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Home My WebLink AboutO 1641. July 24, 2019 2. August 12, 2019 3. August 13, 2019 4. ---------------- 5. November 1, 2019 6. November 26, 2019 Other Order 164 Enforcement action Missing Meter Performance Reports BPXA response and request for informal review AOGCC scheduling of informal review CONFIDENTIAL information held in secure storage BPXA response to order BPXA wire payment letter ORDERS STATE OF ALASKA ALASKA OIL AND GAS CONSERVATION COMMISSION 333 West Seventh Avenue Anchorage Alaska 99501 Re: Missing Meter Performance Reports ) Other Order 164 Custody Transfer Meters ) Docket Number: OTH-19-024 Prudhoe Bay Unit ) Natural Gas Liquids Sales ) October 30, 2019 DECISION AND ORDER On July 24, 2019 the Alaska Oil and Gas Conservation Commission (AOGCC) issued a Notice of Proposed Enforcement Action (Notice) to BP Exploration (Alaska), Inc. (BPXA) regarding Prudhoe Bay Unit natural gas liquids (NGL) custody transfer meters based on BPXA's failure to submit required meter performance reports. The Notice proposed specific corrective actions and a $30,000 civil penalty under AS 31.05.150(a). BPXA requested an informal review. That review was held August 20, 2019. Summary of Proposed Enforcement Action: The Notice identified violations by BPXA of the conditional approval letter dated August 30, 2018 for the NGL sales to ConocoPhillips Alaska Inc.'s Kuparuk River Unit. The Notice proposed a civil penalties totaling $30,000 as follows: - $15,000 for the initial violation — failure to provide meter performance report as specified in condition of approval 3; and - $15,000 for the initial violation — failure to provide required notification for AOGCC witness as specified in condition of approval 6. The Notice also proposed that BPXA submit the required information and describe how it will prevent recurrence of this violation. Violation - Failure to Submit Required Custody Transfer Meter Performance Reports: The custody transfer measurement equipment used for the sale of Prudhoe Bay Unit NGL was conditionally approved by AOGCC on August 30, 2018. Requirements imposed included the meter prove frequency (monthly), notification to AOGCC for opportunity to witness meter proves, required actions before making changes to the custody transfer measurement equipment, and reporting obligations following proves. BPXA initiated NGL sales to the Kuparuk River Unit in September 2018 and immediately encountered mechanical problems that prevented the use of meter proving equipment. Approval to continue the sales of NGL to the Kuparuk River Unit was granted by AOGCC after agreeing to an alternate means of demonstrating an acceptable level of accuracy for the Prudhoe Bay Unit NGL meter. On April 6, 2019 AOGCC was given verbal notice of the initial NGL meter prove which was witnessed on April 7, 2019. BPXA performed subsequent monthly meter proves of the Prudhoe Bay Unit NGL meter in May, June, and July 2019. Condition 3 of the approval letter requires that BPXA "must provide information (table and graph) used to validate meter performance each month". Condition 6 of the approval letter requires that BPXA must give 24-hour notice to AOGCC for the opportunity to witness meter proves. No notice Other Order -164 October 30, 2019 Page 2 of 3 was provided for meter proves in May and July 2019, and no meter performance reports were submitted following meter proves in April, May, June and July 2019.' By letter dated August 12, 2019 BPXA acknowledged receipt of the Notice, requested an informal review of the matter, and provided the current meter factor control chart for the NGL custody transfer meter. The informal review was held August 20, 2019 during which time BPXA asked several clarifying questions and provided an updated NGL custody transfer meter proving procedure, a BPXA organizational management -of -change, and an excerpt from BPXA's Compliance Task Management System showing key personnel responsibilities related to the NGL custody transfer meter. Mitigating Circumstances: The factors in AS 31.05.150(g) were considered in determining the appropriate penalty. BPXA's lack of good faith in its attempts to comply with the imposed conditions and need to deter similar behavior are the factors which most heavily influence AOGCC's decision and the penalty being assessed: - The failure to submit information related to meter performance — e.g., prove reports, meter factor control charts, meter curves, meter factor comparisons — cannot be characterized as a good faith attempt to comply with the AOGCC's conditional approval letter. - During the meter application review, BPXA confirmed to AOGCC its standing instructions for monitoring and reporting meter performance. There was nothing different required in the conditions of approval and nothing ambiguous about the approval conditions requiring submittal of meter prove results. Reliance on recognized practices found in API Manual of Petroleum Measurement Standards was confrrmed.2 - The absence of equipment performance tracking information such as the required meter factor control charts compromises the ability of AOGCC to make informed, fact -based decisions about how frequently to witness meter proves. Mitigating circumstances considered in the assessment of the proposed civil penalty include BPXA's submittal of information identified as missing by the AOGCC in the Notice, demonstrated acceptable performance of the NGL meter as shown in the meter factor control chart, and no injury to the public. Further, AOGCC has significantly reduced the penalty by not invoking per -day or per -month assessments for the violations. Findings and Conclusions: The AOGCC finds that BPXA violated the August 30, 2018 conditional approval of custody transfer measurement equipment used for the sale of Prudhoe Bay Unit NGL to ConocoPhillips Alaska Inc.'s Kuparuk River Unit. Mitigating circumstances outlined above were considered in the Notice and the AOGCC assessment as to the appropriate civil penalty. BPXA has neither disputed the findings in the Notice nor the penalty proposed by AOGCC. Since receiving the Notice, BPXA has provided proper notice and results of each meter prove as required in the conditional approval letter. AOGCC had also confirmed performance of the Prudhoe Bay Unit NGL meter with witnessed meter proves. BPXA measurement personnel in the field were made aware of the need to notify AOGCC for the opportunity to witness meter proves based on June 10, 2019 email and follow-up notice on June 15, 2019. 2 Incorporated by reference into AOGCC regulations at 20 AAC 25.228 Other Order -164 October 30, 2019 Page 3 of 3 Now Therefore It Is Ordered That: After application of the criteria set forth in AS 31.05.150(g) to the evidence presented, BPXA is assessed a civil penalty in the amount of $20,000 for violating the August 30, 2018 conditional approval of custody transfer measurement equipment used for the sale of Prudhoe Bay Unit NGL from the Prudhoe Bay Unit to ConocoPhillips Alaska Inc.'s Kuparuk River Unit. If BPXA chooses not to appeal this Order the fine must be paid within 30 days of issuance. If appealed, the fine will be held in abeyance until the appeal process is complete. In addition to the civil penalty, within 10 days of the date of the AOGCC's final decision, BPXA shall provide a detailed written explanation that describes how it intends to prevent recurrence of this violation. As an Operator involved in an enforcement action, BPXA is required to preserve documents concerning the above action until after resolution of the proceeding. Done at Anchorage, Alaska and Dated October 30, 2019. J em Price Jes ie L. Chmielowski Chair, ommissioner Commissioner cc: AOGCC Inspectors Phoebe Brooks (AOGCC) NOTICE As provided in AS 31.05.080(a), within 20 days after written notice of the entry of this order or decision, or such further time as the AOGCC grants for good cause shown, a person affected by it may file with the AOGCC an application for reconsideration of the matter determined by it. If the notice was mailed, then the period of time shall be 23 days. An application for reconsideration must set out the respect in which the order or decision is believed to be erroneous. The AOGCC shall grant or refuse the application for reconsideration in whole or in part within 10 days after it is filed. Failure to act on it within 10 -days is a denial of reconsideration. If the AOGCC denies reconsideration, upon denial, this order or decision and the denial of reconsideration are FINAL and may be appealed to superior court. The appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision denying reconsideration, UNLESS the denial is by inaction, in which case the appeal MUST be filed within 40 days after the date on which the application for reconsideration was filed. If the AOGCC grants an application for reconsideration, this order or decision does not become final. Rather, the order or decision on reconsideration will be the FINAL order or decision of the AOGCC, and it may be appealed to superior court. That appeal MUST be filed within 33 days after the date on which the AOGCC mails, OR 30 days if the AOGCC otherwise distributes, the order or decision on reconsideration. In computing a period of time above, the date of the event or default after which the designated period begins to run is not included in the period; the last day of the period is included, unless it falls on a weekend or state holiday, in which event the period runs until 5:00 p.m. on the next day that does not fall on a weekend or state holiday. C3 Domestic ❑ Adult Signature E, II I IIIII II II III I III IIII II I II I I III III IIII III ❑ Adult Signature Restricted Delivery ❑ Replstered Mall Restricted CO ❑ Cestiiled Malls Delivery 9590 9402 4351 8190 1895 71 ru ❑ Return Receipt for Merchandise t_ t ❑ Collect on Delivery ❑ Coiled on Delivery Restricted Delivery Ln Cenma Mail ee Nail Vail Restricted Delivery Reatr led Delivery E3 $fL PS Form 3811, July 2015 PSN 7530-02-000-9053 xServices & Fees (ca add Ad aappropaazel ❑RetuReeipt $ n-17 C3 ❑ nature Recelpt (eleraonic) $ Postmark 0 ❑ Certified Mail Restrictetl Delivery $ Here C3 ❑ Adult Signature Required $ r-Atlult Signature Restricted Delrtrery $ C3 jr, -- co C3 Mr. Kollin Fencil ro BP Exploration (Alaska), Inc. C'3 I P.O. Box 196612 Anchorage, AK .. PS Form 3800, April 2015 PSN 7530 02 -ago 9047 See ■ Complete items 1, 2, and 3. A. signatur ■ print your name and address on the reverse X Agent so that we can return the card to you. ❑ Atldre ■ Attach this card to the back of the mailpiece, R. Received by (Pri N e) C. Date of Deli or on the front if space permits. f�� - - —_ — detests different from hem 17 ❑ Yes Mr. Kollin Fencil Yr.¢ek. { JD BP Exploration (Alaska), Inc. 1hF �p ` P.O. Box 196612 JUL 31 2019 Anchorage, AK 99519-6612 3. Service relExpresa® ❑ Adult Signature O Reggt�Sfe ed Maile. II I IIIII II II III I III IIII II I II I I III III IIII III ❑ Adult Signature Restricted Delivery ❑ Replstered Mall Restricted ❑ Cestiiled Malls Delivery 9590 9402 4351 8190 1895 71 ❑ Certified Mail Restricted Delivery ❑ Return Receipt for Merchandise 2. Article Number (rrans/er /rom service label) ❑ Collect on Delivery ❑ Coiled on Delivery Restricted Delivery 0 Signature CongnnafionTM ❑ Signature Confirmation 0680 0002 2052 8900 Nail Vail Restricted Delivery Reatr led Delivery 7018 PS Form 3811, July 2015 PSN 7530-02-000-9053 Domestic Return Receipt Bernie Karl Gordon Severson Penny Vadla K&K Recycling Inc. 3201 Westmar. Cir. 399 W. Riverview Ave. Fairbanks,, AK 99711 P.O. BoxAAnchorage, AK 99508-4336 Soldotna, AK 99669-7714 K George Vaught,. Jr. Darwin Waldsmith Richard Wagner P.O. Box 13557 P.O. Box 39309 P.O. Box 60868 Denver, CO 80201-3557 Ninilchik, AK 99639 Fairbanks, AK 99706 INDEXES Chris Wyatt Senior Counsel Phone: 907-564-5674 Email: chris.wyatt@bp.com November 26, 2019 Jessie L. Chmielowski, Commissioner Alaska Oil and Gas Conservation Commission 333 W. 7'h Avenue Anchorage, AK 99501-3572 Re: Docket No. OTH-19-024 Missing Meter Performance Reports Prudhoe Bay Unit NGL Sales Dear Commissioner Chmielowski: BP Exploration (Alaska) Inc. 900 E. Benson Boulevard Anchorage, AK 99508 P.O. Box 196612 Anchorage, AK 99519-6612 VIA FACSIMILE BP Exploration (Alaska) Inc. (BPXA), operator of the Prudhoe Bay Unit, has received the commission's October 30, 2019, Decision and Order in the referenced matter, in which the commission assessed a civil penalty in the amount of $20,000.00. Please accept this letter as confirmation that BPXA has elected to not contest the assessed civil penalty. BPXA has sent payment via bank wire in the amount of $20,000.00 to the commission's designated bank account. Thank you for your consideration. Sincerely, Chris Wyatt cc: Jack Griffin, CP Barbara Fullmer, CP Sara Denton, Chevron Daniel Walker. EM , , ` NOV 2 7 2019 ,AOGCC, 5 Carlisle, Samantha J (CED) From: Carlisle, Samantha 1 (CED) Sent: Wednesday, October 30, 2019 12:44 PM To: 'AOGCC-Public-Notices' Subject: Other Order 164 Attachments: otherl 64.pdf Missing Meter Performance Reports Custody Transfer Meters Prudhoe Bay Unit Natural Gas Liquids Sales Samantha Carlisle Executive Secretary III Alaska Oil and Gas Consemation Commission 333 West 71n Avenue Anchorage, AK 99501 (907) 793-1223 CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, contains information firm the Alaska Oil and Gas Conservation Commission (AOGCC), State of Alaska and is for the sole use of the intended recipient(s). It may contain confidential and; or privileged information. The unauthorized review. use or disclosure of such information may violate state or federal law. If you are an unintended recipient of this e-mail, please delete it, without first saving or forwarding it, and, so that the AOGCC is aware of the mistake in sending it to you, contact Samantha Carlisle at (907) 793-1223 or Samantha.Carlisi(yitalaska.sov. Carlisle, Samantha J (CED) From: Carlisle, Samantha I (CED) Sent: Wednesday, October 30, 2019 12:47 PM To: DOA AOGCC Prudhoe Bay, Brooks, Phoebe L (CED) Subject: Other Order 164 Attachments: otherl64.pdf Missing Meter Performance Reports Custody Transfer Meters Prudhoe Bay Unit Natural Gas Liquids Sales Samantha Carlisle Executive Secretary III Alaska Oil and Gas Conservation Commission 333 West 711 Avenue Anchorage, AK 99501 (907) 793-1223 CONFIDENTMLITYNOTICE: This e-mail message, including any attachments, eontains uiformation from the Alaska Oil and Gas Conservation Commission (AOGCC), State of Alaska and is for the sole use of the intended recipient(s), It may contain confidential and/or privileged information. 1'7te unauthorizedreview. use or disclosure, of such information may violate state or federal law. Ifyot are an unintended recipient of this e-mail, please delete it, without first saving or foiwarding it, and, so that the AOGCC is aware of the mistake in sending it to you, contact Samantha Carlisle at (907) 793-1223 or Samantha.Cariistotielaska.z ov. November 1, 2019 Mr. Jeremy Price, Chair Alaska Oil and Gas Conservation Commission 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Subject: Docket Number: OTH-19-024 Missing Meter Performance Reports Dear Commissioner Price: Kollin.Fencil BP Exploration (Alaska) Inc. 900 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519-6612 RECEIVED NOV 0 4 2013 AOGCC On October 30, 2019, BP Exploration (Alaska) Inc. (BPXA) received a Decision and Order note from the Alaska Oil and Gas Conservation Commission (AOGCC) regarding failure to report NGL sales meter performance. The letter requested that BPXA provide AOGCC with a detailed written explanation that describes how we intend to prevent recurrence of this violation. BPXA has implemented the following to prevent recurrence: 1. BPXA has amended our reporting procedure to include guidelines on how to prove the NGL meters at Skid 50 and the reporting requirements and accountabilities. 2. BPXA has added specific monthly tasks into our Compliance Task Management (CTM) system to ensure completion. 3. BPXA has added the notification requirement to the accountabilities of the East Offtake Center (ECC) board operators' responsibilities. The requirement details the process to notify AOGCC through its web -based system before all meter proves 24 hours in advance. Please contact me at 907-564-5384 with and any follow-up questions. Sincerely, Kollin Fencil Area Operations Manager BP Exploration (Alaska) Inc. cc: Mr. Jim Regg, Senior Petroleum Engineer AOGCC 4 Confidential, held in secure storage 3 THE STATE °fALASKA GOVERNOR MIKE DUNLEAVY August 13, 2019 Sent by Email Kollin.Fencil@bp.com Mr. Kollin Fencil Area Operations Manager BP Exploration (Alaska), Inc. PO Box 196612 Anchorage, AK 99519 Re: Docket Number:OTH-19-024 Informal Review Missing Meter Performance Reports Prudhoe Bay Unit NGL Sales Dear Mr. Fencil: Alaska Oil and Gas Conservation Commission 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907.279.1433 Fax: 907.276.7542 www. oogc c.al as ka.gov As part of the informal review process, BP Exploration (Alaska), Inc. (BPXA) has the opportunity to submit documentary material and make written and oral statements regarding the Notice of Proposed Enforcement Action for Docket Number OTH-19-024, Missing Meter Performance Reports. There will be no formal record kept of the review and the review will not involve the presence of counsel, either for the AOGCC or the operator. The informal review is scheduled for August 20, 2019 at 9:00 am in the AOGCC's Anchorage office located at 333 West 7th Avenue. Copies of all written submissions and summaries of any oral statements planned by BPXA should be provided to the AOGCC no later than August 19, 2019. Sincerely, � sis k ess Chmielowski Commissioner 2 August 12, 2019 Jessie L. Chmielowski Commissioner Alaska Oil and Gas Conservation Commission 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Subject: Docket Number: 0TH-18-032/OTH-19-024 Custody Transfer Measurement Dear Commissioner Chmielowski: Kollin.Fencil BP Exploration (Alaska) Inc. 906 East Benson Boulevard P.O. Box 196612 Anchorage, Alaska 99519-661-2::m@ �a' Tel E AUG 13 2019 0GC On July 29, 2019, BP Exploration (Alaska) Inc. (BPXA) received a Notice of Violation dated July 24, 2019 from the Alaska Oil and Gas Conservation Commission (AOGCC) regarding the reporting of NGL sales meter performance. The letter requested that BPXA provide AOGCC with a detailed written explanation that describes how we intend to prevent recurrence of alleged violations under 20 AAC 25.535(b)(3) concerning meter performance. BPXA has a reporting procedure that addresses 20 AAC 25.535(b)(3) and is intended to establish guidelines on how to prove the NGL meters at Skid 50. This procedure will be amended to include reporting requirements and accountabilities. Additionally, we will be adding specific monthly tasks into our Compliance Task Management (CTM) system to ensure completion. Per instructions of the August 30, 2018 application to reinstate and operate the Prudhoe Bay Unit (PBU) natural gas liquids (NGL) export metering system, BPXA is providing the monthly meter performance charts. Please find attached charts for April, May, June and July 2019 as requested in your letter dated July 24, 2019. Additionally, we respectfully submit August 2019. Finally, condition 6 of 20 AAC 25.535(b)(3) requires "24-hour notice for the opportunity to witness meter proves" on a monthly basis. BPXA will add the notification requirement to the accountabilities of the East Offtake Center (EOC) board operators' responsibilities and document that accordingly. The requirement will be to notify AOGCC through its web -based system before all meter proves 24 hours in advance. Furthermore, BPXA is requesting an informal review of this violation to discuss findings and mitigations. Please contact me at 907-564-5384 with questions and to schedule the informal review. Jessie L. Chmielowski August 5, 2019 Page 2 Sincerely, Kollin Fencil Area Operations Manager BP Exploration (Alaska) Inc. cc: Mr. Jim Regg, Senior Petroleum Engineer AOGCC LL o m m O m m m m o r o 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 o O o 0 o O o O o r O f0 m M N O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O o O O O O O O O O O O O O 0 0 O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O O 0. e � a o m m m m O m o m m m Q M Q O (p o M N m mf o 0 0 0 0 0 0 0 0 0 0 S L O o 0 0 0 0 0 0 0 0 0¢ a¢ a Q Q¢¢ a¢¢?¢¢¢¢ Q Q Q¢ Q¢¢ Q Q¢¢¢¢ uuuuaauuuuuuuttuuuttuauuauauaaa U m m m m r m m r m m N N N r r r r N r r r m N O O N N N N O N N N N -- - - ' m •- •- ``-- u a a u u u u a u a u u aZ u u a u u u u u uZ u u u uZ U LL y O N N N N NN NN NN N O N N N M 0 0 0 O O O -0 0 0 C O 3 m v Q Q m Q Q Q Q Q m o d o y LL � d � �mN rmi o�mM�mr� m J Lm- M r m N O Z LL A mom p `�Nmn o� oci N � O 1 THE STATE July 24, 2019 °fALASKA GOVERNOR MIKE DUNLEAVY CERTIFIED MAIL — RETURN RECEIPT REQUESTED 7018 0680 0002 2052 8900 Mr. Kollin Fencil Area Operations Manager - Anchorage BP Exploration (Alaska) Inc. P.O. Box 196612 Anchorage, AK 99519-6612 Re: Docket No.OTH-19-024 Missing Meter Performance Reports Prudhoe Bay Unit NGL Sales Dear Mr. Fencil: Alaska Oil and Gas Conservation Commission 333 West Seventh Avenue Anchorage, Alaska 99501-3572 Main: 907,279.1433 Fax: 907.276.7542 vv w.aogcc.aIaska.gov Pursuant to 20 AAC 25.535, the Alaska Oil and Gas Conservation Commission (AOGCC) hereby notifies BP Exploration (Alaska) Inc. (BPXA) of a proposed enforcement action. Nature of the Apparent Violation or Noncompliance (20 AAC 25.535(b)(11). BPXA has violated the provisions of the conditional approval letter for Prudhoe Bay Unit (PBU) natural gas liquids (NGL) custody transfer measurement equipment. Basis for Finding the Violation or Noncompliance (20 AAC 25.535(b)(2)). Custody transfer measurement equipment for BPXA's NGL sales to ConocoPhillips Alaska Inc.'s Kuparuk River Unit was conditionally approved by AOGCC on August 30, 2018. Requirements imposed include the meter prove frequency, notification to AOGCC for opportunity to witness meter proves, required actions before making changes to the custody transfer measurement equipment, and reporting obligations following proves. Condition 2 of the approval letter requires monthly proving of the meters; condition 3 requires that BPXA "provide information (table and graph) used to validate meter performance each month"; and condition 6 requires "24-hour notice for the opportunity to witness meter proves". BPXA has failed to submit meter performance reports for April, May, June, and July 2019. BPXA has also provided no evidence that it completed the required meter proves on May and July 2019. Docket Number: OTH-19-? July 24, 2019 Page 2 of 3 Proposed Action (20 AAC 25.535(b)(3)) For violating provisions of the August 30, 2018 conditional approval letter for the PBU NGL custody transfer measurement equipment, the AOGCC intends to impose a civil penalty on BPXA under AS 31.05.150(a) in the amount of $30,000.1 In determining the amount of the penalty, AOGCC has considered the criteria in AS 31.05.150(g), with emphasis on the extent to which BPXA was acting in good faith in attempting to comply, the extent to which BPXA acted in a willful or knowing manner, the extent and seriousness and actual or potential threat to public health or the environment, injury to the public, the need to deter similar behavior by BPXA and others similarly situated at the time of the violation or in the future, and BPXA's history of compliance issues. In addition to the imposed civil penalty, AOGCC intends to require BPXA to provide - a detailed written explanation that describes how it intends to prevent recurrence of this violation; and - the missing meter performance information within 10 days of this order. As an operator involved in an enforcement action you are required to preserve documents concerning the above actions until after resolution of the proceeding. Ri¢hts and Liabilities (20 AAC 25.535(b)(4)) Within 15 days after receipt of this notification — unless the AOGCC, in its discretion, grants an extension for good cause shown — BPXA may file with the AOGCC a written response that concurs in whole or in part with the proposed action described herein, requests informal review, or requests a hearing under 20 AAC 25.540. If a timely response is not filed, the proposed action will be deemed accepted by default. If informal review is requested, the AOGCC will provide BPXA an opportunity to submit documentary material and make a written or oral statement. If BPXA disagrees with the AOGCC's proposed decision or order after that review; it may file a written request for a hearing within 10 days after the proposed decision or order is issued. If such a request is not filed within that 10 -day period, the proposed decision or order will become final on the l la' day after it was issued. If such a request is timely filed, the AOGCC will hold its decision in abeyance and schedule a hearing. If BPXA does not concur in the proposed action described herein, and the AOGCC finds that BPXA violated a provision of AS 31.05, 20 AAC 25, or an AOGCC order, permit or other approval, then the AOGCC may take any action authorized by the applicable law including ordering one or more of the following: (i) corrective action; (ii) suspension or revocation of a permit or other approval; and (iii) imposition of penalties under AS 31.05.150. In taking action after an informal review or hearing, the AOGCC is not limited to ordering the proposed action ' Penalty amount arrived at considering two violations: failure to submit required meter performance reports, and failure to notify for opportunity to witness proves of the NGL sales meter —each $15,000. Docket Number: OTH-19- July 24, 2019 Page 3 of 3 described herein, as long as BPXA received reasonable notice and opportunity to be heard with respect to the AOGCC's action. Any action described herein or taken after an informal review or hearing does not limit other actions the AOGCC may take. Sincerely, y� aC �-- J sie L Chhmielowski Commissioner cc: Scott Provolt Flow Measurement Engineer BPXA Phoebe Brooks, AOGCC