{"operation":"document","citation":"CPF 520160003W","title":"ALASKA PIPELINE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-03-16","effective_on":null,"summary":"CLOSED warning letter citing 192.491(c), 192.517(a), 192.945(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520160003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520160003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520160003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520160003W","body":"Warning Letter involving ALASKA PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 192.491(c),  192.517(a),  192.945(a). The case was opened on 2016-03-16 and is reported as closed as of 2016-03-16. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520160003W_Warning Letter_03162016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160003W/520160003W_Warning%20Letter_03162016.pdf\n\n520160003W_Warning Letter_03162016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160003W/520160003W_Warning%20Letter_03162016_text.pdf\n\n520160003W_Warning Letter_03162016_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 16, 2016\nMr. Jared Green\nPresident\nAlaska Pipeline Company\n3000 Spenard Road\nAnchorage, AK 99518\nCPF 5-2016-0003W\nDear Mr. Green:\nBetween October 27, 2014 and January 8, 2015, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\ninspected Alaska Pipeline Company’s (APC) Beluga Pipeline system in the Anchorage, Kenai\nPeninsula, and Matanuska-Susitna Boroughs, Alaska.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n1. § 192.491 Corrosion control records.\n(c) Each operator shall maintain a record of each test, survey, or inspection\nrequired by this subpart in sufficient detail to demonstrate the adequacy of\ncorrosion control measures or that a corrosive condition does not exist. These\nrecords must be retained for at least 5 years, except that records related to §§\n192.465 (a) and (e) and 192.475(b) must be retained for as long as the pipeline\nremains in service.\n\n\n\nAt the time of PHMSA’s inspection, Alaska Pipeline Company did not have a record of the\nexamination of all of buried pipe when exposed. Pursuant to § 192.459 External corrosion\ncontrol: Examination of buried pipeline when exposed, whenever an operator has knowledge that\nany portion of a buried pipeline is exposed, the exposed portion must be examined. Pursuant to\n§ 192.491 Corrosion control records, exposed pipe examination reports must be maintained. At\nthe time of PHMSA’s initial request (between October 27 and November 17, 2014) for exposed\npipe examination reports related to the MP39 Pipeline Lowering Project and MEA Eklutna\nLateral Hot Tap Project, APC was unable to provide such reports. Both projects were conducted\nin September 2013. Subsequent to APC’s initial failure to provide the requested reports, APC\nprovided the requested exposed pipe examination reports. The provided exposed pipe\nexamination reports were dated between November 21-26, 2014, after PHMSA’s initial request\nand over one year after the projects were completed. Although the requested records were\neventually provided, they were not completed in a timely manner to demonstrate the adequacy of\nexternal corrosion control measures at the time of pipe examination.\n2. § 192.491 Corrosion control records.\n(c) Each operator shall maintain a record of each test, survey, or inspection\nrequired by this subpart in sufficient detail to demonstrate the adequacy of\ncorrosion control measures or that a corrosive condition does not exist. These\nrecords must be retained for at least 5 years, except that records related to §§\n192.465 (a) and (e) and 192.475(b) must be retained for as long as the pipeline\nremains in service.\nAt the time of PHMSA’s inspection, Alaska Pipeline Company did not have a record of the\ninspection of internal surfaces of all pipe removed from a pipeline. Pursuant to § 192.475\nInternal corrosion control: General, whenever any pipe is removed from a pipeline for any\nreason, the internal surface must be inspected for evidence of corrosion. Pursuant to § 192.491\nCorrosion control records, internal pipe inspection reports must be maintained. At the time of\nPHMSA’s initial request (between October 27 and November 17, 2014) for internal pipe\ninspection reports related to the MP39 Pipeline Lowering Project, MEA Lateral Hot Tap Project,\nand Vine Rd Third Party Damage incident, APC was unable to provide such reports. The MP39\nPipeline Lowering Project and MEA Lateral Hot Tap Project were conducted in September 2013.\nThe Vine Rd Third Party Damage incident occurred in June 2014. Subsequent to APC’s initial\nfailure to provide the requested reports, APC provided the requested internal pipe inspection\nreports. The provided internal pipe inspection reports were dated between November 21-26,\n2014, after PHMSA’s initial request. The Vine Rd Third Party Damage incident internal pipe\ninspection report was completed over 5 months after the incident. The MP39 Pipeline Lowering\nProject and MEA Lateral Hot Tap Project internal inspection reports were completed over one\nyear after the respective projects were completed. Although the requested records were\neventually provided, they were not completed in a timely manner to demonstrate the adequacy of\ninternal corrosion measures at the time of pipe removal.\n\n\n\n3. § 192.517 Records.\n(a) Each operator shall make, and retain for the useful life of the pipeline, a record\nof each test performed under §§ 192.505 and 192.507. The record must contain at\nleast the following information:\n(1) The operator's name, the name of the operator's employee responsible for\nmaking the test, and the name of any test company used.\n(2) Test medium used.\n(3) Test pressure.\n(4) Test duration.\n(5) Pressure recording charts, or other record of pressure readings.\n(6) Elevation variations, whenever significant for the particular test.\n(7) Leaks and failures noted and their disposition.\nAt the time of PHMSA’s inspection, Alaska Pipeline Company did not have a complete record of\nthe pressure test performed on the MEA Eklutna Lateral. When initially requested by PHMSA,\nAPC provided a pressure test record for the MEA Eklutna Lateral which consisted of a\npressure/temperature chart and a Certificate of Conformance Calibration for a\npressure/temperature recorder. The initial pressure test record provided lacked the following\ninformation: date test was performed, operator's name, operator's employee responsible for\nmaking the test, name of any test company used, and test medium used. In addition, the\nCertificate of Conformance Calibration initially provided for the pressure/temperature recorder\ndid not match the recorder information documented on the pressure/temperature chart. As a\nresult of PHMSA's inspection the operator modified the pressure testing record for the MEA\nEklutna Lateral. The pressure test was conducted on September 5, 2013 and the modified\npressure test record was completed on October 30, 2014. The pressure test record was\ncompleted over 1 year after the pressure test was conducted and, as such, was not adequate at the\ntime of our inspection.\n4. § 192.945 What methods must an operator use to measure program effectiveness?\n(a) General. An operator must include in its integrity management program\nmethods to measure whether the program is effective in assessing and evaluating the\nintegrity of each covered pipeline segment and in protecting the high consequence\nareas. These measures must include the four overall performance measures\nspecified in ASME/ANSI B31.8S (incorporated by reference, see § 192.7 of this\npart), section 9.4, and the specific measures for each identified threat specified in\nASME/ANSI B31.8S, Appendix A. An operator must submit the four overall\nperformance measures as part of the annual report required by § 191.17 of this\nsubchapter.\nAlaska Pipeline Company did not adequately measure its integrity management program\neffectiveness. Section 10 of APC’s Integrity Management Plan states that the Performance\nTracking Spreadsheet is used for documentation of the integrity management plan performance\ndata. Alaska Pipeline Company provided a Performance Tracking Spreadsheet dated October 6,\n2014 as evidence of measuring the integrity management program effectiveness, indicated that\n\n\n\nthe spreadsheet was under development, and acknowledged that the for the most part the\nspreadsheet was not populated. Without meaningful integrity management plan performance\ndata, APC has failed to adequately demonstrate the effectiveness of their integrity management\nprogram.\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 items 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 5-2016-0003W. 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,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 Johnson (#147583)","truncated":false,"body_characters":10068}