{"operation":"document","citation":"CPF 52021016WL","title":"ALYESKA PIPELINE SERVICE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-04-14","effective_on":null,"summary":"CLOSED warning letter citing 195.446(h)(6).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52021016wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52021016wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52021016wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52021016WL","body":"Warning Letter involving ALYESKA PIPELINE SERVICE CO. PHMSA's enforcement data identifies the cited regulation as 195.446(h)(6). The case was opened on 2021-04-14 and is reported as closed as of 2021-04-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52021016WL_Warning Letter_04142021_(20-173102).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021016WL/52021016WL_Warning%20Letter_04142021_(20-173102).pdf\n\n52021016WL_Warning Letter_04142021_(20-173102)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021016WL/52021016WL_Warning%20Letter_04142021_(20-173102)_text.pdf\n\n52021016WL_Warning Letter_04142021_(20-173102)_text.pdf\n\nWARNING LETTER\nVIA E-MAIL TO MR. BRIGHAM MCCOWN\nApril 14, 2021\nMr. Brigham McCown\nPresident\nAlyeska Pipeline Service Company\n3700 Centerpoint Drive\nP.O. Box 196660\nAnchorage, Alaska 99515\nCPF 5-2021-016-WL\nDear Mr. McCown:\nDuring the week of August 17 through 21, 2020, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), performed\na virtual inspection of the Alyeska Pipeline Service Company's Control Room located in Anchorage,\nAlaska. This inspection included procedures, records, and virtual observations associated with the Control\nRoom Management Program.\nAs a result of the inspection, it is alleged that you have committed probable violation of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected and the probable\nviolation is:\n1. § 195.446 - Control room management.\n(a) …\n(h) Training. Each operator must establish a controller training program and review the\ntraining program content to identify potential improvements at least once each calendar\nyear, but at intervals not to exceed 15 months. An operator’s program must provide for\ntraining each controller to carry out the roles and responsibilities defined by the operator.\nIn addition, the training program must include the following elements:\n\n\n\n(1) …\n(6) Control room team training and exercises that include both controllers and other\nindividuals, defined by the operator, who would reasonably be expected to operationally\ncollaborate with controllers (control room personnel) during normal, abnormal or\nemergency situations. Operators must comply with the team training requirements under\nthis paragraph no later than January 23, 2018.\nDuring a review of Alyeska’s records for the team training requirement, the records demonstrated that at\nleast one qualified controller participated in the training. However, the records failed to identify the other\npersonnel who attended, or a complete list of attendance to adequately show compliance of the team\ntraining exercise.\nRecords were incomplete and failed to demonstrate that control room team training and exercises\nincluded both controllers and other individuals, defined by the operator, who would reasonably be\nexpected to operationally collaborate with controllers (control room personnel) during normal, abnormal\nor emergency situations.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for a related series\nof violations. For violation occurring on or after July 31, 2019 and before January 11, 2021, the\nmaximum penalty may not exceed $218,647 per violation per day the violation persists, up to a maximum\nof $2,186,465 for a related series of violations. For violation occurring on or after November 27, 2018\nand before July 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a\nmaximum penalty not to exceed $2,132,679. 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 day, with a\nmaximum penalty not to exceed $2,090,022.\nWe have reviewed 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. We advise\nyou to correct the item identified in this letter. Failure to do so will result in Alyeska Pipeline Service\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-\n2021-016-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, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 D. Fehling (#20-173102)","truncated":false,"body_characters":5176}