{"operation":"document","citation":"CPF 520156005W","title":"HILCORP NORTH SLOPE, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-11-04","effective_on":null,"summary":"CLOSED warning letter citing 195.452(j)(5)(iv).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520156005w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520156005w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520156005w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520156005W","body":"Warning Letter involving HILCORP NORTH SLOPE, LLC. PHMSA's enforcement data identifies the cited regulation as 195.452(j)(5)(iv). The case was opened on 2015-11-04 and is reported as closed as of 2015-11-04. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520156005W_Warning Letter_11042015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520156005W/520156005W_Warning%20Letter_11042015.pdf\n\n520156005W_Warning Letter_11042015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520156005W/520156005W_Warning%20Letter_11042015_text.pdf\n\n520156005W_Warning Letter_11042015_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 4, 2015\nMr. Michael Barnes\nVice President, BP Alaska\nBP Exploration Alaska, Inc.\n900 East Benson Boulevard\nAnchorage, Alaska 99501\nCPF 5-2015-6005W\nDear Mr. Barnes:\nFrom February 17 - February 25, 2015, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to\nChapter 601 of 49 United States Code, inspected your Natural Gas Liquids (NGL) Pipeline\nlocated in Prudhoe Bay, Alaska.\nAs a result of the inspection, it appears that you have committed probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violation is:\n1) § 195.452 Assessment methods.\n(j)(5)(iv) Other technology that the operator demonstrates can provide an\nequivalent understanding of the condition of the line pipe. An operator choosing\nthis option must notify OPS 90 days before conducting the assessment, by\nsending a notice to the address or facsimile number specified in paragraph (m)\nof this section.\nAs of the inspection, BPXA was using the original “other technology” notification submitted\nto PHMSA for their integrity inspection of the NGL line on the North Slope of Alaska.\n\n\n\nAlthough PHMSA granted the use of “other technology” to BPXA for the original inspection\nof the NGL products line in 2008, BPXA must notify OPS (PHMSA) each time the\ntechnology is going to be used. This notification is required in 195.452(j)(5)(iv) Assessment\nmethods.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the maximum\npenalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a related series of violations. We have reviewed the circumstances\nand supporting 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 items 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 5-2015-6005W in your response. Be advised that all material you submit in response\nto this enforcement 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,\nFor Chris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 R. Guisinger (# 149279)","truncated":false,"body_characters":3787}