{"operation":"document","citation":"CPF 520155010W","title":"ALYESKA PIPELINE SERVICE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-05-20","effective_on":null,"summary":"CLOSED warning letter citing 195.404(c)(3), 195.420(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520155010w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520155010w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520155010w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520155010W","body":"Warning Letter involving ALYESKA PIPELINE SERVICE CO. PHMSA's enforcement data identifies the cited regulations as 195.404(c)(3),  195.420(a). The case was opened on 2015-05-20 and is reported as closed as of 2015-05-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520155010W_Operator_Response_to_Notice_07172015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155010W/520155010W_Operator_Response_to_Notice_07172015.pdf\n\n520155010W_warning letter_05202015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155010W/520155010W_warning%20letter_05202015.pdf\n\n520155010W_warning letter_05202015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155010W/520155010W_warning%20letter_05202015_text.pdf\n\n520155010W_warning letter_05202015_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 20, 2015\nMr. Tom Barrett\nPresident\nAlyeska Pipeline Service Company\n3700 Centerpoint Drive\nAnchorage, AK 99503\nCPF 5-2015-5010W\nDear Mr. Barrett:\nOn February 2, 2015, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\ntemporary direct-fired heater installation (Project F 857) at RGV-65 which is located\napproximately eighty miles north of Fairbanks, Alaska, and near the villages of Livengood\nand Manley Hot Springs, Alaska. By our letter dated February 11, 2015, PHMSA requested\nspecific design, operation, and maintenance information for this heater installation.\nAs a result of the inspection and examination of requested information, it appears that you\nhave committed probable violations of the Pipeline Safety Regulations, Title 49, Code of\nFederal Regulations (CFR), Part 195. The items inspected and the probable violations are:\n\n\n\n1. §195.404 Maps and Records.\n(c) Each operator shall maintain the following records for the periods specified;\n(3) A record of each inspection and test required by this subpart shall be\nmaintained for at least 2 years or until the next inspection or test is performed,\nwhichever is longer.\nAlyeska did not maintain maps and records per §195.404 (c)(3). Each pipeline operator must\nmaintain a record for each inspection or test required by this subpart [Subpart F- Operations\nand Maintenance] for at least two (2) years or until the next inspection or test is performed,\nwhichever is longer. No records for the 6-inch bypass valve used for the direct-fire heater\ncould be provided to demonstrate compliance with §195.420 Valve Maintenance as stated in\nAlyeska’s government letter No. 32241, dated March 14, 2014 (sic). At a minimum, a record\nshowing what maintenance and testing were performed on the valve to indicate it is fit-for-\nservice prior to installation into the pipeline system should be maintained. This is of\nparticular importance when equipment, such as a valve, is routinely swapped in and out of\nservice over an extended period of time.\nRegulation §195.420(a) states that “Each operator shall maintain each valve that is necessary\nfor the safe operation of its pipeline systems in good working order at all times.” The\nreferenced bypass valve has been used by Alyeska off and on over several years. Alyeska\nrepresentatives stated that they do maintain the valves in storage, but had no records of where\nand when they inspected and maintained this valve while it was located either in service or in\nthe company’s storage yard prior to installing it into the mainline valve by-pass assembly.\n2. §195.420 Valve maintenance.\n(a) Each operator shall maintain each valve that is necessary for the safe\noperation of its pipeline systems in good working order at all times.\nAlyeska was not maintaining all valves needed for the safe operation of their pipeline,\nspecifically a critical valve at the temporary pipeline facilities near RGV-65 during the winter\nof 2014/2015. Alyeska was using a temporary inline heater to warm a slip stream of crude oil\nfrom the Trans-Alaska Pipeline System (TAPS) and then re-injecting the heated crude back\ninto the TAPS system. This was being done in order to maintain the crude oil temperature in\nthe mainline at forty (40) degrees Fahrenheit. Our representative observed that the fuel flow\ncontrol valve, V-LRS-BF, was forced open with a pair of vice grips to prevent the valve from\ninadvertently closing. The valve being maintained in the full open position and inoperable as\ndesigned.\nDiscussion with Alyeska’s onsite contractor representatives, Little Red Services, Inc., and\nHouston Contracting Company, confirmed that they were in fact disabling the control valve\noperation because it had been tripping “off” when not intended. The valve was intended to\ntrip off when the heater trailer shifted, burners got to hot or when power was lost to the trailer.\n2\n\n\n\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the maximum\npenalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a 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 item(s) identified in this letter. Failure to do so will result in Alyeska Pipeline Services\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 5-2015-5010W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 Jeff Gilliam (#138252)\n3","truncated":false,"body_characters":6452}