{"operation":"document","citation":"CPF 520150014W","title":"ALASKA PIPELINE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-10-27","effective_on":null,"summary":"CLOSED warning letter citing 192.805(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520150014w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520150014w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520150014w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520150014W","body":"Warning Letter involving ALASKA PIPELINE CO. PHMSA's enforcement data identifies the cited regulation as 192.805(b). The case was opened on 2015-10-27 and is reported as closed as of 2015-10-27. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520150014W_warning letter_10272015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150014W/520150014W_warning%20letter_10272015.pdf\n\n520150014W_Warning Letter_10272015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150014W/520150014W_Warning%20Letter_10272015_text.pdf\n\n520150014W_Warning Letter_10272015_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 27, 2015\nMr. Jared Green\nPresident\nAlaska Pipeline Company\nP.O. Box 190288\nAnchorage, AK 99519-0288\nCPF 5-2015-0014W\nDear Mr. Green:\nOn April 7 and 15, 2015, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\nBeluga River Horizontal Directional Drilling (HDD) Project on the West Side of Cook Inlet,\nAlaska.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, U.S. Code of Federal Regulations. The items inspected\nand the probable violation is:\n1. §192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n…\nqualified;\n…\n(b) Ensure through evaluation that individuals performing covered tasks are\n\n\n\nAlaska Pipeline Company (APC) failed to ensure that the individuals who performed the visual\ninspection and radiographic testing of field girth welds for the Beluga River HDD Project were\nqualified to perform the covered task. The Beluga River HDD Project included an in-kind\nreplacement of an exposed Beluga Pipeline section at the Beluga River crossing and, as such, it\nwas a maintenance activity. The OQ records provided by APC for the individuals performing\nthe visual inspection and radiographic testing were inadequate, in part, because they did not\naddress the recognition and reaction to abnormal operating conditions, and were not reviewed\nand approved by APC prior to the covered tasks being performed. APC failed to ensure that\nindividuals performing covered tasks were qualified.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item identified in this letter.\nFailure to do so will result in APC being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2015-0014W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document, you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nFor Chris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 T. Johnson (150056)\n2","truncated":false,"body_characters":3938}