# BP PIPELINE (NORTH AMERICA) INC. — Notice of Probable Violation

**Citation:** CPF 420075003  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2007-02-13

CLOSED notice of probable violation citing 195.410(a)(1), 195.420(c), 195.432(a), 195.436, 195.573(a), 195.579(a), 195.581(a).

## Document text

Notice of Probable Violation involving BP PIPELINE (NORTH AMERICA) INC.. PHMSA's enforcement data identifies the cited regulations as 195.410(a)(1),  195.420(c),  195.432(a),  195.436,  195.573(a),  195.579(a),  195.581(a). The case was opened on 2007-02-13 and is reported as closed as of 2012-04-17. Proposed civil penalty: $168,000. Assessed civil penalty: $142,000. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420075003_Amended Decision on the Petition for Reconsideration_02172011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075003/420075003_Amended%20Decision%20on%20the%20Petition%20for%20Reconsideration_02172011.pdf

420075003_Amended Decision on the Petition for Reconsideration_02172011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075003/420075003_Amended%20Decision%20on%20the%20Petition%20for%20Reconsideration_02172011_text.pdf

420075003_Closure_04172012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075003/420075003_Closure_04172012.pdf

420075003_Closure_04172012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075003/420075003_Closure_04172012_text.pdf

420075003_Decision on the Petition for Reconsideration_02042011 .pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075003/420075003_Decision%20on%20the%20Petition%20for%20Reconsideration_02042011%20.pdf

420075003_Decision on the Petition for Reconsideration_02042011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075003/420075003_Decision%20on%20the%20Petition%20for%20Reconsideration_02042011_text.pdf

420075003_FinalOrder_07192010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075003/420075003_FinalOrder_07192010.pdf

420075003_FinalOrder_07192010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075003/420075003_FinalOrder_07192010_text.pdf

420075003_Petition for Reconsideration_08122010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075003/420075003_Petition%20for%20Reconsideration_08122010.pdf

CPF 4-2007-5003 BP Pipeline North America - Response Letter.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075003/CPF%204-2007-5003%20BP%20Pipeline%20North%20America%20-%20Response%20Letter.pdf

CPF 4-2007-5003 BP Pipeline North America NOPV.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075003/CPF%204-2007-5003%20BP%20Pipeline%20North%20America%20NOPV.pdf

CPF 4-2007-5003 BP Pipeline North America NOPV.pdf

U.S. Department
of Transportation
Pipeline and
Hazardous Materials Safety
Administration
8701 South Gessner, Suite 11 10
Houston, TX 77074
NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPI-IANCE ORDER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
February 13, 2007
Mr. Jim La Manna
V. P. Operations
BP Pipeline North America, Inc.
Mail Code 7018
281 00 Torch Parkway
Warrenville, IL 60555
- CPF 4-2007-5003
Dear Mr. La Manna:
4
During the months of August, 2004, July, August, September, October, November and
December, 2005 a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, conducted
pipeline safety inspections of BP Pipeline North America, Inc. (BP) facilities and records
pertaining to the Seaway Products System, in Texas and Oklahoma; West System, New
MexicoTTexas; and Texas/Oklahoma; East System, Oklahoma; and the Cushing Tank
Farm.
As a result of the inspection, it appears that you have committed probable violations of
the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items
inspected and the probable violations are:
1. 9195.410 Line markers
(a) Except as provided in paragraph (b) of this section, each operator shall
place and maintain line markers over each buried pipeline in accordance with
the following:
(1) Markers must be located at each public road crossing, at each railroad



crossing, and in sufficient number along the remainder of each buried line so
that its location is accurately known.
(c) Each operator shall provide line marking at locations where the line is
above ground in areas that are accessible to the public.
BP does not have sufficient markers to accurately show where their pipelines are
located. When crossing cultivated agricultural fields, often the markers on the far side of
the field could not be seen. From valve sites, looking in both directions, the next marker
for the pipeline could not be seen. The lack of pipeline marking is a common problem
with several of the BP pipelines that were inspected. The pipelines were marked at road
crossings.
2. 9195.436 Security of facilities.
Each operator shall provide protection for each pumping station and breakout
tank area and other exposed facility (such as scraper traps) from vandalism
and unauthorized entry.
BP has a number of pump station, junction and scraper trap facilities that do not have
adequate protection against unauthorized entry or vandalism. Barbed wire fences are
not adequate. The Monroe pump station and break out tanks had cyclone fencing with
barbed wire around the top around the pump station, and 3 strands of barbed wire
around the break out tank area. Vandals got into the tank area, climbed up a tank and
walked around the wind girders on one of the tanks spraying graffiti. The vandals then
climbed down onto the floating roof, painted graffiti, and smoked on the floating roof.
The Artesia pump station has a 4 foot high hog and barbed wire fence facing the county
road, and barbed wire around the remainder of the facility. The Fullerton pump station1
break out tank area have no fencing at all. The gravel county road actually cuts through
the pump station. Remote location is also not adequate to meet the requirements of this
regulation.
9195.573 What must I do to monitor external corrosion control?
(a) Protected pipelines. You must do the following to determine whether
cathodic protection required by this subpart complies with Sec. 195.571:
1. Conduct tests on the protected pipeline at least once each calendar year,
but with intervals not exceeding 15 months. However, if tests at those intervals
are impractical for separately protected short sections of bare or ineffectively
coated pipelines, testing may be done at least once every 3 calendar years, but
with intervals not exceeding 39 months.
(d) Breakout tanks. You must inspect each cathodic protection system used to
control corrosion on the bottom of an aboveground breakout tank to ensure
that operation and maintenance of the system are in accordance with API
Recommended Practice 651. However, this inspection is not required if you
note in the corrosion control procedures established under Sec. 195.402(~)(3)
why compliance with all or certain operation and maintenance provisions of
API Recommended Practice 651 is not necessary for the safety of the tank.
BP is just beginning to implement surveys that consider IR drop. This requirement has
been in place since regulations were changed in 2001. A number of locations had
instant off potentials, measured during the PHMSA inspections that were less negative



than the -850 mV criteria. Operator records indicate that the tank bottoms are also not
being surveyed to account for IR drop during annual CP surveys.
4. 9195.579 What must I do to mitigate internal corrosion?
(a) General. If you transport any hazardous liquid or carbon dioxide that would
corrode the pipeline, you must investigate the corrosive effect of the
hazardous liquid or carbon dioxide on the pipeline and take adequate steps to
mitigate internal corrosion.
BP has not done adequate investigations to determine whether there is internal
corrosion or the potential for internal corrosion. BP has performed little monitoring, and
has not done inspections to investigate whether there could be internal corrosion in
facilities and non-piggable piping. The investigation of internal corrosion appears to be
based upon a few internal coupons, which are improperly located on pipelines, and no
other evidence could be produced.
5. 91 95.420 Valve maintenance
(c) Each operator shall provide protection for each valve from unauthorized
operation and from vandalism.
A number of the BP Pipeline valves do not have protection from vandalism at the
sites. The valves were chained and locked to prevent unauthorized use, but
these locations did not provide any deterrence against vandalism. Local
personnel did provide additional information regarding this issue.
During the inspections it was noted that BP' preferred method of complying with
195.420~ is to install locked chain link fencing around the valves. This was
evident in the six BP units that were inspected, where most of above ground
valves were located in locked fences.
Some of the remaining valves in those units were located above ground with no
fences. Some of the valves were inside a pipe post and beam enclosure, which
may be sufficient to keep cattle from rubbing on the valves, but do not address
prevention of vandalism. The number of above ground valves that were
observed without fences by the inspector on the six Texas and New Mexico units
exceeded seven, and the lack of fencing was pointed out to BP personnel at the
time of the inspections.
It should be pointed out that all of the unfenced valves were chain locked and
some had steel barricade posts installed. A review of your procedures by our
inspectors did not reveal any alternative method of security for valve sites
acceptable to you. BP should review their program, procedures, and facilities to
ensure they are compliant with this regulation.
6. 9195.432 Breakout tanks.
(a) Except for breakout tanks inspected under paragraphs (b) and (c) of this
section, each operator shall, at intervals not exceeding 15 months, but at least
once each calendar year, inspect each in-service breakout tank.



(b) Each operator shall inspect the physical integrity of in-service atmospheric
and low-pressure steel aboveground breakout tanks according to section 4 of
API Standard 653. However, if structural conditions prevent access to the tank
bottom, the bottom integrity may be assessed according to a plan included in
the operations and maintenance manual under §195.402(~)(3).
(c) Each operator shall inspect the physical integrity of in-service steel
aboveground breakout tanks built to API Standard 2510 according to section 6
of API 510.
(d) The intervals of inspection specified by documents referenced in
paragraphs (b) and (c) of this section begin on May 3, 1999, or on the
operator's last recorded date of the inspection, whichever is earlier.
During the PHMSA inspections of BP breakout tanks at pump stations and the Cushing
tank farm, a number of breakout tanks were noted for items not in compliance with the
requirements of API 653.
The records indicate that the tanks have been inspected, and the items not in
compliance with API 653 should have been noted and corrected after the inspections.
The records for the internal inspections and in some cases external inspections make it
impossible to determine whether issues documented during the inspections have been
addressed. Record keeping must include the records for the items identified during the
inspections, and their resolution, or reasons for not being resolved.
7. S195.581 Which pipelines must I protect against atmospheric corrosion and
what coating material may I use?
(a) You must clean and coat each pipeline or portion of pipeline that is
exposed to the atmosphere, except pipelines under paragraph (c) of this
section.
Several of the breakout tank roofs, above ground valves, piping in opened vaults and
exposed pipeline areas had coating that was failing or had failed, and was leaving the
pipe or tank top susceptible to external corrosion. If left as is, corrosion could continue
to the extent that the integrity of the pipeline or tanks would be compromised. Coating
should be replaced before serious corrosion occurs.
Under 49 United States Code, 5 60122, you are subject to a civil penalty not to exceed
$1 00,000 for each violation for each day the violations persists up to a maximum of
$1,000,000 for any related series of violations. The Compliance Officer has reviewed
the circumstances and supporting documentation involved in the above probable
violation(s) and has recommended that you be preliminarily assessed a civil penalty of
$168,000 as follows:
Item number
1
2
3
PENALTY
$26,000



With respect to items 5, and 7, we have reviewed the circumstances and supporting
documents involved in this case and have decided not to conduct additional enforcement
action or penalty assessment proceedings at this time. We advise you to promptly
correct these item(s). Be advised that failure to do so may result in BP being subject to
additional enforcement action.
With respect to items 1 through 4, and 6, pursuant to 49 United States Code § 601 18,
the Pipeline and Hazardous Materials Safety Administration proposes to issue a
Compliance Order to BP Products Operating, L.P. Please refer to the Proposed
Compliance Order which is enclosed and made a part of this Notice.
Enclosed as part of this Notice is a document entitled Response Options for Pipeline
Operators in Compliance Proceedings. Please refer to this document and note the
response options. If you do not respond within 30 days of receipt of this Notice, this
constitutes a waiver of your right to contest the allegations in this Notice and authorizes
the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice
without further notice to you and to issue a Final Order.
In your correspondence on this matter, please refer to CPF 4-2007-5003 and for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous
Materials Safety Administration
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Compliance Proceedings



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code $ 60118, the Pipeline and Hazardous Materials
Safety Administration (PHMSA) proposes to issue to BP Pipeline North America, Inc. a
Compliance Order incorporating the following remedial requirements to ensure the
compliance of BP with the pipeline safety regulations:
1. In regard to ltem #1 of the Notice, BP must perform an inspection of pipeline ROW'S
throughout BP's pipeline system. The inspection is to evaluate the line markers
currently posted along the rights-of-way, as well as identify those areas where
additional markers are needed. If there are areas, such as cultivated fields, where it
is impractical to place markers, or because the markers are removed or plowed
under by the farmer, an alternative method of ensuring the safety of the public and
the pipeline should be developed. In areas where there are insufficient markers,
develop a plan and time table to place markers to ensure BP is in compliance with
$1 95.41 O(a)(l).
2. ltem #2 of the Notice indicates a lack of security at some BP facilities. BP shall
perform a survey of their pipeline facilities, identifying any facilities that do not meet
the requirements of $195.436. For BP facilities that do not meet the regulatory
requirements of being protected from unauthorized entry, and vandalism, BP shall
develop a plan and time table to secure the facilities, and ensure that they are in
compliance with $1 95.436.
3. In regard to ltem #3 of the Notice pertaining to BP's pipeline systems, review BP's
CP data collection and evaluation to ensure that data meets the regulatory
requirements, and that the pipelines are protected. In areas where the pipelines are
not adequately protected, develop a plan and time table to improve the CP systems
to bring BP into compliance.
4. In regard to ltem #4 of the Notice pertaining to BP's pipeline systems, perform an
assessment of pipelines and all facilities to determine if there are areas that would be
susceptible to internal corrosion. Perform inspections, install monitoring, and if
active corrosion is determined, implement mitigation methods.
5. Regarding ltem #6 of the Notice, BP must perform a review to ensure that all of BP's
breakout tanks are in compliance with $195.432. Items found not in compliance with
s195.432 and API-653 requirements shall be corrected, and a program to follow
through on future inspection issues implemented.
The data and results generated during API-653 internal and external inspections
shall be presented, along with a report showing resolution of any issues discovered
during the inspection, and explanation of any issues that were not resolved.
6. BP shall maintain documentation of the safety improvement costs associated with
fulfilling this Compliance Order and submit the total to R. M. Seeley, Director,
Southwest Region, Pipeline and Hazardous Materials Safety Administration. Costs



shall be reported in two categories: I) total cost associated with preparationlrevision
of plans, procedures, studies and analyses, and 2) total cost associated with
replacements, additions and other changes to pipeline infrastructure.
7. Submit to the Director, Southwest Region, Pipeline and Hazardous Materials Safety
Administration, 8701 South Gessner, Suite 11 10, Houston, Texas 77074.
1. Results of surveys and plans, with time tables, must be submitted within 30 days
following the receipt of the Final Order.
2. All items shall be completed within 365 days following the receipt of the Final
Order.

420075003_FinalOrder_07192010_text.pdf

JUL 19 2010
Mr. Steve Pankhurst
President
BP Pipelines (North America), Inc.
28100 Torch Parkway
Warrenville, IL 60555
Re: CPF No. 4-2007-5003
Dear Mr. Pankhurst:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation, assesses a reduced civil penalty of $142,000, and specifies certain actions that need to
be taken by BP Pipelines (North America), Inc., to comply with the pipeline safety regulations.
The penalty payment terms are set forth in the Final Order. When the civil penalty has been paid
and the terms of the Compliance Order completed, as determined by the Director, Southwest
Region, this enforcement action will be closed. Service of the Final Order by certified mail is
deemed effective upon the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Rod M. Seeley, Director, Southwest Region, PHMSA
Mr. Rob Knanishu, BP Pipelines (North America), Inc.
Mr. Bill Von Drehle, Director of Safety and Compliance, Centurion Pipeline
5 Greenway Plaza, Suite 110, Houston, TX 77046
Mr. Todd Tullio, Manager, Regulatory Compliance, ConocoPhillips Pipeline Company
600 North Dairy Ashford, Houston, Texas 77079
CERTIFIED MAIL – RETURN RECEIPT REQUESTED[7009 1410 0000 2472 2575]



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, DC 20590
____________________________________
In the Matter of )
BP Pipelines (North America), Inc., ) CPF No. 4-2007-5003
)
)
)
Respondent. )
____________________________________)
FINAL ORDER
During August 2004 and on various dates between July and December 2005, pursuant to 49
U.S.C. § 60117, representatives of the Pipeline and Hazardous Materials Safety Administration
(PHMSA), Office of Pipeline Safety (OPS), conducted an on-site pipeline safety inspection of
the facilities and records of BP Pipelines (North America), Inc. (BP Pipelines or Respondent), at
the company’s New Mexico, Texas, and Oklahoma locations. The inspection included the
following systems: Seaway Products Texas System, a 400-mile system transporting
hydrocarbons across Texas; the Seaway Oklahoma Unit, a 155-mile system transporting
hydrocarbons; the East System Oklahoma Unit, a 246-mile system transporting crude oil; the
West System, a 520-mile system transporting crude oil across Texas and New Mexico; the
Northwest System, a 672-mile system transporting crude oil across Texas and Oklahoma; and the
Cushing Tank Farm, an 80-tank facility in Oklahoma.1 BP Pipelines transports over 450 million
barrel miles of oil, refined products, natural gas liquids, carbon dioxide and chemicals daily
throughout the United States.
2
As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to
Respondent, by letter dated February 13, 2007, a Notice of Probable Violation, Proposed Civil
Penalty, and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the
Notice proposed finding that BP Pipelines had committed certain violations of 49 C.F.R. Part
195 and proposed assessing a civil penalty of $168,000 for the alleged violations. The Notice
1 After the inspection, on February 17, 2006, BP Pipelines submitted a letter to PHMSA indicating that
ConocoPhillips had acquired BP Pipelines’ interest in the Seaway Products Pipeline JV, effective December 1,
2005. The Seaway Products Pipeline carries refined petroleum products from Pasadena, Texas, to Cushing,
Oklahoma. On June 19, 2007, BP Pipelines submitted a second letter to OPS, confirming that it had transferred the
West Texas/New Mexico/Cushing Pipeline system to Centurion Pipeline, L.P., a subsidiary of Occidental Petroleum
Corp. BP Pipelines retained ownership of the Cushing Terminal and Shinn Pence tank farm in Oklahoma. Mr. Bill
Von Drehle represented Centurion Pipeline at the July 23, 2007 hearing. Since the OPS inspection occurred prior to
these ownership changes, the findings of violation set forth below are directed to BP Pipelines, the operator of all the
facilities at the time of the inspection.
2 http://www.bppipelines.com/aboutus.html (last accessed December 2, 2009).



2
also proposed ordering Respondent to take certain measures to correct the alleged violations and
warned Respondent to address other probable violations or be subject to future enforcement
action.
BP Pipelines responded to the Notice by letter dated March 23, 2007 (Response). Respondent
contested the allegations, penalties, and proposed compliance order, and requested a hearing. A
hearing was subsequently held on July 23, 2007, in Houston, Texas, with an attorney from the
Office of Chief Counsel, PHMSA, presiding. BP Pipelines was represented by counsel at the
hearing. Respondent subsequently provided a post-hearing submission dated August 20, 2007
(Brief).
FINDINGS OF VIOLATION
The Notice alleged that Respondent violated 49 C.F.R. Part 195, as follows:
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.436, which states:
§ 195.436 Security of facilities.
Each operator shall provide protection for each pumping station
and breakout tank area and other exposed facility (such as scraper traps)
from vandalism and unauthorized entry.
OPS alleged in the Notice that Respondent violated 49 C.F.R. § 195.436 by failing to provide
protection for a number of pump stations, junctions, and scraper trap facilities from vandalism
and unauthorized entry. Specifically, the Notice alleged that Respondent failed to protect the
Monroe, Artesia, and Fullerton facilities, as follows:
Monroe - The Monroe pump station and breakout tank area allegedly were secured only
by cyclone fencing and with barbed wire around the top of the pump station. BP Pipelines used
three strands of barbed wire around the breakout tank area. As a result, vandals entered the tank
area, sprayed the tank and floating roof with graffiti, and smoked on top of the structure, leaving
cigarette butts on the roof. OPS attached pictures of the damage with the Violation Report.3
Artesia – BP Pipelines allegedly used only a four-foot-high hog fence and barbed wire to
secure the facility. The pump station faces a county road and was therefore readily accessible to
the public.
Fullerton–The Fullerton pump station and breakout tank area allegedly did not have any
fencing. A county road cuts through the facility, providing easy public access to the pump
station.
In its Response, BP Pipelines contended that its procedures and practices were consistent with
Part 195. However, at the hearing and in its submissions, the company agreed to survey its
facilities and provide additional security to prevent vandalism and unauthorized entry. OPS
3 Pipeline Safety Violation Report (Violation Report), (February 15, 2007) (on file with PHMSA).



3
confirms that BP Pipelines has now completed the survey and secured the stations identified in
the Notice. Such corrective action, however, does not negate the fact that Respondent failed to
secure these facilities from unauthorized entry as of the date of the inspection. Accordingly,
having reviewed the evidence in the record, I find that Respondent violated § 195.436 by failing
to provide protection for each pumping station and breakout tank from vandalism and
unauthorized entry.
Item 3: The Notice alleged that Respondent violated 49 C.F.R. § 195.573, which states:
§ 195.573 What must I do to monitor external corrosion control?
(a) Protected pipelines. You must do the following to determine
whether cathodic protection required by this subpart complies with
§ 195.571:
(1) Conduct tests on the protected pipeline at least once each
calendar year, but with intervals not exceeding 15 months. However, if
tests at those intervals are impractical for separately protected short
sections of bare or ineffectively coated pipelines, testing may be done at
least once every 3 calendar years, but with intervals not exceeding 39
months….
(d) Breakout tanks. You must inspect each cathodic protection
system used to control corrosion on the bottom of an aboveground
breakout tank to ensure that operation and maintenance of the system are
in accordance with API Recommended Practice 651. However, this
inspection is not required if you note in the corrosion control procedures
established under § 195.402(c)(3) why compliance with all or certain
operation and maintenance provisions of API Recommended Practice 651
is not necessary for the safety of the tank....
The Notice alleged that Respondent violated 49 C.F.R. § 195.573 by failing to conduct surveys
to determine whether BP Pipelines’ cathodic protection (CP) system complied with § 195.571.
Specifically, the Notice alleged that Respondent failed to account for voltage or “IR drop” in its
annual cathodic protection surveys and therefore the company could not determine if its cathodic
protection system complied with § 195.571.
4 Under § 195.571, operators are required to utilize
CP that meets “one or more of the applicable criteria and other considerations for cathodic
protection contained in paragraphs 6.2 and 6.3 of NACE Standard RP 0169…”. Operators may
use the -850 mV criterion for determining whether adequate levels of CP have been achieved.5
However, when using this factor, voltage drops other than across the structure-to-electrolyte
boundary must be considered.6
4 “IR drop” is the difference between the voltage at the top of the pipe and the voltage at the surface of the earth. An
operator must consider this drop for a valid interpretation of the standards set forth by NACE RPO169, paragraph
6.2.
5 NACE International, RP0169, Paragraph 6.2 (2002).
6 Id. at 6.2.2.1.1.



4
After reviewing and considering BP Pipelines’ annual CP surveys for calendar years 2003, 2004,
and 2005, and discussing them with company personnel, OPS alleged in the Notice that several
locations had “instant-off” potentials that did not meet the -850 mV criterion. The requirement
to conduct tests to determine whether the cathodic protection on the pipeline complies with
§ 195.571 was promulgated by final rule on December 27, 2001, effective January 28, 2002.7
However, according to OPS, BP Pipelines had still not incorporated IR drop into its surveys at
the time of the 2004 OPS inspection. As documented in the Violation Report, BP Pipelines’
corrosion engineer initially argued that the -850 mV criterion already factored in the IR drop.8
In addition to the surveys, OPS also alleged that BP Pipelines failed to demonstrate that the
breakout tanks at pumps stations and at the Cushing Tank Farm met the protection criteria of API
RP 651.9
In its submissions and at the hearing, Respondent argued that its prior external corrosion control
procedures and practices were in compliance with § 195.571 since the company used a
methodology of -850 mV in conjunction with sound engineering practices.
10 BP Pipelines
explained that the sound engineering practices it relied on included the historical performance of
the CP system. The company stated that there had been no DOT-reportable spills caused by
external corrosion on this line. Respondent also stated that interrupted surveys were not the only
acceptable method of considering IR drop. The company contended that it had modified its
procedures in 2004 to include consideration of IR drop in response to a Notice of Amendment
(NOA) issued by OPS.
argued that the allegation of violation should be withdrawn. Finally, Respondent stated that
pursuant to its revised procedures, the company ran a Close Interval Survey (CIS) within a year
of every in-line inspection. Since segments from this inspection were assessed by in-line
inspection in 2006, a CIS would be conducted during the 2007 calendar year. On the basis of
these procedures and actions, BP Pipelines argued that the probable violation, proposed civil
penalty, and compliance order all should be withdrawn.
11 Since these procedures had been approved by OPS, the company
7 Controlling Corrosion on Hazardous Liquid and Carbon Dioxide Pipelines, 66 Fed. Reg. 66999 (Dec. 27, 2001).
8 Pipeline Safety Violation Report (Violation Report), (February 15, 2007) (on file with PHMSA).
9 Notice, at 2-3. Violation Report, at 8.
10 Operators using the -850 mV criterion must consider voltage drop. “Consideration” is further defined as “the
application of sound engineering practice…such as measuring or calculating the voltage drop; reviewing the
historical performance of the cathodic protection system; evaluating the physical and electrical characteristics of the
pipe and its environment; and determining whether or not there is physical evidence of corrosion. NACE Standard
RP0169, Paragraph 6.2.2.1.1.1 (2002).
11 In the Matter of BP Pipeline Company, Final Order, CPF No. 3-2004-5021M)(available at
www.phmsa.dot.gov/pipeline/enforcement). In response to this Notice of Amendment, BP Pipelines submitted
revised procedures on December 16, 2004, June 10, 2005, January 31, 2006, and March 10, 2006. The NOA alleged
that Respondent’s procedures included several “inadequacies”, including §§ 195.571 and 195.573. Upon review of
the company’s revised procedures, the Director stated that the inadequacies had been resolved and closed the case.



5
At the hearing, OPS clarified that the NOA issued to BP Pipelines on August 12, 2004, served as
a notification that OPS considered the company’s procedures inadequate. In fact, OPS stated in
the NOA that “BP Pipelines’ procedures fail[ed] to address identifying circumstances in which a
close-interval survey would apply” and that “BP Pipelines’ procedures fail[ed] to consider IR
drop when utilizing the -850 mVcriteria, as required by NACE RP 0169-96.”12 According to
OPS, BP Pipelines corrected its procedures after receipt of the NOA but did not put the new
procedures into practice. The OPS inspector stated in the Violation Report that it was evident at
the time of the inspection that BP Pipelines was just beginning to conduct interrupted surveys
no indication that Respondent considered voltage drop during its annual CP surveys prior to the
inspection, thereby prompting issuance of the Notice.
and close-interval surveys in conjunction with its Integrity Management Program.13 OPS found
I have reviewed the evidence and the arguments set forth by OPS and BP Pipelines. I find OPS’
argument persuasive in that the 2004 NOA pertained to the operator’s procedures, whereas the
Notice involved the operator’s practices. In 2004, BP Pipelines updated its procedures in
response to the NOA but failed to demonstrate that it had actually incorporated voltage drop in
its CP surveys as of the date of the inspection. Further, I do not find merit in Respondent’s
argument that leak history and a proposed CIS constitute compliance with § 195.571. I note that
the NACE Standard RP 0619, Paragraph 6.1.5, specifically states that corrosion leak history is
not sufficient by itself to determine whether adequate CP levels have been achieved.14 In
addition, BP Pipelines was in violation of this regulation prior to the submission of its revised
procedures in 2004 since consideration of IR drop became a requirement of the code as of
violated 49 C.F.R. § 195.573(a)(1) and (d) by failing to conduct CP surveys to ensure its
January 2002. 15 Therefore, based upon all of the evidence in the record, I find that Respondent
cathodic protection system complied with 49 C.F.R. § 195.571.
Item 4: The Notice alleged that Respondent violated 49 C.F.R. § 195.579(a), which states:
§ 195.579 What must I do to mitigate internal corrosion?
(a) General. If you transport any hazardous liquid or carbon
dioxide that would corrode the pipeline, you must investigate the corrosive
effect of the hazardous liquid or carbon dioxide on the pipeline and take
adequate steps to mitigate internal corrosion….
OPS alleged in the Notice that Respondent violated 49 C.F.R. § 195.579 by failing to investigate
the corrosive effect of its products being transported. Specifically, the Notice and Violation
Report alleged that Respondent failed to perform inspections on dead legs, low points, facility
and non-piggable pipe, and in areas downstream of supplier taps. OPS alleged that these areas
had the potential to collect water that would corrode the pipeline but that Respondent failed to
monitor them for internal corrosion. OPS further alleged that Respondent had been unable to
12 Id. at 3.
13 Violation Report, at 9.
14 NACE International, RP0169, paragraph 6.1.5 (2002).
15 66 Fed. Reg. at 66999.



6
present evidence that it was meeting the requirements of the regulation, other than pointing to a
few internal coupons that had been inappropriately located on the pipeline.
In its Response and at the hearing, BP Pipelines contended that it had examined the facilities
included in the OPS inspection for internal corrosion. As evidence of its investigation
techniques, the company stated that its In-Line Inspection (ILI) results demonstrated the non-
corrosive nature of its crude oil and that the company had not experienced internal corrosion on
these lines. In addition, the company indicated that it had instituted a Facility Integrity
Management Program (FIMP) in 2005 that focused on internal corrosion. Prior to commencing
the program, BP Pipelines had replaced sections of pipe, eliminating dead legs and low-flow
piping. Finally, after the OPS inspection, Respondent performed a sample analysis of the crude
oil transported in its systems, which confirmed its non-corrosive nature.
I have reviewed the record and find that BP Pipelines violated § 195.579. Crude oil can be
corrosive if it contains water or other electrolytes. BP Pipelines was using internal coupons on
this line, demonstrating that the company itself recognized the potential corrosivity of the
products being transported. Under the regulation, BP Pipelines had an obligation to investigate
the corrosive effect of the product being transported and to take “adequate steps” to mitigate
internal corrosion. At the time of the inspection, Respondent failed to meet these affirmative
obligations.
The fact that this line had not had a history of internal corrosion spills is not persuasive.
Although BP Pipelines had not experienced a spill caused by internal corrosion, this fact alone
did not eliminate the possibility of a future incident, nor did it eliminate BP Pipelines’
responsibility to investigate the corrosive nature of its products. Although ILI results are
excellent corrosion indicators for piggable lines, additional preventive and mitigating measures
were necessary. Respondent should have identified the factors that could influence the formation
of internal corrosion, focusing on alignment changes such as dead legs and low points where
water could settle and lead to internal corrosion. Respondent also should have engaged in more
sampling activities. A periodic sampling of product only tests for corrosivity at specific times
and does not reflect a continuous sample of the product.
Finally, in its Response, BP Pipelines pointed to its FIMP program. However, this program was
instituted in 2005, after the OPS inspection had raised the alleged violation. Although the FIMP
program should benefit Respondent’s facilities by removing internal corrosion that has occurred,
Respondent was required to take other steps to effectively investigate and monitor the corrosive
nature of its product. Accordingly, having reviewed the evidence in the record, I find that BP
Pipelines violated § 195.579 by failing to investigate the corrosive effect of its product on the
pipeline and take adequate steps to mitigate internal corrosion.
Item 6: The Notice alleged that Respondent violated 49 C.F.R. § 195.432(b) and (d), which
states:



7
§ 195.432 Inspection of in-service breakout tanks.
(a) Except for breakout tanks inspected under paragraphs (b) and
(c) of this section, each operator shall, at intervals not exceeding 15
months, but at least once each calendar year, inspect each in-service
breakout tank.
(b) Each operator shall inspect the physical integrity of in-service
atmospheric and low-pressure steel aboveground breakout tanks according
to section 4 of API Standard 653. However, if structural conditions
prevent access to the tank bottom, the bottom integrity may be assessed
according to a plan included in the operations and maintenance manual
under § 195.402(c)(3).
(c) Each operator shall inspect the physical integrity of in-service
steel aboveground breakout tanks built to API Standard 2510 according to
section 6 of API 510.
(d) The intervals of inspection specified by documents referenced
in paragraphs (b) and (c) of this section begin on May 3, 1999, or on the
operator’s last recorded date of the inspection, whichever is earlier.
The Notice alleged that BP Pipelines violated § 195.432(b) and (d) by failing to inspect its in-
service breakout tanks at pump stations and at the Cushing Tank Farm in compliance with
Section 4 of API 653, as incorporated by reference in the pipeline safety regulations. Pursuant to
API 653, operators must perform routine visual inspections of in-service breakout tanks, at
intervals not exceeding one month, and document certain areas of non-compliance for follow-up
action.16 Both OPS and the Respondent agree that BP Pipelines conducted the required
inspections. However, OPS alleged in the Notice and Violation Report that the company failed
to document and correct certain areas of non-compliance, as prescribed by API 653.
Specifically, the inspector noted broken and spalling concrete ring walls, cavities under tanks
made by animals and washouts, settlement around tank perimeters, exterior paint failure and
corrosion, lack of sealant between tank bottom and concrete ringwall, rivet/seam leakage, flange
that it was impossible to determine from Respondent’s records whether these issues were
leaks and leaks around flange bolts, and signs of leakage at mixers.17 In the Notice, OPS alleged
documented and resolved. OPS maintained that these items should have been documented
during monthly inspections and corrected before the next inspection.
In response, BP Pipelines asserted that it had inspected its breakout tanks as required by API
653. As part of its Response, BP Pipelines submitted follow-up reports for API 653 inspections
that had been performed on 14 tanks. The company also indicated that it had voluntarily
modified its procedures to require summary reports within 30 days of the API 653 inspections.
Finally, the company provided an analysis from Frishmuth Consulting Services, LLC, dated
August 20, 2007, confirming that the reinforcing plates for Tank 6965, located in Monroe
Station, Texas, were fit for service.
16 “Tank Inspection, Repair, Alteration, and Reconstruction,” American Petroleum Institute Standard 653, Section 6,
“Inspection”, ¶ 6.3, Third Edition, December 2001, Addendum 1, September 2003.
17 Violation Report, at 14.



8
Having reviewed the evidence in the record, I find that BP Pipelines violated § 195.432 by
failing to inspect its in-service breakout tanks in accordance with API 653. Respondent had an
obligation to conduct routine visual inspections of in-service breakout tanks, at intervals not
exceeding one month, and document certain areas of non-compliance for follow-up action.
Although Respondent did conduct the inspections, it could not demonstrate that areas of non-
compliance were documented for follow-up. In addition, certain follow-up actions, such as the
analysis of the reinforcing plates for Tank 6965, occurred after the Notice was issued.
Accordingly, I find that BP Pipelines violated § 195.432 by failing to inspect its in-service
breakout tanks in accordance with API 653.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
WITHDRAWAL OF ALLEGATION
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.410, which states:
§ 195.410 Line markers.
(a) Except as provided in paragraph (b) of this section, each
operator shall place and maintain line markers over each buried pipeline in
accordance with the following:
(1) Markers must be located at each public road crossing, at each
railroad crossing, and in sufficient number along the remainder of each
buried line so that its location is accurately known….
(c) Each operator shall provide line marking at locations where the
line is above ground in areas that are accessible to the public.
The Notice alleged that BP Pipelines violated 49 C.F.R. § 195.410 by failing to place and
maintain line markers along its East Oklahoma Pipeline in sufficient number that the location of
the line was accurately known. Specifically, the Notice alleged that the OPS inspector could not
see Respondent’s next line marker when looking in both directions from each valve site, a
measure commonly referred to as the “line-of-sight” test. In addition, when crossing cultivated
fields, an individual frequently could not see Respondent’s line markers on the far side of the
fields.
At the hearing and in its submissions, Respondent contended that its approach to positioning line
makers met the requirements of § 195.410 and that requiring additional markers beyond road
crossings and fences lines was often impractical. BP Pipelines stated that its procedures required
an annual review of its line markers and that between 2003 and 2006, it replaced 1500 line
markers for the systems identified in this OPS inspection.
18
BP Pipelines also asserted that it
conducted, as part of its Damage Prevention Program, a public awareness campaign in which
landowners were contacted regarding the location of the pipeline. Respondent argued that this
18 Response, at 3.



9
annual review and public awareness campaign fulfilled the regulatory requirements pertaining to
line markers.
OPS countered by arguing that problems arise when buried pipelines are not adequately marked.
Line markers are required by the pipeline safety regulations in order to prevent third-party
damage to pipelines. OPS was concerned that tractor operators and other farm workers may not
receive proper notice of the location of buried pipelines since they are often not the landowners
and therefore not notified during public awareness campaigns.
PHMSA acknowledges that while many operators follow the so-called “line-of-sight” test, as
applied in the Notice in this case, many others do not. Furthermore, the regulation does not
expressly require “line-of-sight.” In an effort to arrive at greater consensus on this and other
whether to issue a notice of proposed rulemaking. Under such circumstances, I find it is
appropriate to withdraw this allegation of violation. Such withdrawal neither constitutes an
interpretation of § 195.410(a)(1) nor prejudices future potential enforcement action against
Respondent or any other operator.
line-marking issues, PHMSA convened a public workshop in 200819 and is currently considering
ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to a civil penalty not to exceed $100,000 per
violation for each day of the violation, up to a maximum of $1,000,000 for any related series of
violations. In determining the amount of the civil penalty under 49 U.S.C. § 60122 and 49
C.F.R. § 190.225, I must consider the following criteria: the nature, circumstances, and gravity
of the violation, including adverse impact on the environment; the degree of Respondent’s
culpability; the history of Respondent’s prior offenses; the Respondent’s ability to pay the
penalty and any effect that the penalty may have on its ability to continue doing business; and the
good faith of Respondent in attempting to comply with the pipeline safety regulations. In
addition, I may consider the economic benefit gained from the violation without any reduction
because of subsequent damages, and such other matters as justice may require. The Notice
proposed a total civil penalty of $168,000 for the alleged violations.
As noted above, I have withdrawn Item 1 of the Notice, including the proposed penalty of
$26,000.
Item 2: The Notice proposed a penalty of $33,000 for Respondent’s violation of 49 C.F.R.
§ 195.436, for failing to provide protection for a number of pump stations, junctions, and scraper
trap facilities from vandalism and unauthorized entry. As noted above, I have found that BP
Pipelines violated § 195.436 by failing to provide protection for such facilities, as required by the
regulation. Unauthorized access to pipeline facilities presents a potential threat to the safety of
the public and the environment, as well as a risk to an operator’s personnel and equipment.
19 PHMSA held a public workshop on February 20-21, 2008, in Houston, Texas, to discuss, among other issues, the
placement of line markers. Pipeline Safety: Workshop on Public Awareness Programs for Pipeline Operators and
Location of Line Markers, 73 Fed. Reg 223 (Jan.2, 2008).



10
Without protection from vandalism and unauthorized entry, pipeline operators cannot protect
their facilities from damage and potential releases. Accordingly, having reviewed the record and
considered the assessment criteria, I assess Respondent a civil penalty of $33,000 for violating
49 C.F.R. § 195.436.
Item 3: The Notice proposed a penalty of $43,000 for Respondent’s violation of 49 C.F.R.
§ 195.573, for failing to conduct surveys to determine whether BP Pipelines’ cathodic protection
system complied with § 195.571. As noted above, I have found that the company failed to
conduct CP surveys required under the regulation. Inadequate cathodic protection can allow
corrosion to occur at rapid rates on pipelines. Corrosion is one of the major causes of pipeline
failure and can lead to leaks, ruptures, and explosions, presenting a major safety threat to the
public and the environment. In its Brief, BP Pipelines requested that the fine be eliminated on
account of the company’s corrective actions, including the revision of its procedures in 2004.
This argument was discussed above in the Findings section. The fact that BP revised its
procedures in 2004 in response to an NOA is not a defense to the violation alleged in the Notice.
The NOA focused on the Respondent’s procedures, whereas the Notice focused on the
company’s failure to implement these new procedures and therefore violated § 195.573. Since
this violation could create a major safety risk to the public and the environment, a civil penalty is
appropriate. It is noteworthy that this regulation was effective in 2002 and yet, during the
inspection, the company could not demonstrate compliance two years after the effective date. I
have considered the assessment criteria, including the gravity of the violation, the company’s
extended period of non-compliance, the location of the violation, and Respondent’s prior
enforcement history. Accordingly, having reviewed the record and considered the assessment
criteria, I assess Respondent a civil penalty of $43,000 for violating 49 C.F.R. § 195.573.
Item 4: The Notice proposed a penalty of $36,000 for Respondent’s violation of 49 C.F.R.
§ 195.579, for failing to investigate the corrosive effect of the product being transported. In its
Brief, BP Pipelines argued that it had complied with the regulation and therefore the violation
and fine should be eliminated. The facts supporting a violation of § 195.579 were addressed in
the Findings section. I have considered the assessment criteria, including, but not limited to, the
gravity, the circumstances of the violation, and the prior history of Respondent. Internal
corrosion is one of the major causes of pipeline failure and can lead to leaks and ruptures,
creating a safety risk for the public and environment. Accordingly, having reviewed the record
and considered the assessment criteria, I assess Respondent a civil penalty of $36,000 for
violating 49 C.F.R. § 195.579.
Item 6: The Notice proposed a civil penalty of $30,000 for Respondent’s violation of 49 C.F.R.
§ 195.432, for failing to inspect in-service breakout tanks in accordance with section 4 of API
Standard 653. Periodic inspections of breakout tanks and documentation of any areas of non-
compliance is important to prevent corrosion, settlement, or other threats to the integrity of these
facilities. These threats can lead to failure of the tank shell and threaten public safety. I have
considered the assessment criteria, including but not limited to, the gravity, the circumstances of
the violation, and the prior history of Respondent. Accordingly, I assess Respondent a civil
penalty of $30,000 for violating 49 C.F.R. § 195.432.



11
In summary, having reviewed the record and considered the assessment criteria for each of the
Items cited above, I assess Respondent a total civil penalty of $142,000.
Payment of the civil penalty must be made within 20 days of service. Federal regulations
(49 C.F.R. § 89.21(b)(3)) require this payment be made by wire transfer, through the Federal
Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed
instructions are contained in the enclosure. Questions concerning wire transfers should be
directed to: Financial Operations Division (AMZ-341), Federal Aviation Administration, Mike
Monroney Aeronautical Center, P.O. Box 269039, Oklahoma City, OK 73125. The Financial
Operations Division telephone number is (405) 954-8893.
Failure to pay the $142,000 civil penalty will result in accrual of interest at the current annual
rate in accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to
those same authorities, a late penalty charge of six percent (6%) per annum will be charged if
payment is not made within 110 days of service. Furthermore, failure to pay the civil penalty
may result in referral of the matter to the Attorney General for appropriate action in a United
States District Court.
COMPLIANCE ORDER
The Notice proposed a Compliance Order with respect to Items 1, 2, 3, 4, and 6 of the Notice.
Under 49 U.S.C. § 60118(a), each person who engages in the transportation of hazardous liquids
or who owns or operates a pipeline facility is required to comply with the applicable safety
standards established under Chapter 601. The Director has indicated that Respondent has
demonstrated completion of the actions listed in the proposed compliance order for Items 1, 2, 3,
and 6. However, Respondent has not completed the actions proposed for Item 4 of the Notice.
Therefore, BP Pipelines must install monitoring equipment and, if active corrosion is discovered,
implement mitigation methods to meet the requirements of § 195.579. Although the company
has removed and replaced dead legs on its pipeline system, it must still implement mitigation
methods.
Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is
ordered to take the following actions in regards to Item 4 of the Notice to ensure compliance
with the pipeline safety regulations applicable to its operations:
1. Perform an assessment of the pipelines and facilities reviewed in this enforcement
matter to determine if there are areas that would be susceptible to internal corrosion.
Perform inspections, install monitoring, and, if active corrosion is determined,
implement migration methods. 20
20 As discussed on page one of this Final Order, this Compliance Order covers the following systems: the Seaway
Products Texas System, the Seaway Oklahoma Unit, the East System Oklahoma Unit, the West System, the
Northwest System, and the Cushing Tank Farm. To the extent that Centurion Pipeline, L.P., or ConocoPhillips
Pipeline Company currently owns or operates any of these facilities, the companies should assess them for internal
corrosion or be subject to future enforcement action.



12
2. BP Pipelines must maintain documentation of the safety improvement costs
associated with fulfilling this Compliance Order and submit the total to R.M. Seeley,
Director, Southwest Region, Pipeline and Hazardous Materials Safety
Administration. Costs shall be reported in two categories: 1) total cost associated
with preparation/revision of plans, procedures, studies, and analyses, and 2) total cost
associated with replacements, additions and other changes to pipeline infrastructure.
3. BP Pipelines must complete the terms of this Compliance Order within 365 days
following receipt of the Final Order.
The Director, Southwest Region, PHMSA, may grant an extension of time to comply upon a
written request timely submitted by Respondent demonstrating good cause for an extension.
Failure to comply with this Order may result in the administrative assessment of civil penalties
not to exceed $100,000 for each violation for each day the violation continues or in referral to the
Attorney General for appropriate relief in a district court of the United States.
WARNING ITEMS
With respect to Items 5 and 7, the Notice alleged probable violations of Part 195 but did not
propose a civil penalty or compliance order for these items. Therefore, these are considered to
be warning items. The warnings were for:
49 C.F.R. § 195.420 (Notice Item 5) ─ Respondent’s alleged failure to provide
protection for each valve from unauthorized operation and vandalism; and
49 C.F.R. § 195.581 (Notice Item 7) ─ Respondent’s alleged failure to clean and
coat each pipeline or portion of pipeline that is exposed to the atmosphere.
In regards to Item 5, some of the operator’s valves were located above-ground and were not
fenced in; the operator did not protect these facilities from vandalism. BP Pipelines indicated in
its procedures that these facilities should be secured by locked chain link fencing.
In regards to Item 7, Respondent failed to maintain the coating of several breakout tank roofs,
above-ground valves, piping in opened vaults, and exposed pipeline areas. The coating on
several of these facilities had failed or was failing, leaving the pipe or tank top susceptible to
external corrosion. This coating should be replaced to prevent corrosion.
Having considered such information, I find, pursuant to 49 C.F.R. § 190.205, that the probable
violations listed in Items 5 and 7 have occurred as of the date of the inspection.
In the event that OPS finds a violation for any of these items in a subsequent inspection, BP
Pipelines may be subject to future enforcement action.



13
Under 49 C.F.R. § 190.215, Respondent has a right to submit a Petition for Reconsideration of
this Final Order. The petition must be sent to: Associate Administrator, Office of Pipeline
Safety, PHMSA, 1200 New Jersey Avenue, S.E., East Building, 2nd Floor, Washington, DC
20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address. PHMSA
will accept petitions received no later than 20 days after receipt of service of this Final Order by
the Respondent, provided that all petitions contain a brief statement of the issue(s) and meet all
other requirements of 49 C.F.R. § 190.215. The filing of the petition automatically stays the
payment of any civil penalty assessed. Unless the Associate Administrator, upon request, grants
a stay, all other terms and conditions of this Final Order are effective upon service in accordance
with 49 C.F.R. § 190.5.
___________________________________ __________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

420075003_Decision on the Petition for Reconsideration_02042011 .pdf

of Transportation
U.S. Department
FEB 4 2D11
1200 New Jersey Ave., SE
Washington, DC 20590
peline and Hazardous Materia
fety Administratio
Mr. Steve Pankhurst
President
BP Pipelines (North America), Inc.
28100 Torch Parkway
Warrenville, IL 60555
Re: CPF No. 4-2007-5003
Dear Mr. Pankhurst:
Enclosed please find the Decision on the Petition for Reconsideration filed by BP Pipelines
(North America), Inc., in the above-referenced case. It denies your Petition and affirms the Final
Order without modification. Service of the Decision by certified mail is deemed effective upon
the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc:
Mr. Rod M. Seeley, Director, Southwest Region, PHMSA
Mr. Rob Knanishu, BP Pipelines (North America), Inc.
CERTIFIED MAIL - RETURN RECEIPT REQUESTED| 7005 1160 0001 0040 0009]



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, DC 20590
In the Matter of
BP Pipelines (North America), Inc.,
CPF No. 4-2007-5003
Petitioner.
DECISION ON PETITION FOR RECONSIDERATION
On July 19, 2010, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued
a Final Order in this case to BP Pipelines (North America), Inc. (BP or Petitioner), finding that
BP had committed four violations of the hazardous liquid pipeline safety regulations and
assessing a total civil penalty of $168,000. The Final Order also required BP to take certain
corrective measures and warned the company of two additional probable violations.
On August 12, 2010, BP filed a Petition for Reconsideration (Petition) seeking review of Item 6,
which found the company in violation of 49 C.F.R. § 195.432, the regulation requiring an
operator to inspect each in-service breakout tank at least once each calendar year. BP also
sought reconsideration of the associated civil penalty ($30,000). BP did not dispute the other
findings or civil penalty assessments.
Section 190.215 provides that a respondent may petition the Associate Administrator for
reconsideration of a final order. It provides that the Associate Administrator will not consider
repetitious information, arguments, or petitions, but may consider additional facts or arguments,
provided that the respondent submits a valid reason why such information was not presented
prior to issuance of the final order. This rule allows a respondent to present information or
arguments that were unavailable or unknown prior to issuance of the final order, and gives
PHMSA an opportunity to correct any errors. The Associate Administrator may grant or deny,
in whole or in part, a petition for reconsideration without further proceedings, or may request
additional information, data, and comment as deemed appropriate.
Finding of Violation of § 195.432(b) and (d)
In its Petition, BP asserts that it performed a review to ensure that its breakout tanks at the
Cushing Tank farm were in compliance with § 195.432 and that all requirements of API 653
were in fact met. The Final Order specifically acknowledged that BP conducted visual
inspections of the tanks in question but found that the operator did not properly document its
follow-up efforts.



2
In its Petition, BP refers to hard copies of records allegedly available at the time of the inspection
and states that the inspector failed to review these documents. Specifically, the Petitioner states
that "the data and results generated during API 653 internal and external inspections were
present, along with a report showing resolution of any issues discovered during the inspection
and an explanation of any issues that were not resolved." BP previously made this argument and
it was evaluated and considered prior to issuance of the Final Order? BP also argues that it
voluntarily modified its procedures after the inspection, upon the recommendation of the OPS
inspector, and yet PHMSA used this voluntary action to support a finding of violation. Finally,
Petitioner argues that a subsequent September 2009 inspection by OPS of these same tanks did
not result in any new alleged violations, implying that the later inspection somehow reflects tacit
approval by OPS of BP's documentation of its follow-up actions.
Petitions for reconsideration provide a vehicle for respondents to submit evidence not previously
available during the proceeding. As stated above, the Associate Administrator does not consider
repetitious information but may consider additional facts or arguments, provided that the
respondent submits a valid reason why such information was not presented prior to issuance of
the final order.
All of the evidence BP submitted in its Response, Post-Hearing brief (Brief), and at the hearing
were reviewed prior to issuance of the Final Order. This review included the Tank
Recommended Repair Checklist for 14 tanks, which BP submitted at the hearing, and the
Monroe Tank analysis conducted after the inspection. These documents reflect follow up
review and repairs after the OPS 2004-05 inspections. All of the follow up inspections and
repairs should have occurred after BP's regular API 653 inspections and not after OPS brought
these areas to the operator's attention.
BP has not provided any additional documents that were not previously reviewed or provided a
valid reason why any additional documents were not produced at the hearing or within the Brief.
BP has had full opportunity to present this evidence before, during and after the hearing but has
failed to do so. In addition, the fact that no Notice of Violation has yet been issued against BP
arising out of the September 2009 inspection does not vitiate or affect any violation that had
occurred as of the date of the 2004-05 OPS inspection.
Finally, BP argues that the fine assessed in the Final Order is disproportionate in comparison to
the finding of violation. In determining the amount of a civil penalty under 49 U.S.C. § 60122
and 49 C.F.R. § 190.225, I must consider the following criteria: the nature, circumstances, and
gravity of the violation, including adverse impact on the environment; the degree of the
' Petition, at 2.
2 BP stated in its March 23, 2007 Response to the Notice that "[it] made such documentation available at the time of
the inspection by means of hard copy files in multiple boxes and believes that those records indicate compliance
with BP's interpretation of API 653 recommendations." Response, at 7.
3 The Final Order erroneously stated that the Monroe Tank analysis report was conducted after the Notice was
However, since the timing of this report occurred after the OPS inspection, it does not cure the violation that BP
issued. PHMSA acknowledges that this report was conducted after the inspection but before the Notice was issued.
failed to document its follow-up efforts pursuant to API 653.



3
respondent's culpability; the history of the respondent's prior offenses; the respondent's ability
to pay the penalty and any effect that the penalty may have on its ability to continue doing
business; and the good faith of the respondent in attempting to comply with the pipeline safety
regulations. In addition, I may consider the economic benefit gained from the violation without
any reduction because of subsequent damages, and such other matters as justice may require. At
the time of the 2004-05 inspection, PHMSA cited BP for failing to comply with § 195.432, for
five of the 112 tanks. The number of tanks involved was taken into account in calculating the
proposed penalty. Accordingly, I find no basis for any reduction of the $30,000 civil penalty
assessed in the Final Order.
Conclusion
Based on a review of the record and the information provided in the Petition, I hereby deny the
Petition and affirm the Final Order without modification, for the reasons set forth above.
Payment of the $168,000 civil penalty must be made within 20 days of service of this Decision.
The payment instructions were set forth in detail in the Final Order. Failure to pay the $168,000
civil penalty will result in accrual of interest at the current annual rate in accordance with 31
U.S.C. § 3717, 31 C.F.R. § 901.9, and 49 C.F.R. § 89.23. Pursuant to those same authorities, a
late penalty charge of six percent (6%) per annum will be charged if payment is not made within
110 days of service. Furthermore, failure to pay the civil penalty may result in referral of the
matter to the Attorney General for appropriate action in a United States District Court.
In addition, the Petitioner is reminded that the Compliance Order was not stayed by the filing of
the Petition and must be completed within 365 days from July 19, 2010, the date of the Final
Order.
This Decision is the final administrative action in this proceeding.
FEB 4 2011
Jeffrey D. Wiese
Date Issued
Associate Administrator
for Pipeline Safety

420075003_Amended Decision on the Petition for Reconsideration_02172011_text.pdf

FEB 17 2011
Mr. Steve Pankhurst
President
BP Pipelines (North America), Inc.
28100 Torch Parkway
Warrenville, IL 60555
Re: CPF No. 4-2007-5003
Dear Mr. Pankhurst:
Please find enclosed an Amended Decision on the Petition for Reconsideration filed in the
above-referenced case. This Amended Decision supersedes the Decision issued on
February 4, 2011. The Decision erroneously assessed a civil penalty of $168,000. As you are
aware, the Final Order issued on July 19, 2010 withdrew Item 1 and the associated civil penalty
of $26,000 making the total assessed civil penalty $142,000. Your petition only raised issues
regarding Item 6 and was denied, therefore, the total assessed civil penalty remains $142,000.
Pursuant to § 190.227, BP Pipelines (North America), Inc. must make the $142,000 payment
within 20 days of receipt of this Amended Decision. Service of the Amended Decision by
certified mail is deemed effective upon the date of mailing, or as otherwise provided under 49
C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Rod M. Seeley, Director, Southwest Region, PHMSA
Mr. Rob Knanishu, BP Pipelines (North America), Inc.
CERTIFIED MAIL – RETURN RECEIPT REQUESTED [7005 1160 0001 0041 3610]



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, DC 20590
____________________________________
In the Matter of )
BP Pipelines (North America), Inc., ) CPF No. 4-2007-5003
)
)
)
Petitioner. )
____________________________________)
AMENDED DECISION ON PETITION FOR RECONSIDERATION
On July 19, 2010, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued
a Final Order in this case to BP Pipelines (North America), Inc. (BP or Petitioner), finding that
BP had committed four violations of the hazardous liquid pipeline safety regulations and
assessing a total civil penalty of $142,000. The Final Order also required BP to take certain
corrective measures and warned the company of two additional probable violations.
On August 12, 2010, BP filed a Petition for Reconsideration (Petition) seeking review of Item 6,
which found the company in violation of 49 C.F.R. § 195.432, the regulation requiring an
operator to inspect each in-service breakout tank at least once each calendar year. BP also
sought reconsideration of the associated civil penalty ($30,000). BP did not dispute the other
findings or civil penalty assessments.
Section 190.215 provides that a respondent may petition the Associate Administrator for
reconsideration of a final order. It provides that the Associate Administrator will not consider
repetitious information, arguments, or petitions, but may consider additional facts or arguments,
provided that the respondent submits a valid reason why such information was not presented
prior to issuance of the final order. This rule allows a respondent to present information or
arguments that were unavailable or unknown prior to issuance of the final order, and gives
PHMSA an opportunity to correct any errors. The Associate Administrator may grant or deny,
in whole or in part, a petition for reconsideration without further proceedings, or may request
additional information, data, and comment as deemed appropriate.
Finding of Violation of § 195.432(b) and (d)
BP’s Petition
In its Petition, BP asserted that it performed a review to ensure that its breakout tanks at the
Cushing Tank farm were in compliance with § 195.432 and that all requirements of API 653
were in fact met. BP referred to hard copies of records allegedly available at the time of the
inspection and stated that the inspector failed to review these documents. Specifically, the



2
Petitioner stated that “the data and results generated during API 653 internal and external
inspections were present, along with a report showing resolution of any issues discovered during
voluntarily modified its procedures after the inspection, upon the recommendation of the OPS
inspector, and yet PHMSA used this voluntary action to support a finding of violation. Further,
not result in any new allegations of a violation. Finally, BP argued that the fine assessed in the
the inspection and an explanation of any issues that were not resolved.”1 BP also argued that it
Petitioner argued that a subsequent September 2009 inspection by OPS of these same tanks did
Final Order is disproportionate in comparison to the finding of violation.
Analysis
Petitions for reconsideration provide a vehicle for respondents to submit evidence not previously
available during the proceeding. As stated above, the Associate Administrator does not consider
repetitious information but may consider additional facts or arguments, provided that the
respondent submits a valid reason why such information was not presented prior to issuance of
the final order.
BP has not provided any additional documents that were not previously reviewed. The Final
Order specifically acknowledged that BP conducted visual inspections of the tanks in question
but found that the operator did not properly document its follow-up efforts. All of the evidence
BP submitted in its Response, Post-Hearing brief (Brief), and at the hearing was reviewed prior
to issuance of the Final Order.2 This review included the Tank Recommended Repair Checklist
for 14 tanks, which BP submitted at the hearing, and the Monroe Tank analysis conducted after
API 653 inspections and not after OPS brought these areas to the operator’s attention. Moreover,
the inspection.3 inspections. All of the follow up inspections and repairs should have occurred after BP’s regular
the fact that no Notice of Violation has yet been issued against BP arising out of the September
2009 inspection does not vitiate or affect any violation that had occurred as of the date of the
2004-05 OPS inspection.
These documents reflect follow up review and repairs after the OPS 2004-05
In determining the amount of a civil penalty under 49 U.S.C. § 60122 and 49 C.F.R. § 190.225, I
considered the following criteria: the nature, circumstances, and gravity of the violation,
including adverse impact on the environment; the degree of the respondent’s culpability; the
history of the respondent’s prior offenses; the respondent’s ability to pay the penalty and any
effect that the penalty may have on its ability to continue doing business; and the good faith of
the respondent in attempting to comply with the pipeline safety regulations. My consideration
may also include the economic benefit gained from the violation without any reduction because
1 Petition, at 2.
2 BP stated in its March 23, 2007 Response to the Notice that “[it] made such documentation available at the time of
the inspection by means of hard copy files in multiple boxes and believes that those records indicate compliance
with BP’s interpretation of API 653 recommendations.” Response, at 7.
3 The Final Order erroneously stated that the Monroe Tank analysis report was conducted after the Notice was
issued. PHMSA acknowledges that this report was conducted after the inspection but before the Notice was issued.
However, since the timing of this report occurred after the OPS inspection, it does not cure the violation that BP
failed to document its follow-up efforts pursuant to API 653.



3
of subsequent damages, and such other matters as justice may require. Contrary to BP’s
argument that the assessed fine was disproportionate to the violation, the number of tanks was
taken into account in calculating the proposed penalty. Certainly, if more than the five tanks had
been involved with this particular violation, a larger fine may have been assessed. As stated in
the Final Order, I considered the assessment criteria in calculating this civil penalty, including
but not limited to, the gravity and circumstances of the violation and the prior history of the
Respondent. Accordingly, I find no basis for any reduction of the $30,000 civil penalty assessed
in the Final Order.
Conclusion
Based on a review of the record and the information provided in the Petition, I hereby deny the
Petition and affirm the Final Order without modification, for the reasons set forth above.
Payment of the $142,000 civil penalty must be made within 20 days of receipt of this Amended
Decision. The payment instructions were set forth in detail in the Final Order. Failure to pay the
$142,000 civil penalty will result in accrual of interest at the current annual rate in accordance
with 31 U.S.C. § 3717, 31 C.F.R. § 901.9, and 49 C.F.R. § 89.23. Pursuant to those same
authorities, a late penalty charge of six percent (6%) per annum will be charged if payment is not
made within 110 days of service. Furthermore, failure to pay the civil penalty may result in
referral of the matter to the Attorney General for appropriate action in a United States District
Court.
In addition, the Petitioner is reminded that the Compliance Order was not stayed by the filing of
the Petition and must be completed within 365 days from July 19, 2010, the date of the Final
Order.
This Amended Decision is the final administrative action in this proceeding.
_____________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

420075003_Decision on the Petition for Reconsideration_02042011_text.pdf

FEB 4 2011
Mr. Steve Pankhurst
President
BP Pipelines (North America), Inc.
28100 Torch Parkway
Warrenville, IL 60555
Re: CPF No. 4-2007-5003
Dear Mr. Pankhurst:
Enclosed please find the Decision on the Petition for Reconsideration filed by BP Pipelines
(North America), Inc., in the above-referenced case. It denies your Petition and affirms the Final
Order without modification. Service of the Decision by certified mail is deemed effective upon
the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Rod M. Seeley, Director, Southwest Region, PHMSA
Mr. Rob Knanishu, BP Pipelines (North America), Inc.
CERTIFIED MAIL – RETURN RECEIPT REQUESTED[ 7005 1160 0001 0040 0009]



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, DC 20590
____________________________________
In the Matter of )
BP Pipelines (North America), Inc., ) CPF No. 4-2007-5003
)
)
)
Petitioner. )
____________________________________)
DECISION ON PETITION FOR RECONSIDERATION
On July 19, 2010, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued
a Final Order in this case to BP Pipelines (North America), Inc. (BP or Petitioner), finding that
BP had committed four violations of the hazardous liquid pipeline safety regulations and
assessing a total civil penalty of $168,000. The Final Order also required BP to take certain
corrective measures and warned the company of two additional probable violations.
On August 12, 2010, BP filed a Petition for Reconsideration (Petition) seeking review of Item 6,
which found the company in violation of 49 C.F.R. § 195.432, the regulation requiring an
operator to inspect each in-service breakout tank at least once each calendar year. BP also
sought reconsideration of the associated civil penalty ($30,000). BP did not dispute the other
findings or civil penalty assessments.
Section 190.215 provides that a respondent may petition the Associate Administrator for
reconsideration of a final order. It provides that the Associate Administrator will not consider
repetitious information, arguments, or petitions, but may consider additional facts or arguments,
provided that the respondent submits a valid reason why such information was not presented
prior to issuance of the final order. This rule allows a respondent to present information or
arguments that were unavailable or unknown prior to issuance of the final order, and gives
PHMSA an opportunity to correct any errors. The Associate Administrator may grant or deny,
in whole or in part, a petition for reconsideration without further proceedings, or may request
additional information, data, and comment as deemed appropriate.
Finding of Violation of § 195.432(b) and (d)
In its Petition, BP asserts that it performed a review to ensure that its breakout tanks at the
Cushing Tank farm were in compliance with § 195.432 and that all requirements of API 653
were in fact met. The Final Order specifically acknowledged that BP conducted visual
inspections of the tanks in question but found that the operator did not properly document its
follow-up efforts.



2
In its Petition, BP refers to hard copies of records allegedly available at the time of the inspection
and states that the inspector failed to review these documents. Specifically, the Petitioner states
that “the data and results generated during API 653 internal and external inspections were
present, along with a report showing resolution of any issues discovered during the inspection
and an explanation of any issues that were not resolved.”1 BP previously made this argument and
it was evaluated and considered prior to issuance of the Final Order.
voluntarily modified its procedures after the inspection, upon the recommendation of the OPS
inspector, and yet PHMSA used this voluntary action to support a finding of violation. Finally,
Petitioner argues that a subsequent September 2009 inspection by OPS of these same tanks did
not result in any new alleged violations, implying that the later inspection somehow reflects tacit
approval by OPS of BP’s documentation of its follow-up actions.
2 BP also argues that it
Petitions for reconsideration provide a vehicle for respondents to submit evidence not previously
available during the proceeding. As stated above, the Associate Administrator does not consider
repetitious information but may consider additional facts or arguments, provided that the
respondent submits a valid reason why such information was not presented prior to issuance of
the final order.
All of the evidence BP submitted in its Response, Post-Hearing brief (Brief), and at the hearing
were reviewed prior to issuance of the Final Order. This review included the Tank
Recommended Repair Checklist for 14 tanks, which BP submitted at the hearing, and the
review and repairs after the OPS 2004-05 inspections. All of the follow up inspections and
repairs should have occurred after BP’s regular API 653 inspections and not after OPS brought
these areas to the operator’s attention.
Monroe Tank analysis conducted after the inspection.3 These documents reflect follow up
BP has not provided any additional documents that were not previously reviewed or provided a
valid reason why any additional documents were not produced at the hearing or within the Brief.
BP has had full opportunity to present this evidence before, during and after the hearing but has
failed to do so. In addition, the fact that no Notice of Violation has yet been issued against BP
arising out of the September 2009 inspection does not vitiate or affect any violation that had
occurred as of the date of the 2004-05 OPS inspection.
Finally, BP argues that the fine assessed in the Final Order is disproportionate in comparison to
the finding of violation. In determining the amount of a civil penalty under 49 U.S.C. § 60122
and 49 C.F.R. § 190.225, I must consider the following criteria: the nature, circumstances, and
gravity of the violation, including adverse impact on the environment; the degree of the
1 Petition, at 2.
2 BP stated in its March 23, 2007 Response to the Notice that “[it] made such documentation available at the time of
the inspection by means of hard copy files in multiple boxes and believes that those records indicate compliance
with BP’s interpretation of API 653 recommendations.” Response, at 7.
3 The Final Order erroneously stated that the Monroe Tank analysis report was conducted after the Notice was
issued. PHMSA acknowledges that this report was conducted after the inspection but before the Notice was issued.
However, since the timing of this report occurred after the OPS inspection, it does not cure the violation that BP
failed to document its follow-up efforts pursuant to API 653.



3
respondent’s culpability; the history of the respondent’s prior offenses; the respondent’s ability
to pay the penalty and any effect that the penalty may have on its ability to continue doing
business; and the good faith of the respondent in attempting to comply with the pipeline safety
regulations. In addition, I may consider the economic benefit gained from the violation without
any reduction because of subsequent damages, and such other matters as justice may require. At
the time of the 2004-05 inspection, PHMSA cited BP for failing to comply with § 195.432, for
five of the 112 tanks. The number of tanks involved was taken into account in calculating the
proposed penalty. Accordingly, I find no basis for any reduction of the $30,000 civil penalty
assessed in the Final Order.
Conclusion
Based on a review of the record and the information provided in the Petition, I hereby deny the
Petition and affirm the Final Order without modification, for the reasons set forth above.
Payment of the $168,000 civil penalty must be made within 20 days of service of this Decision.
The payment instructions were set forth in detail in the Final Order. Failure to pay the $168,000
civil penalty will result in accrual of interest at the current annual rate in accordance with 31
U.S.C. § 3717, 31 C.F.R. § 901.9, and 49 C.F.R. § 89.23. Pursuant to those same authorities, a
late penalty charge of six percent (6%) per annum will be charged if payment is not made within
110 days of service. Furthermore, failure to pay the civil penalty may result in referral of the
matter to the Attorney General for appropriate action in a United States District Court.
In addition, the Petitioner is reminded that the Compliance Order was not stayed by the filing of
the Petition and must be completed within 365 days from July 19, 2010, the date of the Final
Order.
This Decision is the final administrative action in this proceeding.
_____________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

420075003_Closure_04172012_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
April 17, 2012
Mr. Steve Pankhurst
President
BP Pipelines (North America), Inc.
28100 Torch Parkway
Warrenville, IL 60555
CPF 4-2007-5003
Dear Mr. Pankhurst:
On July 19, 2010, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued
to BP Pipelines (North America), Inc. a Final Order in the above-referenced case. This Order
included a Compliance Order and Civil Penalty assessment. Based on our review of the
documentation you provided and confirmation of payment of the civil penalty, it has been
determined that you have complied with the terms of this Order.
Accordingly, this case is now closed and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous
Materials Safety Administration

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/420075003>
- Source ID: `phmsa-enforcement`
- SHA-256: `d1a9afbd58cf0b3668139c7ae0acf6ab94dc3c65579ca775b3416365fc7b2300`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T20:01:01.776Z
- Document slug: `phmsa-enforcement-420075003`

### Source metadata

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```