OLYMPIC PIPE LINE COMPANY — Notice of Probable Violation

party submissionOfficial PDF32021006NOPV_Operator Response to Notice_02192021_(20-196687).pdf#

case documentOfficial PDF32021006NOPV_PCO_01292021_(20-196687).pdf#

case documentOfficial PDF32021006NOPV_PCO_01292021_(20-196687)_text.pdf#

32021006NOPV_Closure Letter_09172021_(20-196687)_text.pdf, page 1Official PDFVIA ELECTRONIC MAIL TO: gerald.maret@bp.com and timothy.smith@bp.com September 17, 2021 Mr. Gerald Maret President Olympic Pipeline Company 30 S Wacker Drive, Chicago, IL 60606 Re: CPF 3-2021-006-NOPV Dear Mr. Maret: On January 29, 2021, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to Olympic Pipeline Company a Notice of Probable Violation (NOPV) Final Order in the above-referenced case. This NOPV included two Compliance Order requirements:  Item A: repair the dent on the 14-inch Portland Delivery Fuel W2 pipeline at site W2F- 2016-003 with an allowable repair method  Item B: interrupt all foreign rectifiers affecting the tank farm to determine if cathodic protection is adequate. Based on our review of the documentation you provided in the August 5, 2021 and September 16, 2021 letters from Mr. Timothy Smith, 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, Gregory A. Ochs Director, Central Region OPS Pipeline and Hazardous Materials Safety Administration#

32021006NOPV_Final Order_03262021_(20-196687)_text.pdf, page 1Official PDFMarch 26, 2021 VIA ELECTRONIC MAIL TO: gerald.maret@bp.com Mr. Gerald Maret President Olympic Pipeline Company 30 S Wacker Drive Chicago, Illinois 60606 Re: CPF No. 3-2021-006-NOPV Dear Mr. Maret: Enclosed please find the Final Order issued in the above-referenced case. It makes findings of violation and specifies actions that need to be taken to comply with the pipeline safety regulations. When the terms of the compliance order are completed, as determined by the Director, Central Region, this enforcement action will be closed. Service of the Final Order by electronic mail is effective upon the date of transmission as provided under 49 C.F.R. § 190.5. Thank you for your cooperation in this matter. Sincerely, Alan K. Mayberry Associate Administrator for Pipeline Safety Enclosures (Final Order and NOPV) cc: Mr. Gregory Ochs, Director, Central Region, Office of Pipeline Safety, PHMSA Mr. Timothy J.R. Smith, Compliance Manager, BP Pipelines (North America), Inc., timothy.smith@bp.com CONFIRMATION OF RECEIPT REQUESTED#

32021006NOPV_Final Order_03262021_(20-196687)_text.pdf, page 2U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 In the Matter of Olympic Pipeline Company, a subsidiary of BP Pipelines (North America), Inc., Respondent. ) ) ) ) ) ) ) ) CPF No. 3-2021-006-NOPV FINAL ORDER On January 29, 2021, pursuant to 49 C.F.R. § 190.207, the Director, Central Region, Office of Pipeline Safety (OPS), issued a Notice of Probable Violation (Notice) to Olympic Pipeline Company (Respondent). The Notice proposed finding that Respondent had violated the pipeline safety regulations in 49 C.F.R. Part 195. The Notice also proposed certain measures to correct the violations. Respondent did not contest the allegations of violation or corrective measures. Based upon a review of all of the evidence, pursuant to § 190.213, I find Respondent violated the pipeline safety regulations listed below, as more fully described in the enclosed Notice, which is incorporated by reference: 49 C.F.R. § 195.452(h)(4)(iii)(B) (Item 1) ─ Respondent failed to repair a dent located on the top of a pipeline with a depth greater than 2% of the pipeline’s diameter within 180 days of discovery of a condition; and 49 C.F.R. § 195.571 (Item 2) ─ Respondent failed to comply with one or more of the applicable criteria and other considerations contained paragraphs 6.2.2, 6.2.3, 6.2.4, 6.2.5 and 6.3 of NACE SP 0169 (incorporated by reference, see § 195.3) for determining the adequacy of its cathodic protection (CP) during annual CP surveys in 2017 through 2019. These findings of violation will be considered prior offenses in any subsequent enforcement action taken against Respondent.#

32021006NOPV_Final Order_03262021_(20-196687)_text.pdf, page 3CPF No. 3-2021-006-NOPV Page 2 COMPLIANCE ACTIONS Pursuant to 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the actions proposed in the enclosed Notice to correct the violations. The Director may grant an extension of time to comply with any of the required items upon a written request timely submitted by the Respondent and demonstrating good cause for an extension. Upon completion of ordered actions, Respondent may request that the Director close the case. Failure to comply with this Order may result in the assessment of civil penalties under 49 C.F.R. § 190.223 or in referral to the Attorney General for appropriate relief in a district court of the United States. The terms and conditions of this order are effective upon service in accordance with 49 C.F.R. § 190.5. March 26, 2021 ___________________________________ _________________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety#