid or pipeline emergency and acquaint the officials with the operator's ability in responding to a hazardous liquid or carbon dioxide pipeline emergency and means of communication. Statoil failed to follow for each pipeline system a manual of written procedures for conducting normal operations by not establishing and maintaining liaison with fire, police and other appropriate public officials to learn the responsibility and resources of each organization that may respond to a hazardous liquid or pipeline emergency and acquaint the officials with Statoil’s response abilities. Statoil failed to produce records demonstrating liaison efforts had occurred with fire and police departments for the 2#

320176009_NOPV PCP PCO_09292017_text.pdf, page 3Cities of Williston and Alexander and emergency management and sheriff departments for the Counties of Williams and McKenzie. 3. §195.410 Line markers. (a) Except as provided in paragraph (b) of this section, each operator shall place and maintain line markers over each buried pipeline in accordance with the following: 2) The marker must state at least the following on a background of sharply contrasting color: (ii) The name of the operator and a telephone number (including area code) where the operator can be reached at all times. Statoil failed to maintain line markers over each buried pipeline with the name of the operator and a telephone number where the operator can be reached at all times. There was no answer when the telephone number on a line marker was called during the field inspection. Operator has since corrected. 4. §195.452 Pipeline integrity management in high consequence areas. (b) What program and practices must operators use to manage pipeline integrity? Each operator of a pipeline covered by this section must: (1) Develop a written integrity management program that addresses the risks on each segment of pipeline in the first column of the following table not later than the date in the second column: Pipeline Date Category 1 March 31, 2002 Category 2 February 18, 2003. Category 3 1 year after the date the pipeline begins operation. Statoil failed to develop a written Integrity Management program (IMP) for a pipeline operating in a High Consequence Area (HCA) within 1 year after the pipeline began operations. Although the operator has Category 3 pipelines with HCAs commissioned in 2013, the IMP plan was not implemented until July 2016, three years after the beginning of operations. 3#

320176009_NOPV PCP PCO_09292017_text.pdf, page 45. §195.509 General. (a) Operators must have a written qualification program by April 27, 2001. The program must be available for review by the Administrator or by a state agency participating under 49 U.S.C. Chapter 601 if the program is under the authority of that state agency. Statoil failed to have a written Operator Qualification (OQ) Program in place at the time of beginning of operations in February 2013 thru October 2015. Prior to October 2015, there were employees and contractors performing covered tasks but Statoil did not have an OQ program in place. The OQ program was developed and operational in October 2015. Proposed Civil Penalty Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $209,002 per violation per day the violation persists up to a maximum of $2,090,022 for a related series of violations. The Compliance Officer has reviewed the circumstances and supporting documentation involved in the above probable violations and has recommended that you be preliminarily assessed a civil penalty of $73,700 as follows: Item number PENALTY 1 $16,900 3 $22,400 4 $17,200 5 $17,200 Proposed Compliance Order With respect to item 2 pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration proposes to issue a Compliance Order to Statoil & Gas LP. Please refer to the Proposed Compliance Order, which is enclosed and made a part of this Notice. Response to this Notice 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. All material you submit in response to this enforcement action may be made publicly available. If you believe that any portion of your responsive material qualifies for confidential 4#

320176009_NOPV PCP PCO_09292017_text.pdf, page 5treatment 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. In your correspondence on this matter, please refer to CPF 3-2017-6009 and for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Allan C. Beshore Director, Central Region, OPS Pipeline and Hazardous Materials Safety Administration Enclosures: Proposed Compliance Order Response Options for Pipeline Operators in Enforcement Proceedings 5#

320176009_NOPV PCP PCO_09292017_text.pdf, page 6PROPOSED COMPLIANCE ORDER Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposes to issue to Statoil & Gas LP a Compliance Order incorporating the following remedial requirements to ensure the compliance of Statoil & Gas LP with the pipeline safety regulations: 1. In regard to Item Number 2 of the Notice pertaining to establishing and maintaining liaison with emergency officials, the operator must locate all missing records and sent them to Allan C. Beshore, Director, Central Region, Pipeline and Hazardous Materials Safety Administration. 2. The operator must complete the above item within 90 days after receipt of the Final Order: 3. It is requested (not mandated) that Statoil & Gas LP maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to Allan C. Beshore, Director, Central Region, Pipeline and Hazardous Materials Safety Administration. It is requested that these costs be reported in two categories: 1) total cost associated with preparation/revision of plans, procedures, studies and analyses, and 2) total cost associated with replacements, additions and other changes to pipeline infrastructure. 6#