{"operation":"document","citation":"CPF 520045019M","title":"HILCORP NORTH SLOPE, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2005-02-23","effective_on":null,"summary":"CLOSED notice of amendment citing 195.452(f)(1), 195.452(f)(4), 195.452(f)(5), 195.452(f)(6), 195.452(f)(7), 195.452(f)(8).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520045019m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520045019m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520045019m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520045019M","body":"Notice of Amendment involving HILCORP NORTH SLOPE, LLC. PHMSA's enforcement data identifies the cited regulations as 195,  195.452(f)(1),  195.452(f)(4),  195.452(f)(5),  195.452(f)(6),  195.452(f)(7),  195.452(f)(8). The case was opened on 2005-02-23 and is reported as closed as of 2007-04-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520045019M_order directing amendment_04252006.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520045019M/520045019M_order%20directing%20amendment_04252006.pdf\n\nCPF_NO_5_2004_5019M.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520045019M/CPF_NO_5_2004_5019M.pdf\n\n520045019M_order directing amendment_04252006.pdf\n\n7 - , \\t\nU.S. Deporlment\nof Tronsportotlon\nPlp€llne qnd\nHozordous ,Uloierlols\nAdmfnbtroillon\nsot3,1y APR 2 5 2006\n.l0O Se\\r€nlh Stre€t, S.W.\nWashirEh, D.C. 20590\nBy f,'ederaf Express and Telefax: (907-564_4264)\nBernard Looney\nSenior Vice President for Alaska Consolidated Team\nBP Exploration (Alaska) Inc.\nP.O. Box 196612\nAnchorage, AK 99519\nRe: CPF No. 5-2004-5019M\nDear Mr. Looney:\nEnclosed is the Order Directing Amendment issued by the Associate Administrator for\nPipeline Safety in the above-referenced case. It makes a finding ofinadequate procedures\nwith respect to Item la of the Notice of Amendment and requirJs that you amend your\nintegrity management program procedures. For the remaining items listed in the Notice of\nAmendment, the order !_{9 that with respect to the Notice, no fu.th\".. r\".rrisions of your\nprocedures are required. When the terms of the Order are completed, as determined by the\nDirector, Westem Region, OPS, this enforcement action will bi closed. your receipt of the\nOrder Directing Amendment constitutes service of that document under 49 C.F.R. 6 190.5.\nSincerely,\nA r ,\n-+4.\" /L\"--\n\\/\nJames Reynolds\nPipeline Compliance Registry\nOffrce of Pipeline Safety\nEnclosure\n\n\n\nDEPARTMENT OF' TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON. DC 20590\nIn the Matter of\nBP Exploration (Alaska), Inc.,\nRespondent\nCPF No. 5-2004-5019M\nORDER DIRECTING AMENDMENT\nBetween September 24 and25,2003, pursuant to 49 u.S.c. $ 60117, representatives of\nthe Pipeline and Hazardous Materials safety Administration (PHMSA), oflice of\nPipeline Safety (OPS), conducted an inspection of Respondent's Integrity Management\nProgram (IMP) in Anchorage, Alaska. As a result of the inspection, the Director,\nwestern Region, oPS, issued to Respondent, by letter dated February 23,200s, a Notice\nof Amendment QrloA). The NoA alleged inadequacies in IMP and proposed to require\namendment ofRespondent's procedures to ensure safe operation ofRespondent's\npipeline facility.\nRespondent requested a 90 day extension in a letter dated March l, 2005. opS granted\nthe extension in a letter dated March 2l\n, 2005; giving Respondent until June I 9, 2005 to\nrespond. Respondent responded to the NOA by letter dated May 15, 2005. In its\nresponse Respondent did not contest the NOA and did not request a hearing;\nconsequently Respondent waived its right to one. Respondent submitted amended IMP\nprocedures to address the inadequacies cited in the NoA. The Director, westem Region,\nreviewed the revised procedures. Based on the results of that review, I find that\nRespondent's original IMP procedures, as described in the NOA, were inadequate to\nensure safe operation ofits pipeline system, but that Respondent has corrected the\ninadequacies identified in NOA Items lb, lc,|d,2,3,4a,4b,4c, 5a, 5b and 6.\nRespondent need not make any further revisions based on the NOA with respect to these\nitems.\nWith respect to Item la of the NOA, the Director, Westem Region, reviewed the\namended procedures. Respondent amended its procedures by incorporating a report\nentitled \"North Slope Pipeline Discharge to Land Analysis.\" The repon was\nRespondent's justification for exclusion of certain Other Populated Area (OPA) HCAs\n\n\n\nz\nfrom its IMP segment identihcation.l Respondent maintained that DOT's National\nPipeline Mapping System (NPMS) is based on 1990 Census data, instead of data from\n2000.' Respondent therefore continues to identify OPAs based on 1990 Census data. In\nfact, in 2003 OPS updated the population HCAs in irs NPMS to reflecr 2000 Census\ndata.r Regardless, even if OPS had not updated the NPMS, Respondent is responsible for\ngathering information on changes in population density near the pipeline directly from\nCensus Bureau maps.n Respondent's procedures are inadequat\" t\"iuutr they do not\ninclude OPAs that were expanded as a result of 2000 Census revisions.\nAdditionally, Respondent continues to exclude work camp populations along its pipelines\nin its evaluation of potential impacts on populated areas. Respondent presents an\nunconvincing argument that these camps can be excluded because workers there are\ntrained in emergency procedures. These work camps are often located immediately\nadjacent to pipelines or pipeline facilities. In the aggregate, hundreds of workers live,\nsleep and work in or near the camps. Many of these camps are located within Prudhoe\nBay OPAs as well as the expanded Town of Deadhorse OPA. Respondent's practice of\nexcluding these work camp populations is inadequate to ensure worker safety.\nRespondent continues to fail to document why its pipeline segments could not affect the\nvarious OPAs. In the absence of clear evidence that OPAs are not affected, respondent\nmust include all OPAs in its segment identification analysis.\nAccordingly, I find Respondent's integrity management program procedures with respect\nto NOA Item la remain inadequate to ensure safe operation of its pipeline system.\nPursuant to 49 U.S.C. g 60108(a) and 49 C.F.R. $ 190.237, Respondent is ordered to\nmake the following revisions to its integrity management program procedures.\nRespondent must -\nI\nl . Modifu its segment identification process to include work camps and any\nother OPAs on the North Slope or provide, to PHMSA's satisfaction,\ndocumentation justifying the exclusion of these areas if there could be no\neffect on any HCA\n2.\nPerform segment identification based on the most current information\navailable; the 2000 census data.\nJ .\nModify its IMP to include all pipeline segments that are located in any\nHCA or that otherwise could affect any HCA through overland spread,\nwater transport or any other means.\n4.\nSubmit the amended procedures to the Director, Western Region, OPS\nI BP Alaska Integrity Managemenr Manual, Appendix 1-C\n'BP Alaska Integrity Management Manual, Section 1.5.2.2\n'Updates of Digital Mapping Data for Hazardous Liquid Pipeline High Consequence Areas, 68 Fed. Reg.\n3092 (lan.22,2003).\n\" 4e c.F.R. $195.4s2(3xi)\n\n\n\n3\nwithin 30 days following receipt of this Order Directing Amendment.\nWith respect to the submission of amended procedures, the Director may\nnotify respondent ifany or all ofthe procedures have been amended\nsatisfactorily, or if further modification is necessary, require respondent to\nmodify the submission to cure deficiencies. If the Director finds\ndeficiencies and orders further modification, Respondent must proceed to\ntake all action to correct its procedures to comply with the Director's\norder. Respondent must conect all deficiencies within the time specified\nby the Director, and resubmit the procedures for review. If a resubmitted\nitem is disapproved in whole or in part, the Director may again require\nRespondent to correct the deficiencies in accordance with the foregoing\nprocedure, or the Director may otherwise proceed to enforce the terms of\nthis Order.\nThe Director may grant an extension of time to comply with any of the required items\nupon a written request timely submitted by the Respondent demonstrating good cause for\nan extension.\nFailure to comply with this Order may result in the assessment of administrative civil\npenalties ofup to $100,000 per violation per day, or in the referral ofthe case forjudicial\nenforcement.\nThe terms and conditions of this Order Directing Amendment are effective upon receipt.\nAPR 2 5 20{)6\nDate Issued\nSt4cey Gerard i\\\nAssociate Admihi trator for Pipeline Safety","truncated":false,"body_characters":8173}