{"operation":"document","citation":"CPF 520085002","title":"ALYESKA PIPELINE SERVICE CO — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-04-01","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.116(e), 195.401(b), 195.406(b), 195.428(a), 195.438, 195.573(c), 195.573(e), 195.579(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085002.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085002.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085002","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520085002","body":"Notice of Probable Violation involving ALYESKA PIPELINE SERVICE CO. PHMSA's enforcement data identifies the cited regulations as 195.116(e),  195.401(b),  195.406(b),  195.428(a),  195.438,  195.573(c),  195.573(e),  195.579(c). The case was opened on 2008-04-01 and is reported as closed as of 2011-06-20. Proposed civil penalty: $112,000. Assessed civil penalty: $112,000. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520085002_amended NOPV PCP PCO_10152008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085002/520085002_amended%20NOPV%20PCP%20PCO_10152008.pdf\n\n520085002_amended nopv pcp pco_10152008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085002/520085002_amended%20nopv%20pcp%20pco_10152008_text.pdf\n\n520085002_closure letter_06202011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085002/520085002_closure%20letter_06202011.pdf\n\n520085002_closure letter_06202011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085002/520085002_closure%20letter_06202011_text.pdf\n\n520085002_Final Order_03212011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085002/520085002_Final%20Order_03212011.pdf\n\n520085002_Final Order_03212011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085002/520085002_Final%20Order_03212011_text.pdf\n\n520085002_NOPV PCP PCO_04012008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085002/520085002_NOPV%20PCP%20PCO_04012008.pdf\n\n520085002_nopv pcp pco_04012008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085002/520085002_nopv%20pcp%20pco_04012008_text.pdf\n\n520085002_operator response_05222008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085002/520085002_operator%20response_05222008.pdf\n\n520085002_closure letter_06202011_text.pdf\n\nVIA UPS : 1Z WR2 588 03 9135 5258\nJune 20, 2011\nMr. Mike Joynor\nSenior Vice President\nOil Movements, Engineering and Pipeline\nAlyeska Pipeline Service Company\n900 East Benson Blvd.\nP.O. Box 196660\nAnchorage, AK 99519-6660\nCPF 5-2008-5002\nDear Mr. Joynor:\nOn March 21, 2010, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued to Alyeska Pipeline Service Company (Alyeska) a Final Order in the above-referenced\ncase. This Order included a Compliance Order and Civil Penalty assessment. Based on our\nreview of the documentation you provided and confirmation of payment of the civil penalty\npaid on April 4, 2011, it has been determined that you have complied with the terms of this\nOrder.\nAccordingly, this case is now closed and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nDennis Hinnah\nDuty Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 B. Flanders (#118831)\n\n520085002_nopv pcp pco_04012008_text.pdf\n\no\nU S. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n12300 W Dakota Ave, Suite 110\nLakewood, CO 80228\nNOTICE OF PROBABLE VIOLATION\nPROPOSED CIVIL PENALTY\nand\nPROPOSED COMPLIANCE ORDER\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nApril 1, 2008\nMr. Jim Johnson\nPipeline Vice President\nAlyeska Pipeline Service Company\n900 East Benson Blvd.\nP. O. Box 196606\nAnchorage, AK 99519\nCPF 5-2008-5002\nDear Mr. Johnson;\nOn July 8 to 13, 2007, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Alyeska\nPipeline Service Company's (ASPC) pipeline segment between Pump Station 1 and Milepost\n126 near Prudhoe Bay, Alaska.\nAs a result of the inspection, 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. $195. 116 Valves.\n(e) Each valve other than a check valve must be equipped with a\nmeans for clearly indicating the position of the valve (open, closed, etc. ).\n\n\n\nDuring the inspection, MGV 10A was found without a valve position indicator.\nEvidence: Photograph of MGV 10A without valve position indicator.\n2. $195. 401 General requirements.\n(b) Whenever an operator discovers any condition that could adversely affect the\nsafe operation of its pipeline system, it shall correct it within a reasonable time.\nHowever, if the condition is of such a nature that it presents an immediate hazard\nto persons or property, the operator may not operate the affected part of the system\nuntil it has corrected the unsafe condition.\nA structural (non-pressure containment) sleeve was installed in 1990 at Mile Post (MP)\n57. 785, due to internal corrosion. Alyeska is operating the pipeline with an\nindeterminate amount of remaining pipe wall thickness under this sleeve. Alyeska did\nnot correct this condition within a reasonable time even though a commitment to cut out\nand replace was made for 2007,\nA 15-foot structural (non-pressure containment) sleeve was installed in 1990 at MP\n57. 785 due to internal corrosion, Alyeska monitored the corrosion at this location with\nUltrasonic Testing (UT) pigs to determine the depth of corrosion until 2001. At that\ntime, Alyeska determined that wax was blocking the ability of the UT pig to accurately\npredict the corrosion depth. In 2004, a Magnetic flux pig was run and it also was unable\nto accurately assess the corrosion depth. Alyeska is operating the pipeline with an\nindeterminate amount of remaining pipe wall thickness under a sleeve design that cannot\ncontain pressure. Alyeska did not correct this condition within a reasonable time, This\nissue was reported to Alyeska in January 2006 and APSC management committed to\nPHMSA they would cut out this sleeve in 2007. Alyeska has now postponed this work\nuntil 2008 or 2009. This is not correction of a condition within a reasonable time.\nEvidence;\n1. '\nSafety Related Condition Report 890028 Report listing internal corrosion as the\ncause, with maximum pit depth. 177.\n2. Alyeska as built data base, listing 15 foot structural sleeve. (Not a pressure\ncontaining sleeve. A structural sleeve will not stop crude oil from leaking onto the\nground, when the internal corrosion eats through the pipe wall).\n3. Alyeska repair procedure for internal corrosion requires a pressure containing sleeve\nor replacement of pipe.\n4. UT Pig data 1994-2001. (2001 pig having trouble with wax at Station 305116. 6).\n5. 2003 BJ MFL Pig did not report any corrosion at sleeve, due to the additional metal\nthickness of the sleeve.\n\n\n\n$195. 406 Maximum operating pressure.\n(b) No operator may permit the pressure in a pipeline during surges or other\nvariations from normal operations to exceed 110 percent of the operating pressure\nlimit established under paragraph (a) of this section. Each operator must provide\nadequate controls and protective equipment to control the pressure within this\nlimit.\nAlyeska's Sadlerochit meter piping at Pump Station 1 has a maximum operating\npressure (MOP) of 275 psig (150 ANSI class, ) and BP's incoming piping to the meter\nhas a MOP up to 740 psig (300 ANSI class). BP's surge report stated that BP's\nmaximum discharge pressure has been limited by pressure shutdown switches at GC-1,\nFS-1 and FS-3, Alyeska must provide adequate controls and protective equipment to\ncontrol the pressure within the maximum operating pressure. If BP switches are utilized,\nthey must be maintained as DOT critical safety devices. Alyeska's \"OM-1, Procedural\nManual for Operations, Maintenance and Emergencies, \" Section 7 does not indicate that\nAlyeska must test and maintain these pressure switches,\nEvidence:\nl. In Alyeska's response to request for specific information, it is stated that Alyeska\nmeter runs WOA & EOA (Sadlerochit oil) has a MOP of 275 psig.\n2. BP's surge analysis report, Executive Summary, states that the high pressure\nswitches are DOT critical safety devices,\n3. OM-1 section 2, surge pressure control, does not list high pressure switches at GC2,\nFS1, and FS3.\n$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 Kuparuk piping has a MOP of 1180 psig, while the Kuparuk pipeline system\nhas a MOP of 1440 psig. Alyeska has installed a pressure transmitter (31-PT-013A) to\nprotect the 1180 psig piping from overpressure. Alyeska's \"OM-1, Procedural Manual\nfor Operations, Maintenance and Emergencies, \" Section 7 does not address this pressure\ntransmitter or list it as required for testing. Alyeska presented records at Pump Station 1\nof performing calibration of this pressure transmitter, indicating that transmitters were\ncalibrated annually.\n\n\n\nEvidence:\nl. In Alyeska's response to request for specific information, it states that Alyeska's\nincoming Kuparuk pipe has a MOP 1180 psig, while Kuparuk's incoming pipeline\nhas an MOP of 1415 psig.\n2. Pressure transmitter calibration sheets for 2005, 2006.\n3. OM-1 Section 7, does not list 31-PT-013A as a pressure-controlling device.\n$195. 573 What must I do to monitor external corrosion control?\n(a) Protected pipelines. You must do the following to determine whether cathodic\nprotection required by this subpart complies with Sec. 195. 571:\n(1) Conduct tests on the protected pipeline at least once each calendar year, but\nwith intervals not exceeding 15 months. However, if tests at those intervals are\nimpractical for separately protected short sections of bare or ineffectively coated\npipelines, testing may be done at least once every 3 calendar years, but with\nintervals not exceeding 39 months.\n(e) Corrective action. You must correct any identified deficiency in corrosion\ncontrol as required by Sec. 195. 401(b).\nAn area (MP 12. 2-13. 2) of the pipeline was found to have inadequate cathodic protection\n(CP). These low CP readings were confirmed by Close Interval Surveys conducted in\n2003, 2004, 2005, and 2006. This low CP area was further confirmed by 2002-2006-\ncoupon readings. This section of the pipeline did not meet criteria set forth in section\n195. 571. This area of low CP levels was reported on a 2002 inspection (see PHMSA\nFinal Order, CPF 5-2003-5002).\nEvidence;\n1. 2003-2006 CIS, Below -850 mil volt.\n2. 2001-, 2006 Coupon survey, Below -850 mil volt and -100 mv shift.\n3. Final Order CPF 5-2003-5002, page 3, Item 6, First allegation.\n$195. 573 What must I do to monitor external corrosion control?\n(c) Rectifiers and other devices. You must electrically check for proper\nperformance each device in the first column at the frequency stated in the second\ncolumn.\n\n\n\nDevice\nRectifier. .\nCheck fre uenc\nAt least six times each calendar year,\nbut with intervals not exceeding 2 Ii\nmonths\nReverse current switch.\nDiode.\nInterference bond whose failure would\n'eo ardize structural rotection\nOther interference bond . . . . . . . . . . . . , . . . . . . . . . .\nAt least once each calendar year, but\nwith intervals not exceeding 15\nmonths.\n(e) Corrective action. You must correct any identified deficiency in corrosion\ncontrol as required by Sec. 195. 401(b).\nA rectifier powered by wind (31 EE 125) was installed in October 2003 at MP 12, 5.\nRecords indicated that the rectifier was only performing correctly on 11 occasions out of\nthe 35 scheduled readings taken between October 2003 and July 2007.\nEvidence:\n1. Rectifier readings 2003-2007, When operational, the output should be in the range of\n5 volts and 1 amp.\n2. Final Order CPF 5-2003-5002, page 3, Item 6, First allegation.\n$195. 438 Smoking or open flames.\nEach operator shall prohibit smoking and open flames in each pump station area\nand each breakout tank area where there is a possibility of the leakage of a\nflammable hazardous liquid or of the presence of flammable vapors.\nDuring the inspection, \"No Smoking\" signs were missing or faded at the following valve\nlocations CKV 5, 8, 9, 10, 14, 16, 17, 18, 22, and MGV 5A andlOA.\n$195. 579 What must I do to mitigate internal corrosion?\n(c) Removing pipe. Whenever you remove pipe from a pipeline, you must inspect\nthe internal surface of the pipe for evidence of corrosion. If you find internal\ncorrosion requiring corrective action under Sec. 195. 585, you must investigate\ncircumferentially and longitudinally beyond the removed pipe (by visual\nexamination, indirect method, or both) to determine whether additional corrosion\nrequiring remedial action exists in the vicinity of the removed pipe.\nAlyeska has removed piping associated with the Endicott meter run. Alyeska did not\nprovide an inspection report for this pipe for internal corrosion,\n\n\n\nPro osed Civil Penalt\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. The Compliance Officer has reviewed the circumstances and\nsupporting documentation involved in the above probable violations and has recommended that\nyou be preliminarily assessed a civil penalty of $112, 000. 00 as follows:\nItem Number PENALTY\n$56, 000\n$56, 000\nWarnin Items\nWith respect to Items 7 and 8, 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 promptly correct this item. Be advised\nthat failure to do so may result in Alyeska Pipeline Service Company being subject to additional\nenforcement action.\nPro osed Com liance Order\nWith respect to Items I, 2, 3, and 4 pursuant to 49 United States Code $ 60118, the Pipeline and\nHazardous Materials Safety Administration proposes to issue a Compliance Order to Alyesk~\nPipeline Service Company. Please refer to the Proposed Compliance Order, which is enclosed\nand made a part of this Notice.\nRes onse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators\nin Compliance 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 qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U. S. C. 552(b). If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipehne Safety to find facts as alleged in\nthis Notice without further notice to you and to issue a Final Order.\n\n\n\nIn your correspondence on this matter, please refer to CPF 5-200S-5002 and for each document\nyou submit, please provide a copy in electronic format whenever possible.\nSincerely,\nChris oidal\nDirector, Western Region\nPipehne and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 B. Flanders (0118831)\nEnclosures' Proposed Compliance Order\nResponse Options for Pipeline Operators in Compliance Proceedings\n\n\n\nPROPOSED COMPLIANCE ORDER\nPursuant to 49 United States Code $ 60118, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) proposes to issue to Alyeska Pipeline Service Company a\nCompliance Order incorporating the following remedial requirements to require that the\nAlyeska Pipeline Service Company complies with the pipeline safety regulations:\n1. In regard to Item Number 1 of the Notice pertaining to the missing valve position\nindicator on MV 10A, Alyeska Pipeline Service Company shall install a valve\nposition indicator on MV 10A,\nIn regard to Item Number 2 of the Notice pertaining to the structural sleeve at\nMP 57. 785, Alyeska Pipeline Service Company shall remove and inspect the\ninternal corrosion inside the pipe under the sleeve during the pump station ¹ 2\npipe replacement now scheduled for 2008. PHMSA shall be notified immediately\nif this sleeve is not removed in 2008.\nIn regard to Item Number 3 of the Notice pertaining to the pressure shutdown\nswitches at GC-I, FS-1 and FS-3, Alyeska shall maintain these pressure\nshutdown switches as DOT critical safety devices or shall install adequate\npressure control equipment within its own facihties at Pump Station 1.\nAlyeska Pipeline Service Company shall revise \"OM-1, Procedural Manual for\nOperations, Maintenance Atmospheric Corrosion and Emergencies\", Section 7,\nto indicate that these pressure shutdown switches are DOT critical safety devices\nor to reflect any additional pressure control equipment Alyeska installs at its own\nfacilities at Pump Station 1. Alyeska shall also arrange to have such pressure\nshutdown switches and any additional pressure control equipment tested annually\nand shall maintain and make available to PHMSA the records of such testing.\nIn regard to Item Number 4 of the Notice pertaining to the pressure transmitter\n(31-PT-013A) on the Kuparuk pipeline incoming line to Alyeska. This pressure\ntransmitter shall be maintained as DOT critical safety devices.\nAlyeska Pipeline Service Company shall revise \"OM-1, Procedural Manual for\nOperations, Maintenance and Emergencies\", Section 7, to indicate that these\npressure shutdown switches are DOT critical safety devices. Alyeska shall also\nconduct annual tests of these pressure shutdown switches and shall maintain and\nmake available to PHMSA the records of such testing.\nAlyeska Pipeline Service Company shall complete the above-listed requirements,\nand submit documentation of such completion within 180 days of receipt of the\nFinal Order.\n\n\n\nAlyeska Pipeline Service Company shall maintain documentation of the safety\nimprovement costs associated with fulfilling this Compliance Order and submit\nthe total to Chris Hoidal, Director, Western, Pipeline and Hazardous Materials\nSafety Administration. Costs shall be reported in two categories: 1) total cost\nassociated with preparation/revision of plans, procedures, studies and analyses,\nand 2) total cost associated with replacements, additions and other changes to\npipeline infrastructure.\n\n520085002_amended nopv pcp pco_10152008_text.pdf\n\nU S. Department\nof Transpottahon\nPipelline and\nHazardous Matsrialls Safety\nAdmirtistmtiiort\n12300 W Dakota Ave, Suite 110\nLakewood, CO 80228\nOctober 15, 2008\nMr Kevin Hostler\nPresident\nAlyeska Pipehne Service Company\n900 East Benson Blvd\nP. O. Box 196660\nAnchorage, AIZ 99519-6660\nBear Mr. Hostler\nOn April 1, 2008, I issued a Notice of Probable Violation, Proposed Civil Penalty, and Proposed\nComphance Order to Alyeska regarding probable violations found during last year's inspection of\nthe facihties between Pump Station 1 and Milepost 126 When the Proposed Order was written,\ntwo corrective items were inadvertently omitted I am resubmitting that letter in its entirety below\nalong with the revisions in underhned itahcs Because we are amending this Proposed Order,\nAlyeska will have another 30 days to respond\nOn July 8 to 13, 2007, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Alyeska\nPipehne Service Company's (ASPC) pipehne segment between Pump Station 1 and Milepost 126\nnear Prudhoe Bay, Alaska.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipehne Safety Regulations, Title 49, Code of Federal Regulations The items inspected and the\nprobable violations are\n\n\n\nDuring the inspection, MGV 10A was found without a valve position nidicator\nEvidence: Photograph of MGV 10A without valve position indicator\nA structural (non-pressure containment) sleeve was installed kn 1990 at Mile Post (MP)\n57. 785, due to mternal corrosion. Alyeska is operating the pipehne with an indeterminate\namount of remaining pipe wall thickness under this sleeve. Alyeska did not correct this\ncondition withm a reasonable time even though a commitment to cut out and replace was\nmade for 2007.\nA 15-foot structural (non-pressure containment) sleeve was installed in 1990 at MP 57. 785\ndue to internal corrosion. Alyeska monitored the corrosion at this location with Ultrasonic\nTesting (UT) pigs to determine the depth of corrosion until 2001 At that time, Alyeska\ndetermmed that wax was blocking the abihty of the UT pig to accurately predict the\ncorrosion depth In 2004, a Magnetic flux pig was run and it also was unable to accurately\nassess the corrosion depth Alyeska is operating the pipehne with an indetermmate amount\nof remaining pipe wall thickness under a sleeve design that cannot contaui pressure.\nAlyeska dhd not correct this condition within a reasonable time This issue was reported to\nAlyeska kn January 2006 and APSC management committed to PHMSA they would cut\nout this sleeve in 2007 Alyeska has now postponed this work until 2008 or 2009 This is\nnot correction of a condition withm a reasonable time\nEvidence:\n1 Safety Related Condition Repokt 890028 Report hsting internal corrosion as the cause,\nwith maximum pit depth. 177\n2 Alyeska as built data base, hsting 15 foot structural sleeve. (Not a pressure containing\nsleeve A structural sleeve will not stop crude oil from leaking onto the ground, when\nthe internal corrosion eats through the pipe wall)\n3 Alyeska repair procedure for internal corrosion requires a pressure containing sleeve or\nreplacement of pipe\n4. UT Pig data 1994-2001 (2001 pig having trouble with wax at Station 305116 6)\n\n\n\n5 2003 BJ MFL Pig did not report any corrosion at sleeve, due to the additional metal\nthicloiess of the sleeve\nAlyeska's Sadlerochit meter pipmg at Pump Station 1 has a maximum operating pressure\n(MOP) of 275 psig (150 ANSI class, ) and BP's nicomnig piping to the meter has a MOP\nup to 740 psig (300 ANSI class). BP's surge report stated that BP's maximum discharge\npressure has been hmited by pressure shutdown switches at GC-1, FS-1 and FS-3\nAlyeska must provide adequate controls and protective equipment to control the pressure\nwithin the maximum operating pressure If BP switches are utihzed, they must be\nmaintained as DOT critical safety devices. Alyeska's \"OM-1, Procedural Manual for\nOperations, Manitenance and Emergencies, \" Section 7 does not indicate that Alyeska must\ntest and maintain these pressure switches\n1. In Alyeska's response to request for specific information, it is stated that Alyesk@\nmeter runs WOA A EOA (Sadlerochit oil) has a MOP of 275 psig\n2. BP's surge analysis report, Executive Summary, states that the high pressure switches\nare DOT critical safety devices.\n3 OM-1 section 2, surge pressure control, does not hst high pressure switches at GC2,\nFS1, and FS3\n(a) Except as provided in paragraph (b) of this section, each operator shaW, at\nintervals not exceeding 15 months, but at least once each calendar year, or in the case\nof pipehnes used to carry highly voiiatile hqmds, at intervals not to exceed 7/2 months,\nbut at least twice each calendar year, inspect and test each pressure hmiting device,\nrelief valve, pressure regulator, or other item of pressure control equipment to\ndetermine that it is functioning properly, is in good mechanical condition, and is\nadequate from the standpoint of capacity and reliability of operation for the service\nin which it is used.\nAlyeska's Kuparuk piping has a MOP of 1180 psig, while the Kuparuk pipehne system has\na MOP of 1440 psig Alyeska has installed a pressure transmitter (31-PT-013A) to protect\nthe 1180 psig pipnig from overpressure Alyeska's \"OM-1, Procedural Manual for\nOperations, Maintenance and Emergencies, \" Section 7 does not address this pressure\ntransmitter or hst it as required for testing Alyeska presented records at Pump Station 1 of\n\n\n\nperforming cahbration of this pressure transmitter, mdicating that transmitters were\ncahbrated annually\n1. In Alyeska's response to request for specific information, it states that Alyeska's\nincoming Ikuparuk pipe has a MOP 1180 psig, while I&uparuk's mcommg pipehne has\nan MOP of 1415 psig\n2 Pressure transmitter calibration sheets for 2005, 2006\n3 OM-1 Section 7, does not list 31-PT-013A as a pressure-controlhng device\nAn area (MP 12 2-13 2) of the pipehne was found to have madequate cathodic protection\n(CP) These low CP readmgs were confirmed by Close Interval Surveys conducted m\n2003, 2004, 2005, and 2006 This low CP area was further confirmed by 2002-2006\ncoupon readings This section of the pipehne did not meet criteria set forth in section\n195 571. This area of low CP levels was reported on a 2002 inspection (see PHMSA Final\nOrder, CPF 5-2003-5002)\n1 2003-2006 CIS, Below -850 mil volt.\n2 2001-2006 Coupon survey, Below -850 rnil volt and -100 mv shift\n3 Fmal Order CPF 5-2003-5002, page 3, Item 6, First allegation\n(c) Rectifiers aud othe~ devices. You must electricaily check for proper performance\neach device iu the first column at the frequency stated iu the second column.\n\n\n\nAt least six times each calendar year,\nbut vvith intervals not exceeding 2 I/~\nmonths\nA rectifier powered by wmd (31 EE 125) was installed in October 2003 at MP 12 5\nRecords indicated that the rectifier was only performing correctly on 11 occasions out of\nthe 35 scheduled readings taken between October 2003 and July 2007\n1 Rectifier readings 2003-2007 When operational, the output should be in the range of 5\nvolts and 1 amp.\n2 Final Order CPF 5-2003-5002, page 3, Item 6, First allegation\nDuring the inspection, \"No Smoking\" signs were missing or faded at the following valve\nlocations CKV 5, 8, 9, 10, 14, 16, 17, 18, 22, and MGV 5A andlOA\n)195. 579 What must I do to mitigate internal corrosion'\n(c) Removing pipe. Whenever you remove pipe from a pipehne, you must inspect the\ninternal surface of the pipe for evidence of corrosion. If you find internal corrosion\nrequiring corrective action under Sec. 195. 585, you must investigate circumferentially\nand longitudinally beyond the removed pipe (by visual examination, indirect method,\nor both) to determine whether additional corrosion requiring remedial action exists\nin the vicinity of the removed pipe.\nAlyeska has removed piping associated with the Endicott meter run Alyeska did not\nprovide an inspection report for this pipe for internal corrosion\n\n\n\nPro osed Civil Penalt\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 The Comphance Officer has reviewed the circumstances and\nsupporting documentation involved m the above probable violations and has recommended that\nyou be prehminarily assessed a civil penalty of $112, 000. 00 as follows\nItem Number PENALTY\n$56, 000\n$56, 000\nWarmn Items\nWith respect to Items 7 and 8, we have reviewed the circumstances and supporting documents\ninvolved m this case and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time We advise you to promptly correct this item. Be advised that\nfailure to do so may result in Alyeska Pipeline Service Company being subject to additional\nenforcement action\nPro osed Com hance Order\nWith respect to Items 1, 2, 3, 4, 5 and 6 pursuant to 49 United States Code ( 60118, the Pipehne\nand Hazardous Materials Safety Admmistration proposes to issue a Comphance Order to Alaska\nPipehne Service Company Please refer to the Proposed Conzpliance Order, which is enclosed\nand made a part of this Notice\nRes onse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipehne Operators in\nComp&ance ProceeCings 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 beheve that any portion of your responsive material quahfies for\nconfidential treatment under 5 U. S C 552(b), along with the complete original document you must\nprovide a second copy of the document with the portions you beheve quahfy for confidential\ntreatment redacted and an explanation of why you beheve the redacted information quahfies for\nconfidential treatment under 5 U S. C 552(b) If you do not respond within 30 days of receipt of\nthis Notice, this constitutes a waiver of your right to contest the allegations in this Notice and\nauthorizes the Associate Administrator for Pipehne Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue a Final Order,\n\n\n\nIn your correspondence on this matter, please refer to CPF 5-2008-5002 and for each document\nyou submit, please provide a copy in electronic format whenever possible\nSmcerely,\nChris Hoidal\nDirector, Western Region\nPipehne and Hazardous Materials Safety Admmistration\ncc PHP-60 Comphance Registry\nPHP-500 8 Flanders {0118831)\nEnclosures Proposed Compliance Order\nResponse Options for Pipeline Operators in Compliance Proceedings\n\n\n\nPursuant to 49 United States Code ( 60118, the Pipeline and Hazardous Materials Safety\nAdmmistration (PHMSA) proposes to issue to Alyeska Pipehne Service Company a Comphance\nOrder incorporating the following remedial requirements to require that the Alyeska Pipelme\nService Company comphes with the pipeline safety regulations\nIn regard to Item Number 1 of the Notice pertaining to the missing valve position\nindicator on MV 10A Alyeska Pipehne Service Company shall mstall a valve\nposition indicator on MV 10A\nIn regard to Item Number 2 of the Notice pertainmg to the structural sleeve at MP\n57. 785, Alyeska Pipeline Service Company shall remove and inspect the internal\ncorrosion inside the pipe under the sleeve during the pump station ¹ 2 pipe\nreplacement now scheduled for 2008 PHMSA shall be notified immediately if this\nsleeve is not removed m 2008\nIn regard to Item Number 3 of the Notice pertaining to the pressure shutdown\nswitches at GC-1, FS-1 and FS-3. Alyeska shall maintain these pressure shutdown\nswitches as DOT critical safety devices or shall install adequate pressure control\nequipment within its own facihties at Pump Station 1\nAlyeska Pipelme Service Company shall revise \"OM-1, Procedural Manual for\nOperations, Maintenance Atmospheric Corrosion and Emergencies\", Section '1, to\nindicate that these pressure shutdown switches are DOT critical safety devices or to\nreflect any additional pressure control equipment Alyeska installs at its own\nfacihties at Pump Station 1. Alyeska shall also arrange to have such pressure\nshutdown switches and any additional pressure control equipment tested annually\nand shall maintain and make available to PHMSA the records of such testing\n4 In regard to Item Number 4 of the Notice peitaining to the pressure transmitter\n(31-PT-013A) on the Kuparuk pipehne mcommg line to Alyeska This pressure\ntransmitter shall be maintained as DOT critical safety devices\nAlyeska Pipehne Service Company shall revise \"OM-1, Procedural Manual for\nOperations, Maintenance and Emergencies\", Section 7, to indicate that these\npressure shutdown switches are DOT critical safety devices Alyeska shall also\nconduct annual tests of these pressure shutdown switches and shall maintam and\nmake available to PHMSA the records of such testing.\n5 In re ard to Item Number 5 o the Notice ertainin to the low cathodic rotection\nlevels on the i eline between MP 12 2-13 2 This section o the i eline must be\nrovided cathodic rotection levels that meet criteria set orth in $195 571\n\n\n\n6 In re ard to Item Number 6 o the Notice ertainin to the wind- owered recti ier\n3I EE I25 located at MP I2 5 The recti ier at that location must be re aired so\nthat it cathodzcall rotects the tar eted i eline se ment and that an o eratin\nde iciencies noted dunn t$ze bzmonthl recti ier readin s are rom tl re aired as\n~ve mred b g~i95 401 b\n7 Alyeska Pipehne Service Company shall complete the above-listed requirements,\nand submit documentation of such completion within 180 days of receipt of the\nFinal Order\n8 Alyeska Pipehne Service Company shall maintain documentation of the safety\nimprovement costs associated with fulfilhng this Comphance Order and submit the\ntotal to Chris Hoidal, Director, Western, Pipehne and Hazardous Materials Safety\nAdministration Costs shall be reported in two categories 1) total cost associated\nwith preparation/revision of plans, procedures, studies and analyses, and 2) total\ncost associated with replacements, additions and other changes to pipeline\ninfrastructure\n\n520085002_Final Order_03212011_text.pdf\n\nMAR 21 2011\nMr. Mike Joynor\nSenior Vice President\nAlyeska Pipeline Service Company\n900 East Benson Blvd.\nP.O. Box 196660\nAnchorage, AK 99519\nRe: CPF No. 5-2008-5002\nDear Mr. Joynor:\nEnclosed please find the Final Order issued in the above-referenced case. It makes findings of\nviolation, assesses a civil penalty of $112,000, and withdraws one of the allegations of violation.\nIt further specifies actions that need to be taken by Alyeska Pipeline Service Company to comply\nwith the pipeline safety regulations.\nThe penalty payment terms are set forth in the Final Order. When the civil penalty has been paid\nand the terms of the compliance order completed, as determined by the Director, Western\nRegion, this enforcement action will be closed. Service of the Final Order by certified mail is\ndeemed effective upon the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. Chris Hoidal, Director, Western Region, PHMSA\nMr. Dennis Hinnah, Deputy Director, Western Region, PHMSA\nMs. Sheila Doody Bishop, Esq., Counsel for Alyeska Pipeline Service Company\nCERTIFIED MAIL – RETURN RECEIPT REQUESTED [7009 1410 0000 2472 2858]\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n__________________________________________\n)\nIn the Matter of )\n)\nAlyeska Pipeline Service Company, ) CPF No. 5-2008-5002\n)\nRespondent. )\n)\nFINAL ORDER\nFrom July 8 to July 13, 2007, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),\nconducted an on-site pipeline safety inspection of the facilities and records of Alyeska Pipeline\nService Company (Alyeska or Respondent). Specifically, OPS inspected Alyeska’s facilities\nbetween Pump Station #1 and Mile Post (MP) 1 near Prudhoe Bay, Alaska. Alyeska is the\noperator of the Trans Alaska Pipeline System (TAPS), an 800-mile-long hazardous liquid\npipeline system that transports crude oil from production facilities at Prudhoe Bay to a marine\nterminal in Valdez, Alaska.1 Approximately 200 miles of the TAPS is considered a High\nConsequence Area (HCA) on the North Slope of Alaska.\nAs a result of the inspection, the Director, Western Region, OPS (Director), issued to Alyeska,\nby letter dated April 1, 2008, a Notice of Probable Violation, Proposed Civil Penalty, and\nProposed Compliance Order. Subsequently, on October 15, 2008, OPS amended its Notice to\ninclude two additional proposed corrective measures. Alyeska was granted an additional 30 days\nto respond to the Amended Notice.2\nIn accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Respondent had\ncommitted various violations of 49 C.F.R. Part 195, that a civil penalty of $112,000 be assessed\nfor the alleged violations, and that Respondent be required to take certain measures to correct the\nalleged violations. The Notice also proposed finding that Respondent had committed certain\nother probable violations of 49 C.F.R. Part 195, and warned Respondent to take appropriate\ncorrective action to address them or be subject to future enforcement action.\nAlyeska responded to the Notice by letters dated April 22, 2008, May 22, 2008, and November\n18, 2008 (collectively, Response). Respondent contested one of the alleged violations, provided\n1 http://www.alyeska-pipe.com (last accessed on Feb. 14, 2010).\n2 All references to “Notice” in this Final Order will refer to the Amended Notice issued on October 15, 2008.\n\n\n\n2\nan explanation of its actions regarding the other allegations, and requested that PHMSA\nwithdraw certain items listed in the proposed compliance order. Respondent did not request a\nhearing and therefore has waived its right to one.\nFINDINGS OF VIOLATION\nIn its Response, Alyeska did not contest the following allegations in the Notice that it violated 49\nC.F.R. Part 195:\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.116(e), which states:\n§ 195.116 Valves.\nfollowing….\nEach valve installed in a pipeline system must comply with the\n(e) Each valve other than a check valve must be equipped with a\nmeans for clearly indicating the position of the valve (open, closed, etc.).\nThe Notice alleged that Alyeska violated 49 C.F.R. § 195.116(e) by failing to equip each valve\nwith a means for clearly indicating the position of the valve. Specifically, the Notice alleged that\nduring the inspection, MGV 10A, a manual gate valve, was found without a valve position\nindicator. OPS attached pictures to the Pipeline Safety Violation Report documenting the\nmissing indicator. Alyeska did not contest this allegation of violation and stated that it had\nscheduled the installation of the valve position indicator. Accordingly, based upon a review of\nall of the evidence, I find that Respondent violated 49 C.F.R. § 195.116(e) by failing to maintain\na valve position indicator on MGV 10A.\nItem 2: The Notice alleged that Respondent violated 49 C.F.R. §195.401 (b), which states:\n§ 195.401 General requirements.\n(a) ….\n(b) Whenever an operator discovers any condition that could\nadversely affect the safe operation of its pipeline system, it shall correct it\nwithin a reasonable time. However, if the condition is of such a nature\nthat it presents an immediate hazard to persons or property, the operator\nmay not operate the affected part of the system until it has corrected the\nunsafe condition.\nThe Notice alleged that Alyeska violated 49 C.F.R. § 195.401(b) by failing to correct a condition\nthat could adversely affect the safe operation of its pipeline system within a reasonable time.\nSpecifically, the Notice alleged that due to internal corrosion Respondent installed a 15-foot non-\npressure containment sleeve at MP 57.785 in 1989. The operator continued to operate the\npipeline segment with the sleeve in place, even though an indeterminate amount of remaining\npipe wall thickness existed under the sleeve. Such a condition could adversely affect the safe\noperation of TAPS because this type of structural sleeve will not stop crude oil from leaking onto\nthe ground when internal corrosion has weakened the pipe wall. Alyeska was notified of this\nissue in January 2007 and scheduled work to repair it in 2007 and again in 2008. Respondent did\n\n\n\n3\nnot correct this condition within a reasonable time. Alyeska did not contest this allegation of\nviolation but requested that the OPS withdraw the proposed compliance order, as discussed\nbelow. Accordingly, based upon a review of all of the evidence, I ","truncated":true,"body_characters":59077}