{"operation":"document","citation":"CPF 520115015M","title":"ALYESKA PIPELINE SERVICE CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2011-06-22","effective_on":null,"summary":"CLOSED notice of amendment citing 195.440(b), 195.440(f).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520115015m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520115015m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520115015m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520115015M","body":"Notice of Amendment involving ALYESKA PIPELINE SERVICE CO. PHMSA's enforcement data identifies the cited regulations as 195.440(b),  195.440(f). The case was opened on 2011-06-22 and is reported as closed as of 2011-10-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520115015M_closure letter_10072011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520115015M/520115015M_closure%20letter_10072011.pdf\n\n520115015M_closure letter_10072011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520115015M/520115015M_closure%20letter_10072011_text.pdf\n\n520115015M_notice of amendment_06222011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520115015M/520115015M_notice%20of%20amendment_06222011.pdf\n\n520115015M_notice of amendment_06222011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520115015M/520115015M_notice%20of%20amendment_06222011_text.pdf\n\n520115015M_operator response_07202011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520115015M/520115015M_operator%20response_07202011.pdf\n\n520115015M_notice of amendment_06222011_text.pdf\n\nNOTICE OF AMENDMENT\nVIA UPS: (1Z WR2 588 03 9441 4894)\nJune 22, 2011\nMr. Mike Joynor\nSenior Vice President\nAlyeska Pipeline Service Company\n900 E. Benson Blvd.\nP.O. Box 196606\nAnchorage, Alaska 99519\nCPF 5-2011-5015M\nDear Mr. Joynor:\nOn June 1-2, 2011, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected\nAlyeska Pipeline Service Company’s (Alyeska) procedures and records for its Public\nAwareness Program in Anchorage, Alaska.\nOn the basis of that inspection, PHMSA has identified the following apparent inadequacies\nfound within Alyeska’s plans and/or procedures, as described below:\n1. §195.440 Public Awareness\n(b) The operator's program must follow the general program recommendations\nof API RP 1162 and assess the unique attributes and characteristics of the\noperator's pipeline and facilities.\nA) Alyeska’s Public Awareness Program (PAP) does not contain a written statement of\nmanagement commitment. Alyeska’s PAP must be amended to meet the requirements of\nManagement Support, section 2.5 of API 1162.\n\n\n\nB) Alyeska’s PAP does not identify the program administrator by name or by position, but\nonly as a corporate communications representative. Alyeska’s PAP must be amended to\nmeet the requirements of Program Documentation, section 7.1 (c) of API 1162.\nC) Alyeska has conducted annual audits, but did not document the topics reviewed.\nAlyeska’s PAP must be amended to meet the requirements of Program Documentation,\nsection 7.1 (g) of API 1162.\nD) Alyeska has conducted annual audits, but has not identified and documented the\nmembers of the self assessment team. Alyeska’s PAP must be amended to meet the\nrequirements of Focus Groups, Appendix E of API 1162.\n2. §195.440 Public Awareness\n(f) The program and the media used must be as comprehensive as necessary to\nreach all areas in which the operator transports hazardous liquid or carbon\ndioxide.\nA) Alyeska states in section 5.2.1 of the PAP, “API recommends 660 to 1000 feet on either\nside of the pipeline. However, the coverage area should be expanded or contracted\nspecific to the particular pipeline, location, and potential impact consequences”\n. In\ndiscussions with Alyeska personnel, they described that they are identifying the affected\npublic by 60 feet on either side of the pipeline. Alyeska must amend section 5.2.1,\nAffected Public, to indicate what Alyeska will use to determine affected public.\nB) In discussions with Alyeska personnel, they described that at this time, the affected\npublic is being identified only in the North Star Borough. Alyeska must amend its PAP\nto include other residential areas along the Right of Way (Delta Junction, Glennallen,\nValdez etc.)\nC) In discussions with Alyeska personnel, they described that the affected public is being\nidentified and communicated through Right of Way Use Guideline (RUG) mailings.\nAlyeska must amend the PAP to include information about RUG mailings.\nD) In the past, Alyeska has not communicated with excavators through mailings, but relied\nupon newspapers and magazines ads. Alyeska must amend the PAP to include\ninformation to excavators through mailings.\n2\n\n\n\nResponse 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 Pipeline Operators in\nCompliance 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\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond\nwithin 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the\nallegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to\nfind facts as alleged in this Notice without further notice to you and to issue a Final Order.\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged\nin this Notice, you may be ordered to amend your plans or procedures to correct the\ninadequacies (49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that\nyou submit your amended procedures to my office within 90 days of receipt of this Notice.\nThis period may be extended by written request for good cause. Once the inadequacies\nidentified herein have been addressed in your amended procedures, this enforcement action\nwill be closed.\nIt is requested (not mandated) that Alyeska Pipeline Service Company maintain\ndocumentation of the safety improvement costs associated with fulfilling this Notice of\nAmendment (preparation/revision of plans, procedures) and submit the total to Dennis\nHinnah, Deputy Director, Western Region, Pipeline and Hazardous Materials Safety\nAdministration. In correspondence concerning this matter, please refer to CPF 5-2011-\n5015M and send all documents to our office at 188 W. Northern Lights Blvd., Suite 520,\nAnchorage, AK 99503. For each document you submit, please provide a copy in electronic\nformat whenever possible.\nSincerely,\nDennis Hinnah\nDeputy Director, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 B. Flanders (#134623)\n3\n\n520115015M_closure letter_10072011_text.pdf\n\nOctober 7, 2011\nMr. Joseph P. Robertson\nRegulatory Affairs Director\nAlyeska Pipeline Service Company\n900 E. Benson Blvd.\nP.O. Box 196606\nAnchorage, Alaska 99519\nCPF 5-2011-5015M\nDear Mr. Robertson:\nOn June 1-2, 2011, a representative from the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an\non-site pipeline safety inspection of Alyeska Pipeline Service Company’s Public Awareness\nProgram procedures in Anchorage, Alaska. As a result of the inspection, Alyeska Pipeline\nService Company was issued a Notice of Amendment on June 22, 2011, which proposed\namendment of your procedures.\nAlyeska Pipeline Service Company submitted its amended procedures on September 26,\n2011. My staff reviewed the amended procedures, and it appears that the inadequacies\noutlined in this Notice of Amendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nDennis Hinnah\nDeputy Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 B. Flanders","truncated":false,"body_characters":8115}