{"operation":"document","citation":"CPF 520085001W","title":"ALYESKA PIPELINE SERVICE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-02-27","effective_on":null,"summary":"CLOSED warning letter citing 195.202, 195.214, 195.228(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520085001W","body":"Warning Letter involving ALYESKA PIPELINE SERVICE CO. PHMSA's enforcement data identifies the cited regulations as 195.202,  195.214,  195.228(b). The case was opened on 2008-02-27 and is reported as closed as of 2008-02-27. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520085001W_operator response_03272008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085001W/520085001W_operator%20response_03272008.pdf\n\n520085001W_region response to operator response_04292008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085001W/520085001W_region%20response%20to%20operator%20response_04292008.pdf\n\n520085001W_warning letter_02272008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085001W/520085001W_warning%20letter_02272008.pdf\n\n520085001W_warning letter_02272008.pdf\n\nSENT TO COMPLLANCE REGISTE\nHardcopy-.\n# of Copies L/ Date 2/27/08\nU.S. Department\n12300 W. Dakota Ave., Suite 110\nof Transportation\nLakewood, CO 80228\nPipeline and\nAdministration\nHazardous Materials Safety\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 27, 2008\nMr. Jim Johnson\nVice President\nAlyeska Pipeline Company\nP.O. Box 196606\nAnchorage, AK 99519\n:\nCPF 5-2008-5001W\nDear Mr. Johnson:\nIn July 12, 2007, representatives of the Pipeline and Hazardous Materials Satet\ndministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected you\nStrategic Reconfiguration (SR) piping at Pump Station #3 on the North Slope of Alaska.\nPHMSA Alaska staff and our third-party consultant, Oak Ridge National Laboratories,\nconducted a review of x-ray film and procedures which concluded on October 31, 2007. While\nall welds were eventually determined to be acceptable, our review revealed several\ndiscrepancies in the original recordkeeping, weld procedures, and the standards of weld\nacceptability.\nAs a result of the inspections, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n1.\n§195.202 Compliance with specifications or standards.\n\n\n\nEach pipeline system must be constructed in accordance with comprehensive written\nspecification or standards that are consistent with the requirements of this part.\nDuring 2006, Alyeska Pipeline Service Company constructed the SR piping at Pump\nStation #3. Alyeska's construction procedure W-3.7, Visual Welding Inspection, requires\n100% visual inspection of 49 CFR 195 girth welds and associated documentation.\nRecords of visual inspection of pump station girth welds were reviewed but, Alyeska\ncould not find visual inspection records for nine welds. We did, however, find satisfactory\nNon-Destructive Testing (NDT) records for all welds.\n2. §195.228 Welds and welding inspection: Standards of acceptability\n(b)The acceptability of a weld is determined according to the standards in Section 9\nof API 1104. However, if a girth weld is unacceptable under those standards for a\nreason other than a crack, and if Appendix A to API 1104 applies to the weld, the\nacceptability of the weld may be determined under that appendix.\nPHMSA, in conjunction with non-destruction testing specialist from the Oak Ridge\nNational Laboratory, examined the radiographs of Pump Station #3 welds for compliance\nwith API 1104 Section 9. Four welds were identified that contained un-repaired defects\nthat the NDT contractor failed to detect. Additionally, eleven radiographs were found to\ncontain unacceptable film density or penetrameters. Finally, Alyeska initially failed to\nidentify these radiographic deficiencies and defective welds. All of the inadequate films\nwere eventually reshot, and all defects repaired.\n3.\n$195.214 Welding procedures.\n(a) Welding must be performed by a qualified welder in accordance with welding\nprocedures qualified under Section 5 of API 1104 or Section IX of the ASME Boiler\nand Pressure Vessel Code.\nPHMSA and experts from the Oak Ridge National Laboratories examined the welding\nprocedures used to complete the welding at Pump Station #3. There were 24 deficiencies\nidentified in these procedures. These deficiencies were brought to the attention of\nAlyeska's engineers.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violation persists up to a maximum of $1,000,000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the items identified in this letter.\nFailure to do so will result in Alyeska Pipeline Service Company being subject to additional\nenforcement action.\n2\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2008-5001 W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nA Harde\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nCC:\nPHP-60 Compliance Registry\nPHP-500 B. Flanders (#118831)\n3","truncated":false,"body_characters":5667}