{"operation":"document","citation":"CPF 520125016M","title":"ALYESKA PIPELINE SERVICE CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-08-09","effective_on":null,"summary":"CLOSED notice of amendment citing 195.120, 195.228(b), 195.402, 195.402(c)(13), 195.403(b), 195.406(a), 195.420(b), 195.420(c), 195.426, 195.428(a), 195.444, 195.52(a)(3), 195.55(b)(3), 195.559, 195.561, 195.561(a), 195.563(a), 195.563(c), 195.567, 195.583(a), 195.583(c), 195.585.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520125016m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520125016m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520125016m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520125016M","body":"Notice of Amendment involving ALYESKA PIPELINE SERVICE CO. PHMSA's enforcement data identifies the cited regulations as 195.120,  195.228(b),  195.402,  195.402(c)(13),  195.403(b),  195.406(a),  195.420(b),  195.420(c),  195.426,  195.428(a),  195.444,  195.52(a)(3),  195.55(b)(3),  195.559,  195.561,  195.561(a),  195.563(a),  195.563(c),  195.567,  195.583(a),  195.583(c),  195.585. The case was opened on 2012-08-09 and is reported as closed as of 2012-12-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520125016M_closure letter_12052012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520125016M/520125016M_closure%20letter_12052012.pdf\n\n520125016M_closure letter_12052012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520125016M/520125016M_closure%20letter_12052012_text.pdf\n\n520125016M_notice of amendment_08092012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520125016M/520125016M_notice%20of%20amendment_08092012.pdf\n\n520125016M_notice of amendment_08092012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520125016M/520125016M_notice%20of%20amendment_08092012_text.pdf\n\n520125016M_operator response_11082012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520125016M/520125016M_operator%20response_11082012.pdf\n\n520125016M_closure letter_12052012_text.pdf\n\nVIA UPS GROUND: 1ZWR25880399056521\nDecember 5, 2012\nMr. Mike Joynor\nSenior Vice President of Operations\nAlyeska Pipeline Service Company\n900 East Benson Boulevard\nAnchorage, Alaska 99519\nCPF 5-2012-5016M\nDear Mr. Joynor:\nOn March 29, 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 (APSC)\nprocedures in Anchorage, Alaska. As a result of the inspection, PHMSA issued a Notice of\nAmendment on August 9, 2012, proposing amendment of your procedures.\nAPSC responded by letter dated November 8, 2012. APSC demonstrated that certain\nrequired procedures that the Notice identified as missing did exist at the time of the\ninspection, though APSC was unable to provide them at that time. Therefore, PHMSA\nwithdraws Items 2, 3, 9, and 19 from the Notice. In response to the other allegations, APSC\nsubmitted amended procedures. My staff has reviewed the amended procedures, and it\nappears that the inadequacies outlined in the Notice have been corrected.\nNo further action is necessary and this case is now closed. Thank you 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 (#133780)\n\n520125016M_notice of amendment_08092012_text.pdf\n\nNOTICE OF AMENDMENT\nVIA UPS GROUND - 1ZWR25880392703656\nAugust 9, 2012\nMr. Mike Joynor\nSenior Vice President of Operations\nAlyeska Pipeline Service Company\n3700 Centerpoint Drive\nAnchorage, Alaska 99503\nCPF 5-2012-5016M\nDear Mr. Joynor:\nFrom March 29 through April 1, 2011, 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 (APSC) procedures for Operations and\nMaintenance in Anchorage, Alaska.\nOn the basis of the inspection, PHMSA has identified the following apparent inadequacies\nfound within APSC’s plans and procedures, as described below:\n1. §195.52 Immediate notice of certain accidents.\n(a) Notice requirements. At the earliest practicable moment following\ndiscovery of a release of the hazardous liquid or carbon dioxide\ntransported resulting in an event described in § 195.50, the operator of\nthe system must give notice, in accordance with paragraph (b) of this\nsection, of any failure that:\n(1) Caused a death or a personal injury requiring hospitalization;\n(2) Resulted in either a fire or explosion not intentionally set by the\noperator;\n(3) Caused estimated property damage, including cost of cleanup and\nrecovery, value of lost product, and damage to the property of the\noperator or others, or both, exceeding $50,000;\n\n\n\nAPSC’s Operations Control Center (OCC) Procedure 3.02, Reporting Significant Events,\nstates that notice is required when there is “Estimated property damage to Alyeska or others\nof $50,000 or more” and does not list all of the factors in § 195.52(a)(3) that contribute to\ncost, such as cleanup and recovery. APSC must amend OCC Procedure 3.02 to include all\ncost factors.\n2. §195.55 Reporting Safety-Related Conditions:\n(a) Except as provided in paragraph (b) of this section, each operator\nshall report in accordance with §195.56 the existence of any of the\nfollowing safety-related conditions involving pipelines in service:\n(1) General corrosion that has reduced the wall thickness to less than that\nrequired for the maximum operating pressure, and localized corrosion\npitting to a degree where leakage might result.\n(2) Unintended movement or abnormal loading of a pipeline by\nenvironmental causes, such as an earthquake, landslide, or flood, that\nimpairs its serviceability.\n(3) Any material defect or physical damage that impairs the serviceability\nof a pipeline.\n(4) Any malfunction or operating error that causes the pressure of a\npipeline to rise above 110 percent of its maximum operating pressure.\n(5) A leak in a pipeline that constitutes an emergency.\n(6) Any safety-related condition that could lead to an imminent hazard\nand causes (either directly or indirectly by remedial action of the\noperator), for purposes other than abandonment, a 20 percent or more\nreduction in operating pressure or shutdown of operation of a pipeline.\n(b) A report is not required for any safety-related condition that—\n(1) Exists on a pipeline that is more than 220 yards (200 meters) from any\nbuilding intended for human occupancy or outdoor place of assembly,\nexcept that reports are required for conditions within the right-of-way of\nan active railroad, paved road, street, or highway, or that occur offshore\nor at onshore locations where a loss of hazardous liquid could reasonably\nbe expected to pollute any stream, river, lake, reservoir, or other body of\nwater;\n(2) Is an accident that is required to be reported under §195.50 or results\nin such an accident before the deadline for filing the safety-related\ncondition report; or\n(3) Is corrected by repair or replacement in accordance with applicable\nsafety standards before the deadline for filing the safety-related condition\nreport, except that reports are required for all conditions under\nparagraph (a)(1) of this section other than localized corrosion pitting on\nan effectively coated and cathodically protected pipeline.\nAPSC’s Procedural Manual for Operations, Maintenance, and Emergencies (OM-1),\nSection 3.2.2, Reporting Safety-Related Conditions, does not state that a report must be filed\nwhen general corrosion is found that has reduced the wall thickness to less than that required\nfor the maximum operating pressure, as required by § 195.55(b)(3). APSC must amend OM-\n1 Section 3.2.2 to include reporting of general corrosion.\n\n\n\n3. §195.120 Passage of internal inspection devices.\n(a) Except as provided in paragraphs (b) and (c) of this section, each new\npipeline and each line section of a pipeline where the line pipe, valve,\nfitting or other line component is replaced, must be designed and\nconstructed to accommodate the passage of instrumented internal\ninspection devices.\nAPSC’s OM-1, Appendix A, indicates that APSC compliance with 49 C.F.R § 195.120 can\nbe found in specification DB-180, “Design Basis Update,” but this specification does not\nprovide procedures requiring new construction to accommodate the passage of instrumented\ninternal inspection devices. APSC must show where compliance with 49 C.F.R § 195.120\ncan be found.\n4. §195.228 Welds and welding inspection: Standards of acceptability.\n(b) The acceptability of a weld is determined according to the standards\nin Section 9 of API 1104. However, if a girth weld is unacceptable under\nthose standards for a reason other than a crack, and if Appendix A to\nAPI 1104 (ibr, see § 195.3) applies to the weld, the acceptability of the\nweld may be determined under that appendix.\nAPSC’s OM-1, Appendix A, references procedure W300, Pipeline Fabrication, for welding\ninspection. Procedure W300 does not list the revision date of API 1104 as required by 49\nC.F.R § 195.3. APSC must list the correct edition of the API 1104 in their procedures.\n5. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline\nsystem a manual of written procedures for conducting normal operations\nand maintenance activities and handling abnormal operations and\nemergencies. This manual shall be reviewed at intervals not exceeding 15\nmonths, but at least once each calendar year, and appropriate changes\nmade as necessary to insure that the manual is effective. This manual\nshall be prepared before initial operations of a pipeline commence, and\nappropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\n(a) APSC’s OM-1, Section 1, Operations and Maintenance Manual Description, incorrectly\nstates “The United States Department of Transportation, Research and Special Programs\nAdministration, Office of Pipeline Safety (DOT/OPS), has jurisdiction over the pipeline\nsystem as it relates to the following processes.” APSC must amend its manual to indicate\nthat Pipeline and Hazardous Materials Safety Administration has jurisdiction over the\npipeline system.\n(b) APSC’s OM-1, Section 7.2, Corrosion Control Supervisor Knowledge states that review\nof the corrosion control procedures is required every two years. All APSC procedures,\nincluding the corrosion control procedures, must be reviewed at intervals not exceeding 15\nmonths, but at least once each calendar year.\n6. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by\n\n\n\nparagraph (a) of this section must include procedures for the following to\nprovide safety during maintenance and normal operations:\n(13) Periodically reviewing the work done by operator personnel to\ndetermine the effectiveness of the procedures used in normal operation\nand maintenance and taking corrective action where deficiencies are\nfound.\nAPSC’s OM-1, Appendix A, references AMS-001, Document Process as the implementing\ndocument for compliance with § 195.402(c)(13). During the inspection, APSC could not\nfind the requirement for periodically reviewing the work done by the operator personnel to\ndetermine the effectiveness of the procedures in AMS-001. APSC must show where\ncompliance with 49 C.F.R §195.402(c)(13) can be found.\n7. §195.403 Emergency Response Training.\n(b) At the intervals not exceeding 15 months, but at least once each\ncalendar year, each operator shall:\n(1) Review with personnel their performance in meeting the objectives of\nthe emergency response training program set forth in paragraph (a) of\nthis section; and\n(2) Make appropriate changes to the emergency response training\nprogram as necessary to ensure that it is effective.\na) APSC’s OM-1, Appendix A, references CP-35-1, Trans Alaska Pipeline System Pipeline\nOil Discharge Prevention and Contingency Plan as the implementing document for\ncompliance with § 195.403(b). APSC’s computer records indicate that the review cycle for\nCP-35-1 is every 5 years. APSC must amend this procedure to be reviewed once each\ncalendar year not to exceed 15 months.\nb) APSC’s OM-1, Appendix A does not reference APSC procedure EC-71 Emergency\nContingency Action Plans. APSC must include all procedures that address emergency\nresponse training in its list in OM-1.\n8. §195.406 Maximum operating pressure.\n(a) Except for surge pressures and other variations from normal\noperations, no operator may operate a pipeline at a pressure that exceeds\nany of the following:\na) APSC’s OM-1, Appendix A, references procedure OCC-2.07, Exceeded or Exceeding\nMaximum Operating Pressure (MOP) as the implementing document for compliance with §\n195.406. OCC-2.07 does not accurately describe how APSC determines their MOP. APSC\nmust amend its procedures to clearly indicate how their MOP is defined at all locations. The\ncriteria below have been utilized by APSC to determine MOP, but they are not included in\nprocedure OCC-2.07:\n1. On the suction side of a pump station, the hydraulic head from the closest upstream\npinch point is maintained constant up to the station.\n2. 3. De-rated as a result of corrosion, road crossings, dents, etc.\nThe design pressure of individual components such as flanges, valves, pumps etc., as\ndetermined by the applicable code or the manufacturer.\n\n\n\nb) APSC’s OM-1, Appendix A, references procedure OCC-2.07, Exceeded or Exceeding\nMaximum Operating Pressure (MOP) as the implementing document for compliance with §\n195.406. The procedure allows the operator to deviate from the procedure under certain very\nbroad circumstances such as “a risk” to equipment, personnel or property. The procedure\ndoes not define any parameters or guidelines to assess the risks or the magnitude of impact of\nthe risks to determine when deviation from the procedure is appropriate. The procedure also\ndoes not give any guidelines as to what actions should be taken if the procedure is to be\ndeviated from.\n9. §195.420 Valve maintenance.\n(b) Each operator shall, at intervals not exceeding 7½ months, but at\nleast twice each calendar year, inspect each mainline valve to determine\nthat it is functioning properly.\nAPSC could not show PHMSA procedures that require valves to be inspected not exceeding\n7½ months, but at least twice each calendar year. APSC must amend OM-1, Appendix A,\nand reference where the required procedures may be found.\n10. §195.420 Valve maintenance.\n(c) Each operator shall provide protection for each valve from\nunauthorized operation and from vandalism.\nAPSC could not show PHMSA documentation that requires protection from unauthorized\noperation or vandalism. Alyeska must amend OM-1, Appendix A, and reference where this\nrequired procedure may be found.\n11. §195.426 Scraper and sphere facilities.\nNo operator may use a launcher or receiver that is not equipped with a\nrelief device capable of safely relieving pressure in the barrel before\ninsertion or removal of scrapers or spheres. The operator must use a\nsuitable device to indicate that pressure has been relieved in the barrel or\nmust provide a means to prevent insertion or removal of scrapers or\nspheres if pressure has not been relieved in the barrel.\nAPSC’s OM-1 does not reference procedures for receiving and launching pigs from Pump\nStation 8 in a safe manner.\n12. §195.428 Overpressure safety devices and overfill protection systems.\n(a) Except as provided in paragraph (b) of this section, each operator\nshall, at intervals not exceeding 15 months, but at least once each\ncalendar year, or in the case of pipelines used to carry highly volatile\nliquids, at intervals not to exceed 7½ months, but at least twice each\ncalendar year, inspect and test each pressure limiting device, relief valve,\npressure regulator, or other item of pressure control equipment to\ndetermine that it is functioning properly, is in good mechanical condition,\nand is adequate from the standpoint of capacity and reliability of\noperation for the service in which it is used.\nAPSC’s OM-1 Table B.3 and Appendix A do not list all of APSC’s overpressure safety\n\n\n\ndevices to be checked annually nor does it list the procedures to perform these tasks. The\nfollowing are devices not listed:\n1) Kuparuk pressure transmitter 31-PT-013A (see CPF 5-2008-5002);\n2) Sadlerochit shut down pressure switches at GC-2, FS-1, and FS-3;\n3) Thermal relief valves;\n4) Break out tank over fill protection devices;\n5) Procedure for testing PS07 Shut down pressure switches; and\n6) RGV 36, 65, 98, 121 Pressure Transmitters.\nAPSC must amend OM-1, to include all overpressure safety devices and procedures to\nperform these tasks.\n13. §195.444 CPM leak detection.\nEach computational pipeline monitoring (CPM) leak detection system\ninstalled on a hazardous liquid pipeline transporting liquid in single\nphase (without gas in the liquid) must comply with API 1130 in operating,\nmaintaining, testing, record keeping, and dispatcher training of the\nsystem.\nAPSC’s OM-1, Appendix A, references CS-238, Control System Software Management and\nCS-238-1, UCOS SCADA Management as the implementing documents for compliance with\n§ 195.444. APSC could not find a reference to API 1130 in either CS238 or CS-238-1.\nAPSC must amend its procedures to indicate that APSC’s leak detection system meets API\n1130.\n14. §195.559 What coating material may I use for external corrosion control?\nCoating material for external corrosion control under §195.557 must--\n(a) Be designed to mitigate corrosion of the buried or submerged\npipeline;\n(b) Have sufficient adhesion to the metal surface to prevent under film\nmigration of moisture;\n(c) Be sufficiently ductile to resist cracking;\n(d) Have enough strength to resist damage due to handling and soil\nstress;\n(e) Support any supplemental cathodic protection; and\n(f) If the coating is an insulating type, have low moisture absorption and\nprovide high electrical resistance.\nAPSC’s OM-1, Appendix A, does not reference MR 48, Trans-Alaska Pipeline Maintenance\nand Repair Manual, Table 18.1, Pipe Coatings as the implementing document for\ncompliance with § 195.559. APSC must reference all appropriate procedures including MR\n48 in Appendix A.\n15. §195.561 When must I inspect pipe coating used for external corrosion control?\n(a) You must inspect all external pipe coating required by Sec. 195.557\njust prior to lowering the pipe into the ditch or submerging the pipe.\nAPSC could not locate a procedure that requires inspection of coating before lowering the\npipe into the ditch or submerging the pipe. APSC must reference or write a new procedure\nrequiring inspection of pipe coating prior to lowering the pipe into the ditch or submerging\n\n\n\nthe pipe.\n16. §195.561 When must I inspect pipe coating used for external corrosion control?\n(a) You must inspect all external pipe coating required by Sec. 195.557\njust prior to lowering the pipe into the ditch or submerging the pipe.\n(b) You must repair any coating damage discovered.\nAPSC’s OM-1, Appendix A, does not reference MR 48, Trans-Alaska Pipeline Maintenance\nand Repair Manual, Table 18.1, Pipe Coatings as the implementing document for\ncompliance with § 195.561. MR 48, Table 18.1 is the information APSC used to show that it\ncomplies with 49 C.F.R §195.561. Alyeska must reference MR 48 in Appendix A.\n17. §195.563 Which pipelines must have cathodic protection?\n(a) Each buried or submerged pipeline that is constructed, relocated,\nreplaced, or otherwise changed after the applicable date in Sec.\n195.401(c) must have cathodic protection. The cathodic protection must\nbe in operation not later than 1 year after the pipeline is constructed,\nrelocated, replaced, or otherwise changed, as applicable.\nAPSC’s OM-1, Appendix A, references MP-166-3.22, Pipeline Cathodic Protection System\nas the implementing document for compliance with § 195.563(a). MP-166-3.22 does not\nindicate that cathodic protection has to be installed within one year. APSC must indicate\nhow it complies with 49 C.F.R §195.563(a).\n18. §195.563 Which pipelines must have cathodic protection?\n(c) All other buried or submerged pipelines that have an effective\nexternal coating must have cathodic protection.(see Note below) Except as\nprovided by paragraph (d) of this section, this requirement does not\napply to breakout tanks and does not apply to buried piping in breakout\ntank areas and pumping stations until December 29, 2003.\nAPSC’s OM-1, Appendix A, references MP-166-3.22, Pipeline Cathodic Protection System\nas the implementing document for compliance with § 195.563(c). MP-166-3.22 does not\nindicate that cathodic protection has to be installed on effectively coated pipelines. APSC\nmust indicate how it complies with 49 C.F.R § 195.563(c).\n19. §195.567 Which pipelines must have test leads and what must I do to install and\nmaintain the leads?\n(a) General.\n(2) Provide enough looping or slack so backfilling will not unduly stress\nor break the lead and the lead will otherwise remain mechanically secure\nand electrically conductive.\n(b) Installation. You must install test leads as follows:\n(1) Locate the leads at intervals frequent enough to obtain electrical\nmeasurements indicating the adequacy of cathodic protection.\nAPSC’s OM-1, Appendix A, references MP-166-3.22, Pipeline Cathodic Protection System.\nMP-166-3.22 does not indicate that cathodic protection test leads have to be installed\nfrequently enough to obtain adequate and accurate electrical measurements of the CP, and\n\n\n\nthat test leads are afforded slack to prevent undue stress. APSC must indicate how it\ncomplies with 49 C.F.R §195.567.\n20. §195.583 What must I do to monitor atmospheric corrosion control?\n(a) You must inspect each pipeline or portion of pipeline that is exposed\nto the atmosphere for evidence of atmospheric corrosion, as follows:\nIf the pipeline is located: Onshore, Then the frequency of inspection is: At\nleast once every 3 calendar years, but with intervals not exceeding 39\nmonths\nAPSC could not provide a procedure for the frequency of atmospheric corrosion monitoring.\nASPC must demonstrate how it complies with 49 C.F.R §195.583(a).\n21. §195.583 What must I do to monitor atmospheric corrosion control?\n(c) If you find atmospheric corrosion during an inspection, you must\nprovide protection against the corrosion as required by §195.581.\nAPSC’s could not provide a procedure for what to do if atmospheric corrosion is discovered.\nAPSC must show how it complies with 49 C.F.R §195.583(c).\n22. §195.585 What must I do to correct corroded pipe?\n(a) General corrosion. If you find pipe so generally corroded that the\nremaining wall thickness is less than that required for the maximum\noperating pressure of the pipeline, you must replace the pipe. However,\nyou need not replace the pipe if you—\n(1) Reduce the maximum operating pressure commensurate with the\nstrength of the pipe needed for serviceability based on actual remaining\nwall thickness; or\n(2) Repair the pipe by a method that reliable engineering tests and\nanalyses show can permanently restore the serviceability of the pipe.\n(b) Localized corrosion pitting. If you find pipe that has localized\ncorrosion pitting to a degree that leakage might result, you must replace\nor repair the pipe, unless you reduce the maximum operating pressure\ncommensurate with the strength of the pipe based on actual remaining\nwall thickness in the pits.\nAPSC’s OM-1, Appendix A, references B-512, Pipeline Corrosion Evaluation Procedures as\nthe implementing document for compliance with § 195.585. B-512 does not discuss reducing\nthe pressure or repairing the pipe. APSC must amend OM-1 to state how it complies with 49\nC.F.R §195.585(a) and (b).\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 5-2012-\n5016M 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\ncc: PHP-60 Compliance Registry\nPHP-500 B. Flanders (#133780)\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings","truncated":false,"body_characters":25764}