{"operation":"document","citation":"CPF 320065033H","title":"BP OIL PIPELINE CO — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2006-03-29","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320065033h.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320065033h.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320065033h","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320065033H","body":"Corrective Action Order involving BP OIL PIPELINE CO. The dataset does not identify a cited regulation for this case. The case was opened on 2006-03-29 and is reported as closed as of 2013-03-12. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320065033H_Closure_03122013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320065033H/320065033H_Closure_03122013.pdf\n\n320065033H_Closure_03122013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320065033H/320065033H_Closure_03122013_text.pdf\n\n320065033H_Corrective Action Order_03292006.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320065033H/320065033H_Corrective%20Action%20Order_03292006.pdf\n\n320065033h_corrective action order_03292006_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320065033H/320065033h_corrective%20action%20order_03292006_text.pdf\n\n320065033h_corrective action order_03292006_text.pdf\n\nU 5 Department\nof Transportation\nPipeline and\nHozordoUs Materials Sofettr\nAdministration\n400 Seventh Street, S W\nWeehrngion, D C 20590\nIriAl 29\nHyped„\nMr Jim Lamanna\nPresident\nBP Pipehnes (North America), Inc\n28100 Torch Parkway\nWarrenville, IL 60555\nRe CPF No 3-2006-5033H\nDear Mr Lamanna\nEnclosed is a Corrective Action Order issued by the Associate Administrator for\nPipehne Safety in the above-referenced case It requires you to take certain corrective actions\nwith respect to your Toledo/West Toledo hazardous liquid pipehne, including successfully\nperforming hydrostatic testing, before resuming operations Service is being made by\ncertified mail and facsimile Your receipt of this Corrective Action Order constitutes service\nof that document under 49 C F R $ 190 5 The terms and conditions of this Corrective Action\nOrder are effective upon receipt\n3 Zpg,\nSincerely,\nJames Reynolds\nPipehne Comphance Registry\nEnclosure\ncc Ivan Huntoon\nDirector, Central Region, PHMSA\n\n\n\nDEPARTMENT OF TRAiVSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nWASHINGTON, DC 20590\nIn the Matter of )\nBP Pipelines (North America), Inc.\n)\n)\n, )\n)\nRespondent )\nCPF No 3-2006-5033H\nCORRECTIVE ACTION ORDER\nPur ose and Bac round\nThis Corrective Action Order is being issued, under authonty of 49 U S C ) 60112, to require\nBP Pipehnes (North America), Inc (Respondent) to take the necessary corrective action to\nprotect the public, property, and the environment from potential hazards associated with a\nfailure involving Respondent's Toledo/West Toledo hazardous hquid pipeline\nOn March 23, 2006, Respondent discovered a leak on its 6-inch Toledo/West Toledo pipeline\nin Toledo, Ohio Pursuant to 49 U S C ll 60117, the Pipehne and Hazardous Matenals Safety\nAdmiiustration (PHMSA) imtiated an investigation of the accident\nPrehminarv Findin s\n~ On March 23, 2006, at approximately 3 00 AM CST, Respondent's personnel at its Tulsa,\nOklahoma control center detected a reduction in pressure and flow on the Toledo/West\nToledo pipehne At 6 11 AM CST, Respondent reported the pipehne failure to the\nNational Response Center (NRC) (Incident Report No 791693)\n~ The failure resulted in a release currently estimated at 200 barrels of unleaded gasohne\nfrom the pipeline Respondent determined the location of the failure site to be at or near\nMile Post 6 7 near the intersection of Laskey and Tractor Roads on the west side of the\ncity of Toledo, Ohio Some of the gasoline migrated via drain tile into the Shantee Creek\nwhich flows to Lake Erie Potential impacts to ground-water and the environment are not\nyet known No fires, in)uncs, or fatalities were reported in connection with the accident\n~ Following the failure, Respondent shut down the pumps and closed the remote valve at the\nToledo Refinery and ceased operating the pipehne Respondent's personnel further\nisolated the failed pipe section by manually closing the mam-hne valves at Mile Posts\n\n\n\n4 66 7 08, and 8 33 Respondent also activated its spill response plan and set up\ncontainment booms along Shantee Creek\n~ The cause of the failure has not yet been determined Respondent s personnel conducted a\npreliminary visual examination at the failure site and identified a narrow, straight,\nlongitudinal split approximately 22-inches in length at the three o clock position on the\npipe Respondent has removed the pipe Joint containing the failure ortgm for transport to\na metallurgist for in-depth analysis\n~ The Toledo/West Toledo pipeline is approximately 14 3 miles long and transports refined\npetroleum products from the Toledo Refinery to the West Toledo Terminal in Lucas\nCounty, Ohio The pipeline runs through populated areas and is in close proximity to\nroads and railroads The enure length of the pipeline is located in a lugh-consequence\narea as defined in 49 C F R lJ 195 450\nRespondent's records indicate that the pipeline was installed in 1951 and is constructed of\n6 625-inch diameter, 0 250-inch wall thickness, grade X-42 seamless pipe It has a coal-\ntar coating and is cathodically protected by impressed current It is not yet known\nwhether the entire pipeline is seamless, or if portions of the line have welded seams, but\nthe type of failure is charactenstic of pipe with a longitudinal seam PHMSA has issued\nadvisory bulletins concerning the susceptibihty of pre-1970 electric-resistance welded\n(ERW) pipe to seam failures\n~ The maximum operating pressure (MOP) of the pipehne is 700 pounds per square-mch\ngauge (psig) The actual operating pressure at the failure site at the time of the failure is\nestimated to have been 350 psig\n~ The pipeline was internally mspected m 1996 and 2002 using both metal loss and\ngeometry tools The 2002 inspection resulted in four immediate repairs which were\ncompleted by January 2003 and mvolved pipe sleeving and/or coating None of these\nrepairs were performed at the failure site A corrosion anomaly of 26'/0 was identified in\nproximity to the failure site but was determined by Respondent to be witlun acceptable\nhmits for conunued safe operation\n~ Dunng the investigation of this release. another leak was identified at an above-ground\ncrossing located at Bennett Road on March 24, 2006 This leak appeared to be minor\nseepage through the pipe wall associated with external corrosion under the coating and\nwas also reported to the NRC\nDetermination of Necessitv for Correchve Action Order and Ri ht to Hearin\nSection 60112 of Title 49, United States Code, provides for the issuance of a Corrective\nAction Order, after reasonable notice and the opportunity for a heanng when PHMSA\ndetermines that operation of a pipehne facihty is or would be hazardous The basis for\ndetermming that a pipehne facihty is hazardous, requiring corrective action, is set forth both\nin the above-referenced statute and 49 C F R IJ 190 233, a copy of v:hich is enclosed\n\n\n\nSection 60112 of Title 49, United States Code, and the regulations promulgated thereunder,\nprovide for the issuance of a Corrective Action Order without prior opportunity for notice and\nheanng upon a finding that failure to issue the Order expeditiously will likely result in serious\nharm to life, property, or the environment In such cases, an opportunity for a hearing will be\nprovided as soon as practicable after the issuance of the Order\nAfter evaluating the foregoing prehminary findings of fact, and consideung the age of the\npipe, the hazardous nature of the product the pipehne transports, the spill volume, the\nproximity of the pipehne to populated areas, the proximity of the pipelme to waterways and\nenvironmentally sensitive areas, and the ongoing investigation to determine the cause of the\nfailure, I find that the continued operation of Respondent's Toledo/West Toledo hazardous\nhquid pipeline without corrective measures would be hazardous to h fe, property, or the\nenvironment I further find that failure to expeditiously issue this Order requiring immediate\ncorrective action will hkely result in serious harm to life, property, or the environment\nAccordingly, this Corrective Action Order mandating immediate corrective action is issued\nwithout prior notice and opportumty for heanng The terms and conditions of this Order are\neffective upon receipt\nWitlun 10 days of receipt of this Order, Respondent may request a hearing, to be held as soon\nas practicable, by notifying the Associate Administrator for Pipehne Safety in writing,\ndehvered personally, by mail or by facsimile at (202) 366-4566 The hearing will be held in\nKansas City, Missouri or Washington, D C on a date that is mutually convenient to PHMSA\nand the Respondent\nAfter receiving and analyzing additional data in the course of tlus investigation, PHMSA may\nidentify other corrective action measures that need to be taken In that event, Respondent will\nbe notified of any additional measures required and amendment of this Order will be\nconsidered To the extent consistent with safety considerations, Respondent will be afforded\nnotice and an opportunity for a hearing prior to the imposition of additional corrective\nmeasures\nRe uired Corrective Action\nPursuant to 49 U S C ) 60112, I hereby order BP Pipelines (North America), Inc to\nimmediately take the following corrective actions with respect to its Toledo/West Toledo\nhazardous liquid pipeline\nI Prior to resuming operation of the pipehne\n(A) Develop and submit a written plan for prior approval of the Director, Central\nRegion, PHMSA, to conduct a short-duration hydrostatic test to a mmimum nressure\nof 100% of SMYS or I 39 X MOP, followed by a 49 C F R Subpart E hydrostatic\ntest Provide the Regional Director with the date and time of the testing which\nPHMSA may elect to witness Conduct the hydrostatic testing as appropnate to the\n\n\n\ncondition(s) causing the March 23, 2006 failure, mcluding metallurgical analysis of\nany failures that occur dunng the testing, and\n(B) Obtain wntten approval prior to resuming operation from the Director, Central\nRegion, PHMSA The Regional Director's determination will be based on whether all\ncorrective actions required by this Order necessary to ensure the safe and\nenvironmentally sound operation of the pipehne have been completed\n2 Conduct metallurgical testing of the failed pipe section as follows\n(A) When handhng and transportmg the failed pipe section and any other evidence\nfrom the failure site, document the chain-of-custody,\n(B) Obtain prior approval of the metallurgical testing laboratory to be used, as well as\nthe testing protocol from the Director, Central Region, PHMSA,\n(C) Pnor to commencing the metallurgical teshng, provide the Director, Central\nRegion, PHMSA with the scheduled date, time, and location of the testing to allow a\nPHMSA representative to witness it, and\n(D) Ensure that the laboratory distributes all resultmg metallurgical reports, whether\ndraft or final, to PHMSA at the same time as they are made available to Respondent\n3 Re-evaluate the data from the metal loss internal inspection tool and the geometry tool\nruns performed in 1996 and 2002, including mformation obtained from the resulting\nexcavations/repairs, for the purpose of determimng whether any anomahes that could\nhave contributed to the failures at Mile Post 6 7 and Bennett Street crossing were\npresent and whether any anomalies with similar characteristics are present along the\nremamder of the pipeline Extract and record dimensional data of all such anomahes,\nincluding data on distance from upstream and downstream girth weld, o' clock\nposition, minimum and maximum remainmg wall thickness, anomaly growth between\ninternal inspections, and any remedial actions taken for each anomaly Make these\ninternal inspection results available to PHMSA or its representative\n4 Provide PHMSA with the technical)ustiftcations documenting the basis for the\nintegrity management program re-assessment interval established for the pipeline\npursuant to 49 C F R ) 195 452(1)(3)\n5 Within 30 days of receipt of this Order, develop and submit a written plan with\ncorrectn e measures for prior approval by the Director, Central Region, PHMSA The\nplan must fully address all known or suspected factors that caused or contributed to\nthe March 23, 2006 failure and the corrosion leak identified on March 24, 2006 and\nmust include\n(A) The identification of the type of pipe, whether seamless or seamed, by mile post\nalong the entire length of the pipeline along v ith the integration of the information\n\n\n\ndeveloped from the actions required by Items 1-3 with any relevant information from\nrecords of previous failure mvestigations, leak history, repair activity, corrosion\ncontrol/cathodic protection activity, in-hne inspections, hydrostatic testing, changes in\npressure cychng, and other relevant operating records for the purpose of performing a\ncomprehensive analysis of the available information associated with the factors that\ncaused or contnbuted to the failure,\n(B) The performance of appropnate field teshng inspections, and evaluations,\nincluding runnmg a high-resolution internal inspection tool if necessary, to determme\nwhether and to what extent the condition(s) associated with the failure including\ncracks, metal loss due to internal, external, or atmosphenc corrosion, or any other\ntntegrtty threatemng conditions, are present along the remainder of the pipehne\nInclude a survey of all below- to above-ground transition areas like the Bennett Street\ncrossing Provide a detailed description of the critena to be used for the field\nevaluation(s) and prtontizatton of any mtegnty threats/anomalies that are identified\nMake the results oi any internai inspections, field excavations, and evaluahons\navailable to PHMSA or its representative,\n(C) The performance of appropnate repairs or other corrective measures fully\nremediating all integrity threatening anomalies and condition(s) everywhere along the\npipeline where such conditions are identified by the evaluation process Include a\ndetailed description of the repair criteria and method(s) to be used in undertaking any\nrepairs or other remedial actions, and\n(D) A proposed schedule for completion of the testing, evaluation, and repairs\nrequired by paragraphs (A)-(C)\n6 Submit all plans and matenals to Director, Central Region, Pipehne and Hazardous\nMaterials Safety Administration, 901 Locust Street, Suite 462, Kansas City, MO 64106-\n2641 The plans must be revised as necessary to incorporate new information obtamed\nduring the failure investigation testing, and remedial activities undertaken pursuant to\nthis Order Submit any such plan revisions to the Director for pnor approval The\nDirector may approve plan elements incrementally\n7 Implement the plans as they are approved, including any plan revisions\n8 Subnut reports to the Director, Central Region, PHMSA, on at least a quarterly basis that\ninclude the available data and results of the testing and evaluations required by this Order\nand descnbe the progress of the repairs or other remedial actions being undertaken\nThe Director, Central Region, PHMSA may grant an extension of time for compliance with\nany of the terms ol this Order for good cause A request for an extension must be m wnting\nRespondent may appeal any decision of the Director, Central Region, PHMSA, to the\nAssociate Admmistrator for Pipeline Safety Decisions of the Associate Admimstrator are\nfinal\n\n\n\n/\nIn accordance with 49 U S C ) 60122 and 49 C F R ss 190 223 failure to comply with this\nOrder may result in the assessment of ctv&I penalties of not more than $100, 000 per day and in\nreferral to the Attorney General for appropnate relief in a United States Distnct Court\nMAR 29 20, \", 6\nDate Issued\nStacey Gerar r\nAssociate Ad ator\nfor Pipeline Safety\n\n320065033H_Closure_03122013_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 12, 2013\nMr. Carl Ostach\nVice President, Domestic Field Operations\nBuckeye Partners, LP\n5 TEK Park\n9999 Hamilton Blvd.\nBreinigsville, Pennsylvania 18031\nMr. Steve Pankhurst\nPresident\nBP Pipelines (North America) Inc.\n150 West Warrenville Road\nNaperville, Illinois 60563\nCPF 3-2006-5033H\nDear Misters Ostach and Pankhurst:\nOn March 29, 2006, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued to BP Pipelines (North America) Inc. a Corrective Action Order in the above-referenced\ncase. This Order included a requirement to take corrective actions on your pipeline. Buckeye\nPartners, LP became operator of the West Toledo pipeline on February 1, 2012. Based on our\nreview of the documentation you provided, it has been determined that you have complied with\nthe terms of this Order.\nAccordingly, this case is now closed and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nDavid Barrett\nDirector, Central Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":16816}