# HILCORP NORTH SLOPE, LLC — Warning Letter

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

Official case documents:

520156005W_Warning Letter_11042015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520156005W/520156005W_Warning%20Letter_11042015.pdf

520156005W_Warning Letter_11042015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520156005W/520156005W_Warning%20Letter_11042015_text.pdf

520156005W_Warning Letter_11042015_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
November 4, 2015
Mr. Michael Barnes
Vice President, BP Alaska
BP Exploration Alaska, Inc.
900 East Benson Boulevard
Anchorage, Alaska 99501
CPF 5-2015-6005W
Dear Mr. Barnes:
From February 17 - February 25, 2015, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to
Chapter 601 of 49 United States Code, inspected your Natural Gas Liquids (NGL) Pipeline
located in Prudhoe Bay, Alaska.
As a result of the inspection, it appears that you have committed probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and
the probable violation is:
1) § 195.452 Assessment methods.
(j)(5)(iv) Other technology that the operator demonstrates can provide an
equivalent understanding of the condition of the line pipe. An operator choosing
this option must notify OPS 90 days before conducting the assessment, by
sending a notice to the address or facsimile number specified in paragraph (m)
of this section.
As of the inspection, BPXA was using the original “other technology” notification submitted
to PHMSA for their integrity inspection of the NGL line on the North Slope of Alaska.



Although PHMSA granted the use of “other technology” to BPXA for the original inspection
of the NGL products line in 2008, BPXA must notify OPS (PHMSA) each time the
technology is going to be used. This notification is required in 195.452(j)(5)(iv) Assessment
methods.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a
related series of violations. For violations occurring prior to January 4, 2012, the maximum
penalty may not exceed $100,000 per violation per day, with a maximum penalty not to
exceed $1,000,000 for a 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 items 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 5-2015-6005W in your response. 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,
For Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 R. Guisinger (# 149279)
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