OLIKTOK PIPELINE COMPANY — Notice of Amendment

party submissionOfficial PDF520085029M_operator_response_12092008.pdf#

520085029m_notice of amendment_09102008_text.pdf, page 1Official PDFU S. Department of Tf'GnspoftGtlon Pmpelllne and Hazardous Matertalls Safety Admrnrstratiort 12300 W Dakota Ave, Suite 110 Lakewood, CO 80228 NOTICE OF AMKNDMKNT September 10, 2008 Mr. Erec Isaacson President Conoco Phillips Alaska, Inc. P. O Box 100360 Anchorage, AIZ 99510 CPF 5-2008-5029M Dear Mr. Isaacson: On July 14-17, 2008, a representative of the Pipehne and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Oliktok Pipehne Company's procedures for Operation and Mamtenance in the Kuparuk field office located in Prudhoe Bay, Alaska. On the basis of the inspection, PHMSA identified the apparent inadequacies found within Ohktok Pipehne Company's procedures, as described below: $195. 402 Procedural manual for operations, maintenance, and emergencies. (c) Maintenance and normal operations. (10) Abandoning pipeline facilities, including safe disconnection from an operating pipeline system, purging of combustibles, and seaHng abandoned facilities left in place to minimize safety and environmental hazards. For each abandoned offshore pipeHne faciHty or each abandoned onshore pipeHne facility that crosses over, under or through commercially navigable waterways the last operator of that facihty must file a report upon abandonment of that facihty in accordance with $195. 59 of this part.#

520085029m_notice of amendment_09102008_text.pdf, page 2The operator's Standard Operatmg Procedures (SOP) OPLM-0000-SD-0062, Page 1, does not require purgmg of permanently abandoned pipe hnes. The operator's SOP did not include detailed procedures for starting the pipe hne up after purging. The procedures did not address the filling, packing, and return to normal operations of a previously-purged line. This abnormal operation of repacking the hne is a foreseeable operation. The operator's SOP OPLM-0000-SD-0043, page 16, references API 1107 for conducting "in-service" repairs. API 1107 is now incorporated in API 1104, Appendix B The SOP should reflect the most current repair standards Res onse to this Notice This Notice is provided pursuant to 49 U S C. ) 60108(a) and 49 C. F. R. ) 190 237. 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. Be advised that all material you submit in response to this enforcement action is subject to being made pubhcly available. If you believe that any portion of your responsive material quahfies for confidential treatment 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 beheve qualify for confidential treatment redacted and an explanation of why you beheve 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#

520085029m_notice of amendment_09102008_text.pdf, page 3If, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C. FR ( 190. 237). If you are not contesting this Notice, wepropose that you submit your amended procedures to my office within [number of days] days of receipt of this Notice This period may be extended by written request for good cause Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed In correspondence concerning this matter, please refer to CPF 5-2008-5029M and, for each document you submit, please provide a copy in electronic format whenever possible Sincerely, ChrikHoidal Director, Western Region Pipehne and Hazardous Materials Safety Administration cc PHP-60 Compliance Registry PHP-500 B. Flanders (4120668) Enclosure: Response Options for Pipeline Operators in Compliance Proceedings#