{"operation":"document","citation":"CPF 520100016W","title":"HILCORP NORTH SLOPE, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-09-21","effective_on":null,"summary":"CLOSED warning letter citing 192.467(d), 192.481, 192.703.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520100016w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520100016w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520100016w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520100016W","body":"Warning Letter involving HILCORP NORTH SLOPE, LLC. PHMSA's enforcement data identifies the cited regulations as 192.467(d),  192.481,  192.703. The case was opened on 2010-09-21 and is reported as closed as of 2010-09-21. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520100016W_warning letter_09212010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520100016W/520100016W_warning%20letter_09212010.pdf\n\n520100016W_warning letter_09212010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520100016W/520100016W_warning%20letter_09212010_text.pdf\n\n520100016W_warning letter_09212010_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED [7007 2560 0000 7825 9471]\nSeptember 21, 2010\nMr. Greg Mattson\nVP, HSSE & Engineering\nBP Exploration (Alaska), Inc.\nP.O. Box 196612\nAnchorage, AK 99519-6612\nCPF 5-2010-0016W\nDear Mr. Mattson:\nOn July 27-29, 2010, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected BP\nExploration Alaska’s (BPXA) Badami Natural Gas Transmission Pipeline in Prudhoe Bay,\nAlaska.\nAs a result of the inspection, it appears that BPXA has committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violations are:\n1. §192.467 External corrosion control: Electrical isolation.\n(d) Inspection and electrical tests must be made to assure that electrical\nisolation is adequate.\nThe 2006-2009 Cathodic Protection Surveys did not check electrical isolation at the insulated\nflanges or all of the cased crossings. The CP survey must address the condition of insulation\nflanges and casings.\nThe probable violation was based on 2006-2009 Cathodic Protection Survey report and\ndiscussion with BPXA personnel.\n\n\n\n2. §192.481 Atmospheric corrosion control: Monitoring.\n(a) Each operator must inspect each pipeline or portion of pipeline that is\nexposed to the atmosphere for evidence of atmospheric corrosion, as follows:\nIf the pipeline is lo-\ncated:\nThen the frequency of inspection is:\nOnshore………….\nOffshore………….\nAt least once every 3 calendar years,\nbut with intervals not exceeding 39\nmonths\nAt least once each calendar year, but\nwith intervals not exceeding 15\nmonths\n(b) During inspections the operator must give particular attention to pipe at\nsoil-to-air interfaces, under thermal insulation, under disbonded coatings, at\npipe supports, in splash zones, at deck penetrations, and in spans over water.\n(c) If atmospheric corrosion is found during an inspection, the operator must\nprovide protection against the corrosion as required by § 192.479.\nExternal pitting corrosion was found on welds at the Little Skookum bridge crossing.\nPipelines need to be surveyed for atmospheric corrosion every year, due to the\nexposure to the ocean, and remediated when corrosion is found.\nThe probable violation is based on photographic evidence taken during the inspection.\n3. §192.703 General.\n(a) No person may operate a segment of pipeline, unless it is maintained in\naccordance with this subpart.\n(b) Each segment of pipeline that becomes unsafe must be replaced, repaired, or\nremoved from service.\nWind-induced vibration dampeners were inspected as PHMSA traveled along the\npipeline. Several were seen with broken lengths, and the damper weights lying on the\ntundra. Badami has had two failures due to wind induced vibration of the gas\npipeline in the past. Badami must repair the pipeline to ensure safe operations.\nThe probable violation is based upon visual inspection by PHMSA and BPXA’s annual Line\nWalk Survey.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of\n$1,000,000 for any related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct\n2\n\n\n\nthe item(s) identified in this letter. Failure to do so will result in BPXA being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2010-0016W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C.\n552(b), along with the complete original document you must provide a second copy of the\ndocument 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).\nSincerely,\nDennis Hinnah\nDeputy Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nB. Flanders (#130728)\n3","truncated":false,"body_characters":5075}