Corrective Action Order:

Following the June 10, 1999, Olympic Pipe Line rupture and explosion, the U.S. Department of Transportation's Office of Pipeline Safety (OPS) issued a series of orders to correct safety deficiencies on the Olympic pipeline system. The orders were aimed at correcting all known design, operational, and maintenance factors that may have caused the accident or in any way contributed to the severity of the accident. The Corrective Action Order (CAO) was issued on June 18, 1999, and was based on preliminary investigative information. As the OPS investigation proceeded and other causal factors were identified, the CAO was modified, first on August 10, 1999, and again on September 24, 1999, to require Olympic to perform other remedial safety actions.

Olympic Pipe Line Company's responses to the CAO have been submitted to OPS over the past several months. These responses have included comprehensive design reviews, numerous system upgrades, enhanced controller training, and integrity assessment of their entire pipeline system. All proposed improvements, integrity testing, and any subsequent repairs to comply with our CAO must first be reviewed and approved by OPS.

On January 14, 2000, Olympic Pipeline Company submitted a formal notice to OPS that it believed that it was in full compliance with the CAO, and requested that the company be allowed to restart its closed sections of pipeline in order to perform mandated integrity testing and to conduct any repairs identified by that testing. On March 9, 2000, OPS sent a letter denying Olympic's restart request, following a detailed review of remedial actions. That letter specified areas that still needed to be corrected prior to OPS approving limited restart for the purpose of testing the Ferndale to Allen pipeline section.

On May 15, 2000, OPS informed Olympic that the previously deficient CAO responses appeared to have been corrected, and OPS allowed them to begin integrity testing and repair of the pipeline. On June 22, 2000 and August 10, 2000, OPS clarified the evaluation and repair criteria that Olympic must use to ensure the integrity of the entire pipeline system.  OPS sent Olympic Pipeline a letter on November 8, 2000 -- in anticipation of BP requesting permission to restart the Ferndale to Allen pipeline segment -- requiring BP to include specific key safety elements in their proposed restart plan.