{"operation":"document","citation":"CPF 520105016W","title":"HILCORP NORTH SLOPE, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-08-19","effective_on":null,"summary":"CLOSED warning letter citing 195.208, 195.563(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520105016w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520105016w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520105016w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520105016W","body":"Warning Letter involving HILCORP NORTH SLOPE, LLC. PHMSA's enforcement data identifies the cited regulations as 195.208,  195.563(a). The case was opened on 2010-08-19 and is reported as closed as of 2010-08-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520105016W_warning letter_08192010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105016W/520105016W_warning%20letter_08192010.pdf\n\n520105016W_warning letter_08192010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105016W/520105016W_warning%20letter_08192010_text.pdf\n\n520105016W_warning letter_08192010_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 19, 2010\nGreg Mattson\nVP, HSSE & Engineering\nBP Exploration (Alaska), Inc.\nPO Box 196612\nAnchorage, AK 99519-6612\nCPF 5-2010-5016W\nDear Mr. Mattson:\nOn July 30, 2009, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\nNatural Gas Liquid (NGL) pipeline in 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. § 195.208 Welding of supports and braces.\nSupports or braces may not be welded directly to pipe that will be operated at a\npressure of more than 100 p.s.i. (689 kPa) gage.\nOur inspector observed prohibited welded supports on the NGL Pipeline. BP had welded\nsupports onto the newly constructed meter run piping in Module 4984. When questioned\nabout the pipe supports welded to the piping, the operator indicated that he was planning on\nreplacing the pipe support with non welded ones. On July 14, 2010, BP provided\nphotographs that showed the welded supports replaced with non welded supports.\n\n\n\n2. § 195.563 Which pipelines must have cathodic protection?\n(a) Each buried or submerged pipeline that is constructed, relocated, replaced,\nor otherwise changed after the applicable date in Sec. 195.401(c) must have\ncathodic protection. The cathodic protection must be in operation not later than\n1 year after the pipeline is constructed, relocated, replaced, or otherwise\nchanged, as applicable.\nA portion of the NGL pipeline, which is insulated and designed to be elevated above the\nground, was found partially buried in the soil near the Central Gas Facility. The metal jacket\nand insulation of the NGL pipeline would not protect the pipeline from corrosion where the\npipeline contacts the soil. Moisture could enter the insulation at this location and corrode the\npipe. The pipeline would require cathodic protection if left in contact with soil. On July 29,\n2010, a PHMSA inspector performing a standard inspection of another facility at Prudhoe\nBay examined the portion of pipe which had been in contact with the soil and found that the\npipe had been raised and was resting on wooden cribbing.\nUnder 49 United States Code, § 60122, you are subject to an administrative civil penalty not\nto exceed $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 take\nmeasures to prevent future deficiencies similar to those described above. Failure to do so will\nresult in BP Exploration Alaska being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2010-5016W. 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\n2","truncated":false,"body_characters":4409}