{"operation":"document","citation":"CPF 520075021M","title":"HILCORP NORTH SLOPE, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-05-03","effective_on":null,"summary":"CLOSED notice of amendment citing 195.452(c), 195.452(f), 195.452(h), 195.452(i), 195.452(j), 195.452(k).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520075021m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520075021m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520075021m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520075021M","body":"Notice of Amendment involving HILCORP NORTH SLOPE, LLC. PHMSA's enforcement data identifies the cited regulations as 195.452(c),  195.452(f),  195.452(h),  195.452(i),  195.452(j),  195.452(k). The case was opened on 2007-05-03 and is reported as closed as of 2007-11-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520075021M_notice of amendment_05032007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075021M/520075021M_notice%20of%20amendment_05032007.pdf\n\n520075021m_notice of amendment_05032007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075021M/520075021m_notice%20of%20amendment_05032007_text.pdf\n\n520075021M_operator response to notice CONFIDENTIAL MATERIAL REMOVED_10082007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075021M/520075021M_operator%20response%20to%20notice%20CONFIDENTIAL%20MATERIAL%20REMOVED_10082007.pdf\n\n520075021m_notice of amendment_05032007_text.pdf\n\nU. S. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n12300 W Dakota Ave, Suite 110\nLakewood, CO 80228\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nMay 3, 2p07\nMs. Sandy Stash\nUice President\nRegulatory Compliance and Ethics\nBP Exploration (Alaska), Inc.\n900 E. Benson Blvd.\nAnchorage, AK 99508\nSR'\" TO CQMPLIANCE REGISTRY\nHSCOOpg Eectronic I\n0 ef CoyiN, &/Date\nCPF 5-2007-5021M\nDear Ms. Stash:\nOn March 21 and 22, 2007, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected BP\nExploration (Alaska) Inc. (BPXA) procedures for specific areas in your Integrity Management\nProgram in Anchorage, Alaska.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nBPXA's plans or procedures, as described below:\nf452 (f) An operator must include, at minimum, each of the following elements in\nits written integrity management program:\n(1) A process for identifying which pipeline segments could affect a high\nconsequence area.\nThe review of the Badami Fate and Transport Analysis indicated that absorption was\ntaken into account for overland spread. While it has been shown through experience\nthat releases in winter can be partially contained by snow and cold temperatures, the\nassumption that releases in summer can be mitigated by absorption should be justified.\nThe Fate and Transport Analysis used current operating flow rates to calculate release\nvolumes along each pipeline. The BPXA IM Plan should describe the process for\nidentifying changing operating conditions that might impact the FAT analysis and how\nthese changes will trigger new FAT analyses.\n\n\n\n$195. 452 (b) What program and practices must operators use to manage pipeline\nintegrity? Each operator of a pipeline covered by this section must:\n(3) Include in the program a plan to carry out baseline assessments of line pipe as\nrequired by paragraph (c) of this section.\n$195. 452 (c) What must be in the baseline assessment plan? (1) An operator must\ninclude each of the following elements in its written baseline assessment plan:\n(i) The methods selected to assess the integrity of the line pipe. An operator must\nassess the integrity of the line pipe by any of the following methods. The methods\nan operator selects to assess low frequency electric resistance welded pipe or lap\nwelded pipe susceptible to longitudinal seam failure must be capable of assessing\nseam integrity and of detecting corrosion and deformation anomalies.\n(A) Internal inspection tool or tools capable of detecting corrosion and\ndeformation anomalies including dents, gouges and grooves;\n(B) Pressure test conducted in accordance with subpart E of this part; or\n(C) Other technology that the operator demonstrates can provide an equivalent\nunderstanding of the condition of the line pipe. An operator choosing this option\nmust notify the Office of Pipeline Safety (OPS) 90 days before conducting the\nassessment, by sending a notice to the address or facsimile number specified in\nparagraph (m) of this section . . . ( iii) An explanation of the assessment methods\nselected and evaluation of risk factors considered in establishing the assessment\nschedule.\nThe dent excavation spreadsheet reviewed during the inspection did not contain the\nrecent ILI information for the EOA 34 inch pipeline. The results of this assessment\nshould have been included in the spreadsheet for completeness.\nAn updated sheet was provided at the end of the inspection. This provided information\non a future ILI inspection to be performed 7I2007 on the EOA FS 2 to FS 1 section.\nThis section has been taken out of service and will be replaced by a new pipeline. The\nupdate did not include the results of dent investigation for the EOA 34 inch FS I to\nSkid 50 ILI run performed in October, 2006. A process for creating and populating\nyour spreadsheets should include a completeness check or explanation for missing\ninformation.\nf452 (f) An operator must include, at minimum, each of the following elements in\nits written integrity management program: (S) A process for review of integrity\nassessment results and information analysis by a person qualified to evaluate the\nresults and information (see paragraph (h)(2) of this section)\nf452 (h) (2) Discovery of a condition. Discovery of a condition occurs when an\noperator has adequate information about the condition to determine that the\ncondition presents a potential threat to the integrity of the pipeline. An operator\nmust promptly, but no later than 1SO days after an integrity assessment, obtain\nsufficient information about a condition to make that determination, unless the\noperator can demonstrate that the 180-day period is impracticable.\n\n\n\nThe BPXA IM Plan states that indications &40% wall loss will be evaluated. These\nindications are not listed as \"other\" repair conditions in Protocol 4. 01 or in BPNA's\nprocedure 200. BPXA should define the criteria that will be used to determine if any\nwall loss indications &40% must be repaired. This criteria needs to be incorporated\ninto all applicable repair procedures.\nThe relationship of existing repair procedure 00090 and its proposed replacement-\nBPNA procedure 200 - to the Tier 2 OMER repair procedure is not clear. The Tier 2\nOMER procedure does not contain all of the IM rule repair requirements for corrosion.\nIn addition, it appears that procedure 00090 Sections 6. 2 and 6. 3 allow clamp on\nsleeves to be used to repair leaks due to corrosion whereas the Tier 2 OMER procedure\ndoes not. BPXA needs to ensure that all repair procedures accurately and completely\naddress IM repair criteria and allowable repair methods. All regulatory requirements\nshould be included on the final process.\n4. $195. 452 (f} What are the elements of an integrity management program? (6)\nIdentification of preventive and mitigative measures to protect the high\nconsequence area (see paragraph of this section)\n$195. 452(i) What preventive and mitigative measures must an operator take to\nprotect the high consequence area?(1) General requirements. An operator must\ntake measures to prevent and mitigate the consequences of a pipeline failure that\ncould affect a high consequence area. These measures include conducting a risk\nanalysis of the pipeline segment to identify additional actions to enhance public\nsafety or environmental protection. Such actions may include, but are not limited\nto, implementing damage prevention best practices, better monitoring of cathodic\nprotection where corrosion is a concern, establishing shorter inspection intervals,\ninstalling EFRDs on the pipeline segment, modifying the systems that monitor\npressure and detect leaks, providing additional training to personnel on response\nprocedures, conducting drills with local emergency responders and adopting\nother management controls.\nThe BPXA IM Plan must address how their proposed improvements to Leak Detection\naddresses the eight required evaluation factors of 195. 452(i)(3). The IM Plan should\nalso address how and when future evaluations of the Leak Detection systems will be\nperformed.\n5. $195. 452 What preventive and mitigative measures must an operator take to protect\nthe high consequence area? (3) Leak detection. An operator must have a means to\ndetect leaks on its pipeline system. An operator must evaluate the capability of its\nleak detection means and modify, as necessary, to protect the high consequence\narea. An operator's evaluation must, at least, consider the following factors-\nlength and size of the pipeline, type of product carried, the pipeline's proximity to\nhigh consequence area, the swiftness of leak detection, location of nearest response\npersonnel, leak history, and risk assessment results.\n\n\n\nThe BPXA IM Plan must address how their proposed improvements to Leak Detection\naddresses the eight required evaluation factors of 195. 452(i)(3). The IM Plan should\nalso address how and when future evaluations of the Leak Detection systems will be\nperformed.\nSection 6. 04 of the IM Plan should fully describe current leak detection systems or\nreference a document where these descriptions are provided.\n$195. 452 (f) An operator must include, at minimum, each of the following\nelements in its written integrity management program: (5) A continual process of\nassessment and evaluation to maintain a pipeline's integrity (see paragraph (j) of\nthis section);\n$195. 452 (g) Whatis an information analysis? In periodically evaluating the\nintegrity of each pipeline segment an operator must analyze all available\ninformation about the integrity of the entire pipeline and the consequences of a\nfailure\n$195. 452 (j) What is a continaal process of evaluation and assessment to maintain a\npipeline's integrity? (1) General. After completing the baseline integrity\nassessment, an operator must continue to assess the line pipe at specified intervals\nand periodically evaluate the integrity of each pipeline segment that could affect a\nhigh consequence area.\n(3) Assessment Intervals. An operator must establish intervals not to exceed five\n(5) years for continually assessing the line pipe's integrity. An operator must base\nthe assessment intervals on the risk the line pipe poses to the high consequence\narea to determine the priority for assessing the pipeline segments. An operator\nmust establish the assessment intervals based on the factors specified in\nparagraph (e) of this section, the analysis of the results from the last integrity\nassessment, and the information analysis required by paragraph (g) of this\nsection.\nPeriodic evaluation is considered to be an ongoing data integration process that takes\ninto account changing conditions on a pipeline that may warrant a change in\nreassessment schedules. The IM Plan states in Section 7. 01/7. 02 \"If assessment results\nor other factors warrant, higher risk areas may require more frequent evaluation\". The\nIM Plan needs to provide more detail as to when evaluations will be performed, by\nwhom, which risk factors will be evaluated, and how re-assessment intervals will be\nchanged,\n$195. 452 (f) An operator must include, at minimum, each of the following\nelements in its written integrity management program:\n(7) Methods to measure the program's effectiveness (see paragraph (k) of this\nsection);\n$195. 452 (k) What methods to measare program effectiveness must be used? An\noperator's program must include methods to measure whether the program is\neffective in assessing and evaluating the integrity of each pipeline segment and in\nprotecting the high consequence areas. See Appendix C of this part for guidance\non methods that can be used to evaluate a program's effectiveness.\n\n\n\nPHMSA recognizes that the BPXA IM program is in a state of transition and that\nBPXA has chosen to focus on Key Performance Indicators that measure\nimplementation process. However, BPXA needs to emphasize development of Key\nPerformance Indicators (KPIs) that measure the effectiveness of the IM program.\nBPXA should use the characteristics of an effective program provided in Protocol 8. 02\nand the performance metrics identified in API 1160 to develop these KPIs.\nRes onse to this Notice\nThis Notice is provided pursuant to 49 U. S. C. $ 60108(a) and 49 C. F. R. $ 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\ninformation qualifies for confidential treatment under 5 U. S. C. 552(b). If you do not respond\nwithin 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the\nallegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to\nfind facts as alleged 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 30 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 5-2007-5021M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSince\nis Hoi al\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 B. Hansen","truncated":false,"body_characters":14279}