{"operation":"document","citation":"CPF 520180002W","title":"OLIKTOK PIPELINE COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-01-17","effective_on":null,"summary":"CLOSED warning letter citing 192.195(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520180002w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520180002w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520180002w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520180002W","body":"Warning Letter involving OLIKTOK PIPELINE COMPANY. PHMSA's enforcement data identifies the cited regulation as 192.195(a). The case was opened on 2018-01-17 and is reported as closed as of 2018-01-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520180002W_Warning Letter_01172018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520180002W/520180002W_Warning%20Letter_01172018.pdf\n\n520180002W_Warning Letter_01172018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520180002W/520180002W_Warning%20Letter_01172018_text.pdf\n\n520180002W_Warning Letter_01172018_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 17, 2018\nMr. Ryan Lance\nChairman and Chief Executive Officer\nConocoPhillips\n600 North Dairy Ashford Road\nP.O. Box 2197\nHouston, Texas 77252-2197\nCPF 5-2018-0002W\nDear Mr. Lance:\nOn February 17 through 26, 2015 and March 16 through 18, 2015, a representative of the Pipeline\nand Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.), inspected your Oliktok Gas Pipeline (OPL) facilities, records, and\nprocedures in Anchorage, Prudhoe Bay, and Kuparuk, Alaska.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violation is:\n1. §192.195 Protection against accidental overpressuring.\n(a) General requirements. Except as provided in §192.197, each pipeline that is\nconnected to a gas source so that the maximum allowable operating pressure could\nbe exceeded as the result of pressure control failure or of some other type of failure,\nmust have pressure relieving or pressure limiting devices that meet the requirements\nof §§192.199 and 192.201.\n\n\n\nOn September 13, 2017, Oliktok Pipeline Company, a wholly owned subsidiary of\nConocoPhillips, was issued a Notice of Probable Violation and Proposed Compliance Order\n(NOPV/PCO) letter for the case number referenced above. The Notice alleged that Oliktok\nPipeline Company (OPC) violated 49 C.F.R. § 192.195 by failing to provide adequate protection\nagainst overpressure on the Oliktok Gas Pipeline (OPL). The Notice proposed to require OPC to\nmake certain modifications to protect the OPL from unsafe operating pressures. Specifically, the\nNotice alleged that a remotely operated valve, ROV 9000, is located at the upstream end of the\nOPL. The valve was designed to “fail in place”, that is fail in its last position. In the event of a\npower loss to the valve’s actuator, the valve “fails in place” and becomes unable and incapable of\nresponding to an overpressure situation.\nConocoPhillips responded to the NOPV/PCO in a letter dated October 11, 2017, offering\ninformation concerning modifications it had made to ROV 9000 and requesting that the\nNOPV/PCO be reduced to a warning. ConocoPhillips has provided PHMSA with documentation\nthat a failsafe design has been implemented. PHMSA is satisfied that ConocoPhillips has\naddressed the probable violation alleged in the Notice.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$209,002 per violation per day the violation persists, up to a maximum of $2,090,022 for a related\nseries of violations. For violations occurring prior to November 2, 2015, the maximum penalty\nmay not exceed $200,000 per violation per day, with a maximum penalty not to exceed\n$2,000,000 for a related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement action\nor penalty assessment proceedings at this time.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2018-0002W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nKim West\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 H. Marlowe (#148605)\nMr. Scott Jepsen, President, Oliktok Pipeline Co.","truncated":false,"body_characters":4631}