{"operation":"document","citation":"CPF 520196011W","title":"HILCORP NORTH SLOPE, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-12-27","effective_on":null,"summary":"CLOSED warning letter citing 194.111(a), 195.208.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520196011w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520196011w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520196011w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520196011W","body":"Warning Letter involving HILCORP NORTH SLOPE, LLC. PHMSA's enforcement data identifies the cited regulations as 194.111(a),  195.208. The case was opened on 2019-12-27 and is reported as closed as of 2019-12-27. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520196011W_Operator Response to Notice_01272020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520196011W/520196011W_Operator%20Response%20to%20Notice_01272020.pdf\n\n520196011W_Warning Letter_12272019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520196011W/520196011W_Warning%20Letter_12272019.pdf\n\n520196011W_Warning Letter_12272019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520196011W/520196011W_Warning%20Letter_12272019_text.pdf\n\n520196011W_Warning Letter_12272019_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 27, 2019\nMr. Donnie W. Brown\nVP Operations\nBP Pipelines (Alaska), Inc.\nPO Box 196612\n900 East Benson Boulevard\nAnchorage, AK 99519\nCPF 5-2019-6011W\nDear Mr. Brown:\nOn February 25 through 26, 2019 and July 18, 2019, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code\n(U.S.C.), inspected your Oil Transit Lines-North Slope, Lisburne Pipeline, and Greater Prudhoe Bay\n(NGL) units in Prudhoe Bay, Alaska.\nAs a result of the inspection, it is alleged that you have committed probable violations of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected and the\nprobable violations are:\n1. § 194.111 Response plan retention.\n(a) Each operator shall maintain relevant portions of its response plan at the operator's\nheadquarters and at other locations from which response activities may be conducted,\nfor example, in field offices, supervisors' vehicles, or spill response trailers.\nOn February 26, 2019, the control room operator at Gathering Center 1 was asked to produce a copy\nof the oil spill response plan along with a list of qualified individuals.\nA copy of the oil spill response plan along with a list of qualified individuals was never produced. The\ncontrol room operator stated that her responsibility was to contact the Environmental Coordinator in\nthe event of an oil spill.\n2. § 195.208 Welding of supports and braces.\nSupports or braces may not be welded directly to pipe that will be operated at a pressure\nof more than 100 p.s.i. (689 kPa) gage.\n\n\n\nSupports were welded directly to the Lisburne Pipeline.\nThere were six instances on the Lisburne pipeline where supports or braces have been welded directly\nto pipe which was operated at pressures greater than 100 p.s.i. gage. Two of these welds were located\non piping within Module 4920, two of these welds were located on piping immediately outside of\nModule 4920, and two of these welds were located on piping within Module 4921. The Maximum\nOperating Pressure (MOP) of this system was 950 p.s.i. gage.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related\nseries of violations. For violation occurring on or after November 27, 2018 and before July 31, 2019,\nthe maximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to\nexceed $2,132,679. For violation occurring on or after November 2, 2015 and before November 27,\n2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum penalty\nnot to exceed $2,090,022. 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 $2,000,000 for\na related series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the items identified in this letter.\nFailure to do so will result in BP Pipelines (Alaska), being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF\n5-2019-6011W. Be advised that all material you submit in response to this enforcement action is\nsubject to being made publicly available. If you believe that any portion of your responsive material\nqualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for confidential\ntreatment redacted and an explanation of why you believe the redacted information qualifies for\nconfidential treatment under 5 U.S.C. 552(b).\nSincerely,\nDustin B. Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 M. Chard (# 164510)\nMs. Storm Herring, Operation Specialist, BPXA, via email\n2","truncated":false,"body_characters":5048}