{"operation":"document","citation":"CPF 520065015H","title":"HILCORP NORTH SLOPE, LLC — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2006-03-15","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520065015h.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520065015h.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520065015h","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520065015H","body":"Corrective Action Order involving HILCORP NORTH SLOPE, LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2006-03-15 and is reported as closed as of 2012-03-06. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520065015H_closure letter_03062012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520065015H/520065015H_closure%20letter_03062012.pdf\n\n520065015H_closure letter_03062012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520065015H/520065015H_closure%20letter_03062012_text.pdf\n\n520065015H_Consent Decree Appendix A_07132011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520065015H/520065015H_Consent%20Decree%20Appendix%20A_07132011.pdf\n\n520065015H_Consent Decree Appendix A_07132011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520065015H/520065015H_Consent%20Decree%20Appendix%20A_07132011_text.pdf\n\n520065015H_Consent Decree_07132011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520065015H/520065015H_Consent%20Decree_07132011.pdf\n\n520065015H_Consent Decree_07132011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520065015H/520065015H_Consent%20Decree_07132011_text.pdf\n\n520065015H_Corrective_Action_Order_03152006.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520065015H/520065015H_Corrective_Action_Order_03152006.pdf\n\nBP 5-2006-5015H - Final.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520065015H/BP%205-2006-5015H%20-%20Final.pdf\n\nCPF_5_2006_5015H.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520065015H/CPF_5_2006_5015H.pdf\n\ncpf_5_2006_5015h_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520065015H/cpf_5_2006_5015h_text.pdf\n\nCPF_NO5-2006-5015H.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520065015H/CPF_NO5-2006-5015H.pdf\n\nCPF_No_5-2006-5015 Amendment-2.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520065015H/CPF_No_5-2006-5015%20Amendment-2.pdf\n\nCPF_No_5-2006-5015 Amendment-2.pdf\n\nQUG-09-2006 23:53 PHMSA AK DIST OFFICE P. 02\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdmlnlstration\n400 Seventh Street, S.W.\nSuite 841 7\nWashington, DOC. 20590\nVia Federal Express and Facsimile To: (907) 564-5000\nMs. Maureen L. Johnson\nSenior Vice President & Greater\nPrudhoe Bay Performance Unit Leader\nBP Exploration (Alaska), Inc.\n900 E. Benson Blvd.\nAnchorage, AK 99508\nRE: CPF #5-2006-5015H\nAmendment No.2 to Corrective Action Order\nDear Ms. Johnson:\nEnclosed is Amendment No. 2 to the March 15,2006 Corrective Action Order (CAO) issued\nby the Associate Administrator for Pipeline Safety to BP Exploration (Alaska), Inc., (BP).\nAmendment No. 2 sets forth further preliminary findings based on PHMSA's continuing\noversight of BP's compliance with the March 15, 2006 CAO, and the results of recent testing and\ninspections of the subject lines. Amendment No. 2 imposes additional monitoring, testing, and\ninformation requirements and prescribes standards and deadlines for the repair of pipeline\ndefects. The Amendment also imposes new requirements arising out of BP's decision to suspend\nor terminate operations involving one or more of its pipelines segments. Except as expressly\nprovided in Additional Preliminary Finding No. 16, Amendment No. 2 does not waive, alter or\nsupplant the original terms and requirements of the July 20,2006 Amendment No. 1 to the CAO\nor the March 15,2006 CAO.\nYour receipt of the enclosed document constitutes service of that document under 49 C.F.R. 8\n190.5. The terms and conditions of this Amendment are effective upon receipt.\nSincerely,\nActing Associate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Chris Hoidal, P,E., Director\nWestern Region, PHMSA\n\n\n\nAUG-09-2006 23:21 PHMSA AK DIST OFFICE\nDEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, DC 20590\nIn the Matter of\nBP Exploration (Alaska) Inc., ) CPF No. 5-2006-5015H\nRespondent\nAMENDMENT No. 2 TO CORRECTIVE ACTION ORDER\nBackground & Purpose\nOn March 15,2006, under authority of 49 U.S.C. 5 601 12, the Associate Administrator for\nPipeline Safety, Pipeline and Hazardous Materials Safety Administration (PHMSA), issued a\nCorrective Action Order (CAO) to BP Exploration (Alaska), Inc., @P), finding that the\ncontinued operation of three crude oil transmission pipelines in BP's Prudhoe Bay Operating\nArea -the Western Operating Area (WOA), Eastern Operating Area (EOA) and Lisburne crude\noil pipelines - would be hazardous to life, property, or the environment without the\nimplementation of corrective measures. The CAO was issued in response to a failure on BP's\nWOA pipeline that caused the discharge of an estimated 20 1,000 gallons of crude oil.\nIn addition to addressing the immediate consequences of the pipeline failure, the March 15,2006\nCAO required BP to take various measures to evaluate the condition of the subject Iines, and to\nmake any necessary repairs. Items 3,4, and 7 of the CAO required BP to perform cleaning\noperations on the three pipelines, assess the condition of the pipeline walls, and measure any\ncorrosion or other defects using an instrumented in-line inspection tool (known as a \"smart-pig\").\nOn July 20,2006, under authority of 49 U.S.C. $601 12, the Associate Administrator issued\nAmendment No. 1 to the March 15,2006 CAO. Amendment No. 1 set forth additional\npreliminary findings based on PHMSA's oversight of BP3s activities and PHMSAYs continuing\ninvestigation of pipeline conditions on BP's Prudhoe Bay Operating Area. Amendment No. 1\nrequired BP to perform additional integrity assessments and to develop and implement plans for\naddressing new and ongoing safety risks associated with its failure to complete diagnostic\nmeasures required by Items 3,4, and 7 of the March 15,2006 CAO.\n\n\n\nQUG-09-2006 23:22 PHMSQ QK DIST OFFICE P. 04\nAdditional Preliminary Findings\nPrudhoe Bay EOA Transmission Pipeline\n1. The EOA pipeline is constructed of X60 Grade, 0.344-inch wall thickness pipe\nmanufactured between 1976 and 1979. The fust segment of the EOA pipeline, extending\napproximately three (3) miles from Flow Station 2 (FS2) to Flow Station 1 (FS l), is\nconstructed of 30-inch nominal diameter pipe. The second segment, constructed of 34-\ninch nominal diameter pipe, extends approximately five (5) miles fiom FS 1 to Skid 50;\njust upstream of the Trans Alaska Pipeline System (TAPS).\n2. 3. 4. 5. 6. On or about July 22,2006,3 7 days after the deadline established under the March 1 5,\n2006 CAO (as extended), BP performed smart pigging of the FS2-FS1 segment of the\nEOA pipeline. BP reportedly received initial reports of the smart pig data on August 4,\n2006.\nThese reports identified sixteen (16) anomalies (representing wall loss in excess of 70\npercent, including two (2) over 80 percent) at twelve (1 2) separate areas on the FS2-FS 1\nsegment of EOA pipeline. According to BP, the data indicated each of the sixteen\nanomalies is approximately 1.5 by 1.5 inches in size and is located in the lower quadrant\nof the pipe (between the 5:45 to 6:45 positions).\nOn or about August 5,2006, BP began performing direct visual and ultrasonic inspection\nof the locations identified by the smart-pig data as having significant wall loss. In the\ncourse of that work, according to BP reports, BP discovered a location where crude oil\napparently had leaked through the pipe wall and onto the insulation material. On the\nbasis of that discovery, BP reportedly initiated shut down of the FS2-FS 1 segment of thc\nEOA pipeline at approximately 6:00 a.m. on August 6,2006.\nLater in the morning of August 6,2006, according to BP, BP personnel discovered crude\noil leaking from a different location on the FS2-FS 1 segment of the EOA pipeline.\nAccording to BP, field inspection of the leak site revealed multiple holes in the pipe wall\nat a single location, contributing to an estimated spill of approximately five (5) barrels of\nprocessed crude oil.\nSince August 6,2006, BP reportedly has discovered pinhole leaks on at least four\nadditional locations on the FS2-FS 1 segment of the EOA pipeline.\n7. On the afternoon of August 6,2006, BP notified the Director of P M S A ' s Western\nRegion Pipeline Safety Ofice of the EOA pipeline spill and advised PHMSA that BP had\ndecided to shut down all of its Prudhoe Bay production fields on the North Slope. BP\nfurther stated that the Lisburne pipeline and associated production facilities would remain\nin service. On August 8,2006, BP indicated its desire to maintain operations of the\nWOA pipeline if pipeline integrity could be demonstrated through further field\nassessments.\n\n\n\nRUG-89-2086 23:22 PHMSR QK DIST OFFICE P. 85\n8. To date, BP has not performed cleaning or smart pigging operations on the FS 1-Skid 50\n(34-inch diameter) segment of the EOA pipeline.\n9. On or about August 7,2006, a team of PHMSA personnel and officials were deployed to\nBP facilities in Alaska to investigate the August 6,2006 spill, examine the basis for BP's\ndecision to cease operations, oversee BP's shutting down o f pipeline operations, and\nevaluate what procedures would be necessary to safely restart operations.\n10. On August 9,2006, BP announced that it had decided to replace the FS2-FSI segment\nand that BP had no plans to return the segment to operation.\nPmdhoe Bav Lisburne Transmission Pipeline\n11. On or about June 30,2006, fifteen (15) days after the deadline established under the\nMarch 15,2006 CAO (as extended), BP performed smart pigging of the Lisbume\npipeline. BP reportedly received initial reports of the smart pig data on or about July 13,\n2006.\n12. BP reports that smart-pigging data indicate ten (10) areas in which external wall loss\nexceeded 40 percent.\nPrudhoe Bay WOA Transmission Pipeline\n13, The WOA pipeline consists of two segments of 34-inch nominal diameter pipe. The first\nsegment (OT-2 1) extends approximately three (3) miles from Gathering Center 2 (GC2)\nto Gathering Center 1 (GCI). The OT-21 segment is currently bypassed by a jumper\npipeline (GHX21). The second, downstream segment extends approximately fivc (5)\nmiles from GC1 to Skid 50, and then to Pump Station 1 (PSI), just upstream of TAPS.\n14. To date, BP has not performed cleaning or smart-pigging operations on either segment of\nthe WOA pipeline.\n15. BP took the OT-21 segment out of service following the spill discovered March 2,2006\nand has not returned the line to service since that date. Pursuant to Item 16 of\nAmendment No. 1 to the March 15,2006 CAO, BP has submitted a plan for de-oiling the\nOT-21 segment beginning on or before August 22,2006. The Director of the Western\nRegion Pipeline Safety Office has reviewed and concurs with the plan.\n16. BP has advised PHMSA by letter dated July 28,2006, that the OT-21 segment will not\nbe returned to service and will be permanently replaced with a new pipeline. To the\nextent that OT-2 1 will not be returned to service and is deoiled, BP is not required to\ncomplete smart-pigging of that segment as otherwise required by the March 15,2006\nCAO.\n17. On June 6,2006, BP submitted a plan for conducting assessment of pipeline wall\nintegrity using ultrasonic testing (UT) to measure the thickness of the pipe wall at\nparticular points on the line. BP proposed to use this inspection method until it conducts\n3\n\n\n\nPHMSR RK DIST OFFICE\nsmart pigging as required by the March 15,2006 CAO, and interprets the results. BP\ncontended that by extrapolation from the UT data, BP could obtain information, of\nequivalent reliability to smart pig results, for understanding the pattern and extent of\ninternal corrosion in its pipelines. BP submitted the results of ultrasonic testing,\nperformed from March through July, 2006, on the GC1-Skid 50 segment of the WOA\npipeline.\n18. Following the recent discovery of leaks and internal corrosion on the EOA line, BP\nannounced a plan to conduct more thorough,continuous automatic UT testing (AUT) of\nthe in-service segment of its WOA pipeline. As of August 9,2006, BP reportedly had\ninitiated AUT testing on the GC1-Skid 50 segment.\n19. As of August 8,2006, BP has advised PHMSA investigators that a11 available resources\nare being deployed for completing inspection of the in-service segment of the WOA\npipeline as soon as possible. BP representatives have advised PHMSA investigators and\nofficials that they have deployed all available equipment and resources in support of\ncompleting continuous AUT testing as soon as possible. At the same time, BP reports\nthat it is moving ahead with plans to smart pig all or part of the WOA pipeline by\nacquiring equipment and planning preliminary operations.\n20. PHMSA has not ordered BP to cease operating the GC1-Skid 50 segment or the OT21\nbypass (CHX21) of the WOA pipeline, and PHMSA is not aware of any data concerning\nthe current condition of pipe on the GC1 -Skid 50 segment, or the GHX21 bypass, that\nwould necessitate an immediate cessation of operations on the WOA pipeline in order to\nprotect life, property, or the environment.\nDETERMINATION OF NECESSITY FOR AMENDMIENT OF C O W C T I V E ACTION\nORDER AND RIGHT TO A HEARING\nSection 601 12 of Title.49, United States Code, provides for the issuance of a Corrective Action\nOrder, after reasonable notice and the opportunity for a hearing, when PHMSA decides that a\npipeline facility is hazardous. Corrective action may include the suspended or restricted use of a\npipeline facility, physical inspection, testing, repair, replacement or other appropriate action.\nThe basis for deciding that a pipeline facility is hazardous, requiring corrective action, is set forth\nboth in the above-referenced statute and 49 C.F.R. 5 190.233.\nSection 601 12(e) of Title 49, United States Code, and the regulations promulgated thereunder\n(49 C.F.R. $190.233(b)), provide for the issuance of a Corrective Action Order without prior\nopportunity for notice and hearing upon a finding that a failure to issue the Order expeditiously\nwill likely result in serious harm to life, property, or the environment. In such cases, an\nopportunity for a hearing will be provided as soon as practicable after the issuance of the Order.\nBased on the additional preliminary findings set forth above and the preliminary findings in the\nMarch 15,2006 CAO and Amendment No. 1, I continue to find that the presence of hazardous\n\n\n\nconditions on the EOA, Lisburne, and WOA pipelines, without the implementation of corrective\nmeasures, would result in likely serious harm to property or the environment.\nAdditionally, after considering the circumstances surrounding the failures discovered on August\n6 and March 2,2006, the number and severity of anomalies discovered on the EOA line, the\nimmediate proximity of the pipeline to environmentally sensitive areas, and the safety and\nenvironmental threats posed by serious internal corrosion of the EOA line, I find that failure to\nexpeditiously issue this Amendment would result in likely serious harm to life, property and the\nenvironment.\nWithin ten (10) days of receipt of this Order, BP may request a hearing, to be held as soon as\npracticable, by notifying the Associate Administrator for Pipeline Safety in writing, delivered\npersonally, by mail or by facsimile at (202) 366-3666. A hearing, if requested, will be held in\nLakewood, Colorado or Washington, DC on a date that is mutually convenient to PHMSA and\nBP. A hearing requested on this Amendment may be consolidated with the hearing BP has\nalready requested on this CAO.\nIn the course of this investigation, P W S A may identifjr additional measures that need to be\ntaken to ensure the safety of BP's pipeIines covered by the CAO. The terms of the March 15,\n2006 CAO and the additional terms added by Amendment No. 1, this amendment, and\nsubsequent amendrnent(s) will remain in place for as long as the Associate Administrator deems\nnecessary to ensure the subject pipelines are operated in a safe and environmentally sound\nmanner. The actions required by this CAO are in addition to and do not waive or modify any\nrequirements that apply to BP's pipeline systems under any provision of Federal or state law, or\nunder any other order issued to BP under authority of 49 U.S.C. §§60101 et seq.\nAmendments to Required Corrective Action\nPursuant to 49 U.S.C. 5 601 12, I hereby order BP to immediately take the following additional\ncorrective actions with respect to BP's Prudhoe Bay oil transmission pipeline system:\nThe following items are added to the Corrective Action Order:\nItem 22. Additional Measures for Monitoring and Response. Within one (1) day of receipt\nof this Amendment No. 2, and until further order of the Western Region Director, BP shall begin\nfour times daily visual and handheld infrared surveys via ground patrol of the entire length of the\nEOA, Lisburne, and WOA pipelines. Surveys shall seek out signs of leaks and any other threats\nto pipeline integrity. BP shall report the results of the surveys to the Western Region Director on\na weekly basis, provided that any leaks or threats to pipeline integrity must be reported\nimmediately.\nPrudhoe Bav EOA Transmission Pioeline\nItem 23. EOA Plan. Within 30 days of receipt of this Amendment No. 2, BP shall submit a\nreport to the Western Region Director, detailing its proposed actions and plans for replacing,\n\n\n\nRUG-09-2086 23:25 PHMSR RK DIST OFFICE P.08\nabandoning, and/or restoring operation of the FSZFS1 and FS 1 -Skid 50 segments of EOA. The\nreport shall include preliminary or final engineering plans and timetables, and identify all\nnecessary equipment, parts, and supplies, specifying, inventories, availability and delivery\nschedules.\nItem 24. Interim Ultrasonic Testing of EOA FS1-Skid 50 Segment. Until BP has completed\ncleaning and smart pigging of the EOA pipeline in accordance with Items 4 and 7 of the March\n15,2006 CAO, BP shall perform interim alternative testing in accordance with the requirements\nof this paragraph, on a basis not to interfere with AUT inspections on operational oil\ntransmission lines. BP shall conduct AUT inspection of the 34-inch diameter segment of the\nEOA line fiom FS1 to Skid 50. The AUT inspection shall cover 100% of the len& of the FS 1 -\nSkid50 segment and the bottom 120 degrees of pipe circumference (between the 4:00 and 8:00\npositions). BP shall ensure that the AUT scans are performed, verified, calibrated, and recorded\nin accordance with established industry practices and shall submit data to the Western Region\nDirector, in raw and graphical formats, within seven (7) days of receipt of AUT results by BP.\nItem 25. Ultrasonic Testing of Anomalies Identified by Smart-Pigging. Within three weeks\nof receipt of this Amendment No. 2, BP shall perform external UT assessment at the location of\neach anomaly where wall loss exceeds SO%, as revealed by smart-pig data collected on the FS2-\nFS 1 segment. BP shall provide PHMSA data reports and a graphical comparison of smart-pig\nand UT data for anomalies specified above within six (6) weeks of receipt of this order.\nItem 26. Plan For De-Oiling EOA Pipeline. Within 30 days of receipt of this Amendment\nNo. 2, BP shall develop, and submit for approval to the Western Region Director, a plan to safely\nremove the crude oil in the segments of the EOA pipeline that will not be restored to operation.\nThe plan shall provide for removal of the crude oil, in a safe and environmentally sound manner,\nand in compliance with all applicable federal, state and local laws and regulations. BP shall\nimplement such plan upon approval.\nItem 27. Safe Resumption of Operations. BP may return the EOA pipeline to operation only\nwith the prior approval of the Director of PHMSA's Western Region Pipeline Safety Office,\nupon a record of satisfactory testing, repair, inspection, and planning in accordance with the\nMarch 15,2006 CAO, the July 20,1006 Amendment No. I, and this Amendment No. 2. Any\nrequest for resumption of operations, temporary or otherwise, shall be submitted no fewer than\nfourteen (14) days in advance of the proposed restart date.\nPrudhoe Bay Lisburne Transmission Piaeline\nItem 28. Ultrasonic Testing of Anomalies Identified by Smart-Pigging. Within three weeks\nof rcceipt of this Amendment No. 2, BP shall perfonn external UT assessment at the location of\neach anomaly where wall loss exceeds 50 %, as revealed by smart-pig data collected on the\nLisburne line. BP shall provide PHMSA data reports and a graphical comparison of smart-pig\nand UT data for anomalies specified above within six (6) weeks of receipt of this order.\nItem 29. Repair of Pipeline Defects. BP shall document and repair all defects and other\nconditions defined under 49 C.F.R. §195.452@)(4)(i) through (iv) on a schedule that at a\n6\n\n\n\nPHMSQ QK DIST OFFICE\nminimum, comports with the deadlines set out in 49 C.F.R. §195.452(h)(4) and in a manner\nconsistent with ASME B-3 1.4. Within 30 days of receipt of this order, BP shall extract, record\nand provide to the Western Region Director dimensional data of all anomalies found, including\ndata on distance from upstream and downstream girth weld, position, minimum and maximum\nremaining wall thickness, and remedial actions taken with respect to each anomaly. As repairs\nare made, BP shall submit monthly reports to the Western Region Director documenting each\nrepair made (including photographs) with respect to each such anomaly.\nPrudhoe Bay WOA Transmission Pi~eline\nItem 30. Information Request. Within 48 hours of receipt of this Amendment No. 2, BP shall\nprovide the Western Region Director with all data and risk analyses not previously provided by\nBP, concerning the current condition of the WOA pipeline, including all data and analyses on the\nbasis of which BP announced its original decision to cease operation of the WOA pipeline.\nItem 31. Ultrasonic Testing Pending Smart-Pigging. Until BP has completed cleaning and\nsmart pigging of the GC1-Skid 50 segment of the WOA pipeline in accordance with Items 3 and\n4 of the March 15,2006 CAO, BP shall perform testing in accordance with the requirements of\nthis paragraph. BP shall conduct AUT inspection of the GC1-Skid 50 segment of WOA. The\nAUT inspection shall cover 100% of the length of the GC1-Skid 50 segment and the lowest 120\ndegrees of pipe circumference (between the 4:00 and 8:00 positions). The entire circumference\nof the pipe shall be visually inspected and any areas of general external corrosion shall be\nassessed and documented. BP shall ensure that the AUT scans are performed, verified,\ncalibrated, and recorded in accordance with established industry practices and shall submit data\nto the Western Region Director, in raw and graphical formats, within seven (7) days of receipt of\nAUT results by BP. Any external corrosion shall also be reported at that time.\nitem 32. Documentation and Repair of Pipeline Defects. BP shall document and repair all\ndefects and other conditions defined under 49 C.F.R. §195.452(h)(4)(i) through (iv) on a\nschedule that at a minimum, comports with the deadlines set out in 49 C.F.R. §195.452@)(4) and\nin a manner consistent with ASME B-3 1.4. Within 30 days of receipt of this order, BP shall\nextract, record and provide to the Western Region Director dimensional data of all anomalies\nfound, including data on distance fiom upstream and downstream girth weld, position, minimum\nand maximum remaining wall thickness, and remedial actions taken with respect to each\nanomaly. As repairs are made, BP shall submit monthly reports to the Western Region Director\ndocumenting each rcpair made (including photographs) with respect to each such anomaly.\nItem 33. Condition of GHX21 Bypass. Within 30 days of receipt of this Amendment No. 2,\nBP shall provide a report to the Western Region Director detailing all maintenance, cleaning and\ninspection, and repair activities with respect to GHX21. BP shall also develop, submit to the\nWestern Region Director for review and approval, o plan for performance of smart pigging at\nregular intervals not to exceed five (5) years, and a schedule for the repair of anomalies\nidentified through those inspections.\n\n\n\nQUG-09-2006 23:26 PHMSR QK DIST OFFICE\nItem 34. Inspection Plan for OT501. Within 30 days of receipt of this Amendment No. 2, BP\nshall provide a report to the Western Region Director detailing the results of inspections and\ntesting of the OT501 section, and plans for future inspection and testing.\nExcept as expressly provided in Additional Preliminary Finding No. 16, this Amendment does\nnot modify, waive or supplant any requirements imposed under the March 15,2006 CAO, the\nJuly 20,2006 CAO Amendment No.1. This Amendment No.2 does not modify, waive, or\nsupplant any requirements that apply to BP7s pipeline systems under any other provision of\nfederal, state, or local law, or permit.\nWith respect to all actions undertaken pursuant to this Amendment, BP is responsible for\nachieving and maintaining compliance with all applicable federal, state and, local laws,\nregulations and permits. This Amendment is not and shall not be construed to be a permit, or a\nmodification of any permit, under any federal, state, or local law or regulation.\nIn accordance with 49 U.S.C. 5 60 122 and 49 C.F.R. 5 190.223, failure to comply with the CAO,\nas amended, may result in the assessment of administrative civil penalties of not more than\n$100,000 per violation per day pursuant to 49 U.S.C. $6012.2, or in the imposition of civil\njudicial penalties and other appropriate relief pursuant to 49 U.S.C. 560120. The terns and\nconditions of this Amendment are effective upon receipt.\nTheodore L. *illke I I\nbate h u e d\nActing Associate Administrator\nfor Pipeline Safety\nTOTRL P.10\n\n520065015H_closure letter_03062012_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 6, 2012\nMr. John Eldred\nVP, Safety & Operational Risk\nBP Exploration Alaska, Inc.\n900 East Benson Boulevard\nMailbox 3-1\nP.O. Box 196612\nAnchorage, AK 99501\nRe: Closure of Corrective Action Order\nCPF 5-2006-5015H\nDear Mr. Eldred:\nOn March 15, 2006, the Associate Administrator for Pipeline Safety, Pipeline and Hazardous Materials\nSafety Administration (PHMSA), issued a Corrective Action Order (CAO) in the above-referenced case.\nThe CAO and subsequent Amendments to the CAO (Amendment 1 dated July 20, 2006, Amendment 2\ndated August 10, 2006, and Amendment 3 dated April 27, 2007) required BP Exploration (BPXA) to take\ncorrective actions, including, but not limited to, cleaning, smart pigging (ILI), and inspection of the Oil\nTransit Lines in Prudhoe Bay, Alaska.\nBPXA did not fully meet the terms of the CAO due to delays in cleaning and internal inspections. The US\nDepartment of Justice filed a complaint on behalf of PHMSA seeking relief in the US District Court for\nthe District of Alaska on March 31, 2009. A Consent Decree resolving this complaint was accepted by the\ncourt on July 13, 2011. In this Consent Decree, BPXA agreed to injunctive relief and a civil penalty and\ncertified that it had replaced the Oil Transit Lines that were the subject of the CAO. PHMSA believes the\nConsent Decree resolves the terms of the CAO and the subsequent Amendments to the CAO. This case is\nnow closed.\nThank you for your cooperation in this matter.\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 D. Hinnah\n\n520065015H_Corrective_Action_Order_03152006.pdf\n\nU.S. Department 400 Seventh Street, S.W.\nof Transportation Washington, D.C. 20590\nPipeline and\nHazardous Materials Safety\nAdministration MAR 1 5 2006\nVIA FEDERAL EXPRESS AND FACSIMILE TO: (907) 564-5000\nMs. Maureen L. Johnson\nSenior Vice President & Greater\nPrudhoe Bay Performance Unit Leader\nBP Exploration (Alaska), Inc.\nP.O. Box 196612\nAnchorage, AK 995 19-66 12\nRe: CPF No. 5-2006-501 5H\nDear Ms. Johnson:\nEnclosed is a Corrective Action Order issued by the Associate Administrator for\nPipeline Safety in the above-referenced case. It requires you to take certain corrective actions\nwith respect to the Prudhoe Bay West Operating Area, Prudhoe Bay East Operating Area, and\nLisburne hazardous liquid pipeline facilities operated by BP Exploration (Alaska), Inc.\nService is being made by Federal Express and facsimile. Your receipt of this Corrective\nAction Order constitutes service of the document under 49 C.F.R. tj 190.5. The terms and,\nconditions of this Corrective Action Order are effective upon receipt.\nSincerely,\nJames Reynolds\nPipeline Compliance Registry\nOffice of Pipeline Safety\nEnclosure\ncc: Chris Hoidal, Director, Western Region, PHMSAIOPS\n\n\n\nDEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, DC 20590\nIn the Matter of\nBP Exploration (Alaska), Inc.,\nRespondent\n1\nCPF NO.5-2006-5015H\nCORRECTIVE ACTION ORDER\nPurpose and Background\nThis Corrective Action Order is being issued, under authority of 49 U.S.C. § 601 12, to require\nBP Exploration (Alaska), Inc. (Respondent), to take necessary corrective action to protect the\npublic, property, and the environment from potential hazards associated with a failure involving\nRespondent's Prudhoe Bay West Operating Area (PBWOA) hazardous liquid pipeline.\nOn March 2,2006, Respondent discovered a leak on the PBWOA hazardous liquid pipeline in\nNorth Slope Borough, Alaska. The probable cause of the failure is internal corrosion. Pursuant\nto 49 U.S.C. 5 601 17, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\ninitiated an investigation of the accident.\nPreliminarv Findings\nOn March 2,2006, at approximately 5:30 AM AKST, Respondent's surveillance crew\ndiscovered a crude oil spill in the proximity of Respondent's PBWOA hazardous liquid\ntransmission pipeline in North Slope Borough, Alaska. Respondent determined the failure\nsite to be at or near Mile 1.0 between Gathering Center 2 (GC-2) and Gathering Center 1\n(GC-1) on the PBWOA pipeline, several miles upstream of the Trans Alaska Pipeline's first\npump station (PS-1). No fires, injuries, or fatalities were reported in connection with the\naccident.\nThe pipeline failure resulted in a release currently estimated at 5,000 barrels of processed\ncrude oil, impacting the arctic tundra and covering approximately 2 acres of permafrost.\nPotential damage to the ecology and environment is presently unknown.\nRespondent's leak detection system was not effective in recognizing and identifing the\nfailure. Following discovery of the spill, Respondent isolated the segment between GC-2\n\n\n\nand GC-1, initiated shutdown at 6:49 AM AKST and depressurized the segment.\nRespondent located the leak site and installed a containment welded sleeve. Respondent also\ninitiated oil spill response.\nThe failure point is a 0.25-inch by 0.5-inch hole in the pipe. The probable cause of the\nfailure is internal corrosion. There is evidence of bacterial corrosion (increased hydrogen\nsulfide and nitric acid in the crude oil) and increased water content.\nRespondent's PB WOA hazardous liquid pipeline system is approximately 10 miles in length\nand transports processed crude oil from GC-2 to PS- 1 on the Trans Alaska Pipeline in North\nSlope, Alaska. The PB WOA system is constructed of 34-inch nominal diameter, X52 Grade,\n0.375-inch wall thickness, submerged arc welded pipe manufactured in 1975 through 1977.\nThe pipe is not coated and it is not cathodically protected. The pipeline sits on a vertical\nsupport member above-ground and is surrounded by an air culvert. The pipe is insulated and\nhas a steel jacket. Although the pipeline is above-ground, at the time of the failure, the\npipeline was lying in water that had pooled from melting snow.\nThe established maximum operating pressure (MOP) for the PBWOA is 826 pounds per\nsquare inch gauge (psig) established by design pressure. Estimated maximum normal\noperating pressure is 100 psig. Actual operating pressure was approximately 80 psig when\nthe failure was discovered.\nThe PBWOA operates at less than 20% of the specified minimum yield strength (SMYS) and\nis therefore a low-stress pipeline under 49 C.F.R. 5 195.2. Federal hazardous liquid pipeline\nsafety regulations (49 C.F.R. Part 195) do not apply to the PBWOA under the exception in\n49 C.F.R. 5 195.1 for onshore low-stress pipelines located in a rural area, outside a waterway\ncurrently used for commercial navigation, which do not transport highly volatile liquids.\nThe PBWOA is one of three similar low-stress pipelines operated by Respondent that feed\ninto PS- 1. The other two pipelines are the Prudhoe Bay East Operating Area (PBEOA)\npipeline and the Lisburne pipeline. All three pipelines were constructed around the same\ntime, operate in similar environmental conditions, transport the same quality crude oil that\ncontributed to the cause of the internal corrosion in PBWOA, and are operated and\nmaintained in a similar manner by Respondent.\nRespondent's failure investigation has identified at least six additional anomalies on the\nPBWOA segment between GC-2 and GC-1. Internal corrosion has been observed at several\nof those anomalies. The worst noted anomaly had a remaining wall thickness of 0.04-inches.\nAn internal inspection of the PBWOA was last performed in 1998 using a high-resolution\nmagnetic flux leakage (MFL) tool. Respondent has not established a regular internal\ninspection or maintenance pigging (cleaning pig) program.\nRespondent plans to bypass the segment between GC-2 and GC-1 using a 24-inch flow-line.\nOnce the bypass is in place, Respondent plans to restart the PBWOA. Respondent\n\n\n\nanticipates the bypass process will take up to 10 days before the PBWOA pipeline can be\nrestarted.\nDetermination of Necessity for Corrective Action Order and Right to Hearing\nSection 601 12 of Title 49, United States Code, provides for the issuance of a Corrective Action\nOrder, after reasonable notice and the opportunity for a hearing, when PHMSA decides that a\npipeline facility is hazardous. A pipeline facility is a pipeline, right-of-way, facility, building, or\nequipment used or intended to be used in the movement of hazardous liquid by pipeline, or the\nstorage of hazardous liquid incidental to the movement of hazardous liquid by pipeline, in or\naffecting interstate or foreign commerce. A pipeline facility does not include movement of\nhazardous liquid through gathering lines in a rural area; onshore production, refining, or\nmanufacturing facilities; or storage or in-plant piping systems associated with onshore\nproduction, refining, or manufacturing facilities. The basis for deciding that a pipeline facility is\nhazardous, requiring corrective action, is set forth both in the above-referenced statute and 49\nC.F.R. 190.233, a copy of which is enclosed.\nSection 601 12 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\nhearing upon a finding that a 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 preliminary findings of fact, I find that the PBWOA, PBEOA, and\nLisburne pipelines operated by Respondent are pipeline facilities within the meaning of that term\nas used in 49 U.S.C. §§ 60101 and 601 12, notwithstanding the inapplicability of the pipeline\nsafety regulations at 49 C.F.R. Part 195. Those pipelines are used in the movement of hazardous\nliquid by pipeline in interstate commerce and are not gathering lines in a rural area, onshore\nproduction, refining, or manufacturing facilities, or in-plant piping systems. Additionally, after\nconsidering the age of the pipe, the hazardousness of the product the pipelines transport, the\nlarge spill volume, the ineffectiveness of the leak detection system to identify the leak, the\nnumber, type, and severity of anomalies discovered on the segment that was inspected, the\nsimilarity of the PBEOA and Lisburne pipelines to the pipeline that failed, and the proximity of\nthe pipelines to wildlife areas or other possible sensitive areas, I find that the continued operation\nof Respondent's PBWOA, PBEOA, and Lisburne hazardous liquid pipelines without corrective\nmeasures will be hazardous to life, property, and the environment. Moreover, failure to\nexpeditiously issue this Order requiring immediate corrective action would likely result in\nserious harm to life, property, or the environment.\nAccordingly, this Corrective Action Order mandating immediate corrective action is issued\nwithout prior notice and opportunity for hearing. The terms and conditions of this Order are\neffective upon receipt.\nWithin 10 days of receipt of this Order, Respondent may request a hearing, to be held as soon as\npracticable, by notifying the Associate Administrator for Pipeline Safety in writing, delivered\npersonally, by mail or by facsimile at (202) 366-4566. The hearing will be held in Lakewood,\n\n\n\nColorado or Washington, D.C. on a date that is mutually convenient to PHMSA and the\nRespondent.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective action measures that need to be taken. In that event, Respondent will be\nnotified of any additional measures required and amendment of this Order will be considered.\nTo the extent it is consistent with safety considerations, Respondent will be afforded notice and\nan opportunity for a hearing prior to the imposition of additional corrective measures.\nRequired Corrective Action\nPursuant to 49 U.S.C. $ 601 12, I hereby order BP Exploration (Alaska), Inc. to immediately take\nthe following corrective actions with respect to the PBWOA, PBEOA, and Lisburne hazardous\nliquid pipeline systems:\n1. Repair all anomalies on the PBWOA segment between GC-2 and GC- 1, including those\nanomalies identified after the March 2, 2006 pipeline failure before resuming service.\nExtract and record dimensional data of all anomalies found, including data on distance\nfrom upstream and downstream girth weld, o'clock position, minimum and maximum\nremaining wall thickness, and remedial actions taken on each anomaly.\n2. Obtain prior written approval from the Director, Western Region, PHMSA before\nresuming operations on the PBWOA pipeline. Operating pressure on the PBWOA is not\nto exceed 80 psig. This pressure restriction shall remain in effect until written approval\nto increase the pressure is obtained from the Director, Western Region, PHMSA.\n3. Perform an internal inspection using a calibrated smart pig on the PBWOA pipeline\nwithin 3 months of placing the pipeline back in service. Take appropriate action to\naddress all anomalies discovered by this inline inspection device, in accordance with the\nstandards for anomaly repair in 49 C.F.R. Part 195. Record differences between inline\ninspection data and actual \"as found\" data for all anomalies and integrate that data in\nfuture analyses, mapping corrosion growth, and confirming data gathered by inline\ninspection tool. Develop and submit for approval a plan to perform internal inspections\nat regular intervals, not to exceed 5 years, and schedule for the repair of anomalies\nidentified through those inspections. Implement that plan upon approval.\n4. Develop and submit for approval a plan for running maintenance pigs (cleaning pigs) on\nthe PBWOA, PBEOA, and Lisburne pipelines at regular intervals. Implement that plan\nupon approval. Until that plan has been approved and implemented, run maintenance\npigs on those pipelines on a weekly basis. Conduct laboratory analyses on sludge to\ndetermine its corrosive properties and integrate those findings into the internal corrosion\nmanagement plan in Item 5 below.\n5. Conduct a review of the leak detection system for the PBWOA, PBEOA, and Lisburne\npipelines and make necessary modifications to ensure that the leak detection systems\ncomply with API 1 13","truncated":true,"body_characters":42546}