# ALASKA PIPELINE CO — Warning Letter

- **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:** Not available
- **summary:** CLOSED warning letter citing 192.805(b).
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- **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.

Official case documents:

520150014W_warning letter_10272015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150014W/520150014W_warning%20letter_10272015.pdf

520150014W_Warning Letter_10272015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150014W/520150014W_Warning%20Letter_10272015_text.pdf

520150014W_Warning Letter_10272015_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
October 27, 2015
Mr. Jared Green
President
Alaska Pipeline Company
P.O. Box 190288
Anchorage, AK 99519-0288
CPF 5-2015-0014W
Dear Mr. Green:
On April 7 and 15, 2015, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your
Beluga River Horizontal Directional Drilling (HDD) Project on the West Side of Cook Inlet,
Alaska.
As a result of the inspection, it appears that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, U.S. Code of Federal Regulations. The items inspected
and the probable violation is:
1. §192.805 Qualification program.
Each operator shall have and follow a written qualification program. The program
shall include provisions to:
…
qualified;
…
(b) Ensure through evaluation that individuals performing covered tasks are



Alaska Pipeline Company (APC) failed to ensure that the individuals who performed the visual
inspection and radiographic testing of field girth welds for the Beluga River HDD Project were
qualified to perform the covered task. The Beluga River HDD Project included an in-kind
replacement of an exposed Beluga Pipeline section at the Beluga River crossing and, as such, it
was a maintenance activity. The OQ records provided by APC for the individuals performing
the visual inspection and radiographic testing were inadequate, in part, because they did not
address the recognition and reaction to abnormal operating conditions, and were not reviewed
and approved by APC prior to the covered tasks being performed. APC failed to ensure that
individuals performing covered tasks were qualified.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000
per violation per day the violation persists up to a maximum of $2,000,000 for a related series of
violations. For violations occurring prior to January 4, 2012, the maximum penalty may not
exceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a
related series of violations. We have reviewed the circumstances and supporting documents
involved in this case, and have decided not to conduct additional enforcement action or penalty
assessment proceedings at this time. We advise you to correct the item identified in this letter.
Failure to do so will result in APC being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 5-2015-0014W. Be advised that all material you submit in response to this enforcement
action is subject to being made publicly available. If you believe that any portion of your
responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the
complete original document, you must provide a second copy of the document with the portions
you believe qualify for confidential treatment redacted and an explanation of why you believe
the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).
Sincerely,
For Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 T. Johnson (150056)
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