{"operation":"document","citation":"CPF 520075042M","title":"ALYESKA PIPELINE SERVICE CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-11-27","effective_on":null,"summary":"CLOSED notice of amendment citing 195.266, 195.402(a), 195.402(c), 195.402(c)(10), 195.404(a)(2), 195.404(a)(3), 195.406(a)(1), 195.422(b), 195.428(a), 195.432(b), 195.452(i)(2), 195.49, 195.54, 195.555, 195.561, 195.563(a), 195.567(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520075042m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520075042m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520075042m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520075042M","body":"Notice of Amendment involving ALYESKA PIPELINE SERVICE CO. PHMSA's enforcement data identifies the cited regulations as 195.266,  195.402(a),  195.402(c),  195.402(c)(10),  195.404(a)(2),  195.404(a)(3),  195.406(a)(1),  195.422(b),  195.428(a),  195.432(b),  195.452(i)(2),  195.49,  195.54,  195.555,  195.561,  195.563(a),  195.567(c). The case was opened on 2007-11-27 and is reported as closed as of 2009-05-27. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520075042M_notice of amendment_11272007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075042M/520075042M_notice%20of%20amendment_11272007.pdf\n\n520075042m_notice of amendment_11272007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075042M/520075042m_notice%20of%20amendment_11272007_text.pdf\n\n520075042M_operator_response_03262008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075042M/520075042M_operator_response_03262008.pdf\n\n520075042m_notice of amendment_11272007_text.pdf\n\n/EN' Tt & (\"(~h, iP1, 'ANt'E QEGtS\nHardcopy. i -ii. i. i~ontcalI'v\n¹ of Cop t P/ t tl te l +(\no\nU. S. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n12300 W Dakota Ave, Suite 110\nLakewood, CO 80228\nNOTICE OF AMENDMENT\nVIA FEDEX AND FACSIMILE to 907 787-8330\nNovember 27, 2007\nMr. Jim Johnson\nPipehne Vice President\nAlyeska Pipeline Service Company\n900 East Benson Blvd.\nP. O. Box 196660\nAnchorage, AK 99519-6660\nCPF 5-2007-5042M\nDear Mr. Johnson:\nOn April 10-14, August 9-24, September 11-15, and October 16-20, 2006 representatives of\nthe Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter\n601 of 49 United States Code, inspected Alyeska Pipeline Service Company's (Alyeska)\nprocedures for reporting, construction, corrosion control, integrity management and operation\nand maintenance in Anchorage and Fairbanks, Alaska.\nPHMSA also investigated a series of pipehne failures that occurred on TAPS in December\n2006 and January 2007. The first of these mcidents occurred on December 12, 2006, in\nconnection with Alyeska's operation of a scraper pig (Pig ¹ 67) between Pump Station 4 (PS4)\nand PS9 on TAPS. Alyeska reported that the scraper pig was destroyed when it was pushed\nmto the Mainhne Unit (MLU) strainer at PS7. This Notice of Amendment (NOA) addresses\nthe Pig ¹67 failure. The other failures are described and addressed in the companion Notice of\nProbable Violation (NOPV) in this case. See 5-2007-5041.\n\n\n\nOn the basis of these inspections and mvestigations, PHMSA has identified apparent\ninadequacies in Alyeska's plans and procedures, as described below:\n$195. 422 Pipeline Repairs.\n(b) No operator may use any pipe, valve, or fitting, for replacement in repairing\npipeline facilities, unless it is designed and constructed as required by this part.\nAlyeska's procedures for operations, maintenance, repairs and construction of its pipeline\nfacihties are inadequate because they do not indicate which editions of standards and/or codes\nare to be used. For example, Alyeska procedure, WP-3. 1, General Welding and Brazing\nRequirements references API 1104 and ASME Section IX standards, but the procedure does\nnot specify the edition that is to be used. Part 195 incorporates by reference specific editions\nof standards and codes Alyeska must amend its procedures to refer to the specific editions\nreferenced by Part 195.\n$195. 49 Annual report\nBeginning no later than June 15, 2005, each operator must annually complete and\nsubmit DOT form RSPA F 7000-1. 1 for each type of hazardous liquid pipeline\nfacility operated at the end of the previous year. A separate report is required for\ncrude oil, HVL (including anhydrous ammonia), petroleum products, and carbon\ndioxide pipelines. Operators are encouraged, but not required, to file an annual\nreport by June 15, 2004, for calendar year 2003.\nAlyeska's OM-1 Section 9 procedures for making reports and notifications to the Government\nare inadequate because they do not include a process for submittal of annual reports. Alyeska\nmust amend its OM-1 Section 9 procedures to include a process for submittal of annual reports\nin accordance with )195. 49.\n3. $195. 54 Accident reports.\n(b) Whenever an operator receives any changes in the information reported or\nadditions to the original report on DOT Form 7000-1, it shall file a supplemental\nreport within 30 days.\nAlyeska's OM-1 9 3. 5. 2 procedure for submitting accident reports is in adequate because it\ndoes not require Alyeska to submit any changes in the information reported or additions to the\noriginal DOT Form 7000-1 within 30 days. Alyeska's procedure states that changes or\nadditions ~ma be submitted within 30 days. Alyeska must amend its OM-1 9. 3. 5. 2 procedure\nto indicate that changes shall be submitted within 30 days via the fihng of a supplemental\nreport.\n4. $195. 266 Construction records.\nA complete record that shows the following must be maintained by the operator\ninvolved for the life of each pipeline facility:\n\n\n\n(a) The total number of girth welds and the number nondestructively tested,\nincluding the number rejected and the disposition of each rejected weld.\n(b) The amount, location, and cover of each size of pipe installed.\n(c) The location of each crossing of another pipeline.\n(d) The location of each buried utility crossing.\n(e) The location of each overhead crossing.\n(f) The location of each valve and corrosion test station.\nAlyeska's OM-1 10. 3. 1. 1 procedure for complying with construction and repair record\nkeepmg requirements is inadequate because it only explains that Alyeska has kept all records\nm the past, rather than what Alyeska does m the present, and will do m the future, to retam\ncurrent girth weld records. Alyeska must amend its OM-1 10. 3. 1. 1 procedure to indicate that\nall current and future girth weld records will be retamed\n$195. 402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall\nbe reviewed at intervals not exceeding 15 months, but at least once each calendar\nyear, and appropriate changes made as necessary to insure that the manual is\neffective. This manual shall be prepared before initial operations of a pipeline\ncommence, and appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\nAlyeska's OM-1 procedures are inadequate because, in several instances, rather than setting\nforth specific provisions on how Alyeska will comply with Part 195, the procedures simply\nreference Part 195 as guidance. For example, Alyeska's OM-1 9. 3. 2. 1 procedure for reporting\nSafety Related Conditions provides that the DOT report shall be submitted accordmg to the\nrequirements of 49 C. F R. 195. Alyeska must amend its OM-1 procedures to mclude specific\nprovisions for comphance with applicable Part 195 regulations. Alyeska may not simply refer\nreaders of OM-1 to Part 195 for guidance.\n6. $195. 402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a)\nof this section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(4) Determining which pipeline facilities are located in areas that would\nrequire an immediate response by the operator to prevent hazards to the\npublic if the facilities failed or malfunctioned.\n(6) Minimizing the potential for hazards identified under paragraph (c)(4)\nof this section and the possibility of recurrence of accidents analyzed under\nparagraph (c)(5) of this section.\n\n\n\nAlyeska's OM-1 procedures are madequate because they do not give guidance or refer to\nguidance to minimize the hazards to the pubhc identified under (c)(4). Alyeska must amend\nits OM-1 procedures to include provisions to give guidance or refer to guidance to minimize\nthe potentials for hazards as identified under (c)(4).\n$195. 402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a)\nof this section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(10) Abandoning pipeline facilities, including safe disconnection from an\noperating pipeline system, purging of combustibles, and sealing abandoned\nfacilities left in place to minimize safety and environmental hazards. For\neach abandoned offshore pipeline facility or each abandoned onshore\npipeline facility that crosses over, under or through commercially\nnavigable waterways the last operator of that facility must file a report\nupon abandonment of that facility in accordance with $195. 59 of this part.\nAlyeska's OM-6. 7. 1 procedure for abandonmg pipeline facilities is inadequate because it does\nnot provide guidance or reference a procedure for purging combustibles &om abandoned\nfacihties. Alyeska must amend OM-6. 7. 1 to include procedures on how combustibles are to\nbe purged from a pipeline facility\n8. $195. 404 Maps and Records.\n(a) Each operator shall maintain current maps and records of its pipeline systems\nthat include at least the following information;\n(2) All crossings of public roads, railroads, rivers, buried utilities, and\nforeign pipelines.\nAlyeska's OM-1 10. 3. 1. 1 procedures regarding the maintenance of maps and records of\npipeline crossings, utilities and other pipeline data are inadequate because they do not indicate\nthat this data is available on the Alyeska intranet website. Alyeska indicated that this\nmformation was in fact available to all company employees on the website. Alyeska must\namend OM-1 10. 3. 1. 1 to indicate that this data is available on Alyeska's intranet website.\n9. $195. 404 Maps and Records.\n(a) Each operator shall maintain current maps and records of its pipeline systems\nthat include at least the following information;\n(3) The maximum operating pressure of each pipeline.\n\n\n\nAlyeska's OM-1 10. 3. 1. 1 procedure is inadequate because it does not indicate where the\nofficial record of the MOP of TAPS resides. Alyeska must amend OM-1 10. 3. 1 1 to mdicate\nthe location of the official record of MOP.\n10. $195. 406 Maximum operating pressure.\n(a) Except for surge pressures and other variations from normal operations, no\noperator may operate a pipeline at a pressure that exceeds any of the following:\n(1) The internal design pressure of the pipe determined in accordance with\n5195. 106.\nAlyeska's OM-1 1. 7 procedures are inadequate because they do not provide or reference the\ndesign formula used for determining the design pressure and do not provide the design factors.\nAlyeska's OM-1 1. 7 includes in the definition of MOP, \"the maximum internal pressure of the\npipe as determined by the design factor from the applicable code, the nominal wall thickness\nand the specified minimum yield strength for the pipe. \"\n11. $195. 428 Overpressure safety devices and overfill protection systems\n(a) Except as provided in paragraph (b) of this section, each operator shall, at\nintervals not exceeding 15 months, but at least once each calendar year, or in the\ncase of pipelines used to carry highly volatile liquids, at intervals not to exceed 7/i\nmonths, but at least twice each calendar year, inspect and test each pressure\nlimiting device, relief valve, pressure regulator, or other item of pressure control\nequipment to determine that it is functioning properly, is in good mechanical\ncondition, and is adequate from the standpoint of capacity and reliability of\noperation for the service in which it is used.\nAlyeska's OM-1 Section 7. 1 procedures are inadequate because they do not list the pressure\ntransmitters that send signals to Alyeska's Operations Control Center (OCC) as pressure\ncontrol equipment. These devices are considered pressure control equipment and are sub]ect\nto the requirements of $195. 428.\nAlyeska's OM-1 Section 7 procedures, including Table 7. 1, are also inadequate because they\ndo not list a number of mainhne speed controllers that are used to prevent pipeline\noverpressure While some of these speed controllers are listed m OM-1 2. 4. 1, they are not\nlisted m Section 7 or Table 7. 1 Alyeska must Amend OM-1 Section 7, including table 7. 1, to\ninclude the Following overpressure devices: PIC-X01 Suction Pressure Controller; PIC-X03,\nSuction Pressure Rate of Rise, PIC-X04, Suction Pressure Relief Controller; PSH-X04,\nSuction Pressure Relief Switch; PIC-X02, Discharge Pressure Speed Controller; PIC-X05,\nDischarge Pressure Rehef Controller; and PSH-X05, Discharge Pressure Rehef Switch.\n12. $195. 428 Overpressure safety devices and overfill protection systems\n\n\n\n(a) Except as provided in paragraph (b) of this section, each operator shall, at\nintervals not exceeding 15 months, but at least once each calendar year, or in the\ncase of pipelines used to carry highly volatile liquids, at intervals not to exceed 7/i\nmonths, but at least twice each calendar year, inspect and test each pressure\nlimiting device, relief valve, pressure regulator, or other item of pressure control\nequipment to determine that it is functioning properly, is in good mechanical\ncondition, and is adequate from the standpoint of capacity and reliability of\noperation for the service in which it is used.\nAlyeska's OM-1 procedures for inspectmg and testing thermal relief valves are madequate\nbecause they state that the valves must be inspected annually under ASME B31. 4 and not once\neach calendar year, not to exceed 15 months, as required under Part 195. Alyeska must amend\nOM-1 to reflect the specific time mterval requirement provided by (195. 428(a).\n13. $195. 432 Breakout tanks.\n(b) Each operator shall inspect the physical integrity of in-service atmospheric\nand low-pressure steel aboveground breakout tanks according to section 4 of API\nStandard 653. However, if structural conditions prevent access to the tank\nbottom, the bottom integrity may be assessed according to a plan included in the\noperations and maintenance manual under $195. 402(c)(3).\nAlyeska's OM-1 Section 7. 3. 5 and 12. 8. 1 procedures are inadequate because they neither\ninclude nor reference clear guidance for the internal inspections that must be performed\naccording to (195. 432 and Section 6 of API 653 as referenced therein. Alyeska must amen/\nOM-1 Sections 7. 3. 5 and 12. 8. 1 to include or reference guidance on internal inspections in\naccordance with Section 6 of API 653.\n14. $195. 432 Breakout tanks.\n(b) Each operator shall inspect the physical integrity of in-service atmospheric\nand low-pressure steel aboveground breakout tanks according to section 4 of API\nStandard 653. However, if structural conditions prevent access to the tank\nbottom, the bottom integrity may be assessed according to a plan included in the\noperations and maintenance manual under $195. 402(c)(3).\nAlyeska's OM-1 Section 7. 3 5 and 12. 8. 1 procedures are inadequate because they do not\nrequire that the actual mternal inspection mterval shall be set to ensure that the bottom plate\nminimum thickness at the next inspection shall not be less than the values listed in Section 6 of\nAPI 653. Alyeska must amend OM-1 Section 7. 3. 5 and 12. 8. 1 to include or reference\nguidance on setting inspection intervals in accordance with Section 6 of API Standard 653.\n\n\n\n15. $195. 555 What are the qualifications for supervisors?\nYou must require and verify that supervisors maintain a thorough knowledge of that\nportion of the corrosion control procedures established under Sec. 195. 402(c)(3) for\nwhich they are responsible for insuring compliance.\nAlyeska's OM-1 Section 12 2 procedures are inadequate because they do not include or\nreference a method for insuring and documenting that corrosion control supervisors have a\nthorough knowledge of corrosion control procedures for which they are responsible Alyeska\nmust amend OM-1 Section 12. 2 to include or reference a method for insuring and\ndocumenting that corrosion control supervisors have a thorough knowledge of corrosion\ncontrol procedures for which they are responsible.\n16. $195. 561 When must I inspect pipe coating used for external corrosion control?\n(a) You must inspect all external pipe coating required by Sec. 195. 557 just prior\nto lowering the pipe into the ditch or submerging the pipe.\n(b) You must repair any coating damage discovered.\nAlyeska's OM-1 coating procedures are inadequate because they do not state that the hohday\ninspection and repair procedures reside under the individual coating specifications, such as\nSpecification B-420, etc. Alyeska must amend OM-1 to state that the hohday inspection and\nrepair procedures reside under the individual coating specifications.\n17. $195. 563 Which pipelines must have cathodic protection?\n(a) Each buried or submerged pipeline that is constructed, relocated, replaced, or\notherwise changed after the applicable date in Sec. 195. 401(c) must have cathodic\nprotection. The cathodic protection must be in operation not later than 1 year\nafter the pipeline is constructed, relocated, replaced, or otherwise changed, as\napplicable.\nAlyeska's OM-1 procedures are madequate because they do not require that cathodic\nprotection must be applied to a pipehne within one year of construction as required by\n)195. 563(a). Alyeska must amend OM-1 to reflect the specific requirements of )195. 563(a).\n18. $195. 563 Which pipelines must have cathodic protection?\n(a) Each buried or submerged pipeline that is constructed, relocated, replaced, or\notherwise changed after the applicable date in Sec. 195. 401(c) must have cathodic\nprotection. The cathodic protection must be in operation not later than 1 year\nafter the pipeline is constructed, relocated, replaced, or otherwise changed, as\napplicable.\n\n\n\nAlyeska's OM-1 procedures are inadequate because they do not include or reference guidance\nfor pipehnes that have been converted under $195. 5, as required by $195. 563(a). Alyeska\nmust amend OM-1 to reflect the specific requirements of $195. 563(a)\n19. $195. 567 Which pipelines must have test leads and what must I do to install and\nmaintain the leads?\n(c) Maintenance. You must maintain the test lead wires in a condition that\nenables you to obtain electrical measurements to determine whether cathodic\nprotection complies with Sec. 195. 571.\nAlyeska's OM-1 Section 12. 5 procedures are inadequate because they do not require that test\nlead repairs be completed as soon as possible to ensure cathodic protection measurements can\nbe made as required under Part 195. Alyeska must amend OM-1 Section 12. 5 to require that\ntest lead repairs are completed as soon as possible.\n20. $195. 452(i) 8'hat preventive and mitigative measures must an operator take to\nprotect the high consequence area?\n(1) General requirements. An operator must take measures to prevent and\nmitigate the consequences of a pipeline failure that could affect a high\nconsequence area. These measures include conducting a risk analysis of the\npipeline segment to identify additional actions to enhance public safety or\nenvironmental protection . . .\n(2) Risk analysis criteria. In identifying the need for additional preventive and\nmitigative measures, an operator must evaluate the likelihood of a pipeline release\noccurring and how a release could affect the high consequence area. This\ndetermination must consider all relevant risk factors, including, but not limited to:\n(i) Terrain surrounding the pipeline segment, including drainage systems such as\nsmall streams and other smaller waterways that could act as a conduit to the high\nconsequence area; (ii) Elevation profile; (iii) Characteristics of the product\ntransported; (iv) Amount of product that could be released; (v) Possibility of a\nspillage in a farm field following the drain tile into a waterway; (vi) Ditches along\nside a roadway the pipeline crosses; (vii) Physical support of the pipeline segment\nsuch as by a cable suspension bridge; (viii) Exposure of the pipeline to operating\npressure exceeding established maximum operating pressure.\nAlyeska's procedures for risk analysis are inadequate because they underestimate\nsegment risk and may be sensitive to segment length assumptions:\na. Risk ranking of pipehne segments is, in part, a function of segment length. Given\nthat risk ranking is based on numeric likelihood criteria, short segment lengths have the\npotential to artificially lower the likelihood classification. Alyeska must perform\nfurther analysis to understand if the segmentation approach artificially results in some\nsegments being classified as category 4 (no P&M evaluations required) or other higher\nrisk categories.\n\n\n\nb. The current segment risk ranking only considers the worst case risk of the three\nconsidered release sizes — small, medium, large. As each of these cases is possible,\nactual segment risk is the sum of the respective release cases. This may increase the\nnumber of segments classified as risk categories 1-3, which require the evaluation of\nP&M measures (and/or increase the number of segments in the higher risk categories\n1-2).\nAlyeska must revise its procedures to comply with 195. 452\n21. $195. 402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a)\nof this section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\nAlyeska's pigging procedures did not address the risks associated with passing a\nscraper pig through Pump Station 7 (PS7) with the piping configuration in place at the\ntime of the pig ruu. Alyeaka'a procedure (OCC-2. 10, Rev 8, dated 08/23/06), ~Sera er\nPi s: Launchin Passin and Receivin and SAFE procedure, 3. 4. 14. -07, Rev 2,\n10/25/05, Manual i assa e at PS 7) did not adequately address the risks associated\nwith passing a scraper pig through Pump Station piping. Alyeska's pigging procedures\nwere not updated as a result of new information. For example, Alyeska had data that\nindicated that certain pig bars were missing from PS7. Alyeska did not modify its\npigging procedure to reflect the risks of losing a pig into the Mainhne Unit as a result\nof the missing pig bars.\nThe cleaning pig launched from PS4 December 16, 2006 did not arrive at PS9 as\nscheduled. Alyeska indicated that the cleaning pig was forced mto the Mainhne Unit\n(MLU) strainer at PS7. Alyeska offered a root cause analysis that asserted that:\na The center pig bar at the PS07 S2 branch connection was missing. The report\nconfirms that in 2005, when check valve CKV67A was installed, photographic\nevidence showed that the middle pig bar at the S2 branch connection was missing.\nb. The newly installed mainhne CKV67A clapper at PS7 was not raised during the\nPig ¹ 67 run. This check valve installation was not identified in Alyeska's pig\npassing procedures. Since the cleaning pig incident at PS7, Alyeska has revised its\nprocedure for launching, passing, and receiving scraper pigs. The new procedure\nnow requires the clapper on CKV 67A to be raised whenever a pig is passing PS7\n\n\n\nAlyeska has also revised its procedure for launching, passing, and receiving\nscraper pigs. The new procedure now requires the pump house at PS07 to be in the\n\"isolate configuration\" during all pig runs.\nPHMSA believes that if the pig bars had been properly installed in 2005 and the procedures\nfor raising the clapper on check valve and isolating the pumps had been in place for the pig run\nthe incident would not have occurred. Alyeska must amend its pigging procedures to\nadequately address the risks presented by changes in the pipeline environment that could affect\nsafety during pig runs\nRes onse to this Notice\nThis Notice is provided pursuant to 49 U. S. C. ) 60108(a) and 49 C. F. R. ) 190. 237. Enclosed\nas part of this Notice is a document entitled Response Options for Pipehne Operators in\nComphance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U. S. C. $ 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe quahfy for\nconfidential treatment redacted and an explanation of why you beheve the redacted\ninformation qualifies for confidential treatment under 5 U. S. C. $ 552(b). Failure to respond\nwithin 30 days of receipt of this Notice will waive Alyeska's right to contest the allegations in\nthis Notice and authorize the Associate Administrator for Pipeline Safety to find facts as\nalleged in this Notice without further notice to Alyeska and to issue a Final Order.\nIf, after opportunity for a hearing, Alyeska's plans or procedures are found inadequate as\nalleged in this Notice, Alyeska may be ordered to amend its plans or procedures to correct the\ninadequacies (49 C. F R $ 190. 237) If Alyeska is not contesting this Notice, we propose that\nyou submit Alyeska's amended procedures to my office within 30 days of receipt of this\nNotice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in Alyeska's amended procedures, this\nenforcement action will be closed.\nIn correspondence concerning this matter, please refer to CPF 5-2007-5042M, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipehne Operators in Comphance Proceedings\n10\n\n\n\nO\nU S. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\nt-i i r t-, ti, stot iANr 1 g}:. '(a1'. jr\nVrnei!I'» .\n0 . -ir i Qp c. . .\ni iuCi OotL iilV\n'\n~ &:gati L'\n12300 W Dakota Ave, Suite 110\nLakewood, CO 80228\nVIA FEDEX AND FACSIMILE to 907 787-8330\nNovember 27, 2007\nMr. Jim Johnson\nPipehne Vice President\nAlyeska Pipeline Service Company\n900 East Benson Blvd.\nP. O. Box 196660\nAnchorage, AK 99519-6660\nCPF 5-2007-5041\nCPF 5-2007-5042M\nDear Mr. Johnson.\nThis letter transmits notices of two enforcement actions brought by the Pipehne and Hazardous\nMaterials Safety Administration (PHMSA) against Alyeska Pipeline Service Company, as\noperator of the Trans Alaska Pipeline System (TAPS). The enclosed Notice of Proposed\nViolation and Notice of Amendment recite proposed findings based on inspections and\nincident investigations conducted by PHMSA in 2006 and 2007. On the basis of these\nfindings, PHMSA alleges specified violations of the Federal Pipehne Safety Regulations, 49\nC. F. R. Part 195, and proposes to assess civil penalties and require specific corrective actions,\nincluding development and implementation of revised safety procedures.\nWithout prejudice to Alyeska's right to a hearing, this will acknowledge the parties' ongoing\ndiscussions concerning actions Alyeska has taken to correct certain deficiencies cited by\nPHMSA and prevent future violations. Beginning last spring, PHMSA also has been working\nwith Alyeska on development of broader risk-management procedures and controls. With an\neye to future conditions and challenges, we expect this \"Unified Plan\" to address management\nprocesses, m addition to engmeering and mamtenance, and to prescribe standards in excess of\n\n\n\nPHMSA's minimum regulatory requirements, We are encouraged by Alyeska's most recent\nprogress and look forward to workmg with you to advance development and implementation\nof the Unified Plan.\nSincerely,\nChris oidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosures: Notice of Probable Violation and Proposed Civil Penalty CPF 5-2007-5041\nProposed Compliance Order CPF 5-2007-5041\nNotice of Amendment CPF 5-2007-5042M\nResponse Options for Pipeline Operators in Compliance Proceedings","truncated":false,"body_characters":28541}