2. Olympic’s management of the construction and commissioning of the Bayview Products Terminal.

4. Bayview Products Terminal

8. Control Valve CV-1904 Inlet control valves had an extended piston stop set. Outlet control valves did not have an extended piston stop set to prevent pumping against a closed valve.

9. Control Valve CV-1904 The stop setting was not reached so it did not play a role in the accident. Demonstrates ineffective management oversight of the terminal construction.

10. RV-1919 Bayview Products Terminal

11. Pilot Set screw Relief Valve

12. Relief Valve RV-1919 The intended design pressure setting was 740 psig which was then lowered to 650 psig.

13. Relief Valve RV-1919 Fisher-Rosemount misinterpreted specification sheets and provided a 100 psig set point.

14. Relief Valve RV-1919 Fisher-Rosemount clearly indicated the 100 psig setting in documentation and on the pilot. Olympic and/or Jacobs should have noticed the discrepancy.

15. Relief Valve RV-1919 No testing under conditions approximating actual operations was conducted prior to start up. Olympic did not discover that RV- 1919 was not set correctly until it started operations at Bayview.

16. Ends of Compressed Spring

17. Relief Valve RV-1919 Inlet block valve closed 35 times due to high pressure in Bayview. In May 1999, Olympic reduced the set point of RV-1919 to 650 psig.

18. Relief Valve RV-1919 Inlet block valve closed 6 more times before the accident. Olympic did not make adequate efforts to investigate the block valve closings.

19. Relief Valve RV-1919 Olympic should have investigated the failure of RV-1919 to operate consistently and taken measures to correct the condition that may have prevented the pressure surge that ruptured the pipeline.

20. Bayview Operations After commencing operations at the Bayview products terminal, Olympic management did not adequately address operational issues.

21. Bayview Operations Did not test RV-1919 under actual operating conditions. Did not correct valve configurations. Did not adequately investigate block valve closings. Did not adequately address operational issues.

22. Bayview Operations Olympic did not exercise effective management oversight of the construction and activation of the Bayview products terminal.

23. Federal Regulations Require annual testing to determine that relief valves are functioning properly, in good mechanical condition, and have adequate capacity and reliability.

24. Federal Regulations Regulations provide insufficient guidance to ensure that test protocols and procedures will effectively indicate relief valve or pilot control malfunctions.

25. Federal Regulations Since Bayview was a new facility, OPS regulations also required that RV-1919 be tested under conditions approximating actual operations.

26. Federal Regulations Regulations for new installations do not provide adequate guidance to ensure that relief valves are tested under conditions approximating actual operations.