{"operation":"document","citation":"CPF 520175017W","title":"KUPARUK TRANSPORTATION CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-07-07","effective_on":null,"summary":"CLOSED warning letter citing 195.581(a), 195.583(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520175017w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520175017w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520175017w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520175017W","body":"Warning Letter involving KUPARUK TRANSPORTATION CO. PHMSA's enforcement data identifies the cited regulations as 195.581(a),  195.583(b). The case was opened on 2017-07-07 and is reported as closed as of 2017-07-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520175017W_Operator Response to Notice_08162017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175017W/520175017W_Operator%20Response%20to%20Notice_08162017.pdf\n\n520175017W_Warning Letter_07072017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175017W/520175017W_Warning%20Letter_07072017.pdf\n\n520175017W_Warning Letter_07072017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175017W/520175017W_Warning%20Letter_07072017_text.pdf\n\n520175017W_Warning Letter_07072017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 7, 2017\nMr. Scott Jepsen\nPresident\nKuparuk Transportation Company\n700 G Street\nAnchorage, Alaska 99501\nCPF 5-2017-5017W\nDear Mr. Jepsen:\nOn August 22 – 24 and September 1, 2016, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\ninspected your Kuparuk Oil Pipeline on the Alaskan North Slope and related documents in\nAnchorage, Alaska.\nAs a result of the inspection, it is alleged 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. §195.583 What must I do to monitor atmospheric corrosion control?\n(b) During inspections you must give particular attention to pipe at soil-to-air\ninterfaces, under thermal insulation, under disbonded coatings, at pipe supports, in\nsplash zones, at deck penetrations, and in spans over water.\nPHMSA representatives performed a visual field inspection for atmospheric corrosion on the\nappurtenances on the breakout tank Divert Tank A at Central Processing Facility Two. The\ninspection of valves, flanges, and other devices appurtenant to Divert Tank A, revealed oxidization\n\n\n\nand incipient pitting corrosion in several places. Inspection records provided by Kuparuk\nTransportation Company (2015 API 570 Inspection) failed to note even oxidation of uncoated\nsurfaces for the tank appurtenances, nor any scaling or pitting. Additional historic atmospheric\ninspection records, the Three Year Atmospheric Corrosion Inspection Locations Spreadsheet, for\nthe Divert Tank A appurtenances failed to note the oxidation, scaling, or pitting as seen during\nPHMSA's field inspection. The records provided by Kuparuk Transportation Company for\natmospheric corrosion were inconsistent with PHMSA’s visual inspection and are insufficient to\nmeet the criteria of §195.583.\n2. §195.581 Which pipelines must I protect against atmospheric corrosion and what\ncoating material may I use?\n(a) You must clean and coat each pipeline or portion of pipeline that is exposed to the\natmosphere, except pipelines under paragraph (c) of this section.\nA visual field inspection for atmospheric corrosion was performed on the appurtenances on\nKuparuk Transportation Company’s breakout tank Divert Tank A at Central Processing Facility\nTwo. Inspection of valves, flanges, and other devices appurtenant to Divert Tank A, including some\ninspected after removal of non-permanent insulated covers, revealed uncoated or poorly coated\nfacilities with incipient pitting corrosion in numerous places.\nAs of April 27, 2017, under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil\npenalty not to exceed $209,002 per violation per day the violation persists up to a maximum of\n$2,090,022 for a related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement action or\npenalty assessment proceedings at this time. Failure to do so will result in Kuparuk Transportation\nCompany 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 5-2017-5017W. 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 the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nHuy Nguyen\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 H. Marlowe/J. Owens (#153684)","truncated":false,"body_characters":4875}