{"operation":"document","citation":"CPF 520195007W","title":"KUPARUK TRANSPORTATION CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-07-15","effective_on":null,"summary":"CLOSED warning letter citing 195.208, 195.452(k).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520195007w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520195007w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520195007w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520195007W","body":"Warning Letter involving KUPARUK TRANSPORTATION CO. PHMSA's enforcement data identifies the cited regulations as 195.208,  195.452(k). The case was opened on 2019-07-15 and is reported as closed as of 2019-07-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520195007W_Operator Response to Notice_08282019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520195007W/520195007W_Operator%20Response%20to%20Notice_08282019.pdf\n\n520195007W_Warning Letter_07152019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520195007W/520195007W_Warning%20Letter_07152019.pdf\n\n520195007W_Warning Letter_07152019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520195007W/520195007W_Warning%20Letter_07152019_text.pdf\n\n520195007W_Warning Letter_07152019_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 15, 2019\nMr. Scott Jepsen\nPresident\nKuparuk Transportation Company\nP.O. Box 100360\nAnchorage, AK 99501\nCPF 5-2019-5007W\nDear Mr. Jepsen:\nFrom February 25 through March 1, 2019, and from March 11 through 15, 2019,\nrepresentatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA),\npursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected your Kuparuk Oil\nPipeline located on the North Slope of Alaska and related documents 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:\n1. § 195.208 Welding of supports and braces.\nSupports or braces may not be welded directly to pipe that will be operated at a\npressure of more than 100 p.s.i. (689 kPa) gage.\nKuparuk Oil Pipeline, which operates above 100 psig, had supports welded directly to pipe.\nPHMSA representatives observed pipeline supports welded directly to the Kuparuk Oil\nPipeline at Central Processing Facility 2, immediately upstream and downstream of valve\nROV-AL-9288.\n\n\n\n2. § 195.452 Pipeline integrity management in high consequence areas.\n(a) …\n(k) What methods to measure program effectiveness must be used? An operator's\nprogram must include methods to measure whether the program is effective in\nassessing and evaluating the integrity of each pipeline segment and in protecting\nthe high consequence areas. See Appendix C of this part for guidance on\nmethods that can be used to evaluate a program's effectiveness.\nThe operator failed to perform, in a timely manner, periodic evaluations of the effectiveness\nof its integrity management program in assessing and evaluating the integrity of each pipeline\nsegment and in protecting the high consequence areas. Specifically, when requested to\nprovide documentation of periodic evaluations of the effectiveness of its integrity\nmanagement program, the operator initially provided performance measures results for 2011,\n2012, 2013, and 2014, and stated that effectiveness evaluations were not conducted for the\ntime periods between 2015 and 2018. Subsequent to PHMSA’s initial request, the operator\nperformed evaluations of the effectiveness of its integrity management program for 2015,\n2016, 2017, and 2018, and provided the results to PHMSA at the end of the inspection. As\nsuch, the operator failed to perform periodic evaluations of the effectiveness of its integrity\nmanagement program for 2015, 2016, and 2017 in a timely manner.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to\nexceed $213,268 per violation per day the violation persists, up to a maximum of $2,132,679\nfor a related series of violations. For violation occurring on or after November 2, 2015 and\nbefore November 27, 2018, the maximum penalty may not exceed $209,002 per violation per\nday, with a maximum penalty not to exceed $2,090,022. For violations occurring prior to\nNovember 2, 2015, the maximum penalty may not exceed $200,000 per violation per day,\nwith a maximum penalty not to exceed $2,000,000 for a related series of violations. We have\nreviewed the circumstances and supporting documents involved in this case, and have decided\nnot to conduct additional enforcement action or penalty assessment proceedings at this time.\nWe advise you to correct the items identified in this letter. Failure to do so will result in\nKuparuk Transportation 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 5-2019-5007W. 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\n2\n\n\n\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nDustin B. Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: Wes Olson, DOT Program Coordinator\nPHP-60 Compliance Registry\nPHP-500 T. Johnson/J. Gano (#162627, #162628)\n3","truncated":false,"body_characters":5331}