{"operation":"document","citation":"CPF 520180014M","title":"ALYESKA PIPELINE SERVICE CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-12-27","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(5), 192.631(h)(1), 192.909(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520180014m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520180014m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520180014m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520180014M","body":"Notice of Amendment involving ALYESKA PIPELINE SERVICE CO. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(5),  192.631(h)(1),  192.909(b). The case was opened on 2018-12-27 and is reported as closed as of 2019-02-11. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520180014M_Closure Letter_02112019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520180014M/520180014M_Closure%20Letter_02112019.pdf\n\n520180014M_Closure Letter_02112019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520180014M/520180014M_Closure%20Letter_02112019_text.pdf\n\n520180014M_Notice of Amendment_12272018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520180014M/520180014M_Notice%20of%20Amendment_12272018.pdf\n\n520180014M_Notice of Amendment_12272018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520180014M/520180014M_Notice%20of%20Amendment_12272018_text.pdf\n\n520180014M_Operator Response to Notice_01282019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520180014M/520180014M_Operator%20Response%20to%20Notice_01282019.pdf\n\n520180014M_Notice of Amendment_12272018_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 27, 2018\nMr. Thomas Barrett\nPresident and CEO\nAlyeska Pipeline Service Company\nPO Box 196660\nAnchorage, AK 99519\nCPF 5-2018-0014M\nDear Mr. Barrett:\nOn multiple occasions between April 24, 2017 and March 16, 2018, a representative of the Pipeline\nand Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code, inspected Alyeska Pipeline Service Company’s Fuel Gas Line procedures for\noperations and maintenance in Anchorage, Alaska.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nAlyeska Pipeline Service Company’s plans or procedures, as described below:\n\n\n\n1. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n…\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n…\n(5) Starting up and shutting down any part of the pipeline in a manner designed to\nassure operation within the MAOP limits prescribed by this part, plus the build-up\nallowed for operation of pressure-limiting and control devices.\nThe Operator’s OCC 2.15 Department Operating Procedures, Fuel Gas Line and Facility\nSection does not explicitly require keeping the pressure within the limits of the Maximum\nAllowable Operating Pressure upon startup and shutdown as required by § 192.605(b)(5).\n2. § 192.631 Control room management\n…\n(h) Training. Each operator must establish a controller training program and\nreview the training program content to identify potential improvements at least\nonce each calendar year, but at intervals not to exceed 15 months. An operator's\nprogram must provide for training each controller to carry out the roles and\nresponsibilities defined by the operator. In addition, the training program must\ninclude the following elements:\n(1) Responding to abnormal operating conditions likely to occur simultaneously or\nin sequence.\nThe Operator’s Operations Control Center Fuel Gas Line and Facility Operations, Section 2.15\nFuel Gas Line and Facility Operations document does not mention simultaneous or sequential\nabnormal operating conditions as required by § 192.631(h)(1).\n3. § 192.909 How can an operator change its integrity management program?\n…\n(b) Notification. An operator must notify OPS, in accordance with §192.949, of any\nchange to the program that may substantially affect the program's implementation\nor may significantly modify the program or schedule for carrying out the program\nelements. An operator must also notify a State or local pipeline safety authority\nwhen either a covered segment is located in a State where OPS has an interstate\nagent agreement, or an intrastate covered segment is regulated by that State. An\noperator must provide the notification within 30 days after adopting this type of\nchange into its program.\nIn IM-246, the Operator's Fuel Gas Line Integrity Management Plan, Section 1.5, the procedure\nis insufficient because there is no provision for notification within 30 days as required by\n2\n\n\n\n§ 192.909(b).\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not\ncontesting this Notice, we propose that you submit your amended procedures to my office within\n30 days of receipt of this Notice. This period may be extended by written request for good\ncause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested (not mandated) that Alyeska Pipeline Service Company maintain documentation\nof the safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Chris Hoidal, Acting Director,\nWestern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 5-2018-0014M and, for each document you submit,\nplease provide a copy in electronic format whenever possible.\n3\n\n\n\nSincerely,\nChris Hoidal\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Owens/T. Johnson (# 155098)\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n4\n\n520180014M_Closure Letter_02112019_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 11, 2019\nMr. Thomas Barrett\nPresident and CEO\nAlyeska Pipeline Service Company\nPO Box 196660\nAnchorage, AK 99519\nCPF 5-2018-0014M\nCase Closure Letter\nDear Mr. Barrett:\nOn multiple occasions between April 24, 2017 and March 16, 2018, representatives from the\nPipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601\nof 49 United States Code, conducted an on-site pipeline safety inspection of Alyeska Pipeline\nService Company’s (Alyeska) procedures in Anchorage, Alaska. As a result of the\ninspection, Alyeska was issued a Notice of Amendment on December 27, 2018, which\nproposed amendment of your procedures.\nAlyeska submitted its amended procedures on January 28, 2019. My staff reviewed the\namended procedures and it appears that the inadequacies outlined in this Notice of\nAmendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nChris Hoidal\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Owens/T. Johnson (#155098)","truncated":false,"body_characters":8196}