{"operation":"document","citation":"CPF 520195005W","title":"ALYESKA PIPELINE SERVICE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-01-25","effective_on":null,"summary":"CLOSED warning letter citing 195.583(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520195005w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520195005w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520195005w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520195005W","body":"Warning Letter involving ALYESKA PIPELINE SERVICE CO. PHMSA's enforcement data identifies the cited regulation as 195.583(a). The case was opened on 2019-01-25 and is reported as closed as of 2019-01-25. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520195005W_Operator Response to Notice_02072019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520195005W/520195005W_Operator%20Response%20to%20Notice_02072019.pdf\n\n520195005W_Warning Letter_01252019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520195005W/520195005W_Warning%20Letter_01252019.pdf\n\n520195005W_Warning Letter_01252019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520195005W/520195005W_Warning%20Letter_01252019_text.pdf\n\n520195005W_Warning Letter_01252019_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 25, 2019\nMr. Thomas Barrett\nPresident and CEO\nAlyeska Pipeline Service Company\nPO Box 196660\nAnchorage, AK 99519\nCPF 5-2019-5005W\nDear Mr. Barrett:\nBetween January 11, 2018 and July 23, 2018, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code\n(U.S.C.), inspected your Alyeska Pipeline Service Company (Alyeska) records, procedures and\nfacilities associated with the Trans-Alaska Pipeline System.\nBased on our inspection findings, PHMSA determined that Alyeska committed a probable\nviolation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The\ndeficiency noted and the probable violation is:\n1) §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\nlocated:\nThen the frequency of inspection is:\nOnshore\nAt least once every 3 calendar years, but with intervals not exceeding 39 months.\nOffshore\nAt least once each calendar year, but with intervals not exceeding 15 months.\n\n\n\nAt the time of the inspection, Alyeska personnel stated that an atmospheric corrosion inspection\non Check Valve 00-CKV-8 was not conducted on the required three year inspection interval for\nonshore facilities per CFR §195.583(a). Alyeska staff provided a record of an atmospheric\ncorrosion inspection that was conducted on July 21, 2014 on Check Valve 00-CKV-8 during the\ninspection. Alyeska personnel scheduled and conducted an atmospheric inspection of Check\nValve 00-CKV-8 on March 13, 2018 and provided records of the inspection to PHMSA on April\n9, 2018. The interval between atmospheric corrosion inspections on Check Valve 00-CKV-8 is\napproximately three and a half years.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$209,002 per violation per day the violation persists, up to a maximum of $2,090,022 for a\nrelated series of violations. For violations occurring prior to November 2, 2015, the maximum\npenalty may not exceed $200,000 per violation per day, with a maximum penalty not to exceed\n$2,000,000 for a related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct the\nitem(s) identified in this letter. Failure to do so will result in Alyeska Pipeline Company being\nsubject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2018-5005W. 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\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: Mr. Rod Hanson, Senior Vice President Operations and Maintenance\nPHP-60 Compliance Registry\nPHP-500 R. Guisinger (#158238)\n2","truncated":false,"body_characters":4412}