{"operation":"document","citation":"CPF 520105010W","title":"HILCORP NORTH SLOPE, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-04-20","effective_on":null,"summary":"CLOSED warning letter citing 195.579(a), 195.583(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520105010w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520105010w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520105010w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520105010W","body":"Warning Letter involving HILCORP NORTH SLOPE, LLC. PHMSA's enforcement data identifies the cited regulations as 195.579(a),  195.583(a). The case was opened on 2010-04-20 and is reported as closed as of 2010-04-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520105010W_operator response_05202010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105010W/520105010W_operator%20response_05202010.pdf\n\n520105010W_warning letter_04202010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105010W/520105010W_warning%20letter_04202010.pdf\n\n520105010W_warning letter_04202010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105010W/520105010W_warning%20letter_04202010_text.pdf\n\n520105010W_warning letter_04202010_text.pdf\n\nWARNING LETTER\nVIA FEDERAL EXPRESS (FEDEX) – 8726 2779 5621\nApril 20, 2010\nMr. Anthony Brock\nVP HSSE & Engineering\nBP Exploration Alaska\nP.O. Box 196612\n900 E. Benson Blvd.\nAnchorage, AK 99501\nCPF 5-2010-5010W\nDear Mr. Brock:\nOn June 22-26, 2009, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected BP\nExploration Alaska, Inc.’s (BPXA) Endicott pipeline at Prudhoe Bay, Alaska.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violations are:\n1. §195.579 What must I do to mitigate internal corrosion?\n(a) General. If you transport any hazardous liquid or carbon dioxide that would\ncorrode the pipeline, you must investigate the corrosive effect of the hazardous\nliquid or carbon dioxide on the pipeline and take adequate steps to mitigate\ninternal corrosion.\n\n\n\nBPXA failed to provide any records, other than ILI data, to show that it investigates the\ncorrosive effects of the hazardous liquid transported in the Endicott pipeline. BPXA is\nrequired by §195.579(a) to investigate the corrosive effects of the hazardous liquid in the\nEndicott pipeline and take steps to mitigate internal corrosion. BPXA failed to provide\nrecords indicating they are mitigating corrosion. The 2005 and 2008 MFL pig runs of the\nEndicott Pipeline identified internal corrosion is occurring, the maximum wall loss reported\nto be about 20%.\n2. §195.583 What must I do to monitor atmospheric corrosion control?\n(a) You must inspect each pipeline or portion of pipeline that is exposed to the\natmosphere for evidence of atmospheric corrosion, as follows:\nIf the pipeline is\nlocated:\nThen the frequency of in-\nspection is:\nOnshore....................... At least once every 3 cal-\nendar years, but with inter-\nvals not exceeding 39\nmonths.\nOffshore....................... At least once each calendar\nyear, but with intervals not\nexceeding 15 months.\n(b) During inspections you must give particular attention to pipe at soil-to-air\ninterfaces, under thermal insulation, under disbonded coatings, at pipe\nsupports, in splash zones, at deck penetrations, and in spans over water.\nBPXA failed to provide records, other than ILI data, to show that they conduct atmospheric\ncorrosion monitoring in accordance with §195.583 (a). During field inspection, PHMSA\npersonnel discovered the following indications of atmospheric corrosion on the Endicott\npipeline.\n1) The 2005 and 2008 MFL pig runs identified external corrosion under insulation. The\nmaximum wall loss reported was 39%.\n2) Cased Road Crossing # 14—Removable fabric insulation jacket appeared to be full of\nwater.\n3) Cased Road Crossing # 09—Water stain on insulation jacket indicated that water may\nhave saturated insulation.\n4) Cased Road Crossing # 03—The casing seal designed to prevent water from entering the\ncasing was torn open.\n5) Vault and Cased Road Crossing #2—At the Badami ice road there is water in the vault to\nthe bottom of the bare pipe, and the insulation jacket stain indicates that water may have\nsaturated the insulation.\n\n\n\n6) Vault and cased road crossing #1—At the Badami pipeline tie-in on the Causeway, there is\nwater in the vault up to the bottom of the pipe.\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\nthe item(s) identified in this letter. Failure to do so will result in Endicott Pipeline being\nsubject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please\nrefer to CPF 5-2010-5010W and provide the information to our office at 188 W. Northern\nLights Blvd. Suite 520, Anchorage, Alaska 99503. Be advised that all material you submit\nin 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\nan explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nSincerely,\nDennis Hinnah\nDeputy Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 B. Flanders (#123920)","truncated":false,"body_characters":5683}