400 Seventh Street, S.W. 
U.S. 
Department Washington, D.C. 20590 
of Transportation 
Pipeline and 
Hazardous Materials Safety APR 2 5 2006 Administration 
By Federal Express and Telefax: (907-564-4264) 
Bernard Looney 
Senior Vice President for Alaska Consolidated Team 
BP Exploration (Alaska) Inc. 
P.O. 
Box 196612 
Anchorage, AK 995 19 
Re: CPF No. 5-2004-5019M 
Dear Mr. Looney: 
Enclosed is the Order Directing Amendment issued by the Associate Administrator for 
Pipeline Safety in the above-referenced case. It makes a finding of inadequate procedures 
with respect to Item l a of the Notice of Amendment and requires that you amend your 
integrity management program procedures. For the remaining items listed in the Notice of 
Amendment, the Order finds that with respect to the Notice, no further. revisions of your 
procedures are required. When the terms of the Order are completed, as determined by the 
Director, Western Region, OPS, this enforcement action will be closed. Your receipt of the 
Order Directing Amendment constitutes service of that document under 49 C.F.R. tj 190.5. 
Sincerely, 
James Reynolds 
Pipeline Compliance Registry 
Office of Pipeline Safety 
Enclosure 

DEPARTMENT OF TRANSPORTATION 
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION 
OFFICE OF PIPELINE SAFETY 
WASHINGTON, DC 20590 
1 
In the Matter of 
BP Exploration (Alaska), Inc., ) CPF No. 5-2004-5019M 
Respondent 1 
) 
ORDER DIRECTING AMENDMENT 
Between September 24 and 25,2003, pursuant to 49 U.S.C. 5 601 17, representatives of 
the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of 
Pipeline Safety (OPS), conducted an inspection of Respondent's Integrity Management 
Program (IMP) in Anchorage, Alaska. As a result of the inspection, the Director, 
Western Region, OPS, issued to Respondent, by letter dated February 23, 2005, a Notice 
of Amendment (NOA). The NOA alleged inadequacies in IMP and proposed to require 
amendment of Respondent's procedures to ensure safe operation of Respondent's 
pipeline facility. 
Respondent requested a 90 day extension in a letter dated March 1,2005. OPS granted 
the extension in a letter dated March 21,2005; giving Respondent until June 19,2005 to 
respond. Respondent responded to the NOA by letter dated May 15,2005. In its 
response Respondent did not contest the NOA and did not request a hearing; 
consequently Respondent waived its right to one. Respondent submitted amended IMP 
procedures to address the inadequacies cited in the NOA. The Director, Western Region, 
reviewed the revised procedures. Based on the results of that review, I find that 
Respondent's original IMP procedures, as described in the NOA, were inadequate to 
ensure safe operation of its pipeline system, but that Respondent has corrected the 
inadequacies identified in NOA Items 1 b, lc, Id, 2, 3, 4a, 4b, 4c, 5a, 5b and 6. 
Respondent need not make any further revisions based on the NOA with respect to these 
items. 
With respect to Item 1 a of the NOA, the Director, Western Region, reviewed the 
amended procedures. Respondent amended its procedures by incorporating a report 
entitled "North Slope Pipeline Discharge to Land Analysis." The report was 
Respondent's justification for exclusion of certain Other Populated Area (OPA) HCAs 

from its IMP segment identification.' Respondent maintained that DOT'S National 
Pipeline Mapping System (NPMS) is based on 1990 Census data, instead of data from 
2000.~ Respondent therefore continues to identify OPAs based on 1990 Census data. In 
fact, in 2003 OPS updated the population HCAs in its NPMS to reflect 2000 Census 
data.3 Regardless, even if OPS had not updated the NPMS, Respondent is responsible for 
gathering information on changes in population density near the pipeline directly from 
Census Bureau maps.4 Respondent's procedures are inadequate because they do not 
include OPAs that were expanded as a result of 2000 Census revisions. 
Additionally, Respondent continues to exclude work camp populations along its pipelines 
in its evaluation of potential impacts on populated areas. Respondent presents an 
unconvincing argument that these camps can be excluded because workers there are 
trained in emergency procedures. These work camps are often located immediately 
adjacent to pipelines or pipeline facilities. In the aggregate, hundreds of workers live, 
sleep and work in or near the camps. Many of these camps are located within Prudhoe 
Bay OPAs as well as the expanded Town of Deadhorse OPA. Respondent's practice of 
excluding these work camp populations is inadequate to ensure worker safety. 
Respondent continues to fail to document why its pipeline segments could not affect the 
various OPAs. In the absence of clear evidence that OPAs are not affected, respondent 
must include all OPAs in its segment identification analysis. 
Accordingly, I find Respondent's integrity management program procedures with respect 
to NOA Item 1 a remain inadequate to ensure safe operation of its pipeline system. 
Pursuant to 49 U.S.C. 5 60 108(a) and 49 C.F.R. 5 190.237, Respondent is ordered to 
make the following revisions to its integrity management program procedures. 
Respondent must - 
1. 
Modify its segment identification process to include work camps and any 
other OPAs on the North Slope or provide, to PHMSA7s satisfaction, 
documentation justifying the exclusion of these areas if there could be no 
effect on any HCA 
2. 
Perform segment identification based on the most current information 
available; the 2000 census data. 
3. 
Modify its IMP to include all pipeline segments that are located in any 
HCA or that otherwise could affect any HCA through overland spread, 
water transport or any other means. 
4. 
Submit the amended procedures to the Director, Western Region, OPS 
BP Alaska Integrity Management Manual, Appendix 1-C 
BP Alaska Integrity Management Manual, Section 1 S.2.2 
Updates of Digital Mapping Data for Hazardous Liquid Pipeline High Consequence Areas, 68 Fed. Reg. 
3092 (Jan. 22, 2003). 
49 C.F.R. Ħħ195.452(3)(i) 

within 30 days following receipt of this Order Directing Amendment. 
With respect to the submission of amended procedures, the Director may 
notify respondent if any or all of the procedures have been amended 
satisfactorily, or if further modification is necessary, require respondent to 
modify the submission to cure deficiencies. If the Director finds 
deficiencies and orders further modification, Respondent must proceed to 
take all action to correct its procedures to comply with the Director's 
order. Respondent must correct all deficiencies within the time specified 
by the Director, and resubmit the procedures for review. If a resubmitted 
item is disapproved in whole or in part, the Director may again require 
Respondent to correct the deficiencies in accordance with the foregoing 
procedure, or the Director may otherwise proceed to enforce the terms of 
this Order. 
The Director may grant an extension of time to comply with any of the required items 
upon a written request timely submitted by the Respondent demonstrating good cause for 
an extension. 
Failure to comply with this Order may result in the assessment of administrative civil 
penalties of up to $100,000per violation per day, or in the referral of the case for judicial 
enforcement. 
The terms and conditions of this Order Directing Amendment are effective upon receipt. 
APR 2 5 2oiih 
Date Issued 
Associate Adrnib$tr&r for Pipeline Safety