# HILCORP NORTH SLOPE, LLC — Warning Letter

- **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:** Not available
- **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.

Official case documents:

520105025W_warning letter_09212010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105025W/520105025W_warning%20letter_09212010.pdf

520105025W_warning letter_09212010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105025W/520105025W_warning%20letter_09212010_text.pdf

520105025W_warning letter_09212010_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED [7007 2560 0000 7825 9471]
September 21, 2010
Mr. Greg Mattson
VP, HSSE & Engineering
BP Exploration (Alaska), Inc.
P.O. Box 196612
Anchorage, AK 99519-6612
CPF 5-2010-5025W
Dear Mr. Mattson:
On July 27-29, 2010, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected BP
Exploration Alaska’s (BPXA) Badami Sales Oil Pipeline in Prudhoe Bay, Alaska.
As a result of the inspection, it appears that BPXA has committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and
the probable violations are:
1. §195.575 Which facilities must I electrically isolate and what inspections, tests,
and safeguards are required?
(c) You must inspect and electrically test each electrical isolation to assure the
isolation is adequate.
The 2006-2009 Cathodic Protection Surveys did not check electrical isolation at the insulated
flanges or all of the cased crossings. The CP survey must address the condition of insulation
flanges.
The probable violation is based on 2006-2009 Cathodic Protection Survey report.



2. §195.102 Design temperature.
(a) Material for components of the system must be chosen for the temperature
environment in which the components will be used so that the pipeline will
maintain its structural integrity.
The operator removed insulation to perform maintenance on electrical heat tracing at the
Badami pig launcher. Operator’s personnel indicated that the insulation and heat tracing was
to protect piping and valves that were not suitable for Arctic temperatures.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
$100,000 for each violation for each day the violation persists up to a maximum of
$1,000,000 for any related series of violations. We have reviewed the circumstances and
supporting documents involved in this case, and have decided not to conduct additional
enforcement action or penalty assessment proceedings at this time. We advise you to correct
the item identified in this letter. Failure to do so will result in BPXA being subject to
additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer
to CPF 5-2010-5025W. Be advised that all material you submit in response to this
enforcement action is subject to being made publicly available. If you believe that any
portion of your responsive material qualifies 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 believe qualify for confidential treatment redacted and an
explanation of why you believe the redacted information qualifies for confidential treatment
under 5 U.S.C. 552(b).
Sincerely,
Dennis Hinnah
Deputy Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
B. Flanders (#130730)
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