HARVEST ALASKA, LLC — Notice of Amendment

party submissionOfficial PDF52022001NOA_Operator Response to Notice_(REDACTED)_04282022_(21-199723).pdf#

52022001NOA_Notice of Amendment_03302022_(21-199723)_text.pdf, page 1Official PDFNOTICE OF AMENDMENT VIA E-MAIL TO MR. SEAN KOLASSA March 30, 2022 Mr. Sean Kolassa President Harvest Alaska, LLC 1111 Travis Street Houston, TX 77002 CPF 5-2022-001-NOA Dear Mr. Kolassa: From May 17 through 21, 2021, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Harvest Alaska, LLC’s (Harvest) procedures for the Northstar Liquid Pipeline near Prudhoe Bay, Alaska. On the basis of the inspection, PHMSA has identified an apparent inadequacy found within Harvest’s plans or procedures, as described below: 1. § 195.412 Inspection of rights-of-way and crossings under navigable waters. (a) Each operator shall, at intervals not exceeding 3 weeks, but at least 26 times each calendar year, inspect the surface conditions on or adjacent to each pipeline right-of-way. Methods of inspection include walking, driving, flying or other appropriate means of traversing the right-of-way. Harvest’s written procedure for inspection of the Northstar Liquid Pipeline rights-of-way (ROW) was inadequate. The 10” Northstar Sales Oil Pipeline - Operation, Maintenance, and Emergency Response Manual, Revision 9, dated May 10, 2021, addressed ROW inspection in Section 5.2 (Procedure). The Procedure was inadequate because it did not require inspection of the offshore right-of-way at intervals not exceeding 3 weeks, but at least 26 times each calendar year. The Procedure only required ROW patrols, 26 times per calendar year, for onshore ROWs. The Procedure did mention that “subsea ROW is analyzed annually as part of a strudel monitoring program”, but the strudel monitoring program does not meet the inspection interval requirements of § 195.412(a). In addition, during the inspection, Harvest#

52022001NOA_Notice of Amendment_03302022_(21-199723)_text.pdf, page 2personnel stated that they did not inspect offshore pipeline ROWs during the winter months due to ice cover. Records of ROW inspection, reviewed by PHMSA personnel during the inspection, indicated that ice is typically present on the offshore right-of-way from approximately October to June. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings. Please refer to this document and note the response options. Be advised that all material you submit in response to this enforcement action is subject to being made publicly available. If you believe that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original document you must provide a second copy of the document with the portions you believe qualify for confidential treatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested that Harvest Alaska maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Dustin Hubbard, Director, Western Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 5-2022-001-NOA and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Dustin Hubbard Director, Western Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings cc: PHP-60 Compliance Registry PHP-500 D. Johnson (#21-199723) Andrew Limmer, Vice President Harvest Alaska (via email) Harold Colgrove, Integrity and Regulatory Compliance Manager, Harvest Alaska, LLC 2#

52022001NOA_Closure Letter_05242022_(21-199723)_text.pdf, page 1Official PDFVIA E-MAIL TO MR. SEAN KOLASSA May 24, 2022 Mr. Sean Kolassa President Harvest Alaska, LLC 1111 Travis Street Houston, TX 77002 CPF 5-2022-001-NOA Closure Letter Dear Mr. Kolassa: From May 17 through 21, 2021, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Harvest Alaska, LLC’s (Harvest) procedures for the Northstar Liquid Pipeline near Prudhoe Bay, Alaska. As a result of the inspection, Harvest Alaska was issued a Notice of Amendment on March 30, 2022, which proposed amendment of Harvest’s procedures. Harvest Alaska submitted its amended procedures on April 28, 2022. My staff reviewed the amended procedures, and it appears the inadequacies outlined in the Notice of Amendment have been corrected. This letter is to inform you that no further action is necessary, and this case is now closed. Thank you for your cooperation. Sincerely, Dustin Hubbard Director, Western Region Pipeline and Hazardous Materials Safety Administration cc: PHP-60 Compliance Registry PHP-500 C. Lyon (#21-199723) Andrew Limmer, Vice President Harvest Alaska (via email) Harold Colgrove, Integrity and Regulatory Compliance Manager, Harvest Alaska (via email)#