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BP gets warning letter on Endicott line Federal regulators note corrosion concerns, direct company to fix the problems or face enforcement action; BP defends its methods Wesley Loy For Petroleum News
Federal pipeline regulators in April gave BP a “warning letter” citing corrosion concerns with the Endicott pipeline on Alaska’s North Slope.
BP, in a May 20 reply to the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration, said it has the “practices and actions” in place to safeguard the line.
The above-ground pipeline, 16 inches in diameter, carries sales-grade crude from the BP-operated Endicott oil field, located offshore east of Prudhoe Bay, about 26 miles to Pump Station 1 of the trans-Alaska pipeline.
The PHMSA warning letter, dated April 20 and addressed to Tony Brock, vice president of health, safety, security and the environment for BP Exploration (Alaska) Inc., said an agency representative inspected the Endicott pipeline on June 22-26, 2009, and found “probable violations” of federal pipeline safety regulations.
The warning letter, signed by PHMSA’s Western Region deputy director, Dennis Hinnah, did not impose a fine. But it advised BP to correct the problems or face “additional enforcement action,” noting the potential for civil penalties of up to $100,000 per violation per day.
According to its website, PHMSA has issued 28 warning letters nationwide so far in 2010. The agency says it issues such letters “for some lower risk probable violations and program deficiencies.”
PHMSA issues a “corrective action order” if it determines a pipeline poses a serious hazard to life, property or the environment.
Problem areas BP Alaska’s struggles with corrosion are well documented on the North Slope, where the company runs the nation’s largest oil field in Prudhoe Bay. BP drew intense scrutiny from pipeline regulators and Congress following pipeline leaks and a major oil spill in 2006 that resulted in costly pipeline replacements and a guilty plea to a federal environmental misdemeanor.
PHMSA’s three-page warning letter detailed two problem areas.
First, with respect to controlling internal corrosion, BP failed to provide any records other than data from inline inspection tools — that is, pig runs — “to show that it investigates the corrosive effects of the hazardous liquid transported in the Endicott pipeline,” the letter said.
Pig runs in 2005 and 2008 showed internal corrosion is occurring in the pipeline, with maximum wall loss reported to be about 20 percent, the letter added.
The second problem area concerns monitoring and control of “atmospheric corrosion” that can occur when a pipeline is exposed to the elements.
Again, BP failed to provide records other than pigging data “to show that they conduct atmospheric corrosion monitoring” according to regulations, the warning letter said.
The PHMSA field inspection turned up several indicators of atmospheric corrosion on the Endicott line, the letter said.
The 2005 and 2008 pig runs showed external corrosion under pipeline insulation, with maximum wall loss of 39 percent reported, the letter said. Problems also were found at several cased road crossings, such as a removable fabric insulation jacket at one crossing that “appeared to be full of water.” And at a crossing at the Badami ice road, “there is water in the vault to the bottom of the bare pipe, and the insulation jacket stain indicates that water may have saturated the insulation.”
PHMSA also issued BP a second letter dated April 20 and labeled “notice of amendment.” It cites a procedural manual deficiency pertaining to the handling of pressure sensing devices when launching and receiving pigs.
BP’s reply BP responded to the warning letter with a three-page reply from David O. Barnes, DOT and integrity manager for BP Pipelines (North America) Inc.
With respect to the agency’s concerns about internal corrosion, the reply letter said BP Alaska “recognized the potential for internal corrosion” on the Endicott pipeline from its inline inspection data.
“BPXA has completed the installation of corrosion coupons in the Endicott pipeline to measure and monitor the bulk corrosivity of the transported fluid,” Barnes wrote. “The fluid flow regime, maintenance pigging frequency, and locations of (corrosion rate monitoring) sites are currently being evaluated to determine what changes in the mitigation program may be required.”
As for atmospheric corrosion, Barnes said BP Alaska uses inline inspection “as the primary tool for detection of both internal and external corrosion,” with pigs run on a three-year frequency in the Endicott line.
“BPXA also performs a walking speed survey of the Endicott pipeline on an annual basis,” the reply letter said. “One component of this survey is the identification of penetrations or damage to the BP insulation or the insulation jacketing that could allow for water infiltration.”
The letter added the company “is unaware of any other atmospheric inspection methodology that can be applied to foam and jacket insulated piping systems that would not require the removal of the insulation.” When inline inspection is available, it would be imprudent to also remove insulation to inspect visually for atmospheric corrosion because this creates more ways for water to reach the pipe, the letter said.
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