# ALYESKA PIPELINE SERVICE CO — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 520095019
- **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:** 2009-04-21
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.126, 195.402.
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520095019.md
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520095019
**body:**

Notice of Probable Violation involving ALYESKA PIPELINE SERVICE CO. PHMSA's enforcement data identifies the cited regulations as 195.126,  195.402. The case was opened on 2009-04-21 and is reported as closed as of 2011-11-16. Proposed civil penalty: $43,800. Assessed civil penalty: $0. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520095019_Compromise Agreement and Order_11162011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095019/520095019_Compromise%20Agreement%20and%20Order_11162011.pdf

520095019_Compromise Agreement and Order_11162011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095019/520095019_Compromise%20Agreement%20and%20Order_11162011_text.pdf

520095019_nopv pcp pco_04212009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095019/520095019_nopv%20pcp%20pco_04212009.pdf

520095019_nopv pcp pco_04212009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095019/520095019_nopv%20pcp%20pco_04212009_text.pdf

520095019_Compromise Agreement and Order_11162011_text.pdf

NOV 16 2011
U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
)
In the Matters of )
) CPF No. 5-2006-5018
Alyeska Pipeline Service Company, ) CPF No. 5-2007-5041
) CPF No. 5-2008-5008
Respondent. ) CPF No. 5-2009-5019
____________________________________)
COMPROMISE AGREEMENT AND ORDER
The U.S. Department of Transportation, Pipeline and Hazardous Materials Safety
Administration (PHMSA) and Alyeska Pipeline Service Company (Alyeska or
Respondent) have engaged in settlement discussions regarding the resolution of the four
enforcement actions listed above. Having concluded those discussions, PHMSA and
Alyeska (collectively, Parties) agree that a settlement of these matters is in the best
interests of the Parties and the public and will avoid further administrative proceedings or
litigation. The Parties further agree that the entry of this Compromise Agreement and
Order is the most appropriate means of accomplishing that objective.
I. Procedural History.
A. CPF No. 5-2006-5018
On April 19, 2006, PHMSA issued to Alyeska a Notice of Probable Violation, Proposed
Civil Penalty, and Proposed Compliance Order (Notice). Item 1 of the Notice alleged
that Alyeska had violated 49 C.F.R. § 195.452(h)(2) and proposed assessing the company
a civil penalty of $260,000 for that violation. Item 2 of the Notice alleged that Alyeska
had violated 49 C.F.R. §§ 195.452(h)(3) and (h)(4)(i)(C) and proposed assessing the
company a civil penalty of $90,000 for that violation. The Notice also proposed ordering
Alyeska to complete certain corrective actions to address both violations.
On April 27, 2006, Alyeska submitted a written response to the Notice and requested an
informal hearing. That hearing was held on January 18, 2007, with an Attorney Advisor
from the Office of Chief Counsel, PHMSA, presiding.



On January 13, 2010, the Associate Administrator for Pipeline Safety, PHMSA, issued a
Final Order in the case. The Final Order found that Alyeska had violated 49 C.F.R.
§ 195.452(h)(2) as alleged in Item 1 of the Notice and assessed a civil penalty of
$173,000. The Final Order further found that Alyeska had violated 49 C.F.R.
§§ 195.452(h)(3) and (h)(4)(i)(C) as alleged in Item 2 of the Notice and assessed a civil
penalty of $90,000. The Final Order also ordered Alyeska to complete certain corrective
measures.
On February 8, 2010, Alyeska submitted a Petition for Reconsideration (Petition) of the
Final Order. The Petition sought, among other things, reconsideration of the civil penalty
assessed against Alyeska for Item 1. On March 1, 2010, the Associate Administrator
denied that part of the Petition in a Decision on Reconsideration (Decision).
On March 22, 2010, Alyeska made a payment of $90,000 in full satisfaction of the civil
penalty assessed for Item 2. On April 20, 2010, Alyeska submitted, to the Director,
PHMSA Western Region (Director), information documenting full compliance with the
corrective actions in the Final Order and the Decision. On July 29, 2010, Alyeska made
another payment of $173,000, under protest and with full reservation of rights, in full
satisfaction of the civil penalty assessed for Item 1.
On August 3, 2010, Alyeska filed a complaint in the United States District Court for the
District of Alaska, Case No. 3:10-CV-00177-JWS (Complaint). The Complaint alleged
that the Associate Administrator (1) had assessed Alyeska an excessive civil penalty for
Item 1; (2) had failed to comply with the procedural requirements in 49 C.F.R.
§ 190.213(e) in issuing his Final Order; and (3) had found Alyeska in violation of 49
C.F.R. § 195.452(h)(2) without substantial evidence. The Complaint sought, among
other things, the return of the $173,000 that Alyeska had paid to PHMSA for Item 1.
On October 20, 2011, PHMSA filed an answer (Answer) to the Complaint. The Answer
denied all of Alyeska’s allegations and asserted that the company had already admitted
all of the facts necessary to affirm the Final Order.
B. CPF 5-2007-5041
On November 27, 2007, PHMSA issued to Alyeska a Notice of Probable Violation,
Proposed Civil Penalty, and Proposed Compliance Order (Notice). The Notice alleged
that Alyeska had committed several violations of 49 C.F.R. Part 195 and proposed
assessing the company a total civil penalty of $817,000 for those violations. The Notice
also proposed ordering Alyeska to complete certain corrective actions and issuing a
warning that the company take appropriate action to address several other probable
violations.
Alyeska responded to the Notice on February 26, 2008, requesting an informal hearing.
That hearing was held on October 28, 2008, with an attorney from the Office of Chief
Counsel, PHMSA, presiding.
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C. CPF 5-2008-5008
On April 1, 2008, PHMSA issued to Alyeska a Notice of Probable Violation, Proposed
Civil Penalty, and Proposed Compliance Order (Notice). The Notice alleged that
Alyeska had committed several violations of 49 C.F.R. Part 195 and proposed a total civil
penalty of $170,000 for those violations. The Notice also proposed ordering Alyeska to
complete certain corrective actions to address several of those violations.
On May 22, 2008, Alyeska responded to the Notice and requested an informal hearing.
That hearing was held on October 30, 2008, with an attorney from the Office of Chief
Counsel, PHMSA, presiding.
D. CPF 5-2009-5019
On April 21, 2009, PHMSA issued to Alyeska a Notice of Probable Violation, Proposed
Civil Penalty, and Proposed Compliance Order (Notice). The Notice alleged that
Alyeska had committed two violations of 49 C.F.R. Part 195 and proposed a civil penalty
of $43,800 for one of those violations. The Notice also proposed issuing a warning that
the company take appropriate corrective action to address the other probable violation.
On May 21, 2009, Alyeska responded to the Notice, requesting an informal hearing. That
hearing was held on October 21, 2009, with an attorney from the Office of Chief
Counsel, PHMSA, presiding.
II. General Provisions.
1. Alyeska acknowledges that the company and its pipeline system, known generally
as the Trans-Alaska Pipeline System (TAPS), are subject to the jurisdiction of the Federal
pipeline safety laws, 49 U.S.C. 60101, et seq., and the regulations and administrative
orders issued thereunder. For purposes of this Compromise Agreement and Order,
Alyeska acknowledges that it received proper notice of PHMSA’s actions in CPF 5-2006-
5018, CPF 5-2007-5041, CPF 5-2008-5008, and CPF 5-2009-5019 (collectively,
Enforcement Actions) and that the Notices, Final Orders, and Decisions issued in the
Enforcement Actions all state claims upon which relief may be granted pursuant to 49
U.S.C. 60101, et seq., and the regulations and orders issued thereunder.
2. By entry of this Compromise Agreement and Order, PHMSA neither vacates nor
withdraws the Final Order and Decision issued in CPF 5-2006-5018. All provisions of
the Final Order and Decision in CPF 5-2006-5018 shall remain in full force and effect,
except as expressly modified by this Compromise Agreement and Order. Nothing in this
Compromise Agreement and Order shall bar consideration of the findings of violation set
forth in the Final Order and Decision in CPF 5-2006-5018 as prior offenses in any future
PHMSA enforcement action.
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3. Alyeska agrees to the issuance of this Compromise Agreement and Order and
hereby waives any further procedural requirements with respect to its issuance. Alyeska
waives all rights to contest the adequacy of the Notices, Final Orders, and Decisions
issued in the Enforcement Actions and the validity of this Compromise Agreement and
Order, including all rights to administrative or judicial hearings or appeals.
4. This Compromise Agreement and Order constitutes the final, complete, and
exclusive agreement and understanding between the Parties with respect to the
Enforcement Actions and the issues embodied in this agreement. The Parties
acknowledge that there are no representations, agreements, or understandings relating to
the amount or collection of any civil penalties other than those expressly contained in this
agreement, except that the terms of this agreement may be construed by reference to any
Notices, Final Orders, and Decisions issued in the Enforcement Actions.
5. Nothing in this Compromise Agreement and Order affects or relieves Alyeska of
its responsibility to comply with all applicable requirements of the Federal pipeline safety
laws, 49 U.S.C. § 60101, et seq., and the regulations and orders issued thereunder.
Nothing in this agreement alters PHMSA’s right of access, entry, inspection, and
information gathering, or its authority to bring any enforcement action against Alyeska
pursuant to the Federal pipeline safety laws, the regulations and orders issued thereunder,
or any other provision of Federal or State law.
6. This Compromise Agreement and Order does not waive or modify any Federal,
state, or local laws or regulations that are applicable to Alyeska’s pipeline system. This
agreement is not a permit or a modification of a permit under any Federal, State, or local
laws or regulations. Alyeska remains responsible for achieving and maintaining
compliance with all applicable Federal, State, and local laws, regulations and permits.
7. This Compromise Agreement and Order does not create rights in, or grant any
cause of action to, any person not a party to this agreement. PHMSA is not liable for any
injuries or damages to persons or property arising from acts or omissions of Alyeska or
its officers, employees, or agents carrying out the work required by this agreement.
PHMSA, its officers, employees, agents, and representatives are not liable for any cause
of action arising from any acts or omissions of Alyeska or its contractors in carrying out
any work required by this agreement.
8. This Compromise Agreement and Order shall apply to and be binding on
Alyeska, its officers, directors, employees, successors and assigns, including, but not
limited to, subsequent purchasers.
III. Finding of Violations.
9. With respect to CPF 5-2007-5041, the Parties mutually agree, and PHMSA hereby
finds, that Alyeska committed the violations alleged in Items 1, 2, 3, 4, 6, 8, and 9 of the
Notice. The Parties mutually agree, and PHMSA hereby finds that Alyeska had
inadequate procedures as alleged in Items 5, 7, 16a, and 16b of the Notice.4



10. With respect to CPF 5-2008-5008, the Parties mutually agree, and PHMSA
hereby finds, that Alyeska committed the violations alleged in Items 1, 2, 3, 5, 6, and 7 of
the Notice, but that the allegation in Item 4 of the Notice should be, and hereby is,
withdrawn.
11. With respect to CPF 5-2009-5019, PHMSA hereby finds that the allegation in
Item 1 of the Notice should be, and hereby is, withdrawn.
12. The findings of violation in Paragraphs 9, 10, and 11 will be considered prior
offenses in any subsequent enforcement actions taken against Alyeska.
IV. Civil Penalty.
13. The Parties mutually agree, and PHMSA hereby orders, that the total civil
penalty assessed for Items 1 to 9 and 16a to 16b of the Notice in CPF 5-2007-5041 and
Items 1 to 3 and 5 to 7 of the Notice for CPF 5-2008-5008 is Six-Hundred-Thousand
Dollars ($600,000).
14. Alyeska will pay the civil penalty amount in Paragraph 13 within 30 days of
signing of this Compromise Order and Agreement. Payment may be made by sending a
certified check or money order, made payable to “U.S. Department of Transportation,” to
the Federal Aviation Administration, Mike Monroney Aeronautical Center, Financial
Operations Division (AMZ-341), P.O. Box 269039, Oklahoma City, Oklahoma 73125.
Payment may also be made by wire transfer through the Federal Reserve
Communications System (Fedwire), to the account of the U.S. Treasury.
15. The Parties agree that the civil penalty assessed and collected in this proceeding
will not be deductible for purposes of Federal taxes.
16. The Parties agree that the civil penalty assessed and collected in this proceeding
will not be used in determining the amount of any civil penalty for any future
enforcement action.
V. Compliance Order.
17. The Parties mutually agree, and PHMSA hereby finds, that Alyeska has satisfied
the terms of all of the proposed compliance orders for the Enforcement Actions, except
for the following:
A. CPF 5-2008-5008
i. With respect to the violation of § 195.583 (Item 7), Alyeska must develop
and implement a risk-based atmospheric corrosion control program for
TAPS, as required under that regulation. Alyeska must submit, for
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approval by the Director, documentation of the program within 180 days
of the Effective Date of this Compromise Order and Agreement.
VI. Warning Items.
18. The Parties mutually agree, and PHMSA hereby orders, that Alyeska has
received a warning for committing the probable violations in Items 10, 13, and 14 of the
Notice in CPF 5-2007-5041 and Item 2 of the Notice in CPF 5-2009-5019, and that the
company must take appropriate corrective actions or be subject to future enforcement
action. PHMSA hereby finds that the warnings in Items 11, 12 and 15 of the Notice in
CPF 5-2007-5041 should be, and hereby are, withdrawn.
VII. Dismissal of Complaint.
19. The Parties agree to sign, and that Alyeska will file, a voluntary "Stipulation for
Dismissal of Action," in a form substantially similar to the document attached to this
order as Exhibit A, in the United States District Court for the District of Alaska within
thirty (30) days of Alyeska’s payment of the civil penalty amount referenced in paragraph
13 of this Compromise Order and Agreement. Said dismissal will be with prejudice and
without costs or fees for either of the Parties.
VIII. Dispute Resolution
20. PHMSA and Alyeska will attempt to resolve any disputes arising under this
Compromise Agreement and Order on an informal basis. If Alyeska and PHMSA are
unable to informally resolve the dispute within 15 days, Alyeska may request in writing,
within 10 days, a written determination resolving the dispute from the Associate
Administrator for Pipeline Safety. Such a request must include all of the information that
Alyeska believes is relevant to the dispute. If the request is submitted as provided herein,
the Associate Administrator will issue a final determination in writing. The existence of
a dispute and PHMSA’s consideration of matters placed in dispute will not excuse, toll,
or suspend any term or timeframe for completion of any work to be performed under this
agreement during the pendency of the dispute resolution process, except as agreed by the
Director or the Associate Administrator in writing.
IX. Enforcement
21. This Compromise Agreement and Order are subject to all enforcement authorities
available to PHMSA under 49 U.S.C. § 60101 et seq. and 49 C.F.R. Part 190, including
the assessment of civil penalties as determined in accordance with the requirements of 49
U.S.C. § 60122 and 49 C.F.R. §§ 190.223 to 190.225, if PHMSA determines that
Alyeska is not complying with the terms of this agreement, any determinations made by
the Director, or, if appealed, with any decisions of the Associate Administrator. Failure
to comply with the terms of this agreement may also result in referral to the Attorney
General for appropriate relief in a United States District Court pursuant to 49 U.S.C.
§ 60120.
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X. Effective Date.
22. The “Effective Date” is the date on which this Compromise Agreement and
Order has been signed by both Alyeska and PHMSA.
XI. Modification.
23. The terms of this Compromise Agreement and Order may be modified by mutual
agreement of the parties. Such modifications must be in writing and signed by both
parties.
XII. Termination.
24. This Compromise Agreement and Order will terminate upon Alyeska’s payment
of the civil penalty referenced in Paragraphs 13 and 14 and upon its completion of the
terms set forth in Paragraph 17 of Section V, as determined, in writing, by the Director.
Nothing in this agreement prevents Alyeska or PHMSA from completing any of the
obligations earlier than the deadlines provided for in this agreement.
XIII. Ratification.
25. The Parties’ undersigned representatives certify that they are fully authorized to
enter into the terms and conditions of this Compromise Agreement and Order and to
execute and legally bind such party to this document.
26. The Parties hereby agree to all conditions and terms of this Compromise
Agreement and Order:
For PHMSA: For Alyeska:
___________________________ ____________________________
Jeffrey D. Wiese Michael W. Joynor
Associate Administrator Senior Vice President of Operations
for Pipeline Safety Alyeska Pipeline Service Company
_____________________ _____________________
Date Date
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520095019_nopv pcp pco_04212009_text.pdf

NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPLIANCE ORDER
Via Federal Express and Facsimile To: (907) 787-8778
April 21, 2009
Mr. Mike Joynor
Pipeline Vice President
Alyeska Pipeline Service Company
900 East Benson Blvd.
P.O. Box 196660
Anchorage, AK 99519-6660
CPF 5-2009-5019
Dear Mr. Joynor:
On September 8 through 12, 2008, representatives of the Pipeline and Hazardous Materials
Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected
Alyeska Pipeline Service Company’s (ASPC) pipeline segment between Pump Station 1 and
Milepost 126 near Prudhoe Bay, Alaska.
As a result of the inspection, it appears that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the
probable violations are:
1. §195.126 Flange connection.
Each component of a flange connection must be compatible with each other
component and the connection as a unit must be suitable for the service in which it
is to be used.



The relief header at Pump Station 03 in the Manifold Building should be designed to be
suitable for the service in which it is to be used, i.e. to handle the pressures experienced
during a relief event. However, a component of this relief header does not appear to be
suitable to withstand surge pressure experienced during a relief event. The ANSI 150
(274 psi) blind flange was found to have released crude oil onto the floor of Pump
Station 03, probably during the past relief events. The release of oil from the ANSI 150
blind flange is evidence that the flange connection is not suitable for the service in which
it is to be used. A similar relief header at Pump Station 05 has an ANSI 600 (1440 psi)
blind flange installed, and showed no sign of crude oil release.
Evidence:
1. Photographs of ANSI 150 blind flange on relief header at Pump Station 03.
2. Photograph of crude oil on the floor under the ANSI 150 blind flange, on relief
header at Pump Station 03.
3. Photograph of crude oil on the floor under the ANSI 150 blind flange, on relief
header at Pump Station 03.
4. Photograph of ANSI 600 flanges on relief header at Pump Station 05.
5. Photograph of ANSI 600 Blind flange on relief header at Pump Station 05.
6. Safety Related Condition Report 19950041 dated 09/26/1995
7. Safety Related Condition Report 19990039 dated 10/22/1999
8. Safety Related Condition Report 19990045 dated 12/29/1999
9. Safety Related Condition Report 20040077 dated 12/20/2004
10. Procedure OCC-3.01-SR, page 8
2. §195.402 Procedural manual for operations, maintenance, and emergencies.
(c) Maintenance and normal operations. The manual required by paragraph (a) of
this section must include procedures for the following to provide safety during
maintenance and normal operations:
(3) Operating, maintaining, and repairing the pipeline system in accordance with
each of the requirements of this subpart and subpart H of this part.
Alyeska’s Facility Corrosion Integrity Monitoring Procedure, MP-166-3.03-01, states:
“The allowable period of time that may lapse between inspections as determined by
either half-life calculation or API 570 classifications. The maximum interval is generally
determined using the calculation of not more than half the remaining life of the subject
piping contingent to its measured corrosion condition, as projected by the established
corrosion rate. Sample ultrasonic testing (UT) inspection intervals should not exceed 5
years for Class 1 piping and 10 years for Class 2 and 3 piping. Visual inspection
intervals are directed to be 5 years for Class 1 and 2 piping and 10 years for Class 3
piping. The inspection intervals described above are based upon API 570. The PIT
Program uses this definition for piping in all design classes.”
2



Alyeska's procedure allows for only a sample of locations to be tested every ten years.
Alyeska has found internal corrosion which has a measured corrosion rate greater than
50 MPY and which if left uninvestigated for 10 years, would leak. (Alyeska’s 2004
Pipeline and Terminal Facilities Corrosion Monitoring Report stated that one location
had a 150 MPY rate.) The sampling and re-inspection must take into consideration the
possibility of new future corrosion colonies developing.
Evidence:
1. Facility Corrosion Integrity Monitoring Procedure MP-166-3.03-01
2. Spread sheet of 2008 Pit Program for Pump Station 01
3. 2004 Pipeline and Terminal Facilities Corrosion Monitoring Report
Proposed Civil Penalty
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000
for each violation for each day the violation persists up to a maximum of $1,000,000 for any
related series of violations. The Compliance Officer has reviewed the circumstances and
supporting documentation involved in the above probable violations and has recommended that
you be preliminarily assessed a civil penalty of $43,800.00 as follows:
Item Number
PENALTY
1 $43,800
Proposed Compliance Order
With respect to Item 1 pursuant to 49 United States Code § 60118, the Pipeline and Hazardous
Materials Safety Administration proposes to issue a Compliance Order to Alyeska Pipeline
Service Company. Please refer to the Proposed Compliance Order, which is enclosed and made
a part of this Notice.
Warning Item
With respect to Item 2, we have reviewed the circumstances and supporting documents involved
in this case and have decided not to conduct additional enforcement action or penalty
assessment proceedings at this time. We advise you to promptly correct this item. Be advised
that failure to do so may result in Alyeska Pipeline Service Company being subject to additional
enforcement action.
Response to this Notice
Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators
in Compliance Proceedings. Please refer to this document and note the response options. Be
advised that all material you submit in response to this enforcement action is subject to being
made publicly available. If you believe that any portion of your responsive material qualifies
for confidential treatment under 5 U.S.C. 552(b), along with the complete original document
3



you must provide a second copy of the document with the portions you believe qualify for
confidential treatment redacted and an explanation of why you believe the redacted information
qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond within 30 days
of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this
Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in
this Notice without further notice to you and to issue a Final Order.
In your correspondence concerning this matter, please refer to CPF 5-2009-5019 and send all
responses to my attention at 222 W. 7th Ave. # 200, PO Box 37, Anchorage, Alaska 99513. For
each document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
Dennis Hinnah
Deputy Director, Western Region
Pipeline and Hazardous Materials Safety Administration
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Compliance Proceedings
cc: PHP-60 Compliance Registry
PHP-500 B. Flanders (#120686)
4



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Alyeska Pipeline Service Company a
Compliance Order incorporating the following remedial requirements to require that the
Alyeska Pipeline Service Company complies with the pipeline safety regulations:
Flange on the relief header at Pump Station 03. Alyeska Pipeline Service
1. In regard to Item Number 1 of the Notice pertaining to the ANSI 150 blind
Company shall install a blind flange of the same pressure rating as was found on
the relief header at Pump Station 05.
2. Alyeska Pipeline Service Company shall complete the above-listed requirements,
and submit documentation of such completion within 180 days of receipt of the
Final Order.
3. Alyeska Pipeline Service Company shall maintain documentation of the safety
improvement costs associated with fulfilling this Compliance Order and submit
the total to Chris Hoidal, Director, Western, Pipeline and Hazardous Materials
Safety Administration. Costs shall be reported in two categories: 1) total cost
associated with preparation/revision of plans, procedures, studies and analyses,
and 2) total cost associated with replacements, additions and other changes to
pipeline infrastructure.
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