{"operation":"document","citation":"CPF 520025016","title":"ALYESKA PIPELINE SERVICE CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2002-05-07","effective_on":null,"summary":"CLOSED notice of amendment citing 195.452(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520025016.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520025016.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520025016","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520025016","body":"Notice of Amendment involving ALYESKA PIPELINE SERVICE CO. PHMSA's enforcement data identifies the cited regulation as 195.452(b)(2). The case was opened on 2002-05-07 and is reported as closed as of 2006-05-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520025016_order directing amendment_03112004.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520025016/520025016_order%20directing%20amendment_03112004.pdf\n\n520025016_order directing amendment_03112004_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520025016/520025016_order%20directing%20amendment_03112004_text.pdf\n\n520025016_order directing amendment_03112004_text.pdf\n\nU 5 Department\nof Transportation\nResearch and\nSpecial Programs\nAdministration\n400 Seventh St S W\nWashington D C 20590\nMAR 1 1 m4\nMr. Robert Shoaf\nUice President\nRegulatory Affairs\n900 East Benson Boulevard\nAlyeska Pipeline Service Company\nAnchorage, AK 99508\nRe: CPF No. 5-2002-5016\nDear Mr. Shoaf:\nEnclosed is the Order Directing Amendment issued by the Associate Administrator for\nPipeline Safety in the above-referenced case. It makes a finding of inadequate procedures and\nrequires that you amend your integrity management program procedures. When the terms of the\nOrder are completed, as determined by the Director, Western Region, OPS, this enforcement action\nwill be closed. Your receipt of the Order Directing Amendment constitutes service of that document\nunder 49 C. F. R. $ 190. 5.\nSincerely,\nJames Reynolds\nPipeline Compliance Registry\nOffice of Pipeline Safety\nEnclosure\ncc: Sheila Doody Bishop\nAttorney\nP. O. Box 60469\nFairbanks, Alaska 99706\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\n\n\n\nDEPARTMENT OF TRANSPORTATION\nRESEARCH AND SPECIAL PROGRAMS ADMINISTRATION\nWASHINGTON, DC 20590\nIn the Matter of )\nAlyeska Pipeline Service Company, )\nRespondent\n)\n)\n)\n)\nCPF No. 5-2002-5016\nFINAL ORDER\nOn April 8-9, 2002, pursuant to 49 U. S. C. $ 60117, representatives of the Western Region, Office\nof Pipeline Safety (OPS), inspected Alyeska Pipeline Service Company's integrity management\nprogram at Respondent's facilities in Fairbanks, Alaska. As a result of the inspection, the Western\nRegional Director, OPS, issued to Respondent by letter dated May 7, 2002, a Notice of Amendment\n(NOA). The NOA alleged inadequacies in Respondent's integrity management program and\nproposed to require amendment of Respondent's procedures to comply with the requirements of\n49 C. F. R. $ 195. 452(b).\nRespondent acknowledged receipt of the NOA by letter dated May 30, 2002 and requested an\nextension to August 15, 2002 to submit its response. The Western Region granted a 60-day\nextension on June 18, 2002. Respondent requested an additional 60-day extension on August 6,\n2002, which OPS granted on August 13, 2002. On October 9, 2002, Respondent submitted its\nresponse to the NOA (Response). Respondent contested the allegations, submitted information to\naddress the allegations and reserved the right to a hearing if OPS did not withdraw the allegations\nbased on the submitted information. Respondent requested a hearing on January 6, 2003. An\ninformal hearing was held in the Western Region, OPS, on April 8, 2003. After the hearing,\nRespondent submitted a Closing Response dated June 6, 2003.\nAMENDMENT OF PROCEDURES\nThe NOA alleged three inadequacies in Respondent's integrity management segment identification\nprocedures:\nthe spill volume Respondent used to calculate the 1/2-mile buffer zone for overland\nspill migration and transport of spilled oil by streams and rivers to high consequence\nareas was not adequate to identify areas that might be affected by larger spills.\nthe results of the revised spill volume calculation should be incorporated into\nRespondent's stream transport analysis and overland spill modeling.\n\n\n\nsituations where the analytical model predicts transport distances longer than an\nassumed buffer zone should be considered.\nRespondent maintained that the spill volumes it used in its stream transport analysis and overland\nspill modeling were extremely conservative. Respondent explained that it considered a broad\nspectrum of spill sizes, scenarios and consequences and that the buffer zone it used for overland spill\nmigration and transport of spilled oil by streams and rivers to high consequence areas is greater than\n95/o of all estimated spill volumes. Respondent contended that its method was supported by a\nreliable engineering evaluation and provides an equivalent level of protection to the public and the\nenvironment.\nRespondent further maintained that since the spill volumes it used were so conservative, it did not\nneed to modify its procedures. Respondent acknowledged that the aggregation of oil spilled on water\nmay extend beyond the ten-mile buffer zone in some cases and agreed to amend its procedures to\nextend the buffer zone where calculations show greater distances. In its June 2003 Closing\nStatement, Respondent included a copy of its amended procedures that extend the buffer zone.\nI do not accept Respondent's arguments that its procedures for identifying segments that could affect\na high consequence area are adequate. Respondent's methodology was based on a leak occurring\n&om a one-inch hole and a spill volume of 27, 000 bbls. I do not consider this methodology as\nproviding adequate protection to high consequence areas. Although Respondent's procedures have\nconsidered historical data, Respondent needs to consider if larger spills have the potential to affect\nthe high consequence areas. Respondent may not have experienced a larger leak in the past, but it\nneeds to do so for its segment identification procedures to ensure that these areas are protected.\nRespondent's methodology must, at minimum, consider high consequence areas that could be\naffected by leaks resulting &om larger holes and larger spill volumes.\nRespondent agreed to amend its integrity management program procedures to extend the buffer zone\nwhere calculations show greater water transport than the 10-mile buffer zone. Although Respondent\namended its procedures, further amendment may be necessary based on the revised spill volume\ncalculations and incorporation of any revised figures into the stream transport analysis and overland\nspill modeling.\nAccordingly, I find that Respondent's integrity management program procedures are inadequate to\nensure safe operation of its pipeline system. Pursuant to 49 U. S. C. $ 60108(a) and 49 C. F. R.\n( 190. 237, Respondent is ordered to make the following changes to its integrity management\nprogram procedures. Respondent must-\nl. Amend its procedures to consider a broader range of failure sizes for identifying pipeline\nsegments that could affect high consequence areas.\n2 Amend its procedures to incorporate the results of the revised spill volume calculation into\nits stream transport analysis and its overland spill modeling.\n3. Amend its procedures extending the buffer zone for water transport if the amendments in\n¹ 1 and ¹ 2 above necessitate further amendment.\n\n\n\n4. Submit the amended procedures to the Regional Director, Western Region, OPS within 30\ndays following receipt of the Order Directing Amendment.\nThe Regional Director may extend the period for complying with the required items if the\nRespondent requests an extension and adequately justifies the reasons for the extension.\nThe terms and conditions of this Order Directing Amendment are effective upon receipt.\nFailure to comply with this Order may result in the assessment of civil penalties of up to $100, 000\nper violation per day, or in the referral of the case for judicial enforcement.\nMAR ] I 2004\nDate Issued\nS cey Gerard\nssociate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":7742}