{"operation":"document","citation":"CPF 52020002WL","title":"ALASKA PIPELINE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-10-09","effective_on":null,"summary":"CLOSED warning letter citing 192.479(a), 192.479(b), 192.479(c), 192.479(c)(1), 192.479(c)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52020002wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52020002wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52020002wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52020002WL","body":"Warning Letter involving ALASKA PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 192.479(a),  192.479(b),  192.479(c),  192.479(c)(1),  192.479(c)(2). The case was opened on 2020-10-09 and is reported as closed as of 2020-10-09. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52020002WL_Warning Letter_10092020_(20-179456).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52020002WL/52020002WL_Warning%20Letter_10092020_(20-179456).pdf\n\n52020002WL_Warning Letter_10092020_(20-179456)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52020002WL/52020002WL_Warning%20Letter_10092020_(20-179456)_text.pdf\n\n52020002WL_Warning Letter_10092020_(20-179456)_text.pdf\n\nWARNING LETTER\nVIA E-MAIL TO MR. JOHN SIMS\nOctober 9, 2020\nMr. John Sims\nPresident\nAlaska Pipeline Company\nP.O. Box 190288\nAnchorage, AK 99519-0288\nCPF 5-2020-002-WL\nDear Mr. Sims:\nFrom February 3 through 6, March 2 through 4 and June 29 through July 2, 2020, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.), inspected your natural gas distribution system.\nAs a result of the inspection, it is alleged that you have committed probable violations of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected and the probable\nviolations are:\n1. § 192.479 - Atmospheric corrosion control: General.\n(a) Each operator must clean and coat each pipeline or portion of pipeline that is exposed to the\natmosphere, except pipelines under paragraph (c) of this section.\n(b) Coating material must be suitable for the prevention of atmospheric corrosion.\n(c) Except portions of pipelines in offshore splash zones or soil-to-air interfaces, the operator need\nnot protect from atmospheric corrosion any pipeline for which the operator demonstrates by test,\ninvestigation, or experience appropriate to the environment of 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 inspection.\nIn Whittier, where the military pipeline daylights above ground, shortly after exiting the tunnel at the old\npig trap station, the tape wrap was failing at the soil-to-air interface. A photo taken during the field visit\nshowed tape wrap peeling off and corrosion on the surface of the pipeline under the failed coating.\n\n\n\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related series\nof violations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the\nmaximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to exceed\n$2,132,679. For violation occurring on or after November 2, 2015 and before November 27, 2018, the\nmaximum penalty may not exceed $209,002 per violation per day, with a maximum penalty not to exceed\n$2,090,022. For violations occurring prior to November 2, 2015, the maximum penalty may not exceed\n$200,000 per violation per day, with a maximum penalty not to exceed $2,000,000 for a related series of\nviolations. We have reviewed the circumstances and supporting documents involved in this case, and\nhave decided not 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 Alaska Pipeline\nCompany being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 5-\n2020-002-WL. Be advised that all material you submit in response to this enforcement action is subject\nto being made 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 must\nprovide a second copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 G. St. Pierre (#20-179456)\nMr. Rusty Allen, Compliance / Integrity Engineer (via email)\nMr. Steve Cooper, Director of Operations (via email)\n2","truncated":false,"body_characters":4605}