{"operation":"document","citation":"CPF 52021054CAO","title":"BETA OFFSHORE — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-10-04","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52021054cao.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52021054cao.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52021054cao","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52021054CAO","body":"Corrective Action Order involving BETA OFFSHORE. The dataset does not identify a cited regulation for this case. The case was opened on 2021-10-04 and is reported as closed as of 2024-03-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52021054CAO_Closure Letter_03152024_(21-225379).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021054CAO/52021054CAO_Closure%20Letter_03152024_(21-225379).pdf\n\n52021054CAO_Closure Letter_03152024_(21-225379)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021054CAO/52021054CAO_Closure%20Letter_03152024_(21-225379)_text.pdf\n\n52021054CAO_Corrective Action Order (AMENDED)_10202022_(21-225379).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021054CAO/52021054CAO_Corrective%20Action%20Order%20(AMENDED)_10202022_(21-225379).pdf\n\n52021054CAO_Corrective Action Order (AMENDED)_10202022_(21-225379)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021054CAO/52021054CAO_Corrective%20Action%20Order%20(AMENDED)_10202022_(21-225379)_text.pdf\n\n52021054CAO_Corrective Action Order_10042021_(21-225379).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021054CAO/52021054CAO_Corrective%20Action%20Order_10042021_(21-225379).pdf\n\n52021054CAO_Corrective Action Order_10042021_(21-225379)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021054CAO/52021054CAO_Corrective%20Action%20Order_10042021_(21-225379)_text.pdf\n\n52021054CAO_Corrective Action Order (AMENDED)_10202022_(21-225379)_text.pdf\n\nVIA ELECTRONIC MAIL TO: martyn.willsher@amplifyenergy.com\nMartyn Willsher\nPresident and Chief Executive Officer\nAmplify Energy Corp.\n111 Ocean Boulevard, Suite 1240\nLong Beach, CA 90802\nCPF No. 5-2021-054-CAO\nDear Mr. Willsher:\nEnclosed please find an Amendment to the Corrective Action Order (CAO) issued by the\nPipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS), in the above- referenced case on October 4, 2021.\nService by electronic transmission is deemed complete upon transmission and acknowledgement\nof receipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms and conditions of this\nAmendment to the CAO are effective upon completion of service.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure: Amendment to the CAO\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS\nMr. Dustin Hubbard, Director, Western Region, OPS\nMr. Dan Steward, Vice President of Operations, Beta Offshore, via email at\ndan.steward@amplifyenergy.com\nMr. Rick Armstrong, Pipeline and Marketing Manager, Beta Offshore, via email at\nrick.armstrong@amplifyenergy.com\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nBeta Offshore, ) CPF No. 5-2021-054-CAO\na subsidiary of Amplify Energy Corp., )\n)\n)\n)\nRespondent. )\n____________________________________)\nAMENDMENT TO CORRECTIVE ACTION ORDER\nPurpose and Background\nOn October 4, 2021, pursuant to 49 U.S.C. § 60112, the Associate Administrator for Pipeline\nSafety, Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a Corrective\nAction Order to Beta Offshore (Respondent), a subsidiary of Amplify Energy, Corp., finding that\ncontinued operation of Respondent’s San Pedro Bay Pipeline, without corrective action, would\nbe hazardous to life, property, or the environment and required Respondent to take immediate\ncorrective action to ensure the safe operation of the pipeline. PHMSA issued the October 4, 2021\nCAO (Original CAO) in response to a failure on the San Pedro Bay Pipeline, a 16-inch hazardous\nliquid pipeline located off the coast of Southern California in San Pedro Bay (Accident).\nPHMSA initiated an investigation into the Accident which remains ongoing.\nAdditional Preliminary Finding\nDue to a bend just below the riser pipe, the original transverse tool that Respondent was ordered\nto run in the Original CAO (Item 4) would become stuck in the bend.\nDetermination of Necessity for Amended Corrective Action Order and Right to Hearing\nSection 60112 of Title 49, United States Code, authorizes PHMSA to determine that a pipeline\nfacility is or would be hazardous to life, property, or the environment and if there is a likelihood\nof serious harm, to expeditiously order the operator of the facility to take necessary corrective\naction, including suspended or restricted use of the facility, physical inspection, testing, repair,\nreplacement, or other appropriate action. An order issued expeditiously must provide an\nopportunity for a hearing as soon as practicable after the order is issued.\nIn deciding whether to issue an order, PHMSA must consider the following, if relevant: (1) the\ncharacteristics of the pipe and other equipment used in the pipeline facility, including the age,\n\n\n\nmanufacture, physical properties, and method of manufacturing, constructing, or assembling the\nequipment; (2) the nature of the material the pipeline facility transports, the corrosive and\ndeteriorative qualities of the material, the sequence in which the material are transported, and the\npressure required for transporting the material; (3) the aspects of the area in which the pipeline\nfacility is located, including climatic and geologic conditions and soil characteristics; (4) the\nproximity of the area in which the hazardous liquid pipeline facility is located to environmentally\nsensitive areas; (5) the population density and population and growth patterns of the area in which\nthe pipeline facility is located; (6) any recommendation of the National Transportation Safety\nBoard made under another law; and (7) other factors PHMSA may considers appropriate.\nAfter evaluating the foregoing additional preliminary finding of fact, and having considered the\ncharacteristics of the pipeline, including its location offshore, the hazardous nature of the material\n(crude oil) transported, the uncertainty as to the root cause(s) of the Accident, the uncertainty of\nthe failure location, the sensitive environmental areas in the vicinity of the pipeline, the ongoing\nimpacts to marine and wildlife, and risk of additional, related accidents, I continue to find that\noperation of the pipeline without corrective measures is or would be hazardous to life, property,\nor the environment, and that failure to issue this Order expeditiously would result in the likelihood\nof serious harm. Further, I find that performance of Item 4 of the Original CAO is no longer\ntechnically feasible, and therefore it is necessary to order alternative actions.\nAccordingly, this Amendment to the CAO mandating immediate corrective action is issued\nwithout prior notice and opportunity for a hearing. The additional actions set forth in this\nAmendment to the CAO are in addition to the actions set forth in the Original CAO and do not\nsuspend or eliminate the requirements of the Original CAO, unless otherwise specifically\nprovided herein. The terms and conditions of this Amendment to the CAO are effective upon\nreceipt.\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, with a copy\nto the Director, Western Region, PHMSA (Director). If a hearing is requested, it will be held in\naccordance with 49 C.F.R. § 190.211.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective measures that need to be taken. Respondent will be notified of any\nadditional measures required and, if appropriate, PHMSA will consider amending this Order. To\nthe extent consistent with safety, Respondent will be afforded notice and an opportunity for a\nhearing prior to the imposition of any additional corrective measures.\nAmendment to Required Corrective Actions\nItem 4 of the Original CAO is revised as follows:\n4. In-Line Assessment. Upon completion of final repairs of the Affected Pipeline, subject to the\napproval by the Director of its Restart Plan, Beta Offshore must conduct an ILI of the Affected\nPipeline using a geometry tool, a high-resolution axial magnetic flux leakage (MFL) tool and\nmust follow all the applicable requirements set forth in 49 C.F.R. § 195.452. In addition, Beta\n\n\n\nOffshore must perform a strength test to be an eight (8) hour hold to a minimum pressure of\n125% of the MOP of 1,152 psig (i.e 1,440 psig) in conformance with 49 C.F.R. § 192.506 and\nconsist of a fifteen (15) minute hold of 2,220 psig, which is 1.5 times the working pressure of the\nANSI 600 series flange.\nBe advised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. § 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for confidential\ntreatment redacted and an explanation of why you believe the redacted information qualifies for\nconfidential treatment under 5 U.S.C. § 552(b).\nIn your correspondence on this matter, please refer to “CPF No. 5-2021-054-CAO” and for each\ndocument you submit, please provide a copy in electronic format whenever possible. The actions\nrequired by this Order are in addition to and do not waive any requirements that apply to\nRespondent’s pipeline system under 49 C.F.R. Parts 190 through 199, under any other order issued\nto Respondent under authority of 49 U.S.C. Chapter 601, or under any other provision of Federal\nor State law. This Order does not preclude additional enforcement by PHMSA.\nRespondent may appeal any decision of the Director to the Associate Administrator for Pipeline\nSafety. Decisions of the Associate Administrator shall be final.\nFailure to comply with this Order may result in the assessment of civil penalties and in referral to\nthe Attorney General for appropriate relief in United States District Court pursuant to\n49 U.S.C. § 60120.\nThe terms and conditions of this Order are effective upon service in accordance with 49 C.F.R.\n§ 190.5.\n___________________________________ __________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n52021054CAO_Corrective Action Order_10042021_(21-225379)_text.pdf\n\nVIA ELECTRONIC MAIL TO: martyn.willsher@amplifyenergy.com\nMartyn Willsher\nPresident and Chief Executive Officer\nAmplify Energy Corp.\n111 Ocean Boulevard, Suite 1240\nLong Beach, CA 90802\nCPF No. 5-2021-054-CAO\nDear Mr. Willsher:\nEnclosed please find a Corrective Action Order (CAO) issued by the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), in the above-\nreferenced case. It requires Beta Offshore (Respondent), a subsidiary of Amplify Energy Corp.,\nto take certain corrective actions with respect to a rupture that occurred on the 16-inch San Pedro\nBay Pipeline that failed offshore near the cities of Long Beach, and Huntington Beach, California.\nService of the CAO by electronic transmission is deemed complete upon transmission and\nacknowledgement of receipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms and\nconditions of this Order are effective upon completion of service.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure: CAO\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS\nMr. Dustin Hubbard, Director, Western Region, OPS\nMr. Dan Steward, Vice President of Operations, Beta Offshore, via email at\ndan.steward@amplifyenergy.com\nMr. Rick Armstrong, Pipeline & Marketing Manager, Beta Offshore, via email at\nrick.armstrong@amplifyenergy.com\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\nIn the Matter of )\n)\n)\nBeta Offshore,\na subsidiary of Amplify Energy, Corp. )\nRespondent. )\n)\n)\n) CPF No. 5-2021-054-CAO\nCORRECTIVE ACTION ORDER\nPurpose and Background\nThis Corrective Action Order (CAO or Order) is being issued under the authority of 49 U.S.C.\n§ 60112 to require Beta Offshore (Respondent), a subsidiary of Amplify Energy, Corp.,1 to take\nthe necessary corrective actions to protect the public, property, and the environment from potential\nhazards associated with the October 2, 2021 rupture of its 16-inch hazardous liquid pipeline located\noff the coast of Southern California in San Pedro Bay (Accident).\nAt approximately 02:30 Pacific Daylight Time (PDT) on October 2, 2021, Beta Offshore’s 16-\ninch San Pedro Bay Pipeline ruptured, resulting in a release of crude oil into the San Pedro Bay,\nan inlet of the Pacific Ocean. Initial estimates indicated that the failed pipeline released\napproximately 700 barrels (BBLs) of crude oil, although the company estimates a maximum\npotential release of approximately 3,134 BBLs.2 Prior to the rupture, the line was reported to be\noperating at approximately 300-400 pounds per square inch gauge (psig).\nBeta Offshore reported that the pipeline was shut down at approximately 06:01 PDT on October\n2, 2021. Diving crews and a remotely operated vehicle have been deployed to identify the exact\nlocation of the failure, which remains unknown. Federal, state, and local agencies responded to the\nscene, including the Pipeline and Hazardous Materials Safety Administration (PHMSA), the\nUnited States Coast Guard, the U.S. Department of Interior’s Bureau of Safety and Environmental\nEnforcement (BSEE), the National Transportation Safety Board (NTSB), the California\n1 Amplify Energy Corp. is an independent oil and natural gas company engaged in the production of oil and natural\ngas properties, with assets in Oklahoma, the Rockies, federal waters offshore in Southern California, East Texas /\nNorth Louisiana, and the Eagle Ford. See Amplify Energy Corp. website, available at www.amplifyenergy.com (last\naccessed Oct. 4, 2021).\n2 The company later reported that the amount released may be 588 BBLs.\n\n\n\nCPF No. 5-2021-054-CAO\nDepartment of Fish and Wildlife (CDFW), the Los Angeles County Sheriff’s Department, and the\nHuntington Beach Police Department.\nPursuant to 49 U.S.C. § 60117, PHMSA, Office of Pipeline Safety (OPS) initiated an investigation\nof the Accident. The preliminary findings of PHMSA’s ongoing investigation are outlined below.\nPreliminary Findings\n At approximately 02:30 PDT (05:30 Eastern Daylight Time (EDT)) on October 2,\n2021, Beta Offshore’s control room personnel received a low-pressure alarm on the\nSan Pedro Bay Pipeline, indicating a possible failure.\n Beta Offshore reported the San Pedro Bay Pipeline was shut down at approximately\n06:01 PDT (09:01 EDT) on October 2, 2021—over three hours later.\n At 12:07 EDT on October 2, 2021 (NRC Report No. 1318463), over six hours after the\ninitial alarm and three hours after the company shut down the pipeline, Beta Offshore\nreported the Accident to the National Response Center (NRC) indicating there was a\nrelease of crude oil in the vicinity of its pipeline near Platform Elly. The U.S. Coast\nGuard submitted a second NRC report at 16:41 EDT on October 3, 2021 (NRC Report\nNo. 1318540), reporting oiled marine life and dead fish. The U.S. Coast Guard\nsubmitted a third NRC report at 17:20 EDT on October 3, 2021 (NRC Report No.\n1318543), reporting that the failure may have been caused by a crack in the pipeline.\n Various state and federal agencies responded to the scene, including the U.S. Coast\nGuard, BSEE, NTSB, PHMSA, CDFW, and local law enforcement. Private oil spill\nresponse organizations under contract with Beta Offshore are also responding.\n An oil sheen can be observed in the San Pedro Bay, an inlet of the Pacific Ocean, for\napproximately 13 miles. Local beaches have been closed. On October 3, 2021,\nCDFW’s Office of Environmental Health Hazard Assessment issued a Declaration of\nFisheries Closure Due to a Public Health Threat Caused by an Oil Spill into Marine\nWaters.\n Clean-up operations are underway. The Wildlife Branch of CDFW’s Office of Spill\nPrevention and Response deployed two Oiled Wildlife Care Network Recovery Teams\nto monitor the shoreline to recover affected wildlife. The Bolsa Chica Restored\nWetlands and Talbert Marsh were boomed to protect the shoreline. Additionally,\nprotection strategies were deployed at Anaheim Bay, Lower Newport Bay, and the\nSanta Ana River.\n The San Pedro Bay Pipeline is approximately 17 miles in length, beginning offshore at\nPlatform Elly and traveling onshore to the Beta Pump Station in the City of Long\nBeach, California. The offshore portion of the pipeline is approximately 15 miles in\nlength and the onshore portion is approximately 2 miles in length.\n\n\n\nCPF No. 5-2021-054-CAO\n The San Pedro Bay Pipeline traverses a High Consequence Area (HCA) as defined in\n49 C.F.R. § 195.450 and an ecologically unusually sensitive area as defined in § 195.6.\n The exact failure location remains unknown. Preliminary reports indicate that the\nfailure location may be approximately 5 miles offshore at a depth of approximately 98\nfeet.\n The pipeline was installed in 1980. It has a 16-inch nominal diameter with 0.500-\ninch wall thickness for the offshore portion and 0.375-inch wall thickness for the\nonshore portion. The pipeline consists of X-42 grade pipe, and has a double-\nsubmerged arc-welded longitudinal seam. The pipe coating type is concrete. The\nonshore portion is cathodically-protected and the offshore portion has sacrificial\nanodes on the pipeline.\n The pipeline remains shut down and the operator is in the process of recovering product\nin the pipeline.\n Prior to the rupture, the San Pedro Bay Pipeline was reported to be operating at\napproximately 300-400 psig. The maximum operating pressure (MOP) of the San\nPedro Bay Pipeline is 1152 psig.\n The root cause of the Accident remains unconfirmed at this time. Preliminary reports\nindicate that the failure may have been caused by an anchor that hooked the pipeline,\ncausing a partial tear.\nDetermination of Necessity for Corrective Action Order and Right to Hearing\nSection 60112 of Title 49, United States Code, authorizes PHMSA to determine that a pipeline\nfacility is or would be hazardous to life, property, or the environment and if there is a likelihood\nof serious harm, to expeditiously order the operator of the facility to take necessary corrective\naction, including suspended or restricted use of the facility, physical inspection, testing, repair,\nreplacement, or other appropriate action. An order issued expeditiously must provide an\nopportunity for a hearing as soon as practicable after the order is issued.\nIn deciding whether to issue an order, PHMSA must consider the following, if relevant: (1) the\ncharacteristics of the pipe and other equipment used in the pipeline facility, including the age,\nmanufacture, physical properties, and method of manufacturing, constructing, or assembling the\nequipment; (2) the nature of the material the pipeline facility transports, the corrosive and\ndeteriorative qualities of the material, the sequence in which the material are transported, and the\npressure required for transporting the material; (3) the aspects of the area in which the pipeline\nfacility is located, including climatic and geologic conditions and soil characteristics; (4) the\nproximity of the area in which the hazardous liquid pipeline facility is located to environmentally\nsensitive areas; (5) the population density and population and growth patterns of the area in which\n\n\n\nCPF No. 5-2021-054-CAO\nthe pipeline facility is located; (6) any recommendation of the National Transportation Safety\nBoard made under another law; and (7) other factors PHMSA may considers appropriate.\nAfter evaluating the foregoing preliminary findings of fact, and having considered the\ncharacteristics of the pipeline, including its location offshore, the hazardous nature of the material\n(crude oil) transported, the uncertainty as to the root cause(s) of the Accident, the uncertainty of\nthe failure location, the sensitive environmental areas in the vicinity of the pipeline, the ongoing\nimpacts to marine and wildlife, and risk of additional, related accidents, I find that continued\noperation of the pipeline without corrective measures is or would be hazardous to life, property,\nor the environment, and that failure to issue this Order expeditiously would result in the likelihood\nof serious harm.\nAccordingly, this Corrective Action Order mandating immediate corrective action is issued without\nprior notice and opportunity for a hearing. The terms and conditions of this Order are effective\nupon 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, with a copy\nto the Director, Western Region, PHMSA (Director). If a hearing is requested, it will be held in\naccordance with 49 C.F.R. § 190.211.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective measures that need to be taken. Respondent will be notified of any\nadditional measures required and, if appropriate, PHMSA will consider amending this Order. To\nthe extent consistent with safety, Respondent will be afforded notice and an opportunity for a\nhearing prior to the imposition of any additional corrective measures.\nRequired Corrective Actions\nDefinitions:\nAffected Pipeline – The “Affected Pipeline” means Beta Offshore’s entire San Pedro Bay\nPipeline, which is approximately 17 miles long, beginning offshore at Platform Elly and ending\nonshore at the Beta Pump Station.\nPursuant to 49 U.S.C. § 60112, I hereby order Beta Offshore to immediately take the following\ncorrective actions:\n1. Shutdown of the Affected Pipeline. The Affected Pipeline, as defined above, must remain\nshut in and may not be operated until authorized to be restarted by the Director in\naccordance with the terms of this Order.\n2. Records Verification. Beta Offshore must verify the records for the Affected Pipeline that\nwere used to establish the MOP. Beta Offshore must submit documentation of this record\nverification to the Director within 45 days of receipt of this Order.\n\n\n\nCPF No. 5-2021-054-CAO\n3. 4. 5. Review of Prior Inline Inspection (ILI) Results. Within 180 days of receipt of this\nOrder, Beta Offshore must conduct a review of any previous ILI results of the Affected\nPipeline, including a review of the ILI vendors’ raw data and analysis. Beta Offshore\nmust determine whether any features were present near the failure site. In addition, Beta\nOffshore must determine if any features with similar characteristics are present elsewhere\non the Affected Pipeline. Beta Offshore must submit documentation of this ILI review to\nthe Director within 180 days of receipt of this Order as follows:\na. b. List all ILI tool runs, tool types, and the calendar years of the tool runs.\nList, describe (type, size, wall loss, etc.), and identify the specific location of all ILI\nfeatures present in the vicinity of the failure location.\nc. List, describe (type, size, wall loss, etc.), and identify the specific location of all ILI\nfeatures with similar characteristics present elsewhere on the Affected Pipeline.\nd. Explain the process used to review the ILI results and the results of the reevaluation.\nIn-Line Assessment. Within 180 days of receipt of this Order, subject to the approval by\nthe Director of its Restart Plan, Beta Offshore must conduct an ILI of the Affected\nPipeline using a geometry tool, a high-resolution axial magnetic flux leakage (MFL) tool\nand a transverse MFL tool, and must follow all the applicable requirements set forth in 49\nC.F.R. § 195.452.\nMechanical and Metallurgical Testing. Within 45 days of receipt of this Order,\ncomplete mechanical and metallurgical testing and failure analysis of the failed pipe,\nincluding an analysis of soil samples and any foreign materials. Complete the testing and\nanalysis as follows:\na. Document the chain-of-custody when handling and transporting the failed pipe\nsection and other evidence from the failure site.\nb. Within 10 days of receipt of this Order, develop and submit the testing protocol and\nthe proposed testing laboratory to the Director for prior approval.\nc. Prior to beginning the mechanical and metallurgical testing, provide the Director\nwith the scheduled date, time, and location of the testing to allow for an OPS\nrepresentative to witness the testing.\nd. Ensure the testing laboratory distributes all reports whether draft or final in their\nentirety to the Director at the same time they are made available to Beta Offshore.\n6. Root Cause Failure Analysis (RCFA). Within 90 days following receipt of this Order,\ncomplete a root cause failure analysis (RCFA) and submit a final report of this RCFA to\nthe Director. The RCFA must be supplemented/facilitated by an independent third-party\nacceptable to the Director and must document the decision-making process and all factors\ncontributing to the failure. The final report must include findings and any lessons learned\nand whether the findings and any lessons learned are applicable to other locations within\nBeta Offshore’s pipeline system.\n7. Remedial Work Plan (RWP).\na. Within 90 days following receipt of this Order, Beta Offshore must submit a\nremedial work plan (RWP) to the Director for approval.\n\n\n\nCPF No. 5-2021-054-CAO\nb. The Director may approve the RWP incrementally without approving the entire\nc. d. e. i. ii. iii. iv. v. RWP.\nOnce approved by the Director, the RWP will be incorporated by reference into this\nOrder.\nThe RWP must specify the tests, inspections, assessments, evaluations, and\nremedial measures Beta Offshore will use to verify the integrity of the Affected\nPipeline. It must address all known or suspected factors and causes of the Accident.\nBeta Offshore must consider the risks and consequences of another failure to\ndevelop a prioritized schedule for RWP-related work along the Affected Pipeline.\nThe RWP must include a procedure or process to:\nIdentify pipe in the Affected Pipeline with characteristics similar to the\ncontributing factors identified for the Accident, including the age and\nmanufacture of the entire length of the Affected Pipeline.\nGather all data necessary to review the failure history (in service and pressure test\nfailures) of the Affected Pipeline and to prepare a written report containing all the\navailable information such as the locations, dates, and causes of leaks and\nfailures.\nIntegrate the results of the mechanical and metallurgical tests, root cause failure\nanalysis, and other corrective actions required by this Order with all relevant pre-\nexisting operational and assessment data for the Affected Pipeline. Pre-existing\noperational data includes, but is not limited to, design, construction, operations,\nmaintenance, testing, repairs, prior metallurgical analyses, and any third-party\nconsultation information. Pre-existing assessment data includes, but is not limited\nto, ILI tool runs, hydrostatic pressure testing, direct assessments, close interval\nsurveys, and direct current voltage gradient (DCVG)/alternating current voltage\ngradient (ACVG) surveys.\nDetermine if conditions similar to those contributing to the Accident are likely to\nexist elsewhere on the Affected Pipeline.\nConduct additional field tests, inspections, assessments, and evaluations to\ndetermine whether, and to what extent, the conditions associated with the\nAccident, and other failures from the failure history (see (e)(ii) above) or any\nother integrity threats are present elsewhere on the Affected Pipeline. At a\nminimum, this process must consider all failure causes and specify the use of one\nor more of the following:\n1) Hydrostatic pressure testing;\n2) Close-interval surveys;\n3) Cathodic protection survey;\n4) Coating surveys;\n5) Stress corrosion cracking surveys;\n6) Selective seam corrosion surveys; and\n7) Other tests, inspections, assessments, and evaluations appropriate for the\n\n\n\nCPF No. 5-2021-054-CAO\n8. 9. failure cause(s).\nNote: Beta Offshore may use the results of previous tests, inspections, assessments, and\nevaluations if approved by the Director, provided the results of the tests, inspections,\nassessments, and evaluations are analyzed with regard to the factors known or\nsuspected to have caused the Accident.\nvi. Describe the inspection and repair criteria Beta Offshore will use to prioritize,\nexcavate, evaluate, and repair anomalies, imperfections, and other identified\nintegrity threats. Include a description of how any defects will be graded and a\nschedule for repairs or replacement.\nvii. Based on the known history and condition of the Affected Pipeline, describe the\nmethods Beta Offshore will use to repair, replace, or take other corrective\nmeasures to remediate the conditions associated with the Accident and to address\nother known integrity threats along the Affected Pipeline. The repair,\nreplacement, or other corrective measures must meet the criteria specified in\n(e)(vi) above.\nviii. Implement continuing long-term periodic testing and integrity verification\nmeasures to ensure the ongoing safe operation of the Affected Pipeline\nconsidering the results of the analyses, inspections, evaluations, and corrective\nmeasures undertaken pursuant to the Order.\nf. g. The RWP must include a proposed schedule for completion of the RWP.\nBeta Offshore must revise the RWP as necessary to incorporate new information\nobtained during the failure investigation and remedial activities, to incorporate the\nresults of actions undertaken pursuant to this Order, and to incorporate\nmodifications required by the Director.\ni. Beta Offshore must submit any plan revisions to the Director for prior approval.\nii. The Director may approve plan revisions incrementally.\niii. All revisions to the RWP after it has been approved and incorporated by\nreference into this Order will be fully described and documented in the CAO\nDocumentation Report.\nh. Beta Offshore must implement the RWP as it is approved by the Director, including\nany revisions to the plan, prior to restart.\nEmergency Response Plan and Training Review. Within 90 days following receipt of\nthis Order, Beta Offshore must review and assess the effectiveness of its emergency\nresponse plan with regard to the Accident. Beta Offshore must include in the review and\nassessment the on-scene response and support, coordination, notification, and\ncommunication with emergency responders and public officials. Also, Beta Offshore\nmust include a review and assessment of the effectiveness of its emergency training\nprogram. Beta Offshore must amend its emergency response plan and emergency\ntraining, if necessary, to reflect the results of this review, within 30 days of completion of\nthe review. The documentation of this Emergency Response Plan and Training Review\nmust be available for inspection by OPS or provided to the Director, if requested.\nPublic Awareness Program Review. Within 90 days following receipt of this Order,\n\n\n\nCPF No. 5-2021-054-CAO\nBeta Offshore must review and assess the effectiveness of its Public Awareness Program\nwith regards to the failure. Beta Offshore must amend its Public Awareness Program, if\nnecessary, to reflect the results of this review within 30 days of completion of the review.\nThe documentation of this Public Awareness Program Review must be available for\ninspection by OPS or provided to the Director, if requested.\n10. CAO Documentation Report (CDR). Beta Offshore must create and revise, as necessary,\na CAO Documentation Report (CDR). When Beta Offshore has concluded all the items\nin this Order, it will submit the final CDR in its entirety to the Director. This will allow\nthe Director to complete a thorough review of all actions taken by Beta Offshore with\nregards to this Order prior to approving the closure of this Order. The intent is for the\nCDR to summarize all activities and documentation associated with this Order in one\ndocument.\na. The Director may approve the CDR incrementally without approving the entire\nCDR.\nb. Once approved by the Director, the CDR will be incorporated by reference into\nthis Order.\nc. The CDR must include, but is not necessarily limited to, the following:\ni. Table of Contents;\nii. iii. Summary of the Accident and the response activities;\nSummary of pipe data, material properties and all prior assessments of the\nAffected Pipeline;\niv. Summary of all tests, inspections, assessments, evaluations, and analysis\nrequired by the Order;\nv. vi. vii. Summary of the metallurgical testing as required by the Order;\nSummary of the RCFA with all root causes as required by the Order;\nDocumentation of all actions taken by Beta Offshore to implement the RWP,\nthe results of those actions, and the inspection and repair criteria used;\nviii. Documentation of any revisions to the RWP including those necessary to\nincorporate the results of actions undertaken pursuant to this Order and\nwhenever necessary to incorporate new information obtained during the\nfailure investigation and remedial activities;\nix. x. Lessons learned while completing this Order;\nA path forward describing specific actions Beta Offshore will take on its\nentire pipeline system as a result of the lessons learned from work on this\nOrder; and\nxi. Appendices (if required).\n11. Restart Plan. No restart of the Affected Pipeline may occur, unless and until a written\nRestart Plan has been submitted and approval had been granted by the Director, and which\nis to be subject to the following:\n\n\n\nCPF No. 5-2021-054-CAO\na. b. The Director may approve the Restart Plan incrementally without approving the\nentire plan, but the Affected Pipeline cannot resume operation until the Restart Plan is\napproved in its entirety.\nOnce approved by the Director, the Restart Plan will be incorporated by reference\ninto this Order.\nc. The Restart Plan must include an 8-hour hydrostatic test, to be held at a minimum of\n1.25 times the MOP, after repairs are completed. Beta Offshore must report the\nresults of the test to the Director.\nd. e. The Restart Plan must provide for adequate patrolling of the Affected Pipeline during\nthe restart process and must be subject to incremental pressure increases during start\nup, with each increment to be held for at least 2 hours.\nThe Restart Plan must provide for sufficient surveillance of the pipeline during each\npressure increment to ensure that no leaks are present when operation of the line\nresumes.\nf. The Restart Plan must specify a day-light restart and include advance\ncommunications with local emergency response officials and adjacent property\nowners, if any.\ng. The Restart Plan must provide for a review of the Affected Pipeline for conditions\nsimilar to those of the failure including a review of construction, operating and\nmaintenance (O&M) and integrity management records such as ILI results,\nhydrostatic tests, root cause failure analyses of any prior failures, aerial and ground\npatrols, corrosion, cathodic protection, excavations and pipe replacements. Beta\nOffshore must address any findings that require remedial measures to be implemented\nprior to restart.\nh. The Restart Plan must also include documentation of the completion of all mandated\nactions, and a management of change plan to ensure that all procedural modifications\nare incorporated into Beta Offshore’s O&M procedures manual.\n12. Operating Pressure Restriction. In accordance with the terms of this Order, upon restart\nBeta Offshore must maintain no less than a twenty percent (20%) pressure reduction in the\nactual operating pressure along the entire length of the Affected Pipeline such that the\noperating pressure along the Affected Pipeline will not exceed eighty percent (80%) of the\nactual operating pressure in effect at the failure location immediately prior to the Accident.\na. This pressure restriction is to remain in effect until written approval to increase the\npressure or return the pipeline to its pre-failure operating pressure is obtained from\nthe Director in accordance with the terms of this Order.\nb. c. Within 15 days of receipt of this Order, Beta Offshore must provide the Director the\nactual operating pressure at the Beta Pump Station on the Affected Pipeline at the time\nof failure and the reduced pressure restriction set-points required by this Order.\nThis pressure restriction requires any relevant remote or local alarm limits, software\nprogramming set-points or control points, and mechanical over-pressure devices to be\nadjusted accordingly.\n\n\n\nCPF No. 5-2021-054-CAO\nd. When determining the pressure restriction set-points, Beta Offshore must take into\naccount any in-line inspection (ILI) features or anomalies present in the Affected\nPipeline to provide for continued safe operation while further corrective actions are\ncompleted.\ne. Beta Offshore must review the pressure restriction monthly by analyzing the\noperating pressure data, taking into account any ILI features or anomalies present in\nthe Affected Pipeline. Beta Offshore must immediately reduce the operating pressure\nfurther to maintain the safe operations of the Affected Pipeline, if warranted by the\nmonthly review. Further, Beta Offshore must submit the results of the monthly review\nto the Director including, at a minimum, the current discharge set-points (including\nany additional pressure reductions), and any pressure exceedance at discharge set-\npoints. Submittals may be made quarterly, in accordance with the terms of this Order.\n13. Return to Service. Upon approval of the Restart Plan, Beta Offshore may return the\nAffected Pipeline to service according to the terms of the Restart Plan, but the operating\npressure must not exceed the limit in accordance with the terms of this Order.\n14. Removal of Pressure Restriction.\na. The Director may allow the removal or modification of the pressure restriction upon a\nwritten request from Beta Offshore demonstrating that restoring the pipeline to its\npre-failure operating pressure is justified based on a reliable engineering analysis\nshowing that the pressure increase is safe considering all known defects, anomalies,\nand operating parameters of the pipeline.\nb. The Director may allow the temporary removal or modification of the pressure\nrestrictions upon a written request from Beta Offshore demonstrating that temporary\nmitigative and preventive measures are implemented prior to and during the\ntemporary removal or modification of the pressure restriction. The Director’s\ndetermination will be based on available information, including the failure cause and\nprovision of evidence that preventative and mitigative actions taken by the operator\nprovide for the safe operation of the Affected Pipeline during the temporary removal\nor modification of the pressure restriction. Appeals to determinations of the Director\nin this regard will be decided by the Associate Administrator for Pipeline Safety.\n15. Leakage Survey. Within 24 hours of returning the pipeline to service, Beta Offshore\nmust perform an aerial survey (off-shore) and ground leakage survey (on-shore) of the\nAffected Pipeline Right-of-Way. If Beta Offshore identifies any leak indications, it must\nimmediately shut down the Affected Pipeline and investigate all leak indications and\nremedy all leaks discovered prior to restart. Beta Offshore must submit documentation of\nthis survey to the Director within 48 hours of a return to service.\nOther Requirements:\n16. Approvals. With respect to each submission that under this Order requires the approval\nof the Director, the Director may: (a) approve, in whole or part, the submission; (b)\napprove the submission on specified conditions; (c) modify the submission to cure any\ndeficiencies; (d) disapprove in whole or in part, the su","truncated":true,"body_characters":44762}