{"operation":"document","citation":"CPF 520105030W","title":"ALYESKA PIPELINE SERVICE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-11-05","effective_on":null,"summary":"CLOSED warning letter citing 195.404(a)(4), 195.579(a), 195.579(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520105030w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520105030w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520105030w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520105030W","body":"Warning Letter involving ALYESKA PIPELINE SERVICE CO. PHMSA's enforcement data identifies the cited regulations as 195.404(a)(4),  195.579(a),  195.579(b). The case was opened on 2010-11-05 and is reported as closed as of 2010-11-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520105030W_operator response_12092010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105030W/520105030W_operator%20response_12092010.pdf\n\n520105030W_warning letter_11052010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105030W/520105030W_warning%20letter_11052010.pdf\n\n520105030W_warning letter_11052010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105030W/520105030W_warning%20letter_11052010_text.pdf\n\n520105030W_warning letter_11052010_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 5, 2010\nMr. Mike Joynor\nPipeline Vice President\nAlyeska Pipeline Service Company\n900 East Benson Blvd.\nP.O. Box 196660\nAnchorage, AK 99519-6660\nCPF 5-2010-5030W\nDear Mr. Joynor:\nOn August 25-29, and September 11-19, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States\nCode, inspected Alyeska Pipeline Service Company’s (Alyeska) pipeline segment between\nPump Station 4 (Milepost 126) and Pump Station 6 (Milepost 397), and between Pump\nStation 9 (Milepost 496) and Pump Station 10 (Milepost 647), in Fairbanks, 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\nthe probable violations are:\n1. § 195.404 Maps and Records.\n(a) Each operator shall maintain current maps and records of its pipeline\nsystems that include at least the following information;\n(4) The diameter, grade, type and nominal wall thickness of all pipe.\nAlyeska failed to maintain current maps and records of certain pressure relief piping at Pump\nStation 5 (PS05). During the inspection, PHMSA asked Alyeska to provide maps and\nrecords for the PS05 manifold building relief piping. In response, Alyeska provided “Pump\n\n\n\nStation 05, Drawing D35 M102.” This drawing does not reflect the modifications made to the\nrelief piping in the mid-1990s, and therefore does not reflect the current configuration of the\npipeline system.\nIn addition, Alyeska failed to maintain current maps and records for 48 inch diameter fittings\ninstalled on the mainline pipe at RGV 39, (approximate stationing 11475+89-11477+54).\nDuring the inspection, PHMSA asked to see the pipeline as-built records that would show\nthese fittings. Alyeska informed PHMSA that the as built records had not been updated to\nreflect the fittings.\nThe probable violation is based on photographs and Drawing D35 M102.\n2. §195.579 What must I do to mitigate internal corrosion?\n(a) General. If you transport any hazardous liquid or carbon dioxide that would\ncorrode the pipeline, you must investigate the corrosive effect of the hazardous\nliquid or carbon dioxide on the pipeline and take adequate steps to mitigate\ninternal corrosion.\nAlyeska does not investigate the corrosive effect of the hazardous liquid on all portions of the\npipeline. Specifically, Alyeska has not included known bottom-of-pipe fittings or\nappurtenances at Mile Post 200 in its internal corrosion program. Alyeska did not provide\nany record that they had investigated corrosive effects on these appurtenances. During the\ninspection, PHMSA observed the bottom-of-pipe appurtenances at Mile Post 200. PHMSA\nrequested that Alyeska provide a list of all bottom-of-pipe fittings on the mainline. In\nresponse, Alyeska informed PHMSA that its In-Line Inspection (ILI) contractor does not\nreport such appurtenances.\nBottom-of-pipe appurtenances must be investigated for corrosion. These appurtenances\npresent a corrosion risk because water and solids may accumulate inside of them. Such water\nand solids may contribute to internal corrosion, particularly, because they may not be\nremoved during maintenance pigging operations. In addition, ILI tools cannot typically\ndetect corrosion damage inside appurtenances. Given the corrosion risks, Alyeska should\ninclude all appurtenances in their internal corrosion control program\nThe probable violation is based on photographs and conversation with Alyeska’s corrosion\ncontrol personnel.\n3. § 195.579 What must I do to mitigate internal corrosion?\n(a) …\n(b) Inhibitors. If you use corrosion inhibitors to mitigate internal corrosion, you\nmust-\n2\n\n\n\n(1) Use inhibitors in sufficient quantity to protect the entire part of the pipeline\nsystem that the inhibitors are designed to protect;\n(2) Use coupons or other monitoring equipment to determine the effectiveness of\nthe inhibitors in mitigating internal corrosion; and\n(3) …\nAlyeska uses corrosion inhibitors in the 36-inch diameter relief piping at Pump Stations 06\nand 10. These sections of crude piping are known as a “dead legs,” because they are part of\nthe pipeline system that experiences low or no flow. Dead legs may be susceptible to\ninternal corrosion. Alyeska’s 2008 inhibitor injection records indicate that inhibitor is\ninjected into these dead legs. However, during the inspection, PHMSA observed that\ncoupons used to monitor corrosion were only installed on high points in the relief piping.\nThe coupons installed at the high points of the relief piping are not exposed to conditions\nwhich are representative of the below ground segments because of gravity segregation of\nfluids and accumulation of wax and solid on the bottom of the pipe. The amount of corrosion\ninhibitor required to adequately protect the high points is substantially different from the\namount and type of corrosion inhibitor required to protect the below ground segments.\nAlyeska has no coupons for determining the effectiveness of the inhibitor in the below-\nground segment.\nAlyeska presented information on June 24, 2010 that Alyeska would take the following steps\nto mitigate internal corrosion in the dead legs:\n- Change inhibitor\n- Flush dead legs and treat annually\n- Install coupon in the lower portion of the dead legs by the end of 2011\n- Remove dead legs at Pump Stations 6, 10 and 11 by 2013\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of\n$1,000,000 for any related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct\nthe items identified in this letter. Failure to do so will result in Alyeska Pipeline Service\nCompany being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, please send your response to 188\nW. Northern Lights Blvd. Suite 520, Anchorage, Alaska 99503, and in your correspondence\nplease refer to CPF 5-2010-5030W. Be advised that all material you submit in response to\nthis enforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C.\n552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\n3\n\n\n\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 5 U.S.C. 552(b).\nSincerely,\nDennis Hinnah\nDeputy Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP60 – Compliance Registry\nB. Flanders (#120662, 120658)\n4","truncated":false,"body_characters":7816}