# CHAPARRAL ENERGY, LLC — Corrective Action Order

**Citation:** CPF 420155017H  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2015-08-28

CLOSED corrective action order.

## Document text

Corrective Action Order involving CHAPARRAL ENERGY, LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2015-08-28 and is reported as closed as of 2019-12-03. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420155017H_Closure Letter_09162019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155017H/420155017H_Closure%20Letter_09162019.pdf

420155017H_Closure Letter_09162019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155017H/420155017H_Closure%20Letter_09162019_text.pdf

420155017H_Corrective Action Order_08282015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155017H/420155017H_Corrective%20Action%20Order_08282015.pdf

420155017H_Corrective Action Order_08282015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155017H/420155017H_Corrective%20Action%20Order_08282015_text.pdf

420155017H_Post-Hearing Decision Regarding CAO_10082015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155017H/420155017H_Post-Hearing%20Decision%20Regarding%20CAO_10082015.pdf

420155017H_Post-Hearing Decision Regarding CAO_10082015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155017H/420155017H_Post-Hearing%20Decision%20Regarding%20CAO_10082015_text.pdf

420155017H_Post-Hearing Decision Regarding CAO_10082015_text.pdf

VIA CERTIFIED MAIL AND FAX TO: 405-425-8421
Mr. Mark A. Fischer
Chairman & CEO
Chaparral Energy, LLC
701 Cedar Lake Blvd.
Oklahoma City, OK 73114
Re: CPF No. 4-2015-5017H
Dear Mr. Fischer:
Please find enclosed the Post-Hearing Decision regarding the Corrective Action Order issued to
Chaparral Energy, LLC on August 28, 2015. The Decision confirms the Corrective Action
Order with respect to the Coffeyville pipeline. This Decision is being served by facsimile and
certified mail in accordance with 49 C.F.R. § 190.5. The terms of the decision are effective upon
receipt.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS
Mr. R.M. Seeley, Director, Southwest Region, OPS
Mr. Ahren Tryon, Tryon Law Firm (via email to atryon@tryonenergy.com)



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
___________________________________
)
In the Matter of )
)
Chaparral Energy, LLC, ) CPF No. 4-2015-5017H
)
Respondent. )
___________________________________ )
POST-HEARING DECISION CONFIRMING
CORRECTIVE ACTION ORDER
On August 28, 2015, the Associate Administrator for Pipeline Safety, Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), issued a Corrective
Action Order (CAO) under authority of 49 U.S.C. § 60112 and 49 C.F.R. § 190.233, finding that
continued operation by Chaparral Energy, LLC (Chaparral or Respondent) of its Coffeyville
carbon dioxide (CO2) pipeline would be hazardous to life, property, or the environment. The
CAO made preliminary findings that the hazards were associated with a failure of the pipeline
discovered August 25, 2015, and the hazards would continue unless certain corrective measures
were taken. The CAO also found that failure to issue the order expeditiously without prior
notice would result in a likelihood of serious harm to life, property, or the environment.
Pursuant to § 190.233, Respondent requested expedited review of the CAO to determine whether
the order should remain in effect. In accordance with 49 C.F.R. §§ 190.211 and 190.233(c), a
hearing was held October 1, 2015, in Houston, Texas, before a Presiding Official from the Office
of Chief Counsel, PHMSA, who presided by video teleconference.
At the hearing, Respondent provided an overview of its pipeline system, discussed the
characteristics of CO2, updated factual information about the pipeline accident, and argued the
CAO should be terminated because there is not a hazardous condition. In the alternative,
Respondent requested that the terms of the corrective action be amended.
Background
On August 25, 2015, at 9:00 a.m. CDT, Chaparral received a report from a landowner of a vapor
cloud in the area of its Coffeyville CO2 pipeline. Chaparral personnel arrived on site shortly
before 10:00 a.m. CDT and confirmed there was a pipeline leak. Personnel closed valves
upstream and downstream of the failure and blew down the line between the two valves, a total
distance of 20 miles, by 12:35 p.m. CDT.



CPF No. 4-2015-5017H
Page 2
It is not known when the release started. The pipeline was not operating when the accident was
discovered, but it was shut-in at operating pressure. After looking at pressure recording charts,
Respondent initially believed the release started approximately 7 days prior to discovery.
Respondent later revised that estimate to 2-3 days prior to discovery.
Respondent initially estimated that the amount of CO2 released as a result of the failure was
2,648 barrels. At the hearing, Respondent explained this early estimate was made without
benefit of knowing the size of the hole. Based on more accurate information concerning the hole
size, Respondent believed the failure resulted in a release of only 28 barrels. Even if the release
occurred for 7 days, Respondent stated the release would still be less than 100 barrels. The
blowdown resulted in an additional 6,800 barrels of CO2 released. Respondent reported that
property damage as a result of the release was less than $11,000.
The accident occurred in a remote location and did not cause any injuries, evacuations, or
impacts to the environment. Video of the release shows CO2 vapor rising through an opening in
the ground above the pipeline. As the vapor gets five to ten feet off the ground, it moves
downwind and then dissipates into the atmosphere. Respondent reported the plume of vapor was
approximately 15 feet downwind.
Respondent repaired the pipeline and returned it to service under a restart plan approved by the
Director pursuant to the terms of the CAO. The failed section of pipe was sent to a metallurgical
lab for testing under protocols approved by the Director. An inline inspection was also
performed on the pipeline. The results of the metallurgical testing and inline inspection are
pending.
Photographs of the removed pipe show what appears to be localized external corrosion with two
pinholes. Respondent’s preliminary investigation leads the Company to believe the external
corrosion was caused by stray current from a nearby pipeline.
The Coffeyville pipeline was constructed in 2012 and consists of 8-inch, 0.220” nominal wall
thickness, Grade X-65 pipe. The pipeline began operating in 2013. When Chaparral performed
a deformation tool run following construction, Respondent identified an area with 43% wall loss
from external corrosion. The pipeline has experienced two failures since operations began, both
seemingly caused by external corrosion. In addition to the failure discovered August 25, 2015,
there was an earlier failure discovered May 4, 2015.
Chaparral operates approximately 300 miles of pipeline transporting CO2 in Texas, Oklahoma,
and Kansas. The Coffeyville pipeline is approximately 68 miles long and transports CO2 from
the Coffeyville Resources Nitrogen Fertilizer Plant in Coffeyville, Kansas, to the North Burbank
production field near Shidler, Oklahoma. The pipeline travels through Montgomery County in
Kansas and the counties of Nowata, Washington, and Osage in Oklahoma. The failure occurred
near the end of the pipeline in proximity to Shidler, Oklahoma. The maximum operating
pressure (MOP) of the pipeline is 2,220 psig, established by hydrostatic test in 2013. The
pressure at the point of the failure was approximately 1,100 psig when the failure occurred.



CPF No. 4-2015-5017H
Page 3
Standard for Reviewing Issuance of a Corrective Action Order
The authority for issuing a CAO is specified in 49 U.S.C. § 60112 and 49 C.F.R.
§ 190.233. Under those provisions, the Associate Administrator may issue a CAO if a pipeline
facility is or would be hazardous to life, property, or the environment. Prior notice to the
operator of the facility must be given before issuance of a CAO, but prior notice may be waived
if the Associate Administrator finds that failure to do so would result in the likelihood of serious
harm to life, property, or the environment. The CAO may include corrective measures including
suspended or restricted use of the facility, physical inspection, testing, repair, replacement, or
other appropriate action.
The primary purpose of a hearing following issuance of a CAO without prior notice is to
determine whether the CAO should remain in effect or be terminated or amended.1 If the
Associate Administrator finds the facility is or would be hazardous to life, property, or the
environment, the Associate administrator confirms the CAO. If the Associate Administrator
does not find the facility is or would be hazardous, the Associate Administrator terminates the
order.
In making such a determination, the Associate Administrator must consider, if relevant: (1) the
characteristics of the pipe and other equipment used in the pipeline facility, including its age,
manufacturer, physical properties (including its resistance to corrosion and deterioration), and
the method of its manufacture, construction or assembly; (2) the nature of the materials
transported (including their corrosive and deteriorative qualities), and the pressure required for
such transportation; (3) the characteristics of the geographical areas in which the pipeline facility
is located, in particular the climatic and geologic conditions (including soil characteristics)
associated with such areas, and the population density and population and growth patterns of
such areas; and (4) any other factors the Associate Administrator consider appropriates. These
factors are considered below.
(1) Characteristics of the Pipe
The Coffeyville pipeline is relatively new. It was constructed in 2012 and began operating in
2013. New pipe generally presents a lower risk of time dependent threats because such
conditions, like external corrosion, usually take extended periods of time to develop and
potentially lead to a failure.
Despite being relatively new, Respondent’s pipeline has already experienced external corrosion
significant enough to cause multiple failures. In addition to the August 25, 2015, failure that
gave rise to this proceeding, Respondent’s pipeline experienced a failure in May 2015 that was
also preliminarily attributed to external corrosion. An estimated 4.5 barrels of CO2 were
released as a result of that failure, with estimated property damage of approximately $13,000.
Blowdown of the line after the May 2015 release resulted in the loss of 6,800 barrels of CO2.
1 § 190.233(b).



CPF No. 4-2015-5017H
Page 4
Also, following construction of Respondent’s pipeline, Chaparral performed a deformation tool
run that identified an area with 43% wall loss due to external corrosion.
The Coffeyville pipeline is evidently not resistant to external corrosion at the level required for
safe operation of the facility. The rate at which Respondent’s new pipeline has developed
significant wall loss from corrosion is concerning. Without immediate corrective action,
including investigation and remediation, more corrosion and potential pipeline failures would
likely occur.
(2) Nature of the Materials Transported
Respondent reported that the CO2 transported by the Coffeyville pipeline is 99.984% pure and
does not contain any flammable or toxic hydrocarbons. Respondent explained that CO2 is an
odorless, colorless, non-flammable gas. It occurs naturally in the atmosphere, is used by plants,
produced by humans during respiration, and produced in various manufacturing and industrial
facilities. Respondent contended that the CO2 transported by the Coffeyville pipeline presents
very little hazard.
At atmospheric pressure CO2 is a gas. At higher pressures, CO2 enters a supercritical fluid state,
resembling the density of a liquid. This occurs at a critical pressure of roughly over 1,000 psig.
Pipelines transporting CO2 are operated at very high pressures to keep the product in a
supercritical fluid state. Respondent stated that most CO2 pipelines are operated between 1,200
and 3,000 psig. The maximum operating pressure of the Coffeyville pipeline is 2,220 psig.
Since the line has no pump stations, pressure decreases as product moves downstream. Pressure
at the failure location near the end of the pipeline was estimated to be 1,100 psig at the time of
the accident.
Respondent produced information about CO2 from the Occupational Safety and Health
Administration (OSHA) website. The OSHA documentation confirmed CO2 is a colorless,
odorless, non-flammable gas. It is also classified as an asphyxiant gas.2 In the atmosphere, CO2
normally exists at concentrations between 300-700 ppm. The OSHA permissible exposure limit
is 5,000 ppm. Exposure to higher concentrations can result in increased respiratory rate,
headache, convulsions, dizziness or narcosis. At 30,000 ppm there may be loss of
consciousness; at 40,000 ppm, CO2 becomes immediately dangerous to life.3
Chaparral argued the risk of such harm resulting from a pipeline release is very low, since the
release would be in the open air. Respondent noted that the August 25, 2015, release resulted in
a released concentration of CO2 of just under 3,100 ppm, which is less than the OSHA
permissible exposure limit. Respondent also cited a presentation by an individual from the
University of Texas who concluded the likelihood of a fatality from a CO2 pipeline failure was
2 Chaparral Pre-hearing Submission, Supporting Documentation (SD) at 97.
3 Chaparral SD at 93.



CPF No. 4-2015-5017H
Page 5
less than the likelihood of a fatality from a lightning strike.4 In conclusion, Respondent argued
the nature of CO2 does not support finding Respondent’s pipeline is or would be hazardous to
life, property, or the environment.
PHMSA agrees the information presented by Respondent demonstrates CO2 does not pose the
same risk as hazardous liquids that are flammable or toxic. PHMSA notes the pipeline safety
regulations in 49 C.F.R. Part 195 define hazardous liquids to include petroleum, petroleum
products, anhydrous ammonia, and ethanol, but supercritical CO2 is not included in that
definition.
When PHMSA initially proposed amending the safety regulations in 1989 to include CO2
pipelines, the Agency noted that CO2 differed from flammable and toxic substances already
regulated under the definition of hazardous liquid.5 Therefore, PHMSA proposed to regulate
CO2 pipelines in Part 195 without calling CO2 a hazardous liquid.
This is not to say CO2 pipelines are without risk. The primary hazard of CO2, as noted by
PHMSA in the proposed rule, is the potential for asphyxiation if a high concentration is
accidentally released from a pipeline. PHMSA noted that Congressional concerns over the
safety of CO2 pipelines were reflected in the Pipeline Safety Reauthorization Act of 1988, which
directed the Agency to amend Part 195 to ensure the safety of CO2 pipelines. As documented in
the proposed rule, Congress recognized despite “its pervasive nature and absolute necessity to
life, CO2 has the potential to be as lethal as any other gas when it is present in concentrations
greater than 10 percent. This could happen if a CO2 pipeline ruptured.”6
Since then, PHMSA has applied the pipeline safety regulations to supercritical CO2 pipelines
and hazardous liquid pipelines in essentially the same manner. For example, integrity
management regulations require “each hazardous liquid pipeline and carbon dioxide pipeline that
could affect a high consequence area” to be covered by an integrity management program (IMP)
designed to ensure greater safety in those areas.7 Operators must design, test, operate, and
maintain CO2 pipelines to prevent accidental release just as they must for hazardous liquids
pipelines. Accidents must be reported for both hazardous liquid and carbon dioxide pipelines.8
Respondent has made a strong case that the risks of CO2 are generally considered to be less than
other hazardous liquids, but there are still risks. PHMSA has determined through rulemaking
4 Chaparral SD at 149.
5 Transportation of Carbon Dioxide by Pipeline, 54 Fed. Reg. 41912, 41914 (proposed Oct. 12, 1989).
6 54 Fed. Reg. at 41913.
7 § 195.452. Respondent noted that some high consequence areas, namely unusually sensitive
environmental areas, are only applicable to hazardous liquid pipelines. Populated areas, which are of
importance here, are applicable to both hazardous liquid pipelines and CO2 pipelines.
8 §§ 195.50 and 195.52.



CPF No. 4-2015-5017H
Page 6
that the risks inherent to the transportation of CO2 by pipeline must be managed to protect life
and property. The nature of the CO2 transported by Respondent’s pipeline is no less hazardous.
(3) Characteristics of the Geographical Areas in Which the Pipeline Facility Is Located
Respondent’s pipeline is approximately 68 miles long and travels through the high consequence
area (HCA) of Coffeyville, Kansas, at the very beginning of the pipeline. There are two other
HCAs that could be affected by the pipeline. South Coffeyville, Oklahoma, is 471 feet from
Respondent’s pipeline near the beginning of the line. Shidler, Oklahoma, is 0.51 miles from the
pipeline near the end. All three HCAs are populated areas.
The remainder of the 68-mile pipeline, including the location of the failure, is rural. Pictures
from the location of the failure show flat, grassy land in all four directions. The Director noted
that Respondent’s pipeline traverses ravines and low-lying areas, which could pose a risk of CO2
pooling in higher concentrations.
Respondent argued that if corrosion is being caused by stray current, then the risk of corrosion is
confined to the later portion of the Coffeyville pipeline where a third-party pipeline runs parallel.
Respondent noted that both pipeline failures and wall loss anomaly occurred in the later portion
of the Coffeyville line. Respondent reasoned that the HCAs near the beginning of the pipeline
are not subject to the same risk. Respondent also questioned whether its pipeline could actually
affect the HCA near the end of the line.
PHMSA notes that the cause of the external corrosion has not yet been determined to be stray
current from the parallel pipeline. Until such a decision is reached, PHMSA cannot discount the
possibility that additional corrosion could develop and lead to failure affecting an HCA. Also
the risks to persons and property from a CO2 pipeline release in a rural area cannot be entirely
discounted. In fact, the August 25, 2015, failure was discovered by a local land owner.
(4) Other Appropriate Factors
Respondent presented several other arguments to support its position that the CAO should be
terminated. Firstly, Respondent noted that the August 25, 2015, accident did not meet the
regulatory threshold for immediate telephonic reporting.
PHMSA recognizes the revised volume of product released would not have exceeded the
threshold for immediate telephonic reporting. Respondent initially believed the release resulted
in the loss of 2,648 barrels, which exceeds the threshold for immediate reporting. It should be
noted that Respondent was still required to file a written accident report under § 195.50, because
the accident resulted in the loss of more than 5 barrels of product.
Respondent also analyzed past data on CAOs, telephonic reports, and PHMSA accident reports
to demonstrate the relatively low risk of CO2 pipeline failures and the absence of past
enforcement by the Agency similar to this case. For example, Respondent looked at all CAOs
issued since 2005, and found virtually all involved either fire, evacuation, environmental



CPF No. 4-2015-5017H
Page 7
damage, affected water, closure of roadway, or a high consequence area. Respondent’s pipeline
failure did not involve any of those.
Respondent analyzed telephonic reports to the National Response Center since 1990, including
all 24 reports involving releases of CO2 from a pipeline. None involved a fatality, injury, or
damage to wildlife or the environment. Only one involved an evacuation, and Chaparral
theorized this was due to the presence of hydrogen sulfate with the CO2.
Respondent then analyzed PHMSA 7000.1 Accident Reports filed by operators since 1994,
including all 71 reports involved CO2 pipeline released. Respondent found zero fatalities,
injuries, fires, damage to environment, evacuations, or third-party property damage.
The data submitted by Respondent demonstrates the Agency does not have a history of issuing
CAOs for pipeline failures involving CO2. The Parties can only postulate as to the reasons for
an absence of enforcement. The assumption of Chaparral that this could be due to the lack of
serious consequences associated with CO2 accidents is a plausible explanation.
In reviewing the issuance of the CAO in this case, however, PHMSA must evaluate the facts of
this particular accident to determine if the Coffeyville pipeline is or would be hazardous. The
data provided by Respondent, while informative of past Agency practice, has limited relevance
to this evaluation because it does not concern the actual facts of this case. I find it more relevant
to consider the characteristics of the Coffeyville pipeline, the nature of CO2 transported by the
pipeline, and the geographical areas through which the pipeline travels.
Analysis and Finding of Hazardousness
As noted above, the characteristics of Respondent’s pipeline are concerning. The pipeline has
already experienced two corrosion failures and another significant corrosion anomaly in the short
period of time it has been in operation. The cause of the corrosion has not yet been determined,
and therefore has not been remediated. The evidence suggests Respondent’s pipeline is
experiencing corrosion at an usually high rate and the pipeline would likely experience more
failures caused by corrosion until appropriate corrective action is taken. Such failures could
affect populated areas.
There are documented risks of CO2 in elevated concentrations even if the product does not
present the same level of risk as flammable and toxic liquids. A CO2 pipeline experiencing
periodic failures resulting in uncontrolled releases of product at very high pressures is a
hazardous condition that must be promptly addressed to ensure safety. Given all of these
considerations, the evidence in the record demonstrates there is a hazardous condition that
warrants continuation of the CAO.
Whether the Terms of the CAO Should Be Amended
Respondent requested, in the alternative, that the CAO be amended. Specifically, at the hearing
Chaparral requested the pressure restriction be modified. Following the hearing, Chaparral
submitted a document requesting several other modifications.



CPF No. 4-2015-5017H
Page 8
(1) Pressure Restriction
The pressure restriction in Paragraph 3 of the CAO states that when Chaparral returns the
Coffeyville pipeline to service “the operating pressure must not exceed eighty percent (80%)
of the actual operating pressure in effect immediately prior to the Failure.”
Respondent argued this pressure restriction is problematic from a technical standpoint because it
would prevent Respondent from delivering CO2 in a supercritical state. The pipeline was
operating at approximately 1,100 psig at the location of the failure when the accident occurred.
Eighty percent of that pressure is approximately 880 psig, which is below the pressure required
for CO2 in a supercritical state. Chaparral suggested that a revised pressure restriction should be
80% of MOP.
From a legal perspective, Respondent also argued the pressure restriction would be problematic
because the pipeline safety regulations in 49 C.F.R. Part 195 apply to pipelines that transport
CO2 in a supercritical state. Respondent contended that if at any point in time the CO2 is not in
a supercritical state, the pipeline cannot be subject to Part 195.
Operating a pipeline at no more than 80% of the highest pressure the line was safely operated or
tested is a long-established method of ensuring an appropriate safety margin. For example,
under Part 195, pipelines may be operated at a pressure up to 80% of their test pressure.9 When
a pipeline failure occurs, the terms of any CAO will regularly require a similar margin of safety
based on the level of pressure on the line when the failure occurred.
After considering Respondent’s technical position, PHMSA finds the hazardous condition
requires the same margin of safety until Respondent can demonstrate it is safe to resume
operations on the Coffeyville pipeline at its pre-failure level. The Director has authority under
the existing terms of the CAO to modify the pressure restriction upon a showing that a pressure
increase is safe.
With regard to the legal argument, PHMSA disagrees with Respondent’s contention that the
pipeline would not be subject to Part 195 at a lower pressure. The Coffeyville pipeline is subject
to the pipeline safety regulations by virtue of its regular transport of CO2 in a supercritical state.
The pipeline remains subject to those regulations, including applicable maintenance
requirements, during any temporary conditions involving lowered pressure, shutdown, idling, or
purging of product.
(2) Other Amendments
Following the hearing, Respondent submitted a document requesting additional amendments to
the terms of the CAO. These amendments were not discussed at the hearing.
9 § 195.406.



CPF No. 4-2015-5017H
Page 9
Pressure test or ILI in lieu of pressure restriction. As an alternative to its proposal for a revised
pressure restriction, Respondent requested to return the pipeline to service either after
performing a pressure test or submitting certain ILI data. Since these proposals were not
discussed at the hearing, PHMSA finds no basis to amend the CAO at this time. The Director
has authority under the existing terms of the CAO to remove or modify the pressure restriction
upon a showing that a pressure increase is safe.
Time periods. Respondent requested to change the 90-day time period to 150 days for
performing a root cause failure analysis and for developing a remediation work plan. Chaparral
also requested to delay the start date for quarterly reporting. No reason was given for these
requested extensions. PHMSA finds no basis to amend the CAO in this regard. The Director
has authority under the existing terms of the CAO to grant an extension of time for compliance
with any of the terms in the order upon a written request timely submitted demonstrating good
cause for an extension.
Completed actions. Respondent requested to eliminate a provision in the CAO regarding the
remedial work plan because the Company has already performed the required ILI tool run.
PHMSA finds no reason to amend the CAO to eliminate provisions that are satisfied; by
definition, completed terms require no further action.
Scope of remedial work plan. Respondent requested to eliminate a provision regarding the
remedial work plan that requires Chaparral to determine if conditions similar to those
contributing to the August 25, 2015, failure are likely to exist elsewhere within the Company’s
pipeline systems. Respondent did not provide an argument for why Chaparral should not be
required to perform this action. PHMSA finds no support to eliminate this provision.
Conclusion
The CAO issued to Chaparral Energy, LLC on August 28, 2015, is confirmed and will remain in
effect without change to its terms or deadlines.
_______________________________ _______________________
Jeffrey D. Wiese, Date Issued
Associate Administrator
for Pipeline Safety

420155017H_Corrective Action Order_08282015_text.pdf

August 28, 2015
VIA CERTIFIED MAIL AND FAX TO: 405-425-8421
Mr. Mark A. Fischer
Chairman & CEO
Chaparral Energy, LLC
701 Cedar Lake Blvd.
Oklahoma City, OK 73114
Re: CPF No. 4-2015-5017H
Dear Mr. Fischer:
Enclosed is a Corrective Action Order issued in the above-referenced case. It requires Chaparral
Energy, LLC, to take certain corrective actions with respect to its Coffeyville CO2 line that
failed on August 25, 2015, near Shidler, Oklahoma. Service is being made by certified mail and
facsimile. Service of the Corrective Action Order by electronic transmission is deemed complete
upon transmission and acknowledgement of receipt, or as otherwise provided under 49 C.F.R.
§ 190.5. The terms and conditions of this Order are effective upon completion of service.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS
Mr. Rodrick Seeley, Southwest Regional Director, OPS



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Chaparral Energy, LLC, ) CPF No. 4-2015-5017H
)
)
)
Respondent. )
____________________________________)
CORRECTIVE ACTION ORDER
Purpose and Background:
This Corrective Action Order (Order or CAO) is being issued, under the authority of 49 U.S.C.
§ 60112, to require Chaparral Energy, LLC (Chaparral or Respondent), to take the necessary
corrective action to protect the public, property, and the environment from potential hazards
associated with the recent failure on Chaparral’s Coffeyville carbon dioxide (CO2) pipeline.
On August 25, 2015, a reportable accident occurred on the Coffeyville CO2 line, resulting in the
release of approximately 2,648 barrels of carbon dioxide (Failure). The Coffeyville CO2 line
(Coffeyville Line) is an 8-inch diameter pipeline approximately 65.7 miles in length that
transports carbon dioxide from the Coffeyville Resources Nitrogen Fertilizer Plant in
Coffeyville, Kansas, to the North Burbank production fields near Shidler, Oklahoma. The cause
of the Failure has not yet been determined. Pursuant to 49 U.S.C. § 60117, the Pipeline and
Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), initiated
an investigation of the accident. The preliminary findings of the ongoing investigation are as
follows.
Preliminary Findings:
• Chaparral is a privately owned company with oil and gas operations and 480 employees
operating in Oklahoma, the Texas Panhandle and Southwest Kansas.1
• The Coffeyville Pipeline System consists of 67.5 miles of 8" carbon dioxide pipeline
running from the Coffeyville Resources Nitrogen Fertilizer Plant in Coffeyville, Kansas,
to the North Burbank production field near Shidler, Oklahoma. The pipeline originates in
Montgomery County, Kansas, and travels through Nowata, Washington, and Osage
1 See http://www.chaparralenergy.com/operations. Current as of August 27, 2015.



CPF No. 4-2015-5017H
Page 2
Counties, Oklahoma, a distance of approximately 67.5 miles (Affected Segment). The
Failure occurred 1.7 miles east of mainline valve (MLV) 14 between milepost (MP) 67
and MP 66 near Shidler, Oklahoma (Failure Site).
• The Coffeyville Line was installed in 2012 and began operating in 2013. The Affected
Segment consists of 8-inch diameter, 0.220” wall thickness and Grade X65 pipe. The
pipe was manufactured in 2011, and the pipe at the Failure Site has not had any changes
in material since its installation.
• The maximum operating pressure (MOP) of the pipeline is 2,220 psig, as established by
hydrostatic test in 2013. At the time of the Failure, the pipeline was not operating.
Chaparral received a report from a landowner regarding a potential leak on the
company’s Coffeyville Line at 9:00 a.m. CST on August 25, 2015. Chaparral personnel
arrived on site shortly before 10 a.m. CST and confirmed the leak and resulting release of
approximately 2,648 barrels of carbon dioxide from the pipeline. Review of data
indicates the leak may have started as early as August 18, 2015. The Failure occurred in a
remote location, and was reported to the National Response Center (NRC Report No.
1126631) on August 25, 2015, at approximately 10:36 a.m. CST.
• The Coffeyville Line was shut-in at the time of the Failure since the source plant at
Coffeyville was offline. After notification from the landowner regarding a vapor cloud,
Chaparral responded to the site and closed the valves immediately upstream and
downstream of the failure location. The MLV at valve location 12 was closed at 11:55 am
CST, and the MLV at valve location 13 was closed at 12:35 p.m. CST. Chaparral “blew
down” the line from both valve locations (MLV 12 & MLV 13) at 12:35 p.m. CST, a
total distance of 20 miles.
• The Failure occurred in a remote location so PHMSA was the only agency to respond to
the scene.
• The cause of the Failure is unknown and the investigation is ongoing. The Coffeyville
Line was installed in 2012 and began operating in 2013. Since the line has been in
service, there has been both a reported corrosion failure on May 4, 2015, and an
excavated dig site that identified a section of pipe with a 43% wall loss. Preliminary
indications from the Failure also indicate the presence of external corrosion on the
pipeline. Chaparral did not have adequate cathodic protection on the line until the year
following initial construction. The pipeline currently remains out of service.
• The accident did not cause any known injuries and no one was evacuated. There are no
impacts to any water body. A vapor cloud was formed from released CO2, but has since
cleared.
• Following construction of the pipeline, a deformation in-line inspection tool was run
through the pipeline. The tool run resulted in the identification of 19 anomalies.
Chaparral has recently completed the investigation of those anomalies and made repairs
to all but one of the anomalies as required. One of the anomalies identified by the pre-
operational dent tool indicated a 43% wall loss due to external corrosion.



CPF No. 4-2015-5017H
Page 3
Determination of Necessity for Corrective Action Order and Right to Hearing:
Section 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action
Order, after reasonable notice and the opportunity for a hearing, requiring corrective action,
which may include the suspended or restricted use of a pipeline facility, physical inspection,
testing, repair, replacement, or other action, as appropriate. The basis for making the
determination that a pipeline facility is or would be hazardous, requiring corrective action, is set
forth both in the above-referenced statute and 49 C.F.R. § 190.233, a copy of which is enclosed.
Section 60112 and the regulations promulgated thereunder provide for the issuance of a
Corrective Action Order, without prior notice and opportunity for hearing, upon a finding that
failure to issue the Order expeditiously would result in the likelihood of serious harm to life,
property, or the environment. In such cases, an opportunity for a hearing and expedited review
will be provided as soon as practicable after the issuance of the Order.
After evaluating the foregoing preliminary findings of fact, I find that continued operation of the
pipeline without corrective measures is or would be hazardous to life, property, or the
environment. Additionally, having considered the release of product from the pipeline that
resulted in a vapor cloud that could have affected the public and would be a problem in a
subsequent release (the line originates in a populated area and traverses through populated areas
and CO2 is an asphixyant), the risk to the environment which would result in frostbite to skin
and eyes or the formation of frozen ground during a high pressure release from the pipeline, and
a history of known problems on this pipeline, I find that a failure to issue this Order
expeditiously to require immediate corrective action would result in the likelihood of serious
harm to life, property, or the environment.
Accordingly, this Corrective Action Order mandating immediate corrective action is issued
without prior notice and opportunity for a hearing. The terms and conditions of this Order are
effective upon receipt.
Within 10 days of receipt of this Order, Respondent may contest its issuance and obtain
expedited review, either by answering in writing or requesting a hearing under 49 C.F.R.
§ 190.211, to be held as soon as practicable under the terms of such regulation, by notifying the
Associate Administrator for Pipeline Safety in writing, with a copy to the Director, Southwest
Region, PHMSA (Director). If Respondent requests a hearing, it will be held telephonically or
in-person in the Southwest Region office or Washington, D.C.
After receiving and analyzing additional data in the course of this investigation, PHMSA may
identify other corrective measures that need to be taken. In that event, PHMSA will notify
Respondent of any additional measures that are required and an amended Order issued, if
necessary. To the extent consistent with safety, Respondent will be afforded notice and an
opportunity for a hearing prior to the imposition of any additional corrective measures.
Required Corrective Actions:
The “Affected Segment” means the entire 67.8 miles of Chaparral’s 8-inch pipeline from its
origination in Coffeyville, Kansas, to Chaparral’s North Burbank production field near Shidler,



CPF No. 4-2015-5017H
Page 4
Oklahoma. The pipeline originates in Montgomery County, Kansas, and travels through Nowata,
Washington, and Osage Counties, Oklahoma.
The "Isolated Segment" means the 20-mile segment of Chaparral’s 8-inch Line from the
company’s MLV at valve location 12 to MLV 13. It is the portion of the "Affected Segment" that
was shut-in after the Failure on August 25, 2015, by closing main line valves MLV 12 (upstream
of the Failure Site) and MLV 13 (downstream of the Failure Site) and that must remain shut-in
until a restart plan is approved by the Director.
The "Director" means the Director, Pipeline and Hazardous Materials Safety Administration
(PHMSA), Office of Pipeline Safety, Southwest Region. The Director’s address is 8701 S.
Gessner, Suite 1110, Houston, Texas 77074.
Pursuant to 49 U.S.C. § 60112, I hereby order Chaparral to immediately take the following
corrective actions for the Affected Segment and Isolated Segment, as applicable:
CORRECTIVE ACTIONS:
1. 2. Shutdown of Pipeline. Chaparral must not operate the Affected Segment until authorized to
do so by the Director.
Restart Plan. Prior to resuming operation of the Affected Segment, develop and submit a
written Restart Plan to the Director for prior approval.
a. The Director may approve the Restart Plan incrementally without approving the entire
plan but the Affected Segment cannot resume operation until the Restart Plan is approved
in its entirety.
b. Once approved by the Director, the Restart Plan will be incorporated by reference into
this Order.
c. d. e. f. g. The Restart Plan must provide for adequate patrolling of the Affected Segment during the
restart process and must include incremental pressure increases during start up, with each
increment to be held for at least two hours.
The Restart Plan must include sufficient surveillance of the pipeline during each pressure
increment to ensure that no leaks are present when operation of the line resumes.
The Restart Plan must specify a day-light restart and include advance communications
with local emergency response officials.
The Restart Plan must provide for a review of the Affected Segment for conditions similar
to those of the Failure, including a review of construction, operating and maintenance
(O&M) and integrity management records such as in-line inspection (ILI) results,
hydrostatic tests, root cause failure analysis of prior failures, aerial and ground patrols,
corrosion, cathodic protection, excavations and pipe replacements. Operator must
address any findings that require remedial measures to be implemented prior to restart.
The Restart Plan must also include documentation of the completion of all mandated
actions, and a management of change plan to ensure that all procedural modifications are
incorporated into Chaparral’s operations and maintenance procedures manual.



CPF No. 4-2015-5017H
Page 5
3. Return to Service. After the Director approves the Restart Plan, Chaparral may return the
Affected Segment to service but the operating pressure must not exceed eighty percent (80%)
of the actual operating pressure in effect immediately prior to the Failure.
4. Removal of Pressure Restriction.
a. The Director may allow the removal or modification of the pressure restriction upon a
written request from Chaparral, demonstrating that restoring the pipeline to its pre-failure
operating pressure is justified based on a reliable engineering analysis showing that the
pressure increase is safe, considering all known defects, anomalies, and operating
parameters of the pipeline.
5. The Director may allow the temporary removal or modification of the pressure restrictions
upon a written request from Chaparral demonstrating that temporary mitigative and
preventive measures are implemented prior to and during the temporary removal or
modification of the pressure restriction. The Director's determination will be based on the
failure cause and provision of evidence that preventative and mitigative actions taken by the
operator provide for the safe operation of the Affected Segment during the temporary removal
or modification of the pressure restriction. Appeals to determinations of the Director in this
regard will be decided by the Associate Administrator for Pipeline Safety.
6. Mechanical and Metallurgical Testing. Within 45 days of receipt of this Order, complete
mechanical and metallurgical testing and failure analysis of the failed pipe, including an
analysis of soil samples and any foreign materials. Complete the testing and analysis as
follows:
a. Document the chain-of-custody when handling and transporting the failed pipe section
and other evidence from the Failure Site.
b. Within 10 days of receipt of this Order, develop and submit the testing protocol and the
proposed testing laboratory to the Director for prior approval.
c. Prior to beginning the mechanical and metallurgical testing, provide the Director with the
scheduled date, time, and location of the testing to allow for an OPS representative to
witness the testing.
d. Ensure the testing laboratory distributes all reports whether draft or final in their entirety
to the Director at the same time they are made available to Chaparral.
7. Root Cause Failure Analysis. Within 90 days following receipt of this Order, complete a
root cause failure analysis (RCFA) and submit a final report of this RCFA to the Director.
The RCFA must be supplemented/facilitated by an independent third-party acceptable to the
Director and must document the decision-making process and all factors contributing to the
Failure. The final report must include findings and any lessons learned and whether the
findings and any lessons learned are applicable to other locations within Chaparral’s pipeline
system.
8. Remedial Work Plan (RWP).
a. Within 90 days following receipt of this Order, Chaparral must submit a Remedial Work
Plan (RWP) to the Director for approval.
b. c. The Director may approve the RWP incrementally without approving the entire RWP.
Once approved by the Director, the RWP will be incorporated by reference into this Order.



CPF No. 4-2015-5017H
Page 6
d. The RWP must specify the tests, inspections, assessments, evaluations, and remedial
measures Chaparral will use to verify the integrity of the Affected Segment. It must address
all known or suspected factors and causes of the Failure. Chaparral should consider both
the risk of another failure and the consequence of another failure to develop a prioritized
schedule for RWP related work along the Affected Segment.
e. The RWP must include a procedure or process to:
i. Identify pipe in the Affected Segment with characteristics similar to the contributing
factors identified in the August 25, 2015 Failure.
ii. Gather all data necessary to review the failure history (in service and pressure test
failures) of the Affected Segment and to prepare a written report containing all the
available information such as the locations, dates, and causes of leaks and failures.
iii. Integrate the results of the metallurgical testing, root cause failure analysis, and other
corrective actions required by this Order with all relevant pre-existing operational and
assessment data for the Affected Segment. Pre-existing operational data includes, but
is not limited to, construction, operations, maintenance, testing, repairs, prior
metallurgical analyses, and any third party consultation information. Pre-existing
assessment data includes, but is not limited to, ILI tool runs, hydrostatic pressure
testing, direct assessments, close interval surveys, and DCVG/ACVG surveys.
iv. Determine if conditions similar to those contributing to the Failure are likely to exist
elsewhere within the Chaparral pipeline systems.
v. Conduct additional field tests, inspections, assessments, and/or evaluations to
determine whether, and to what extent, the conditions associated with the Failure and
other failures from the failure history or any other integrity threats are present
elsewhere on the Affected Segment. At a minimum, this process must consider all
failure causes and specify the use of one or more of the following:
1) ILI tools that are technically appropriate for assessing the pipeline system based
on the cause of Failure on August 25, 2015 and that can reliably detect and
identify anomalies;
2) Hydrostatic pressure-testing;
3) Close-interval surveys;
4) Cathodic protection surveys, to include interference surveys in coordination with
other utilities (e.g. underground utilities, overhead power lines, etc.) in the area;
5) Coating surveys;
6) Stress corrosion cracking surveys;
7) Selective seam corrosion surveys; and
8) Other tests, inspections, assessments, and evaluations appropriate for the failure
causes.
vi. Note: Chaparral may use the results of previous tests, inspections, assessments, and
evaluations if approved by the Director, provided the results of the tests, inspections,
assessments, and evaluations are analyzed with regard to the factors known or
suspected to have caused the August 25, 2015 Failure.
Describe the inspection and repair criteria Chaparral will use to prioritize, excavate,



CPF No. 4-2015-5017H
Page 7
vii. viii. f. g. evaluate, and repair anomalies, imperfections, and other identified integrity threats.
Include a description of how any defects will be graded and a schedule for repairs or
replacement.
Based on the known history and condition of the Affected Segment, describe the
methods Chaparral will use to repair, replace, or take other corrective measures to
remediate the conditions associated with the Failure and to address other known
integrity threats along the Affected Segment.
Implement continuing long-term periodic testing and integrity verification measures
to ensure the ongoing safe operation of the Affected Segment, considering the results
of the analyses, inspections, evaluations, and corrective measures undertaken
pursuant to the Order.
Include a proposed schedule for completion of the RWP.
Chaparral must revise the RWP as necessary to incorporate new information obtained
during the failure investigation and remedial activities, to incorporate the results of actions
undertaken pursuant to this Order, and/or to incorporate modifications required by the
Director.
i. Submit any plan revisions to the Director for prior approval.
ii. The Director may approve plan revisions incrementally.
iii. Any and all revisions to the RWP after it has been approved and incorporated by
reference into this Order will be fully described and documented in the CAO
Documentation Report (CDR).
Implement the RWP as it is approved by the Director, including any revisions to the plan.
Reporting. Submit quarterly reports to the Director that: (1) include all available data
and results of the testing and evaluations required by this Order; and (2) describe the
progress of the repairs or other remedial actions being undertaken. The first quarterly
report is due on November 1, 2015. The Director may change the interval for the
submission of these reports
Other Requirements:
1. Documentation of Costs. It is requested but not required that Respondent maintain
documentation of the costs associated with implementation of this Order. Include in each
monthly report the to-date total costs associated with: (1) preparation and revision of
procedures, studies and analyses; (2) physical changes to pipeline infrastructure,
including repairs, replacements and other modifications; and (3) environmental
remediation, if applicable.
Approvals. With respect to each submission requiring the approval of the Director, the
Director may: (a) approve the submission in whole or in part; (b) approve the submission
on specified conditions; (c) modify the submission to cure any deficiencies; (d)
disapprove the submission in whole or in part and direct Respondent to modify the
submission; or (e) any combination of the above. In the event of approval, approval upon
conditions, or modification by the Director, Respondent shall proceed to take all action
required by the submission, as approved or modified by the Director. If the Director
h. 9. 2.



CPF No. 4-2015-5017H
Page 8
disapproves all or any portion of a submission, Respondent must correct all deficiencies
within the time specified by the Director and resubmit it for approval.
3. Extensions of Time. The Director may grant an extension of time for compliance with
any of the terms of this Order upon a written request timely submitted and demonstrating
good cause for an extension.
The actions required by this Corrective Action Order are in addition to and do not waive any
requirements that apply to Respondent’s pipeline system under 49 C.F.R. Part 195, under any
other order issued to Respondent under authority of 49 U.S.C. § 60101, et seq., or under any
other provision of Federal or State law.
Respondent may appeal any decision of the Director to the Associate Administrator for Pipeline
Safety. Decisions of the Associate Administrator shall be final.
Be advised that all material you submit in response to this enforcement action is subject to being
made publicly available. If you believe that any portion of your responsive material qualifies for
confidential treatment under 5 U.S.C. 552(b), along with the complete original document you
must provide a second copy of the document with the portions you believe qualify for
confidential treatment redacted and an explanation of why you believe the redacted information
qualifies for confidential treatment under 5 U.S.C. 552(b).
Failure to comply with this Order may result in the assessment of civil penalties and in referral to
the Attorney General for appropriate relief in United States District Court pursuant to 49 U.S.C.
§ 60120.
In your correspondence on this matter, please refer to CPF No. 4-2015-5017H and for each
document you submit, please provide a copy in electronic format whenever possible.
The terms and conditions of this Corrective Action Order are effective upon receipt.
______________________ ______________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

420155017H_Closure Letter_09162019_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
September 16, 2019
Robert Sutherland
Senior Vice President Operations
Perdure Petroleum, LLC
12012 Wickchester Lane
Houston, Texas 77079
CPF No. 4-2015-5017H
Dear Mr. Sutherland:
On August 28, 2015, the Pipeline and Hazardous Materials Safety Administration (PHMSA)
issued a Corrective Action Order (CAO) to Chaparral Energy, LLC (Chaparral) for the Coffeyville
CO2 Pipeline. Perdure Petroleum, LLC (Perdure) acquired the Coffeyville CO2 Pipeline from
Chaparral on November 17, 2017, and immediately assumed operational control.
PHMSA monitored the actions taken within the Remedial Work Plan and reviewed records
submitted by Perdure. PHMSA has determined that the operator has substantially completed the
requirements of the CAO.
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,
Mary L. McDaniel, P.E.
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/420155017H>
- Source ID: `phmsa-enforcement`
- SHA-256: `49085a403a8cdc2c8c52032118e59da898d775d8d79788c1dc509cc77c3d2a52`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T20:16:36.002Z
- Document slug: `phmsa-enforcement-420155017h`

### Source metadata

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