# ALASKA PIPELINE CO — Notice of Amendment

- **operation:** document
- **citation:** CPF 520160002M
- **title:** ALASKA PIPELINE CO — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2016-03-16
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 192.605(b)(1), 192.605(b)(5), 192.605(b)(8).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520160002m.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520160002m.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520160002m
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520160002M
**body:**

Notice of Amendment involving ALASKA PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(1),  192.605(b)(5),  192.605(b)(8). The case was opened on 2016-03-16 and is reported as closed as of 2016-04-27. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520160002M_Closure Letter_04272016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160002M/520160002M_Closure%20Letter_04272016.pdf

520160002M_Closure Letter_04272016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160002M/520160002M_Closure%20Letter_04272016_text.pdf

520160002M_Notice of Amendment_03162016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160002M/520160002M_Notice%20of%20Amendment_03162016.pdf

520160002M_Notice of Amendment_03162016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160002M/520160002M_Notice%20of%20Amendment_03162016_text.pdf

520160002M_Operator Response to Notice_04042016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160002M/520160002M_Operator%20Response%20to%20Notice_04042016.pdf

520160002M_Closure Letter_04272016_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
April 27, 2016
Mr. Jared Green
President
Alaska Pipeline Company
3000 Spenard Road
Anchorage, AK 99518
CPF 5-2016-0002M
Dear Mr. Green,
Between October 27, 2014 and January 8, 2015, representatives from the Pipeline and
Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United
States Code, conducted an on-site pipeline safety inspection of Alaska Pipeline Company
(APC) procedures in Anchorage, Alaska. As a result of the inspection, APC was issued a
Notice of Amendment (NOA) on March 16, 2016, which proposed amendment of your
procedures.
Alaska Pipeline Company submitted its amended procedures on April 4, 2016, which were
received by PHMSA on April 13, 2016. My staff reviewed the amended procedures and it
appears that the inadequacies outlined in this NOA have been corrected.
This letter is to inform you no further action is necessary and this case is now closed
Sincerely,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 Johnson (#147583)

520160002M_Notice of Amendment_03162016_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
March 16, 2016
Mr. Jared Green
President
Alaska Pipeline Company
3000 Spenard Road
Anchorage, AK 99518
CPF 5-2016-0002M
Dear Mr. Green:
Between October 27, 2014 and January 8, 2015, representatives of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,
inspected Alaska Pipeline Company (APC) procedures for operations and maintenance in
Anchorage, Alaska.
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
APC’s plans or procedures, as described below:
1. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(b) Maintenance and normal operations. The manual required by paragraph (a) of
this section must include procedures for the following, if applicable, to provide
safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in accordance with each of
the requirements of this subpart and subpart M of this part.



At the time of the inspection, APC did not provide a procedure for determining the maximum
allowable operating pressure in accordance with § 192.619 Maximum allowable operating
pressure: Steel or plastic pipelines. A procedure for determining the maximum allowable
operating pressure in accordance with 49 C.F.R. Part 192, subpart L, § 192.619 is required by
§ 192.605(b)(1).
2. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(b) Maintenance and normal operations. The manual required by paragraph (a) of
this section must include procedures for the following, if applicable, to provide
safety during maintenance and operations.
(5) Starting up and shutting down any part of the pipeline in a manner designed to
assure operation within the MAOP limits prescribed by this part, plus the build-up
allowed for operation of pressure-limiting and control devices.
At the time of the inspection, APC did not provide a procedure for starting up and shutting down
any part of the pipeline in a manner designed to assure operation within the MAOP limits
prescribed by this part, plus the build-up allowed for operation of pressure-limiting and control
devices.
3. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(b) Maintenance and normal operations. The manual required by paragraph (a) of
this section must include procedures for the following, if applicable, to provide
safety during maintenance and operations.
(8) Periodically reviewing the work done by operator personnel to determine the
effectiveness, and adequacy of the procedures used in normal operation and
maintenance and modifying the procedures when deficiencies are found.
Alaska Pipeline Company did not modify its procedure manual of operations, maintenance, and
emergencies as recommended by its investigation of a near miss occurrence. An APC letter
dated May 10, 2011, Subject: "Recommended modifications to ENSTAR/APC procedures to
enhance Contractor Safety working around Transmission Lines" contained several
recommendations for modifications to company protocols and Standard Operating Procedures.
These recommendations were a result of an APC investigation regarding a near miss which was
discovered by APC on April 28, 2011. At the time of the PHMSA's inspection the Standard
Operating Procedures had not been modified as recommended.



Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed as
part of this Notice is a document entitled Response Options for Pipeline Operators in
Compliance Proceedings. Please refer to this document and note the response options. 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). If you do not respond within 30 days
of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this
Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in
this Notice without further notice to you and to issue a Final Order.
If, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in
this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies
(49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that you submit your
amended procedures to my office within 45 days of receipt of this Notice. This period may be
extended by written request for good cause. Once the inadequacies identified herein have been
addressed in your amended procedures, this enforcement action will be closed.
It is requested (not mandated) that APC maintain documentation of the safety improvement costs
associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures)
and submit the total to Chris Hoidal, Director, Western Region, Pipeline and Hazardous
Materials Safety Administration. In correspondence concerning this matter, please refer to
CPF 5-2016-0002M and, for each document you submit, please provide a copy in electronic
format whenever possible.
Sincerely,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
cc: PHP-60 Compliance Registry
PHP-500 Johnson (#147583)
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