U.S. 
Department 400 Seventh Street, S.W. 
of Transportation Washington, D.C. 20590 
Pipeline and 
nazardous Materials Safety 
Administration 
APR I 0 ?COS 
Mr. Jim Lamanna 
President 
BP Pipelines (North America) Inc. 
28 100 Torch Parkway 
Warrenville, IL 60555 
Re: CPF No. 3-2005-50 12 
Dear Mr. Lamanna: 
Enclosed is the Final Order issued by the Associate Administrator for Pipeline Safety in 
the above-referenced case. It makes findings of violation and assesses a civil penalty of 
$45,250. The penalty payment terms are set forth in the Final Order. This enforcement action 
closes automatically upon payment. Your receipt of the Final Order constitutes service of that 
document under 49 C.F.R. 5 190.5. 
Sincerely, 
James Reynolds 
Pipeline Compliance Registry 
Office of Pipeline Safety 
Enclosure 
cc: 
Mr. Ivan Huntoon 
Director, Central Region, OPS 
CERTIFIED MAIL - RETURN RECEIPT REQUESTED 

DEPARTMENT OF TRANSPORTATION 
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION 
OFFICE OF PIPELINE SAFETY 
WASHINGTON, D.C. 20590 
In the Matter of 
BP Pipelines (North America) Inc. ) CPF No. 3-2005-5012 
Respondent. 
FINAL ORDER 
During the weeks of June 7,2004, June 28,2004, August 9,2004, August 16,2004, August 23, 
2004, and September 13,2004, pursuant to 49 U.S.C. Ħħ 601 17, a representative of the Pipeline 
and Hazardous Materials Safety Administration (PHMSA) conducted on-site pipeline safety 
inspections of Respondent's River Rouge pipeline facilities and records in Indiana and Michigan; 
its Chicap pipeline facilities and records in Illinois; its Bushton pipeline facilities and records in 
Kansas; and all of its pipeline facilities in Ohio. As a result of the inspections, the Director, 
Central Region, PHMSA, issued to Respondent, by letter dated March 2,2005, a Notice of 
Probable Violation and Proposed Civil Penalty (Notice). In accordance with 49 C.F.R. Ħħ 
190.207, the Notice proposed finding that Respondent had committed violations of 49 C.F.R. 
Part 195, and proposed assessing a civil penalty of $50,250 for the alleged violations. 
Respondent responded to the Notice by letter dated April 6,2005 (Response). Respondent did 
not contest the allegations of violation, but provided information concerning the corrective 
actions it has taken and requested that the proposed civil penalty be reduced. Respondent did not 
request a hearing, and therefore has waived its right to one. 
FINDINGS OF VIOLATION 
In its Response, Respondent did not contest the alleged violations in the Notice. Accordingly, I 
find that Respondent violated the following sections of 49 C.F.R. Part 195, as more fully 
described in the Notice: 
49 C.F.R. Ħħ 195.412(a) (Notice Item 2) - failing to inspect the rights-of-way at certain 
specified locations using a method that allowed the surface conditions to be observed; 
49 C.F.R. Ħħ 195.428(a) (Notice Item 3) -failing to inspect three specified pressure control 
valves on a HVL line within the required interval; 

49 C.F.R. Ħħ 195.567(c) (Notice Item 4) -failing to maintain five specified test leads in a 
condition enabling electrical testing to determine the adequacy of cathodic protection. 
These findings of violation will be considered prior offenses in any subsequent enforcement 
action taken against Respondent. 
ASSESSMENT OF PENALTY 
Under 49 U.S.C. Ħħ 60122, Respondent is subject to a civil penalty not to exceed $1 00,000 per 
violation for each day of the violation up to a maximum of $1,000,000 for any related series of 
violations. 
49 U.S.C. Ħħ 60122 and 49 C.F.R. Ħħ 190.225 require that, in determining the amount of the civil 
penalty, I consider the following criteria: nature, circumstances, and gravity of the violation, 
degree of Respondent's culpability, history of Respondent's prior offenses, Respondent's ability 
to pay the penalty, good faith by Respondent in attempting to achieve compliance, the effect on 
Respondent's ability to continue in business, and such other matters as justice may require. 
With respect to Item 2, the Notice proposed a civil penalty of $40,000 for Respondent's failure to 
inspect the rights-of-way at eight specified locations using a method that allowed the surface 
conditions to be observed. In order for pipeline right-of-way patrolling to achieve its purpose of 
alerting a pipeline operator to encroachments or other conditions that could affect its pipeline, it 
must be done by a method that allows the surface conditions to be observed. If a pipeline 
operator chooses to use aerial patrolling, that operator is obligated to ensure vegetation that 
obstructs the pilot's ability to observe the surface is not present. In its response, Respondent 
demonstrated that one of the eight areas specified in the Notice was adequately patrolled from 
the air. Accordingly, I find that a reduction of 1/8 ($5,000) in the civil penalty amount proposed 
in the Notice is warranted. Having reviewed the record and considered the assessment criteria, I 
assess Respondent a civil penalty of $35,000 for violating 49 C.F.R. tj 195.412(a). 
With respect to Item 3, the Notice proposed a civil penalty of $9,000 for Respondent's failure to 
inspect three specified pressure control valves on a HVL line within the required interval. 
Timely inspection of pressure control devices is an important part of pipeline safety because if 
these devices fail to operate properly they can contribute to an overpressure event which has the 
potential to cause damage to the pipeline. In its response, Respondent described the corrective 
action it took after the PHMSA inspection to ensure that these HVL line valves will be inspected 
at the appropriate interval in the future, but Respondent has presented no information that would 
warrant a reduction in the civil penalty amount proposed in the Notice for this violation. 
Accordingly, having reviewed the record and considered the assessment criteria, I assess 
Respondent a civil penalty of $9,000 for violating 49 C.F.R. tj 195.428(a). 
With respect to Item 4, the Notice proposed a civil penalty of $1,250 for Respondent's fziilure to 
maintain five specified test leads in a condition enabling the electrical testing necessary to 
determine the adequacy of cathodic protection. In order for a pipeline system's corrosion control 
program to be effective, the adequacy of the cathodic protection must be monitored on an 
ongoing basis. Any broken electrical test leads must be promptly repaired so that the required 

readings can be taken. In its response, Respondent described the corrective action it took after 
the PHMSA inspection to repair the broken test leads, but Respondent has presented no 
information that would warrant a reduction in the civil penalty amount proposed in the Notice for 
this violation. Accordingly, having reviewed the record and considered the assessment criteria, I 
assess Respondent a civil penalty of $1,250 for violating 49 C.F.R. $ 195.567(c). 
Accordingly, having reviewed the record and considered the assessment criteria, I assess 
Respondent a total civil penalty of $45,250. 
Payment of the civil penalty must be made within 20 days of service. Federal regulations 
(49 C.F.R. Ħħ 89.21 (b)(3)) require this payment be made by wire transfer, through the Federal 
Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed 
instructions are contained in the enclosure. Questions concerning wire transfers should be 
directed to: Financial Operations Division (AMZ-300), Federal Aviation Administration, Mike 
Monroney Aeronautical Center, P.O. Box 25082, Oklahoma City, OK 73 125; (405) 954-8893. 
Failure to pay the $45,250 civil penalty will result in accrual of interest at the current annual rate 
in accordance with 3 1 U.S.C. Ħħ 3717,31 C.F.R. Ħħ 901.9 and 49 C.F.R. Ħħ 89.23. Pursuant to 
those same authorities, a late penalty charge of six percent (6%) per annum will be charged if 
payment is not made within 1 10 days of service. Furthermore, failure to pay the civil penalty 
may result in referral of the matter to the Attorney General for appropriate action in a United 
States District Court. 
WARNING ITEM 
The Notice did not propose a civil penalty or corrective action for Item 1 in the Notice- 
Respondent's failure to maintain current maps of the specified facilities in accordance with 
$ 195.404. Therefore, this is considered to be a warning item. Respondent is warned that if it 
does not take appropriate action to correct this item, enforcement action will be taken if a 
subsequent inspection reveals a violation. 
Under 49 C.F.R. Ħħ 190.2 15, Respondent has a right to submit a petition for reconsideration of 
this Final Order. Should Respondent elect to do so, the petition must be received within 20 days 
of Respondent's receipt of this Final Order and must contain a brief statement of the issue(s). 
The filing of a petition automatically stays the payment of any civil penalty assessed. However 
* 
if Respondent submits payment for the civil penalty, the Final Order becomes the final 
administrative decision and the right to petition for reconsideration is waived. The terms and 
conditions of this Final Order are effective on receipt. 
APR 1 n 2006 
Date Issued 
As oci te Administrator for Pipeline Safety 
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