{"operation":"document","citation":"CPF 520176030W","title":"CONOCOPHILLIPS ALASKA, INC. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-08-15","effective_on":null,"summary":"CLOSED warning letter citing 195.581, 195.583.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520176030w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520176030w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520176030w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520176030W","body":"Warning Letter involving CONOCOPHILLIPS ALASKA, INC.. PHMSA's enforcement data identifies the cited regulations as 195.581,  195.583. The case was opened on 2017-08-15 and is reported as closed as of 2017-08-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520176030W_Operator Response To Notice_10112017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176030W/520176030W_Operator%20Response%20To%20Notice_10112017.pdf\n\n520176030W_Warning Letter_08152017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176030W/520176030W_Warning%20Letter_08152017.pdf\n\n520176030W_Warning Letter_08152017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176030W/520176030W_Warning%20Letter_08152017_text.pdf\n\n520176030W_Warning Letter_08152017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 15, 2017\nMr. Joseph Marushack\nPresident\nConocoPhillips Alaska, Inc.\n700 G Street\nP.O. Box 100360\nAnchorage, Alaska 99501\nCPF 5-2017-6030W\nDear Mr. Marushack:\nOn August 17 through 19 and August 29 through 31, 2016, representatives of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code, inspected your Alpine Diesel Pipeline on the Alaskan North Slope and related\ndocuments in Anchorage, 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 (CFR). The items\ninspected and the probable violations are:\n\n\n\n1. §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\nthe atmosphere, except pipelines under paragraph (c) of this section.\n(b) Coating material must be suitable for the prevention of atmospheric\ncorrosion.\n(c) Except portions of pipelines in offshore splash zones or soil -to-air interfaces,\nyou need not protect against atmospheric corrosion any pipeline for which you\ndemonstrate by test, investigation, or experience appropriate to the environment\nof the pipeline that corrosion will-\n(1) Only be a light surface oxide; or\n(2) Not affect the safe operation of the pipeline before the next scheduled\ninspection.\nConocoPhillips Alaska, Inc. (CPAI) did not provide records demonstrating that its Alpine\nDiesel Pipeline was protected from atmospheric corrosion. CPAI produced a March 2, 2013\nAPI inspection report, including inspection of atmospheric corrosion, which stated that the\npipeline was “showing signs of external scale due to oxidation.” The subsequent 2016 API\n570 inspection report stated nothing about external corrosion. Visual inspection of the\nuncoated Alpine Diesel Pipeline at the Colville River crossing revealed significant scaling and\npitting corrosion, not a light surface oxide. No records provided by CPAI demonstrated by\ntest, investigation, or experience appropriate to the environment of the pipeline that corrosion\nwas only a light surface oxide or did not affect the safe operation of the pipeline before the\nnext scheduled inspection.\n2. §195.583 What must I do to monitor atmospheric corrosion control?\n(a) You must inspect each pipeline or portion of pipeline that is exposed to the\natmosphere for evidence of atmospheric corrosion, as follows:\nIf the pipeline is located: Onshore Then the frequency of inspection is: At least\nonce every 3 calendar years, but with intervals not exceeding 39 months.\nIf the pipeline is located: Offshore Then the frequency of inspection is: At least\nonce each calendar year, but with intervals not exceeding 15 months.\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,\nin splash zones, at deck penetrations, and in spans over water.\n(c) If you find atmospheric corrosion during an inspection, you must provide\nprotection against the corrosion as required by §195.581.\nCPAI provided a March 2, 2013 record of an API 570 inspection, including inspection of\natmospheric corrosion, which stated that the Alpine Diesel Pipeline “was showing signs of\nexternal scale due to oxidation.” The succeeding January 2016 API 570 inspection report was\nsilent about external corrosion. Additionally, CPAI’s API 570 Checklist Inspection Report\nform does not include provisions for looking at uncoated or covered/insulated parts of the\npipeline facilities. Visual inspections of the Alpine Diesel Pipeline by PHMSA\n2\n\n\n\nrepresentatives confirm that oxidation is present, as well as scaling and pitting. For the\nreasons stated above, the operator's 2016 atmospheric inspection is not sufficient to satisfy\n§195.583.\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(s) identified in this letter. Failure to do so will result in CPAI\nbeing subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2017-6030W. 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 H. Marlowe/J. Owens (#153689)\n3","truncated":false,"body_characters":6211}