# OLYMPIC PIPE LINE COMPANY — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 520155014
- **title:** OLYMPIC PIPE LINE COMPANY — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2015-07-02
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.401(b)(1), 195.452(h)(1), 195.573(e), 195.575(c).
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520155014
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520155014
**body:**

Notice of Probable Violation involving OLYMPIC PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.401(b)(1),  195.452(h)(1),  195.573(e),  195.575(c). The case was opened on 2015-07-02 and is reported as closed as of 2017-08-25. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520155014_Closure Letter_08252017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155014/520155014_Closure%20Letter_08252017.pdf

520155014_Closure Letter_08252017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155014/520155014_Closure%20Letter_08252017_text.pdf

520155014_Final Order_01132016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155014/520155014_Final%20Order_01132016.pdf

520155014_Final Order_01132016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155014/520155014_Final%20Order_01132016_text.pdf

520155014_NOPV PCO_07022015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155014/520155014_NOPV%20PCO_07022015.pdf

520155014_NOPV PCO_07022015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155014/520155014_NOPV%20PCO_07022015_text.pdf

520155014_Operator Response to Notice_08062015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155014/520155014_Operator%20Response%20to%20Notice_08062015.pdf

520155014_Final Order_01132016_text.pdf

January 13, 2016
Mr. Donald Porter
President
BP Pipelines (North America), Inc.
150 W. Warrenville Road
Naperville, IL 60563
Re: CPF No. 5-2015-5014
Dear Mr. Porter:
Enclosed please find the Final Order issued in the above-referenced case to your affiliate,
Olympic Pipe Line Company. It makes findings of violation and specifies actions that need to be
taken by Olympic Pipe Line Company to comply with the pipeline safety regulations. When the
terms of the compliance order have been completed, as determined by the Director, Western
Region, this enforcement action will be closed. Service of the Final Order by certified mail is
deemed effective upon the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Chris Hoidal, Director, Western Region, OPS
Ms. Clorinda Nothstein, Operations Manager, BP Pipelines (North America), Inc.
CERTIFIED MAIL - RETURN RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________________________
In the Matter of )
)
)
Olympic Pipe Line Company, an affiliate of BP Pipelines (North America), Inc., )
)
Respondent. )
____________________________________________________ )
) CPF No. 5-2015-5014
FINAL ORDER
Between August 11 and 29, 2014, pursuant to 49 U.S.C. § 60117, representatives of the Pipeline
and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), and
the Washington Utilities and Trade Commission (WUTC), conducted an on-site pipeline safety
inspection of the facilities and records of Olympic Pipe Line Company (OPL or Respondent) in
the States of Oregon and Washington. OPL is jointly owned by BP Pipelines (North America),
Inc. (BPNA) and Enbridge Energy Partners, LP, and is operated by BPNA. The OPL hazardous
liquid products pipeline consists of approximately 400 miles of intrastate and interstate pipelines
running from Blaine, Washington, to Portland, Oregon. The system transports gasoline, diesel,
and jet fuel, with a capacity of 315,000 barrels, and includes 10 breakout tanks.1
As a result of the inspection, the Director, Western Region, OPS (Director), issued to
Respondent, by letter dated July 2, 2015, a Notice of Probable Violation and Proposed
Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed
finding that OPL had violated 49 C.F.R. §§ 195.573 and 195.575, and proposed ordering
Respondent to take certain measures to correct the alleged violations.
BPNA responded to the Notice on behalf of OPL, by letter dated August 6, 2015 (Response).
Respondent did not contest the allegations of violation but provided information concerning the
corrective actions it had taken since the August 2014 inspection. Respondent did not request a
hearing and therefore has waived its right to one.
1 BP Pipelines (North America), Inc., website, available at http://www.olympicpipeline.com/ (last accessed
November 27, 2015).



CPF No. 5-2015-5014
Page 2
FINDINGS OF VIOLATION
In its Response, OPL did not contest the allegations in the Notice that it violated 49 C.F.R.
Part 195, as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.573(e), which states:
§ 195.573 What must I do to monitor external corrosion control?
(a) . . .
(e) Corrective action. You must correct any identified deficiency in
corrosion control as required by §195.401(b). However, if the deficiency
involves a pipeline in an integrity management program under §195.452,
you must correct the deficiency as required by §195.452(h).
The Notice alleged that Respondent failed to correct identified deficiencies in its corrosion
control system that could adversely affect the safe operation of the pipeline, as required by
49 C.F.R. § 195.401(b). That section provides, in relevant part:
§ 195.401 General requirements.
(a) . . .
(b) An operator must make repairs on its pipeline system according to
the following requirements:
(1) Non Integrity management repairs. Whenever an operator
discovers any condition that could adversely affect the safe operation of its
pipeline system, it must correct the condition within a reasonable time.
The Notice also alleged that Respondent violated 49 C.F.R. § 195.452(h)(1), cited in
§ 195.573(e), which states:
§ 195.452 Pipeline integrity management in high consequence areas.
(a) Which pipelines are covered by this section? This section applies
to each hazardous liquid pipeline and carbon dioxide pipeline that could
affect a high consequence area, including any pipeline located in a high
consequence area unless the operator effectively demonstrates by risk
assessment that the pipeline could not affect the area. . .
(h) What actions must an operator take to address integrity issues?
(1) General requirements. An operator must take prompt action to
address all anomalous conditions the operator discovers through the
integrity assessment or information analysis. In addressing all conditions,
an operator must evaluate all anomalous conditions and remediate those
that could reduce a pipeline's integrity. An operator must be able to
demonstrate that the remediation of the condition will ensure the condition
is unlikely to pose a threat to the long-term integrity of the pipeline. An
operator must comply with §195.422 when making a repair.
The Notice alleged that Respondent failed to correct deficiencies in its corrosion control system



CPF No. 5-2015-5014
Page 3
within a reasonable time, in accordance with § 195.401(b)(1). According to the Notice, in 2010
Respondent performed an in-line-inspection (ILI) that revealed discrepancies in the ILI data,
revealing unrecorded casings on the pipeline system. Subsequent excavations performed by
Respondent revealed additional unrecorded casings, sleeves, and half-sections of pipe at several
locations. In 2011, OPL allegedly initiated a “Casing Wire Repairs” project to further evaluate
and repair casing deficiencies within a 10-year time frame. The Notice alleged that
Respondent’s 10-year time frame to complete the inspections and repairs was not a reasonable
period of time in which to correct the identified deficiencies.
In addition, the Notice alleged that OPL violated 49 C.F.R. § 195.452(h)(1) by failing to take
prompt action to address all anomalous conditions in high consequence areas (HCAs).
2
Specifically, the Notice alleged that Respondent’s “Casing Wire Repairs” project did not
differentiate between anomalous conditions discovered in HCA areas versus non-HCA areas and
that the company’s 10-year time frame for completing the project did not constitute prompt
action for remediating deficiencies found in such areas.
Respondent did not contest these allegations of violation. Accordingly, based upon a review of
all of the evidence, I find that Respondent violated 49 C.F.R. §§ 195.573(e), 195.401(b)(1), and
195.452(h)(1), by failing to correct identified deficiencies in corrosion control within a
reasonable time and to take prompt action to address all anomalous conditions that could affect
HCAs discovered through its integrity assessment or information analysis.
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.575(c), which states:
§ 195.575 Which facilities must I electrically isolate and what
inspections, tests, and safeguards are required?
(a) . . .
(c) You must inspect and electrically test each electrical isolation to
assure the isolation is adequate.
The Notice alleged that Respondent violated 49 C.F.R. § 195.575(c) by failing to test the
electrical isolation of each buried pipeline in the OPL system to assure that the isolation was
adequate. Specifically, the Notice alleged the Respondent failed to test the electrical isolation of
previously unrecorded casings, as described in Item 1 above, to ensure that the isolation from
other metallic structures was adequate. The Notice alleged that several casings were not present
on alignment sheets or other cathodic protection records, indicating previously unrecorded
pipelines had not been tested for adequate isolation.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. 49 C.F.R. § 195.575(c), by failing to
2 An HCA is defined as: (1) a commercially navigable waterway, which means a waterway where a substantial
likelihood of commercial navigation exists; (2) a high population area, which means an urbanized area, as defined
and delineated by the Census Bureau, that contains 50,000 or more people and has a population density of at least
1,000 per square mile; (3) an other populated area, which means a place, as defined and delineated by the Census
Bureau, that contains a concentrated population, such as an incorporated or unincorporated city, town, village, or
other designated residential or commercial area; and (4) an unusually sensitive area. See 49 C.F.R. § 195.450.



CPF No. 5-2015-5014
Page 4
test the electrical isolation of each buried pipeline to assure that the isolation was adequate.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Items 1 and 2 in the Notice for
violations of 49 C.F.R. §§ 195.573(e) and 195.575(c), respectively. Under 49 U.S.C. § 60118(a),
each person who engages in the transportation of hazardous liquids or who owns or operates a
pipeline facility is required to comply with the applicable safety standards established under
chapter 601. In its Response, OPL indicated that it had taken certain actions to comply with the
Proposed Compliance Order. The Director has reviewed such actions and recommended that this
Compliance Order be modified accordingly. Therefore, pursuant to the authority of 49 U.S.C.
§ 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following actions to
ensure compliance with the pipeline safety regulations applicable to its operations:
1. With respect to the violations of § 195.573(e) (Item 1) and § 195.575(c) (Item 2),
Respondent must:
A. Schedule the “Casings Wire Repair” project to mitigate all remaining
indications in HCAs and non-HCAs no later than 18 months from the date of this
Order;
B. Determine whether additional casings exist on its pipeline. Update maps and
records, as necessary, to ensure all programmatic systems which use this data,
including IMP, are accurate; and
C. Submit changes to the “Casing Wire Repair” project within 30 days after the
receipt of this Final Order to Mr. Chris Hoidal, Director, Western Region,
Pipeline and Hazardous Materials Safety Administration.
2. It is requested (not mandated), that Respondent maintain documentation of the
safety improvement costs associated with fulfilling this Final Order and submit the
total to Mr. Chris Hoidal, Director, Western Region, Pipeline and Hazardous
Materials Safety Administration. It is requested these costs be reported in two
categories: 1) total costs associated with preparation/revision of plans, procedures,
studies an analyses; and 2) total cost associated with replacements, additions and
other changes to pipeline infrastructure.
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.
Failure to comply with this Order may result in the administrative assessment of civil penalties



CPF No. 5-2015-5014
Page 5
not to exceed $200,000 for each violation for each day the violation continues or in referral to the
Attorney General for appropriate relief in a district court of the United States.
Under 49 C.F.R. § 190.243, Respondent has a right to submit a Petition for Reconsideration of
this Final Order. The petition must be sent to: Associate Administrator, Office of Pipeline
Safety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC
20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address. PHMSA
will accept petitions received no later than 20 days after receipt of service of this Final Order by
the Respondent, provided they contain a brief statement of the issue(s) and meet all other
requirements of 49 C.F.R. § 190.243. Unless the Associate Administrator, upon request, grants a
stay, the terms and conditions of this Final Order are effective upon service in accordance with
49 C.F.R. § 190.5.
___________________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

520155014_Closure Letter_08252017_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
August 25, 2017
Mr. Donald Porter
President
BP Pipelines (North America), Inc.
Olympic Pipeline Line Company
150 W. Warrenville Road
Naperville, IL 60563
CPF 5-2015-5014
Case Closure
Dear Mr. Porter:
Between August 11 and August 29, 2014, representatives of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), and Washington Utilities and Trade Commission
(WUTC), pursuant to Chapter 601 of 49 United States Code, inspected your Olympic Pipe
Line Co. (OPL) system in the States of Oregon and Washington. As a result of the
inspection, OPL was issued a Final Order and Compliance Order on January 13, 2016.
Based on our review of the documentation you provided and confirmation of the field
inspection by PHSMA and WUTC inspectors, 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,
Dustin Hubbard
Acting Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 C. Allen (Activities: 147690 and 147691)
WUTC
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