{"operation":"document","citation":"CPF 520115021W","title":"ALYESKA PIPELINE SERVICE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2011-12-14","effective_on":null,"summary":"CLOSED warning letter citing 195.452(j)(2), 195.579(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520115021w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520115021w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520115021w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520115021W","body":"Warning Letter involving ALYESKA PIPELINE SERVICE CO. PHMSA's enforcement data identifies the cited regulations as 195.452(j)(2),  195.579(b)(2). The case was opened on 2011-12-14 and is reported as closed as of 2011-12-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520115021W_operator_response_01132012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520115021W/520115021W_operator_response_01132012.pdf\n\n520115021W_warning letter_12142011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520115021W/520115021W_warning%20letter_12142011.pdf\n\n520115021W_warning letter_12142011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520115021W/520115021W_warning%20letter_12142011_text.pdf\n\n520115021W_warning letter_12142011_text.pdf\n\nWARNING LETTER\nVIA UPS GROUND\nDecember 14, 2011\nMr. Mike Joynor\nPipeline Vice President\nAlyeska Pipeline Service Company\n900 East Benson Blvd.\nP.O. Box 196660\nAnchorage, AK 99519-6660\nCPF 5-2011-5021W\nDear Mr. Joynor:\nOn June 13, 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) pipeline segment between Milepost 367 and\nMilepost 496, including Pump Stations 7 & 8, in 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. §195.452 Pipeline integrity management in high consequence areas.\n(j) What is a continual process of evaluation and assessment to maintain a\npipeline's integrity?—\n(2) Evaluation. An operator must conduct a periodic evaluation as\nfrequently as needed to assure pipeline integrity. An operator must base\nthe frequency of evaluation on risk factors specific to its pipeline,\nincluding the factors specified in paragraph (e) of this section. The\nevaluation must consider the results of the baseline and periodic integrity\nassessments, information analysis (paragraph (g) of this section), and\n\n\n\ndecisions about remediation, and preventive and mitigative actions\n(paragraphs (h) and (i) of this section).\nAlyeska has not included the barrel sleeve at Mile Post 457.53 in its continual process of\nevaluation and assessment. During the inspection on June 15, 2011, OPS observed the barrel\nsleeve at Mile Post 457.53 on the mainline and requested that Alyeska provide information\nconcerning internal corrosion inspection on this sleeve. OPS sent a formal request for the\nsame information to Alyeska in a Request for Specific Information on July 5, 2011.\nAlyeska’s response dated September 1, 2011, indicated that this sleeve was installed in 1989\nover a bolted split sleeve that had been installed in 1978. Alyeska’s September 1st letter also\nstated “To date, there have been no inspections or assessments completed at this location”.\nThis sleeve must be included in Alyeska’s integrity management program, and must be\ninvestigated for corrosion. This particular sleeve presents a corrosion risk because water and\nsolids may accumulate inside of the barrel. Such water and solids may contribute to internal\ncorrosion, particularly because they may not be removed during maintenance pigging\noperations. In addition, ILI tools cannot detect corrosion damage inside a barrel sleeve.\nGiven the corrosion risks, Alyeska should include this barrel sleeve in their internal corrosion\ncontrol program.\nThis probable violation is based on photographs, conversation, the information received from\nAlyeska’s Government Letter No. 24186, and Alyeska’s IM-244, TAPS Integrity\nManagement Plan for High Consequence Areas.\n2. § 195.579 What must I do to mitigate internal corrosion?\n(b) Inhibitors. If you use corrosion inhibitors to mitigate internal corrosion,\nyou must –\n(2) Use coupons or other monitoring equipment to determine the effectiveness\nof the inhibitors in mitigating internal corrosion; and\nAlyeska is not properly determining the effectiveness of their internal corrosion inhibitors.\nThe existing pipeline coupons used to monitor the effectiveness of corrosion inhibitors are\ncurrently installed at high points in the pipeline that do not reflect conditions of the below-\nground pipeline segments. The below-ground segments differ because the heavier fluids\nsettle and wax and solids accumulate on the bottom of the pipe. The procedures, type and\nquantity of inhibitor could be significantly different if coupons are measuring corrosion\nactivity in the below-ground segments of piping.\nAlyeska uses corrosion inhibitors in the 36-inch diameter relief piping at Pump Station 07.\nThe suction and discharge relief lines are no longer connected to the relief valves at PS07.\nThese sections of crude piping are known as “dead legs” because they are part of the pipeline\nsystem that experiences low or no flow. Dead legs are susceptible to internal corrosion.\nThese dead legs consist of both above-ground and below-ground segments. During the\n2\n\n\n\ninspection, OPS observed that the coupons used to monitor corrosion were only installed on\nhigh points in the relief piping.\nAlyeska’s Integrity Management Engineering Team gave a PowerPoint presentation of\nAlyeska’s Internal Corrosion Program on June 24, 2010, at PHMSA’s Anchorage office.\nThe presentation provided Alyeska’s plans for mitigating internal corrosion in the 36” relief\ndead legs at their Pump Stations, but did not make any representations about the dead legs at\nPS07.\nThis probable violation is based on photographs, conversation, and the information presented\nduring Alyeska’s Internal Corrosion Program presentation on June 24, 2010.\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, in your correspondence please refer\nto CPF 5-2011-5021W and send all documents to our office at 188 W. Northern Lights\nBlvd., Suite 520, Anchorage, AK 99503. Be advised that all material you submit in response\nto this enforcement action is subject to being made publicly available. If you believe that\nany portion 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\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: PHP-60 Compliance Registry\nPHP-500 B. Flanders (#133348)\n3","truncated":false,"body_characters":7271}