{"operation":"document","citation":"CPF 520175020W","title":"ALYESKA PIPELINE SERVICE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-08-10","effective_on":null,"summary":"CLOSED warning letter citing 195.402(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520175020w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520175020w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520175020w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520175020W","body":"Warning Letter involving ALYESKA PIPELINE SERVICE CO. PHMSA's enforcement data identifies the cited regulation as 195.402(a). The case was opened on 2017-08-10 and is reported as closed as of 2017-08-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520175020W_Warning Letter_08102017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175020W/520175020W_Warning%20Letter_08102017.pdf\n\n520175020W_Warning Letter_08102017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175020W/520175020W_Warning%20Letter_08102017_text.pdf\n\n520175020W_Warning Letter_08102017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 10, 2017\nMr. Thomas Barrett\nPresident & CEO\nAlyeska Pipeline Service Company\nPO Box 196660\nAnchorage, AK 99519\nCPF 5-2017-5020W\nDear Mr. Barrett:\nOn November 3, 2016, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\nAlyeska Pipeline Service Company (APSC) facilities located at Pump Station Number Nine,\n11 miles south of Delta Junction, Alaska on the Richardson Highway.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item\ninspected and the probable violation is:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and\nmaintenance activities and handling abnormal operations and emergencies. This\nmanual shall be reviewed at intervals not exceeding 15 months, but at least once\neach calendar year, and appropriate changes made as necessary to insure that\nthe manual is effective. This manual shall be prepared before initial operations of\n\n\n\na pipeline system commence, and appropriate parts shall be kept at locations\nwhere operations and maintenance activities are conducted.\nDuring the records review of quarterly tank inspection tasks completed for Pump Station Nine\ncrude relief tank, TK-190, it became evident that the Third Quarter 2016 inspection was not\nconducted in accordance with APSC Safe Operating Procedure 3.5.17 (Procedure). The\nSeptember 2016 APSC work order #161022976 reflects that no tank level measurements were\nrecorded as required by the Procedure.\nA review of the previous and the subsequent inspections verified that the Third Quarter 2016\ninspection documentation error was a singular occurrence and was not a systemic or recurring\nissue. The subsequent inspection was conducted and recorded per the APSC Procedure.\nAs of April 27, 2017, under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a\ncivil penalty not to exceed $209,002 per violation per day the violation persists up to a\nmaximum of $2,090,022 for a related series of violations. We have reviewed the\ncircumstances and supporting documents involved in this case, and have decided not to\nconduct additional enforcement action or penalty assessment proceedings at this time. We\nadvise you to correct the item identified in this letter. Failure to do so will result in Alyeska\nPipeline Service Company 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 5-2017-5020W. 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,\nKim West\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 M. Chard (#153634)\nMr. Rod Hanson, Sr. Vice-President, Operations & Maintenance, Alyeska\n2","truncated":false,"body_characters":4253}