# BETA OFFSHORE — Corrective Action Order

- **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:** Not available
- **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.

Official case documents:

52021054CAO_Closure Letter_03152024_(21-225379).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021054CAO/52021054CAO_Closure%20Letter_03152024_(21-225379).pdf

52021054CAO_Closure Letter_03152024_(21-225379)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021054CAO/52021054CAO_Closure%20Letter_03152024_(21-225379)_text.pdf

52021054CAO_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

52021054CAO_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

52021054CAO_Corrective Action Order_10042021_(21-225379).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021054CAO/52021054CAO_Corrective%20Action%20Order_10042021_(21-225379).pdf

52021054CAO_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

52021054CAO_Corrective Action Order (AMENDED)_10202022_(21-225379)_text.pdf

VIA ELECTRONIC MAIL TO: martyn.willsher@amplifyenergy.com
Martyn Willsher
President and Chief Executive Officer
Amplify Energy Corp.
111 Ocean Boulevard, Suite 1240
Long Beach, CA 90802
CPF No. 5-2021-054-CAO
Dear Mr. Willsher:
Enclosed please find an Amendment to the Corrective Action Order (CAO) issued by the
Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
(OPS), in the above- referenced case on October 4, 2021.
Service by electronic transmission is deemed complete upon transmission and acknowledgement
of receipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms and conditions of this
Amendment to the CAO are effective upon completion of service.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure: Amendment to the CAO
cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS
Mr. Dustin Hubbard, Director, Western Region, OPS
Mr. Dan Steward, Vice President of Operations, Beta Offshore, via email at
dan.steward@amplifyenergy.com
Mr. Rick Armstrong, Pipeline and Marketing Manager, Beta Offshore, via email at
rick.armstrong@amplifyenergy.com



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Beta Offshore, ) CPF No. 5-2021-054-CAO
a subsidiary of Amplify Energy Corp., )
)
)
)
Respondent. )
____________________________________)
AMENDMENT TO CORRECTIVE ACTION ORDER
Purpose and Background
On October 4, 2021, pursuant to 49 U.S.C. § 60112, the Associate Administrator for Pipeline
Safety, Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a Corrective
Action Order to Beta Offshore (Respondent), a subsidiary of Amplify Energy, Corp., finding that
continued operation of Respondent’s San Pedro Bay Pipeline, without corrective action, would
be hazardous to life, property, or the environment and required Respondent to take immediate
corrective action to ensure the safe operation of the pipeline. PHMSA issued the October 4, 2021
CAO (Original CAO) in response to a failure on the San Pedro Bay Pipeline, a 16-inch hazardous
liquid pipeline located off the coast of Southern California in San Pedro Bay (Accident).
PHMSA initiated an investigation into the Accident which remains ongoing.
Additional Preliminary Finding
Due to a bend just below the riser pipe, the original transverse tool that Respondent was ordered
to run in the Original CAO (Item 4) would become stuck in the bend.
Determination of Necessity for Amended Corrective Action Order and Right to Hearing
Section 60112 of Title 49, United States Code, authorizes PHMSA to determine that a pipeline
facility is or would be hazardous to life, property, or the environment and if there is a likelihood
of serious harm, to expeditiously order the operator of the facility to take necessary corrective
action, including suspended or restricted use of the facility, physical inspection, testing, repair,
replacement, or other appropriate action. An order issued expeditiously must provide an
opportunity for a hearing as soon as practicable after the order is issued.
In deciding whether to issue an order, PHMSA must consider the following, if relevant: (1) the
characteristics of the pipe and other equipment used in the pipeline facility, including the age,



manufacture, physical properties, and method of manufacturing, constructing, or assembling the
equipment; (2) the nature of the material the pipeline facility transports, the corrosive and
deteriorative qualities of the material, the sequence in which the material are transported, and the
pressure required for transporting the material; (3) the aspects of the area in which the pipeline
facility is located, including climatic and geologic conditions and soil characteristics; (4) the
proximity of the area in which the hazardous liquid pipeline facility is located to environmentally
sensitive areas; (5) the population density and population and growth patterns of the area in which
the pipeline facility is located; (6) any recommendation of the National Transportation Safety
Board made under another law; and (7) other factors PHMSA may considers appropriate.
After evaluating the foregoing additional preliminary finding of fact, and having considered the
characteristics of the pipeline, including its location offshore, the hazardous nature of the material
(crude oil) transported, the uncertainty as to the root cause(s) of the Accident, the uncertainty of
the failure location, the sensitive environmental areas in the vicinity of the pipeline, the ongoing
impacts to marine and wildlife, and risk of additional, related accidents, I continue to find that
operation of the pipeline without corrective measures is or would be hazardous to life, property,
or the environment, and that failure to issue this Order expeditiously would result in the likelihood
of serious harm. Further, I find that performance of Item 4 of the Original CAO is no longer
technically feasible, and therefore it is necessary to order alternative actions.
Accordingly, this Amendment to the CAO mandating immediate corrective action is issued
without prior notice and opportunity for a hearing. The additional actions set forth in this
Amendment to the CAO are in addition to the actions set forth in the Original CAO and do not
suspend or eliminate the requirements of the Original CAO, unless otherwise specifically
provided herein. The terms and conditions of this Amendment to the CAO are effective upon
receipt.
Within 10 days of receipt of this Order, Respondent may request a hearing, to be held as soon as
practicable, by notifying the Associate Administrator for Pipeline Safety in writing, with a copy
to the Director, Western Region, PHMSA (Director). If a hearing is requested, it will be held in
accordance with 49 C.F.R. § 190.211.
After receiving and analyzing additional data in the course of this investigation, PHMSA may
identify other corrective measures that need to be taken. Respondent will be notified of any
additional measures required and, if appropriate, PHMSA will consider amending this Order. To
the extent consistent with safety, Respondent will be afforded notice and an opportunity for a
hearing prior to the imposition of any additional corrective measures.
Amendment to Required Corrective Actions
Item 4 of the Original CAO is revised as follows:
4. In-Line Assessment. Upon completion of final repairs of the Affected Pipeline, subject to the
approval by the Director of its Restart Plan, Beta Offshore must conduct an ILI of the Affected
Pipeline using a geometry tool, a high-resolution axial magnetic flux leakage (MFL) tool and
must follow all the applicable requirements set forth in 49 C.F.R. § 195.452. In addition, Beta



Offshore must perform a strength test to be an eight (8) hour hold to a minimum pressure of
125% of the MOP of 1,152 psig (i.e 1,440 psig) in conformance with 49 C.F.R. § 192.506 and
consist of a fifteen (15) minute hold of 2,220 psig, which is 1.5 times the working pressure of the
ANSI 600 series flange.
Be advised that all material you submit in response to this enforcement action is subject to being
made publicly available. If you believe that any portion of your responsive material qualifies for
confidential treatment under 5 U.S.C. § 552(b), along with the complete original document you
must provide a second copy of the document with the portions you believe qualify for confidential
treatment redacted and an explanation of why you believe the redacted information qualifies for
confidential treatment under 5 U.S.C. § 552(b).
In your correspondence on this matter, please refer to “CPF No. 5-2021-054-CAO” and for each
document you submit, please provide a copy in electronic format whenever possible. The actions
required by this Order are in addition to and do not waive any requirements that apply to
Respondent’s pipeline system under 49 C.F.R. Parts 190 through 199, under any other order issued
to Respondent under authority of 49 U.S.C. Chapter 601, or under any other provision of Federal
or State law. This Order does not preclude additional enforcement by PHMSA.
Respondent may appeal any decision of the Director to the Associate Administrator for Pipeline
Safety. Decisions of the Associate Administrator shall be final.
Failure to comply with this Order may result in the assessment of civil penalties and in referral to
the Attorney General for appropriate relief in United States District Court pursuant to
49 U.S.C. § 60120.
The terms and conditions of this Order are effective upon service in accordance with 49 C.F.R.
§ 190.5.
___________________________________ __________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety

52021054CAO_Corrective Action Order_10042021_(21-225379)_text.pdf

VIA ELECTRONIC MAIL TO: martyn.willsher@amplifyenergy.com
Martyn Willsher
President and Chief Executive Officer
Amplify Energy Corp.
111 Ocean Boulevard, Suite 1240
Long Beach, CA 90802
CPF No. 5-2021-054-CAO
Dear Mr. Willsher:
Enclosed please find a Corrective Action Order (CAO) issued by the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), in the above-
referenced case. It requires Beta Offshore (Respondent), a subsidiary of Amplify Energy Corp.,
to take certain corrective actions with respect to a rupture that occurred on the 16-inch San Pedro
Bay Pipeline that failed offshore near the cities of Long Beach, and Huntington Beach, California.
Service of the CAO by electronic transmission is deemed complete upon transmission and
acknowledgement of receipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms and
conditions of this Order are effective upon completion of service.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure: CAO
cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS
Mr. Dustin Hubbard, Director, Western Region, OPS
Mr. Dan Steward, Vice President of Operations, Beta Offshore, via email at
dan.steward@amplifyenergy.com
Mr. Rick Armstrong, Pipeline & Marketing Manager, Beta Offshore, via email at
rick.armstrong@amplifyenergy.com



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
In the Matter of )
)
)
Beta Offshore,
a subsidiary of Amplify Energy, Corp. )
Respondent. )
)
)
) CPF No. 5-2021-054-CAO
CORRECTIVE ACTION ORDER
Purpose and Background
This Corrective Action Order (CAO or Order) is being issued under the authority of 49 U.S.C.
§ 60112 to require Beta Offshore (Respondent), a subsidiary of Amplify Energy, Corp.,1 to take
the necessary corrective actions to protect the public, property, and the environment from potential
hazards associated with the October 2, 2021 rupture of its 16-inch hazardous liquid pipeline located
off the coast of Southern California in San Pedro Bay (Accident).
At approximately 02:30 Pacific Daylight Time (PDT) on October 2, 2021, Beta Offshore’s 16-
inch San Pedro Bay Pipeline ruptured, resulting in a release of crude oil into the San Pedro Bay,
an inlet of the Pacific Ocean. Initial estimates indicated that the failed pipeline released
approximately 700 barrels (BBLs) of crude oil, although the company estimates a maximum
potential release of approximately 3,134 BBLs.2 Prior to the rupture, the line was reported to be
operating at approximately 300-400 pounds per square inch gauge (psig).
Beta Offshore reported that the pipeline was shut down at approximately 06:01 PDT on October
2, 2021. Diving crews and a remotely operated vehicle have been deployed to identify the exact
location of the failure, which remains unknown. Federal, state, and local agencies responded to the
scene, including the Pipeline and Hazardous Materials Safety Administration (PHMSA), the
United States Coast Guard, the U.S. Department of Interior’s Bureau of Safety and Environmental
Enforcement (BSEE), the National Transportation Safety Board (NTSB), the California
1 Amplify Energy Corp. is an independent oil and natural gas company engaged in the production of oil and natural
gas properties, with assets in Oklahoma, the Rockies, federal waters offshore in Southern California, East Texas /
North Louisiana, and the Eagle Ford. See Amplify Energy Corp. website, available at www.amplifyenergy.com (last
accessed Oct. 4, 2021).
2 The company later reported that the amount released may be 588 BBLs.



CPF No. 5-2021-054-CAO
Department of Fish and Wildlife (CDFW), the Los Angeles County Sheriff’s Department, and the
Huntington Beach Police Department.
Pursuant to 49 U.S.C. § 60117, PHMSA, Office of Pipeline Safety (OPS) initiated an investigation
of the Accident. The preliminary findings of PHMSA’s ongoing investigation are outlined below.
Preliminary Findings
 At approximately 02:30 PDT (05:30 Eastern Daylight Time (EDT)) on October 2,
2021, Beta Offshore’s control room personnel received a low-pressure alarm on the
San Pedro Bay Pipeline, indicating a possible failure.
 Beta Offshore reported the San Pedro Bay Pipeline was shut down at approximately
06:01 PDT (09:01 EDT) on October 2, 2021—over three hours later.
 At 12:07 EDT on October 2, 2021 (NRC Report No. 1318463), over six hours after the
initial alarm and three hours after the company shut down the pipeline, Beta Offshore
reported the Accident to the National Response Center (NRC) indicating there was a
release of crude oil in the vicinity of its pipeline near Platform Elly. The U.S. Coast
Guard submitted a second NRC report at 16:41 EDT on October 3, 2021 (NRC Report
No. 1318540), reporting oiled marine life and dead fish. The U.S. Coast Guard
submitted a third NRC report at 17:20 EDT on October 3, 2021 (NRC Report No.
1318543), reporting that the failure may have been caused by a crack in the pipeline.
 Various state and federal agencies responded to the scene, including the U.S. Coast
Guard, BSEE, NTSB, PHMSA, CDFW, and local law enforcement. Private oil spill
response organizations under contract with Beta Offshore are also responding.
 An oil sheen can be observed in the San Pedro Bay, an inlet of the Pacific Ocean, for
approximately 13 miles. Local beaches have been closed. On October 3, 2021,
CDFW’s Office of Environmental Health Hazard Assessment issued a Declaration of
Fisheries Closure Due to a Public Health Threat Caused by an Oil Spill into Marine
Waters.
 Clean-up operations are underway. The Wildlife Branch of CDFW’s Office of Spill
Prevention and Response deployed two Oiled Wildlife Care Network Recovery Teams
to monitor the shoreline to recover affected wildlife. The Bolsa Chica Restored
Wetlands and Talbert Marsh were boomed to protect the shoreline. Additionally,
protection strategies were deployed at Anaheim Bay, Lower Newport Bay, and the
Santa Ana River.
 The San Pedro Bay Pipeline is approximately 17 miles in length, beginning offshore at
Platform Elly and traveling onshore to the Beta Pump Station in the City of Long
Beach, California. The offshore portion of the pipeline is approximately 15 miles in
length and the onshore portion is approximately 2 miles in length.



CPF No. 5-2021-054-CAO
 The San Pedro Bay Pipeline traverses a High Consequence Area (HCA) as defined in
49 C.F.R. § 195.450 and an ecologically unusually sensitive area as defined in § 195.6.
 The exact failure location remains unknown. Preliminary reports indicate that the
failure location may be approximately 5 miles offshore at a depth of approximately 98
feet.
 The pipeline was installed in 1980. It has a 16-inch nominal diameter with 0.500-
inch wall thickness for the offshore portion and 0.375-inch wall thickness for the
onshore portion. The pipeline consists of X-42 grade pipe, and has a double-
submerged arc-welded longitudinal seam. The pipe coating type is concrete. The
onshore portion is cathodically-protected and the offshore portion has sacrificial
anodes on the pipeline.
 The pipeline remains shut down and the operator is in the process of recovering product
in the pipeline.
 Prior to the rupture, the San Pedro Bay Pipeline was reported to be operating at
approximately 300-400 psig. The maximum operating pressure (MOP) of the San
Pedro Bay Pipeline is 1152 psig.
 The root cause of the Accident remains unconfirmed at this time. Preliminary reports
indicate that the failure may have been caused by an anchor that hooked the pipeline,
causing a partial tear.
Determination of Necessity for Corrective Action Order and Right to Hearing
Section 60112 of Title 49, United States Code, authorizes PHMSA to determine that a pipeline
facility is or would be hazardous to life, property, or the environment and if there is a likelihood
of serious harm, to expeditiously order the operator of the facility to take necessary corrective
action, including suspended or restricted use of the facility, physical inspection, testing, repair,
replacement, or other appropriate action. An order issued expeditiously must provide an
opportunity for a hearing as soon as practicable after the order is issued.
In deciding whether to issue an order, PHMSA must consider the following, if relevant: (1) the
characteristics of the pipe and other equipment used in the pipeline facility, including the age,
manufacture, physical properties, and method of manufacturing, constructing, or assembling the
equipment; (2) the nature of the material the pipeline facility transports, the corrosive and
deteriorative qualities of the material, the sequence in which the material are transported, and the
pressure required for transporting the material; (3) the aspects of the area in which the pipeline
facility is located, including climatic and geologic conditions and soil characteristics; (4) the
proximity of the area in which the hazardous liquid pipeline facility is located to environmentally
sensitive areas; (5) the population density and population and growth patterns of the area in which



CPF No. 5-2021-054-CAO
the pipeline facility is located; (6) any recommendation of the National Transportation Safety
Board made under another law; and (7) other factors PHMSA may considers appropriate.
After evaluating the foregoing preliminary findings of fact, and having considered the
characteristics of the pipeline, including its location offshore, the hazardous nature of the material
(crude oil) transported, the uncertainty as to the root cause(s) of the Accident, the uncertainty of
the failure location, the sensitive environmental areas in the vicinity of the pipeline, the ongoing
impacts to marine and wildlife, and risk of additional, related accidents, I find that continued
operation of the pipeline without corrective measures is or would be hazardous to life, property,
or the environment, and that failure to issue this Order expeditiously would result in the likelihood
of serious harm.
Accordingly, this Corrective Action Order mandating immediate corrective action is issued without
prior notice and opportunity for a hearing. The terms and conditions of this Order are effective
upon receipt.
Within 10 days of receipt of this Order, Respondent may request a hearing, to be held as soon as
practicable, by notifying the Associate Administrator for Pipeline Safety in writing, with a copy
to the Director, Western Region, PHMSA (Director). If a hearing is requested, it will be held in
accordance with 49 C.F.R. § 190.211.
After receiving and analyzing additional data in the course of this investigation, PHMSA may
identify other corrective measures that need to be taken. Respondent will be notified of any
additional measures required and, if appropriate, PHMSA will consider amending this Order. To
the extent consistent with safety, Respondent will be afforded notice and an opportunity for a
hearing prior to the imposition of any additional corrective measures.
Required Corrective Actions
Definitions:
Affected Pipeline – The “Affected Pipeline” means Beta Offshore’s entire San Pedro Bay
Pipeline, which is approximately 17 miles long, beginning offshore at Platform Elly and ending
onshore at the Beta Pump Station.
Pursuant to 49 U.S.C. § 60112, I hereby order Beta Offshore to immediately take the following
corrective actions:
1. Shutdown of the Affected Pipeline. The Affected Pipeline, as defined above, must remain
shut in and may not be operated until authorized to be restarted by the Director in
accordance with the terms of this Order.
2. Records Verification. Beta Offshore must verify the records for the Affected Pipeline that
were used to establish the MOP. Beta Offshore must submit documentation of this record
verification to the Director within 45 days of receipt of this Order.



CPF No. 5-2021-054-CAO
3. 4. 5. Review of Prior Inline Inspection (ILI) Results. Within 180 days of receipt of this
Order, Beta Offshore must conduct a review of any previous ILI results of the Affected
Pipeline, including a review of the ILI vendors’ raw data and analysis. Beta Offshore
must determine whether any features were present near the failure site. In addition, Beta
Offshore must determine if any features with similar characteristics are present elsewhere
on the Affected Pipeline. Beta Offshore must submit documentation of this ILI review to
the Director within 180 days of receipt of this Order as follows:
a. b. List all ILI tool runs, tool types, and the calendar years of the tool runs.
List, describe (type, size, wall loss, etc.), and identify the specific location of all ILI
features present in the vicinity of the failure location.
c. List, describe (type, size, wall loss, etc.), and identify the specific location of all ILI
features with similar characteristics present elsewhere on the Affected Pipeline.
d. Explain the process used to review the ILI results and the results of the reevaluation.
In-Line Assessment. Within 180 days of receipt of this Order, subject to the approval by
the Director of its Restart Plan, Beta Offshore must conduct an ILI of the Affected
Pipeline using a geometry tool, a high-resolution axial magnetic flux leakage (MFL) tool
and a transverse MFL tool, and must follow all the applicable requirements set forth in 49
C.F.R. § 195.452.
Mechanical and Metallurgical Testing. Within 45 days of receipt of this Order,
complete mechanical and metallurgical testing and failure analysis of the failed pipe,
including an analysis of soil samples and any foreign materials. Complete the testing and
analysis as follows:
a. Document the chain-of-custody when handling and transporting the failed pipe
section and other evidence from the failure site.
b. Within 10 days of receipt of this Order, develop and submit the testing protocol and
the proposed testing laboratory to the Director for prior approval.
c. Prior to beginning the mechanical and metallurgical testing, provide the Director
with the scheduled date, time, and location of the testing to allow for an OPS
representative to witness the testing.
d. Ensure the testing laboratory distributes all reports whether draft or final in their
entirety to the Director at the same time they are made available to Beta Offshore.
6. Root Cause Failure Analysis (RCFA). Within 90 days following receipt of this Order,
complete a root cause failure analysis (RCFA) and submit a final report of this RCFA to
the Director. The RCFA must be supplemented/facilitated by an independent third-party
acceptable to the Director and must document the decision-making process and all factors
contributing to the failure. The final report must include findings and any lessons learned
and whether the findings and any lessons learned are applicable to other locations within
Beta Offshore’s pipeline system.
7. Remedial Work Plan (RWP).
a. Within 90 days following receipt of this Order, Beta Offshore must submit a
remedial work plan (RWP) to the Director for approval.



CPF No. 5-2021-054-CAO
b. The Director may approve the RWP incrementally without approving the entire
c. d. e. i. ii. iii. iv. v. RWP.
Once approved by the Director, the RWP will be incorporated by reference into this
Order.
The RWP must specify the tests, inspections, assessments, evaluations, and
remedial measures Beta Offshore will use to verify the integrity of the Affected
Pipeline. It must address all known or suspected factors and causes of the Accident.
Beta Offshore must consider the risks and consequences of another failure to
develop a prioritized schedule for RWP-related work along the Affected Pipeline.
The RWP must include a procedure or process to:
Identify pipe in the Affected Pipeline with characteristics similar to the
contributing factors identified for the Accident, including the age and
manufacture of the entire length of the Affected Pipeline.
Gather all data necessary to review the failure history (in service and pressure test
failures) of the Affected Pipeline and to prepare a written report containing all the
available information such as the locations, dates, and causes of leaks and
failures.
Integrate the results of the mechanical and metallurgical tests, root cause failure
analysis, and other corrective actions required by this Order with all relevant pre-
existing operational and assessment data for the Affected Pipeline. Pre-existing
operational data includes, but is not limited to, design, construction, operations,
maintenance, testing, repairs, prior metallurgical analyses, and any third-party
consultation information. Pre-existing assessment data includes, but is not limited
to, ILI tool runs, hydrostatic pressure testing, direct assessments, close interval
surveys, and direct current voltage gradient (DCVG)/alternating current voltage
gradient (ACVG) surveys.
Determine if conditions similar to those contributing to the Accident are likely to
exist elsewhere on the Affected Pipeline.
Conduct additional field tests, inspections, assessments, and evaluations to
determine whether, and to what extent, the conditions associated with the
Accident, and other failures from the failure history (see (e)(ii) above) or any
other integrity threats are present elsewhere on the Affected Pipeline. At a
minimum, this process must consider all failure causes and specify the use of one
or more of the following:
1) Hydrostatic pressure testing;
2) Close-interval surveys;
3) Cathodic protection survey;
4) Coating surveys;
5) Stress corrosion cracking surveys;
6) Selective seam corrosion surveys; and
7) Other tests, inspections, assessments, and evaluations appropriate for the



CPF No. 5-2021-054-CAO
8. 9. failure cause(s).
Note: Beta Offshore may use the results of previous tests, inspections, assessments, and
evaluations if approved by the Director, provided the results of the tests, inspections,
assessments, and evaluations are analyzed with regard to the factors known or
suspected to have caused the Accident.
vi. Describe the inspection and repair criteria Beta Offshore will use to prioritize,
excavate, evaluate, and repair anomalies, imperfections, and other identified
integrity threats. Include a description of how any defects will be graded and a
schedule for repairs or replacement.
vii. Based on the known history and condition of the Affected Pipeline, describe the
methods Beta Offshore will use to repair, replace, or take other corrective
measures to remediate the conditions associated with the Accident and to address
other known integrity threats along the Affected Pipeline. The repair,
replacement, or other corrective measures must meet the criteria specified in
(e)(vi) above.
viii. Implement continuing long-term periodic testing and integrity verification
measures to ensure the ongoing safe operation of the Affected Pipeline
considering the results of the analyses, inspections, evaluations, and corrective
measures undertaken pursuant to the Order.
f. g. The RWP must include a proposed schedule for completion of the RWP.
Beta Offshore must revise the RWP as necessary to incorporate new information
obtained during the failure investigation and remedial activities, to incorporate the
results of actions undertaken pursuant to this Order, and to incorporate
modifications required by the Director.
i. Beta Offshore must submit any plan revisions to the Director for prior approval.
ii. The Director may approve plan revisions incrementally.
iii. All revisions to the RWP after it has been approved and incorporated by
reference into this Order will be fully described and documented in the CAO
Documentation Report.
h. Beta Offshore must implement the RWP as it is approved by the Director, including
any revisions to the plan, prior to restart.
Emergency Response Plan and Training Review. Within 90 days following receipt of
this Order, Beta Offshore must review and assess the effectiveness of its emergency
response plan with regard to the Accident. Beta Offshore must include in the review and
assessment the on-scene response and support, coordination, notification, and
communication with emergency responders and public officials. Also, Beta Offshore
must include a review and assessment of the effectiveness of its emergency training
program. Beta Offshore must amend its emergency response plan and emergency
training, if necessary, to reflect the results of this review, within 30 days of completion of
the review. The documentation of this Emergency Response Plan and Training Review
must be available for inspection by OPS or provided to the Director, if requested.
Public Awareness Program Review. Within 90 days following receipt of this Order,



CPF No. 5-2021-054-CAO
Beta Offshore must review and assess the effectiveness of its Public Awareness Program
with regards to the failure. Beta Offshore must amend its Public Awareness Program, if
necessary, to reflect the results of this review within 30 days of completion of the review.
The documentation of this Public Awareness Program Review must be available for
inspection by OPS or provided to the Director, if requested.
10. CAO Documentation Report (CDR). Beta Offshore must create and revise, as necessary,
a CAO Documentation Report (CDR). When Beta Offshore has concluded all the items
in this Order, it will submit the final CDR in its entirety to the Director. This will allow
the Director to complete a thorough review of all actions taken by Beta Offshore with
regards to this Order prior to approving the closure of this Order. The intent is for the
CDR to summarize all activities and documentation associated with this Order in one
document.
a. The Director may approve the CDR incrementally without approving the entire
CDR.
b. Once approved by the Director, the CDR will be incorporated by reference into
this Order.
c. The CDR must include, but is not necessarily limited to, the following:
i. Table of Contents;
ii. iii. Summary of the Accident and the response activities;
Summary of pipe data, material properties and all prior assessments of the
Affected Pipeline;
iv. Summary of all tests, inspections, assessments, evaluations, and analysis
required by the Order;
v. vi. vii. Summary of the metallurgical testing as required by the Order;
Summary of the RCFA with all root causes as required by the Order;
Documentation of all actions taken by Beta Offshore to implement the RWP,
the results of those actions, and the inspection and repair criteria used;
viii. Documentation of any revisions to the RWP including those necessary to
incorporate the results of actions undertaken pursuant to this Order and
whenever necessary to incorporate new information obtained during the
failure investigation and remedial activities;
ix. x. Lessons learned while completing this Order;
A path forward describing specific actions Beta Offshore will take on its
entire pipeline system as a result of the lessons learned from work on this
Order; and
xi. Appendices (if required).
11. Restart Plan. No restart of the Affected Pipeline may occur, unless and until a written
Restart Plan has been submitted and approval had been granted by the Director, and which
is to be subject to the following:



CPF No. 5-2021-054-CAO
a. b. The Director may approve the Restart Plan incrementally without approving the
entire plan, but the Affected Pipeline cannot resume operation until the Restart Plan is
approved in its entirety.
Once approved by the Director, the Restart Plan will be incorporated by reference
into this Order.
c. The Restart Plan must include an 8-hour hydrostatic test, to be held at a minimum of
1.25 times the MOP, after repairs are completed. Beta Offshore must report the
results of the test to the Director.
d. e. The Restart Plan must provide for adequate patrolling of the Affected Pipeline during
the restart process and must be subject to incremental pressure increases during start
up, with each increment to be held for at least 2 hours.
The Restart Plan must provide for sufficient surveillance of the pipeline during each
pressure increment to ensure that no leaks are present when operation of the line
resumes.
f. The Restart Plan must specify a day-light restart and include advance
communications with local emergency response officials and adjacent property
owners, if any.
g. The Restart Plan must provide for a review of the Affected Pipeline for conditions
similar to those of the failure including a review of construction, operating and
maintenance (O&M) and integrity management records such as ILI results,
hydrostatic tests, root cause failure analyses of any prior failures, aerial and ground
patrols, corrosion, cathodic protection, excavations and pipe replacements. Beta
Offshore must address any findings that require remedial measures to be implemented
prior to restart.
h. The Restart Plan must also include documentation of the completion of all mandated
actions, and a management of change plan to ensure that all procedural modifications
are incorporated into Beta Offshore’s O&M procedures manual.
12. Operating Pressure Restriction. In accordance with the terms of this Order, upon restart
Beta Offshore must maintain no less than a twenty percent (20%) pressure reduction in the
actual operating pressure along the entire length of the Affected Pipeline such that the
operating pressure along the Affected Pipeline will not exceed eighty percent (80%) of the
actual operating pressure in effect at the failure location immediately prior to the Accident.
a. This pressure restriction is to remain in effect until written approval to increase the
pressure or return the pipeline to its pre-failure operating pressure is obtained from
the Director in accordance with the terms of this Order.
b. c. Within 15 days of receipt of this Order, Beta Offshore must provide the Director the
actual operating pressure at the Beta Pump Station on the Affected Pipeline at the time
of failure and the reduced pressure restriction set-points required by this Order.
This pressure restriction requires any relevant remote or local alarm limits, software
programming set-points or control points, and mechanical over-pressure devices to be
adjusted accordingly.



CPF No. 5-2021-054-CAO
d. When determining the pressure restriction set-points, Beta Offshore must take into
account any in-line inspection (ILI) features or anomalies present in the Affected
Pipeline to provide for continued safe operation while further corrective actions are
completed.
e. Beta Offshore must review the pressure restriction monthly by analyzing the
operating pressure data, taking into account any ILI features or anomalies present in
the Affected Pipeline. Beta Offshore must immediately reduce the operating pressure
further to maintain the safe operations of the Affected Pipeline, if warranted by the
monthly review. Further, Beta Offshore must submit the results of the monthly review
to the Director including, at a minimum, the current discharge set-points (including
any additional pressure reductions), and any pressure exceedance at discharge set-
points. Submittals may be made quarterly, in accordance with the terms of this Order.
13. Return to Service. Upon approval of the Restart Plan, Beta Offshore may return the
Affected Pipeline to service according to the terms of the Restart Plan, but the operating
pressure must not exceed the limit in accordance with the terms of this Order.
14. Removal of Pressure Restriction.
a. The Director may allow the removal or modification of the pressure restriction upon a
written request from Beta Offshore demonstrating that restoring the pipeline to its
pre-failure operating pressure is justified based on a reliable engineering analysis
showing that the pressure increase is safe considering all known defects, anomalies,
and operating parameters of the pipeline.
b. The Director may allow the temporary removal or modification of the pressure
restrictions upon a written request from Beta Offshore demonstrating that temporary
mitigative and preventive measures are implemented prior to and during the
temporary removal or modification of the pressure restriction. The Director’s
determination will be based on available information, including the failure cause and
provision of evidence that preventative and mitigative actions taken by the operator
provide for the safe operation of the Affected Pipeline during the temporary removal
or modification of the pressure restriction. Appeals to determinations of the Director
in this regard will be decided by the Associate Administrator for Pipeline Safety.
15. Leakage Survey. Within 24 hours of returning the pipeline to service, Beta Offshore
must perform an aerial survey (off-shore) and ground leakage survey (on-shore) of the
Affected Pipeline Right-of-Way. If Beta Offshore identifies any leak indications, it must
immediately shut down the Affected Pipeline and investigate all leak indications and
remedy all leaks discovered prior to restart. Beta Offshore must submit documentation of
this survey to the Director within 48 hours of a return to service.
Other Requirements:
16. Approvals. With respect to each submission that under this Order requires the approval
of the Director, the Director may: (a) approve, in whole or part, the submission; (b)
approve the submission on specified conditions; (c) modify the submission to cure any
deficiencies; (d) disapprove in whole or in part, the su
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