U.S. 
Department 400 Seventh Street, S.W. 
of Transportation' Washington, D.C. 20590 
Pipeline and APR 2 5 2006 
Hazardous Materials Safety 
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. 5-2002-5024M 
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 and 
requires that you amend your integrity management program procedures. 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. Ħħ 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 
In the Matter of 
) 
) 
1 
BP Exploration (Alaska) Inc., ) CPF NO. 5-2002-5024M 
Respondent 
1 
1 
ORDER DIRECTING AMENDMENT 
On April 10 and 11,2002, pursuant to 49 U.S.C. $601 17, representatives of the 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 June 24,2002, a Notice of 
Amendment (NOA). The NOA alleged inadequacies in Respondent's IMP and proposed 
to require amendment of Respondent's procedures to ensure safe operation of 
Respondent's pipeline facility. 
In a letter dated July 19,2002, Respondent replied to the NOA by requesting a 120 day 
extension and indicating its intent to implement OPS's recommendations. OPS granted 
the extension. Respondent submitted its amended procedures by letter dated October 3 1, 
2002. 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, and, in its response, explained the changes it 
had made. The Director, Western Region, reviewed the amended 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. 
With respect to Item 1 a of the NOA, Respondent amended its procedures to consider a 
broader range of leak sizes and pipeline characteristics in ca!cu!zting buffer zones 
stream transport. These procedures are necessary for proper identification of pipeline 
segments that may affect any and all types of HCAs. Respondent provided its Oil 
Discharge Prevention and Contingency Plan (ODPCP) as the basis for the water transport 

analysis portion of its segment identification program. The ODPCP does not consider 
impacts to HCAs in its assessment of potential releases to water. The regulations set 
forth at 49 C.F.R. 195.452(b)(2) require the inclusion of any pipeline segment that could 
affect a HCA. Since the ODPCP does not address HCAs, Respondent's water transport 
analysis remains insufficient. 
Regarding Item 1 b, several of Respondent's pipelines directly intersect Drinking Water 
HCAs as defined by the National Pipeline Mapping System (NPMS). Respondent's 
current IMP segment identification process excludes impacts on certain Drinking Water 
HCAs. Respondent argues that alternate drinking water sources are available for each 
potential Drinking Water HCA. Respondent contends, therefore, that these areas do not 
meet the regulatory definition of HCAs. In reaching the conclusion that the areas in 
question are not HCAs, Respondent has failed to perform an adequate water transport 
analysis. 
A proper water transport analysis is a required component of a comprehensive segment 
identification program. Mere identification of alternate drinking water resources, without 
a determination of how they could be affected by water transport or other direct or 
indirect processes, in the event of a spill, is insufficient. Respondent's failure to include 
these segments, or justify their exclusion based on a well documented finding of no 
possible impact, is inconsistent with the requirements of the regulations. 
With respect to Item 1 c, Respondent cofitinues to exclude some direct pipeline 
intersections with North Slope Ecological HCAs because it finds that impacts on the 
spectacled eider population andlor habitat would be minimal. Section 195.452(a) 
specifically requires IMP planning for any pipeline segment that could affect an HCA; 
regardless of the magnitude of the potential impact. Respondent's Spectacled Eider study 
confirms the possibility of impact. Therefore, Respondent cannot exclude pipeline 
segments on this basis. 
In general, Respondent's risk assessment concludes that the only portion of its North 
Slope pipeline system that can affect HCA is the offshore portion of the Northstar 
pipeline. Again, Section 195.452(a) requires that IMP planning must include all pipeline 
segments that could affect any HCA. Respondent must carefully revisit its IMP and 
include any pipeline segment where there is any possibility of impact to an HCA. 
Accordingly, based on the results of this review, I find that Respondent's IMP procedures 
remain inadequate to ensure safe operation of its pipeline system. Pursuant to 49 U.S.C. $ 
60108(a) and 49 C.F.R. 4 190.237, Respondent is ordered to make the following 
revisions to its integrity management program procedures. Respondent must - 
1. 
Modify its IMP segment identification process to include all pipeline 
segments on the North Slope that are located in any HCA or that otherwise 
could affect any HCA. Only by demonstration, through risk assessment, 
that a pipeline segment could not affect an HCA, can such an area be 
excluded from Respondent's IMP. 

2. 
Perform segment identification utilizing the most current available 
information, including but not limited to the 2000 census data. 
3. 
Modify the water transport analysis portion of its segment identification 
process to include any impacts to any HCAs; taking into consideration the 
variety of seasonal conditions that exist on the North Slope. In particular, 
water transport analysis must consider the differing conditions posed by 
heavy spring flooding, winter ice, and summer environments. 
4. 
Submit the amended procedures to the Director, Western Region, OPS 
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 $1 00,000 per 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. 
Date Issued 
~ssociateMdnistrator for Pipeline Safety