{"operation":"document","citation":"CPF 520105025W","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 195.102(a), 195.575(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520105025w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520105025w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520105025w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520105025W","body":"Warning Letter involving HILCORP NORTH SLOPE, LLC. PHMSA's enforcement data identifies the cited regulations as 195.102(a),  195.575(c). 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\n520105025W_warning letter_09212010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105025W/520105025W_warning%20letter_09212010.pdf\n\n520105025W_warning letter_09212010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105025W/520105025W_warning%20letter_09212010_text.pdf\n\n520105025W_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 5-2010-5025W\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 Sales Oil Pipeline in Prudhoe Bay, Alaska.\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. §195.575 Which facilities must I electrically isolate and what inspections, tests,\nand safeguards are required?\n(c) You must inspect and electrically test each electrical isolation to assure the\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.\nThe probable violation is based on 2006-2009 Cathodic Protection Survey report.\n\n\n\n2. §195.102 Design temperature.\n(a) Material for components of the system must be chosen for the temperature\nenvironment in which the components will be used so that the pipeline will\nmaintain its structural integrity.\nThe operator removed insulation to perform maintenance on electrical heat tracing at the\nBadami pig launcher. Operator’s personnel indicated that the insulation and heat tracing was\nto protect piping and valves that were not suitable for Arctic temperatures.\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 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 5-2010-5025W. 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 (#130730)\n2","truncated":false,"body_characters":3734}