U.S. 
Department 400 Seventh Street, S.W. 
of Transportation Washington, D.C. 20590 
Pipeline and Hazardous 
Materials Safety Administration 
JUL 2 0 2006 
Via Federal Express and Facsimile To: (907) 564-5000 
Ms. Maureen L. Johnson 
Senior Vice President & Greater 
Prudhoe Bay Performance Unit Leader 
BP Exploration (Alaska), Inc. 
P.O. 
Box 196612 
Anchorage, AK 995 19-66 12 
RE: CPF #5-2006-5015H 
Amendment No.1 to Corrective Action Order 
Dear Ms. Johnson: 
Enclosed is Amendment No. 1 to the March 15,2006 Corrective Action Order (CAO) issued 
by the Associate Administrator for Pipeline Safety to BP (Alaska) Inc. (BP). Amendment No. 1 
requires you to take additional actions based on the results of our continuing investigation into 
the failure on BP's pipeline discovered March 2,2006. 
It has been and remains BP's continuing responsibility to complete all of the actions required 
by the March 15 CAO, including all maintenance and smart pigging operations on each of the 
specified lines. BP is obligated to explore all available options for overcoming any engineering 
issues that might complicate or delay those operations and put in place appropriate contingency 
plans. Based on additional information and in light of the current state of the pipeline system, we 
are setting forth additional requirements to assess readiness for internal inspection and to plan for 
measures to execute our order in a safe manner that will minimize risk to Trans Alaska Pipeline 
System (TAPS). The additional requirements include removing the crude oil in the section of 
the Prudhoe Bay Western Operating Area Oil pipeline that is now idle, and enhanced measures to 
monitor and handle the sediments from the pipelines. Amendment No. 1 does not waive, alter or 
supplant the original terms and requirements of the March 15 CAO, including the deadlines 
imposed by Items 3,4 and 7. 
PHMSA will issue a separate amendment (Amendment No. 2) to address additional integrity 
requirements. 

Your receipt of the enclosed document constitutes service of that document under 49 C.F.R. 
5190.5. The terms and conditions of this Amendment are effective upon receipt. 
Sincerely, 
James Reynolds 
Pipeline Compliance Registry, 
Office of Pipeline Safety 
Enclosure 
cc: 
Chris Hoidal, P.E., Director 
Western Region 
Pipeline and Hazardous 
Material Safety Administration 

DEPARTMENT OF TRANSPORTATION 
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION 
OFFICE OF PIPELINE SAFETY 
WASHINGTON, DC 20590 
In the Matter of 
) 
) 
BP Exploration (Alaska) Inc., 
) 
) CPF NO. 5-2006-5015H 
BP 
) 
) 
AMENDMENT No.1 TO CORRECTIVE ACTION ORDER 
Background & Purpose 
On March 15,2006, under authority of 49 U.S.C. S60112, the Associate Administrator for 
Pipeline Safety, Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a 
Corrective Action Order (CAO) to BP Exploration (Alaska) Inc. (BP), finding that the continued 
operation of BP1s Prudhoe Bay Western Operating Area (WOA), Eastern Operating Area (EOA) 
and Lisburne crude oil pipelines, would be hazardous to life, property, or the environment 
without the implementation of corrective measures. The CAO was issued in response to a failure 
on BP1s WOA pipeline that caused the discharge of an estimated 201,000 gallons of crude oil on 
the North Slope tundra. 
Additional Preliminary Findings 
Prudhoe Bay Transmission Pipelines (EOA, WOA, and Lisburne) 
1. 
BP has been on notice since at least May 2006 that cleaning of the WOA, EOA, and 
Lisburne pipelines could dislodge sediments and solids that had accumulated in the 
pipelines over a period of years. 
2. 
In 1992, BP's predecessor suspended cleaning of the EOA oil transmission pipeline when 
residues, waxes, and calcium carbonate deposits clogged the strainers maintained by 
Alyeska Pipeline Service Company (Alyeska) at Pump Station-1 on the Trans Alaska 
Pipeline System (TAPS). The calcium carbonate was primarily encountered between 
Flow Station-3 and Skid 50. 

3. 
In May 2006, BP performed gamma ray scans to determine the volume of sludge inside 
the EOA and WOA oil transmission pipelines. BP advised PHMSA that sediment levels 
in some areas in the EOA oil transmission pipeline were in the range of 9 to 12 inches. 
4. 
On May 22,2006, PHMSA received a copy of a report by Alyeska entitled TAPS Impact 
Assessment of BPXA Pigging -Interim Report. Alyeska performed this study to 
understand the potential risk to TAPS if the sludge volumes estimated by BP were pushed 
into the TAPS pipeline in the process of performing cleaning operations on the pipelines. 
The report concluded that the solids from the WOA and EOA pipelines could adversely 
impact the operations of TAPS. 
5. 
Alyeska7s analysis was based on anecdotal evidence and results from the last time the 
EOA and WOA pipelines were pigged, and reports of the gamma ray surveys performed 
by BP in May 2006. 
6. 
In June 2006, BP informed PHMSA that it had overestimated the volume of solids 
detected by the May 2006 gamma ray scans and that, upon reinterpretation of the scans, it 
estimated average sediment levels as follows: 
a. 
Lisburne pipeline: 0.4-inch from LS 1 to TAPS Pump Station-1; 
b. 
EOA pipeline: l-inch from FS2 to FS1 and 0.6-inch from FS 1 to Skid 50; 
c. 
WOA pipeline: 2.8-inches from GC 2 to GC 1; 0.8-inch from GC1 to GC3, and 
1.9-inches from GC3 to Skid 50; 
d. 
Skid 50 to TAPS Pump Station-1: l-inch. 
7. 
BP began cleaning and maintenance pigging of the Lisburne pipeline on or about June 9, 
2006, and ending on or about June 22,2006. Approximately one cubic yard of sediment 
was removed from the Lisburne oil transmission pipeline. That amount is consistent with 
the predicted volume from the gamma ray scan conducted in May 2006. 
8. 
BP inspected the Lisburne oil transmission pipeline with an instrumented in-line 
inspection device on or about June 30,2006. The inspection results are still pending. 
9. 
BP launched the first cleaning pig in the outer segment of EOA from FS-2 to FS-1 during 
the week of July 3,2006. BP has advised PHMSA that these cleaning operations are 
ongoing. 
10. 
Based on reported cleaning results to date, it appears that additional scale, debris or 
sediment may have been pushed from the 30-inch EOA segment into the 34-inch segment 
during these cleaning operations. 
11. 
Strainers on TAPS Pump Station -1 meter runs have an approximately 1 barrel capacity, 
and a % inch mesh size. 

12. 
BP does not currently have large volume facilities to sequester solids displaced by 
cleaning pigs. 
13. 
TAPS has two 210,000 BBL storage tanks located at Pump Station-1. Beginning in 
August, these breakout tanks are expected to have excess capacity for the remainder of 
2006. 
14. 
BP has not reached an agreement or arrangement with Alyeska concerning handling of 
the solids in the WOA and EAO pipelines and has not made arrangements for capturing 
and removing sediments from the pipelines without the use of Alyeska facilities. 
Idled OT-2 1 Section of WOA pipeline 
15. 
After the failure on BP's WOA pipeline, the segment that failed extending from 
Gathering Center two (GC2) to Gathering Center one (GC 1) and is known as the OT-21 
Segment (OT-2 1) was idled. The approximately three-mile long OT-2 1 segment was not 
drained after it was idled and still contains crude oil. BP has not run cleaning and 
maintenance pigs on the OT-21 segment or on the connecting segments of WOA, as 
required by Items 3 and 4 of the March 15,2006 CAO. 
16. 
According to information provided by BP, OT-2 1 currently contains approximately 
17,000 barrels (BBL)' 
17. 
At this time, BP theorizes that OT-21 leaked because of "enhanced corrosion." BP's 
theory of this corrosion is based on the aggregate effect of several likely factors: 
a. Although corrosion inhibitor was injected at the production stage, none was being 
injected at GC2 for an extended period prior to the pipeline failure. 
b. The OT-21 crude oil stream contained a reduced level of corrosion inhibitor. 
c. This resulted in a corresponding decrease in the toxicity of the water in the 
pipeline and a corresponding increase in the bacterial activity in the pipeline. 
18. 
PHMSA has preliminarily determined that these conditions created an environment in 
which extensive corrosion occurred. Although the ultimate cause of failure cannot be 
determined until a metallurgical analysis to determine the root cause of failure and the 
contents of OT-2 1 from the failure is analyzed, the postulated corrosive environment that 
existed inside OT-2 1 and led to the failure most likely remains in existence today and the 
pipeline may still be corroding OT-21, even at the current lower temperatures (40 to 50 
degrees Fahrenheit) of the idled oil. 
19. 
The stagnant environment inside OT-21, in combination with other risk factors, including 
the presence of water in the pipeline, poses an ongoing leak threat. In the aggregate, the 
' 1 BBL =42 US gallons. 17,000 BBL = 714,000 gallons. 
BP's June 6,2006 Request for Extension, Appendix G, OT-2 1 Leak Failure Theory and 
Application, 1-2. 

risk factors warrant corrective action to remove the contents of OT-21 before the onset of 
winter weather conditions on the North Slope. 
20. 
The oil in OT-21 will become more viscous and difficult to extract as temperatures drop. 
All other factors being equal, conducting the de-oiling operation before the onset of 
winter weather will minimize engineering complications and associated risks. 
DETERMINATION OF NECESSITY FOR AMENDMENT OF CORRECTIVE ACTION 
ORDER AND RIGHT TO A HEARING 
Section 601 12 of Title 49, United States Code, provides for the issuance of a corrective action 
order, after reasonable notice and the opportunity for a hearing, requiring corrective action, 
which may include the suspended or restricted use of a pipeline facility, physical inspection, 
testing, repair, replacement, or other appropriate action. The basis for making the determination 
that a pipeline facility is hazardous, requiring corrective action, is set forth in the abovereferenced 
statute and in 49 C.F.R. S190.233. 
Section 601 12(e) and the regulations promulgated there under (49 C.F.R. Ħħ190.233(b), provide 
for the issuance of a corrective action order without prior opportunity for notice and hearing upon 
a finding that failure to issue the order expeditiously will result in likely serious harm to life, 
property or the environment. In such cases, an opportunity for a hearing will be provided as soon 
as practicable after the issuance of the order. 
Based upon the preliminary and additional findings, I continue to find that the presence of 
hazardous conditions on the specified pipelines, including the OT-21 segment, without the 
implementation of corrective measures, would result in likely serious harm to life, property or the 
environment. BP has failed to meet its continuing responsibility to pursue all available options 
for meeting the requirements of Items 3,4, and 7 of the March 15,2006 CAO, and to address the 
risks associated with idling of OT-21, including simultaneous preparation of contingency plans, 
risk analyses, and engineering plans for alternative options and timely acquisition of necessary 
information and materials. The lack of sufficient progress towards completing items 3,4, and 7 
of the CAO necessitates a permanent solution that is not dependent on, and does not pose a risk 
to, TAPS. 
Additionally, after considering the circumstances surrounding the failure discovered on March 2, 
2006, the hazardous nature of the liquids remaining in OT-2 1, the immediate proximity of the 
pipeline to environmentally sensitive areas, the extensive corrosion and wall thinning found in 
OT-21, the potential for additional corrosion and wall thinning due to current idle conditions, the 
presence of water, and the safety and environmental threats posed by those conditions, I find that 
failure to expeditiously issue this Amendment would result in likely serious harm to property and 
the environment. 
Accordingly, this Amendment ordering immediate corrective action is issued without prior notice 
and opportunity for a hearing. The terms and conditions of this Amendment are effective upon 
receipt. 

Within 10 days of receipt of this Amendment, BP may request a hearing, to be held as soon as 
practicable, by notifying the Associate Administrator for Pipeline Safety in writing, delivered 
personally, by mail or by facsimile at (202) 366-3666. A hearing, if requested, will be held in 
Lakewood, CO or Washington, DC on a date that is mutually convenient to PHMSA and BP. A 
hearing requested on this Amendment may be consolidated with the hearing BP has already 
requested on this CAO. 
In the course of this investigation, PHMSA has identified and may identify additional measures 
that need to be taken to ensure the safety of BP's pipelines covered by the CAO. Such measures 
will be embodied in subsequent amendment(s) to the March 15,2006, CAO and will impose 
additional requirements pending BP's completion of cleaning and smart pigging operations 
required by the March 15,2006 CAO. The terms of the March 15,2006 CAO and the additional 
terms added by this Amendment and subsequent amendment(s) will remain in place for as long 
as the Associate Administrator deems necessary to ensure that the specified pipelines are 
operated in a safe and environmentally sound manner. 
AMENDMENTS TO REQUIRED CORRECTIVE ACTION 
Pursuant to 49 U.S.C. s60112, I hereby order BP to immediately take the following additional 
corrective actions with respect to BP's Prudhoe Bay oil transmission pipeline system: 
The following items are added to the Corrective Action Order: 
Item 11. Within fourteen (14) days from receipt of this Amendment No. 1, BP shall conduct 
and provide to PHMSA additional gamma ray scans of the EOA 34-inch (FS-1 to Skid 50) 
segment, at the same locations scanned with gamma ray technology in May 2006. BP shall 
conduct the gamma ray scans in a manner sufficient to ensure that the results are accurate and 
representative of the sediment loads throughout the EOA 34-inch segment of the oil 
transmission pipeline. Following each successive run, BP shall provide PHMSA an estimate 
of the volume of sediment removed and supporting field data for that estimate. 
Item 12. At least 30 days prior to beginning cleaning operations on any segment of the 
WOA oil transmission pipeline, BP shall conduct and provide to PHMSA gamma ray scans 
at all elevation change locations on those segments. BP shall conduct the gamma ray scans in 
a manner and at locations sufficient to ensure that the results are accurate and representative 
of the sediment loads throughout the inspected segments. Following each successive run, BP 
shall provide PHMSA an estimate of the volume of sediment removed and supporting field 
data for that estimate. BP shall complete all requirements of the March 15 CAO with respect 
to all segments of the WOA, EOA, and Lisburne pipelines that BP is operating or intends to 
restore to operations. 
Item 13. Within seven (7) days of receipt of this Amendment, BP shall submit a plan for 
approval by the Western Region Director to extract and analyze representative samples from 

the pipe wall of the EOA 34-inch pipeline. The plan shall be designed to ensure that the 
sampling and analysis is sufficient to enable BP to determine the amount of calcium 
carbonate deposits present in this section of the EOA oil transmission pipeline. These 
representative pipe samples will be taken fiom locations in the pipe wall to avoid disrupting 
the cleaning pig operations. BP shall implement the plan within seven (7) days of approval. 
Item 14. Within 48 hours of receiving the contractor report, BP shall report to Alyeska the 
information collected in accordance with Items 11, 12, and 13, so that Alyeska can revise its 
Impact Assessment of BPXA Pigging-Interim Report and evaluate the downstream risks to 
TAPS of permitting BP to move sediments, deposits, or other materials dislodged in cleaning 
operations into the TAPS pipeline. 
Item 15. No later than August 8,2006, BP shall develop, and submit for approval by the 
Western Region Director, preliminary engineering design and implementation plans to install 
permanent facilities for handling solids that may result fiom cleaning pig operations on the 
specified pipelines. BP shall ensure the facilities do not impair or pose a risk to the 
operations of TAPS and do not allow large amounts of solids to be moved into the TAPS 
metering and station piping facilities. Furthermore, these plans shall demonstrate to PHMSA 
and Alyeska that the oil will meet transit quality specifications. In addition to any facilities 
that BP proposes, BP shall also concurrently develop a contingency plan, including 
preliminary engineering design and implementation plans, to create a by-pass around TAPS 
PS-1 facilities, so solids can be delivered directly into TAPS storage tanks. Upon approval 
by the Western Region Director, BP shall commence construction in accordance with the 
plans, unless it has earlier demonstrated to the satisfaction of the Western Region Director 
that it is implementing or immediately prepared to implement an alternative method for 
handling solids dislodged in cleaning operations or that such construction is otherwise 
unnecessary. 
Item 16. No later than August 1,2006, BP shall develop, and submit for approval to the 
Western Region Director, a plan to safely remove the crude oil in the OT-2 1 line segment by 
August 22,2006. The plan shall provide for removal of the crude oil in the OT-21 pipeline 
segment in a safe and environmentally sound manner, and in compliance with all applicable 
federal, state and local laws and regulations. 
Item 17. Within 30 days fiom receipt of this Amendment, BP shall submit a report to the 
Western Region Director, detailing its actions and plans for replacing, abandoning, and/or 
restoring operation of OT-2 1. The report shall include preliminary or final engineering and 
implementation plans and timetables. 
Item 18. BP shall carry out the requirements of the CAO, as amended, in accordance with all 
applicable federal, state and local laws and regulations, including any applicable federal, state 
and/or local regulations regarding oil transfer procedures, spill prevention and response, the 
State of Alaska's Oil and Hazardous Substances Control Statutes and Regulations in the 
Alaska Administrative Code, Title 18, Chapter 75, and the US Environmental Protection 
Agency's Spill Prevention Countermeasures and Control Regulations found in Title 40 Code 

of Federal Regulations, Part 1 12. These regulations as well as others may contain certain 
requirements for transfer procedures, spill containment, clean-up and reporting requirements 
that pertain to operations associated with removal of the crude oil from the pipeline. 
Item 19. With respect to each submission that under this Order requires the approval of the 
Western Region 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 the 
deficiencies, (d) disapprove, in whole or in part, the submission, directing that BP modifL the 
submission, or (e) any combination of the above. In the event of approval, approval upon 
conditions, or modification by the Western Region Director, BP shall proceed to take all 
action required by the submission as approved or modified by the Western Region Director. 
In the event that the Western Region Director disapproves all or any portion of the 
submission, BP shall correct all deficiencies within the time specified by the Western Region 
Director, and resubmit it for approval. In the event that a resubmitted item is disapproved in 
whole or in part, the Director may again require BP to correct the deficiencies in accordance 
with the foregoing procedure, and/or the Director may otherwise proceed to enforce the terms 
of this Order. 
Item 20. BP shall maintain documentation of the safety improvement costs associated with 
hlfilling the March 15,2006 CAO and submit to the Western Region Director, Pipeline and 
Hazardous Materials Safety Administration. Costs shall be reported in two categories: 1) 
total cost associated with preparationlrevision of plans, procedures, studies and analyses, and 
2) total cost associated with replacements, additions and other changes to pipeline 
infrastructure. 
Item 21. The requirements of this Amendment may be modified only by written notice of the 
Associate Administrator for Pipeline Safety. A request for modification of any requirements 
imposed by this order shall be in writing and include an engineering justification and 
certification by an authorized officer of the company as to the accuracy of any facts offered in 
support of the request. 
This Amendment does not modify, waive or supplant any requirements imposed under the March 
15,2006 CAO or any requirements that apply to BP's pipeline systems under any other provision 
of federal, state, or local law, or permit. 
With respect to all actions undertaken pursuant to this Amendment, BP is responsible for 
achieving and maintaining compliance with all applicable federal, state, and local laws, 
regulations, and permits. This Amendment is not and shall not be construed to be a permit, or a 
modification of any permit, under any federal, state, or local law or regulation. 

In accordance with 49 U.S.C. s60122 and 49 C.F.R. Ħħ190.233, failure to comply with the CAO, 
as amended, may result in the assessment of administrative civil penalties of up to $100,000 per 
violation per day pursuant to 29 U.S.C. s60122, or in the imposition of civil judicial penalties 
and other appropriate relief pursuant to 49 U.S.C. s60120. The terms and conditions of this 
Amendment are effective upon receipt. 
JUL 2 0 2006 
Date Issued 
for Pipeline Safety