{"operation":"document","citation":"CPF 32024080NOA","title":"BP PIPELINE (NORTH AMERICA) INC. — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-12-23","effective_on":null,"summary":"CLOSED notice of amendment citing 195.452(h)(4)(i)(C).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024080noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024080noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024080noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32024080NOA","body":"Notice of Amendment involving BP PIPELINE (NORTH AMERICA) INC.. PHMSA's enforcement data identifies the cited regulation as 195.452(h)(4)(i)(C). The case was opened on 2024-12-23 and is reported as closed as of 2025-03-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32024080NOA_Closure Letter_03052025_(24-296835).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024080NOA/32024080NOA_Closure%20Letter_03052025_(24-296835).pdf\n\n32024080NOA_Closure Letter_03052025_(24-296835)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024080NOA/32024080NOA_Closure%20Letter_03052025_(24-296835)_text.pdf\n\n32024080NOA_Notice of Amendment_12232024_(24-296835).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024080NOA/32024080NOA_Notice%20of%20Amendment_12232024_(24-296835).pdf\n\n32024080NOA_Notice of Amendment_12232024_(24-296835)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024080NOA/32024080NOA_Notice%20of%20Amendment_12232024_(24-296835)_text.pdf\n\n32024080NOA_Operator Response to Notice_01172025_(24-296835).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024080NOA/32024080NOA_Operator%20Response%20to%20Notice_01172025_(24-296835).pdf\n\n32024080NOA_Closure Letter_03052025_(24-296835)_text.pdf\n\nVIA ELECTRONIC MAIL TO: Chris.Vodicka@bp.com; Jim.Bruen@bp.com;\nJohn.Page@bp.com; Scott.Fitzgerald@bp.com; Lori.knutson@bp.com\nMarch 5, 2025\nChris Vodicka\nVice President\nBP Pipeline (North America) Inc.\n30 S. Wacker Drive\nChicago, IL 60606\nRE: CPF 3-2024-080-NOA\nDear Mr. Vodicka:\nFrom September 23, 2024 through September 27, 2024, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.), inspected the procedures for the hazardous liquid pipeline system of BP\nPipeline (North America) Inc. (BP) in Merrillville, Indiana. On December 23, 2024, pursuant to\n49 CFR § 190.206, PHMSA issued a Notice of Amendment (Notice) in the above-referenced\ncase. The Notice proposed amendment of BP’s procedures.\nBP submitted its amended procedures on January 17, 2025. PHMSA has reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice have been corrected.\nThis letter is to inform you that no further action is necessary, and this case is now closed.\nThank you for your cooperation.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Lori Knutson, Vice President, Lori.knutson@bp.com\nJim Bruen, Senior DOT Compliance Advisor, Jim.Bruen@bp.com\nJohn Page, DOT Compliance Advisor, john.page@bp.com\nScott Fitzgerald, DOT Compliance Advisor, Scott.fitzgerald@bp.com\n\n32024080NOA_Notice of Amendment_12232024_(24-296835)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: Chris.Vodicka@bp.com; Jim.Bruen@bp.com;\nJohn.Page@bp.com; Scott.Fitzgerald@bp.com; Lori.knutson@bp.com\nDecember 23, 2024\nChris Vodicka\nVice President\nBP Pipeline (North America) Inc.\n30 S. Wacker Drive\nChicago, Il, 60606\nCPF 3-2024-080-NOA\nDear Mr. Vodicka:\nFrom September 23, 2024, through September 27, 2024, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.), inspected BP Pipeline (North America) Inc.’s (BP) procedures for its\nhazardous liquid pipeline system in Merrillville, Indiana.\nAs a result of the inspection, PHMSA has identified the apparent inadequacy found within BP’s\nplans or procedures. The item inspected and the inadequacy are described below:\n1. § 195.452 Pipeline integrity management in high consequence areas.\n(a) . . . .\n(h) What actions must an operator take to address integrity issues?\n(1) . . . .\n(4) Special requirements for scheduling remediation —\n(i) Immediate repair conditions. An operator's evaluation and remediation schedule\nmust provide for immediate repair conditions. To maintain safety, an operator must\ntemporarily reduce the operating pressure or shut down the pipeline until the\noperator completes the repair of these conditions. An operator must calculate the\ntemporary reduction in operating pressure using the formulas referenced in\nparagraph (h)(4)(i)(B) of this section. If no suitable remaining strength calculation\nmethod can be identified, an operator must implement a minimum 20 percent or\n\n\n\ngreater operating pressure reduction, based on actual operating pressure for two\nmonths prior to the date of inspection, until the anomaly is repaired. An operator\nmust treat the following conditions as immediate repair conditions:\n(A) . . . .\n(C) A dent located on the top of the pipeline (above the 4 and 8 o'clock positions)\nthat has any indication of metal loss, cracking or a stress riser.\nBP’s written process for scheduling the evaluation and remediation of immediate repair conditions\nin high consequence areas (HCAs) was inadequate to address the requirements of\n§ 195.452(h)(4)(i)(C). Specifically, section 7.2 of BP’s Technical Practice document, USPL-GP\n32-0200, entitled, \"In-Line Inspection (ILI) Data Evaluation and Resulting Repair Program\nProcedures for ILI Repair Projects\" (July 14, 2024), did not adequately describe the criteria for the\nexcavation, inspection and repair of topside dents (above the 4 and 8 o'clock positions) of a\nregulated liquid pipeline that have any indication of metal loss, cracking or a stress riser. Section\n7.2 categorizes anomalous conditions into seven categories where “Category (1) Conditions” are\nintended to identify immediate repair conditions regardless of the location of the condition (HCA\nor Non-HCA). However, the criteria provided for treating a topside dent with an indication of\nmetal loss, cracking, or stress riser as a “Category (1) Condition” is specific to pipeline segments\nthat are either subject to very aggressive cyclic operating conditions or those segments that are not\nsubject to very aggressive cyclic conditions, but whose topside dents are greater than or equal to 1\npercent of nominal diameter. These criteria are inconsistent with the regulatory requirement of\ntreating any topside dent with a metal loss, cracking, or stress riser indication as an immediate\nrepair condition, as required by § 195.452(h)(4)(i)(C). BP’s Technical practice document,\ntherefore, has to be amended to address the requirement for properly classifying a topside dent\nwith a metal loss, cracking, or stress riser indication as an immediate repair condition in HCA in\naccordance with § 195.452(h)(4)(i)(C).\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\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nEnforcement Proceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under\n5 U.S.C. § 552(b), along with the complete original document you must provide a second copy\nof the document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 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\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\n\n\n\nthis Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not\ncontesting this Notice, we propose that you submit your amended procedures to my office within\n45 days of receipt of this Notice. This period may be extended by written request for good cause.\nOnce the inadequacies identified herein have been addressed in your amended procedures, this\nenforcement action will be closed.\nIt is requested (not mandated) that BP maintain documentation of the safety improvement costs\nassociated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures)\nand submit the total to Gregory A. Ochs, Director, Central Region, Pipeline and Hazardous\nMaterials Safety Administration. In correspondence concerning this matter, please refer to\nCPF 3-2024-080-NOA and, for each document you submit, please provide a copy in electronic\nformat whenever possible.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Lori Knutson, Vice President, BP Pipeline (North America) Inc.,\nLori.knutson@bp.com\nJim Bruen, Senior DOT Compliance Advisor, BP Pipeline (North America) Inc.,\nJim.Bruen@bp.com\nJohn Page, DOT Compliance Advisor, BP Pipeline (North America) Inc.,\njohn.page@bp.com\nScott Fitzgerald, DOT Compliance Advisor, BP Pipeline (North America) Inc.,\nScott.fitzgerald@bp.com\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings","truncated":false,"body_characters":9476}