{"operation":"document","citation":"CPF 52022031NOA","title":"ALYESKA PIPELINE SERVICE CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-06-03","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(c)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52022031noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52022031noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52022031noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52022031NOA","body":"Notice of Amendment involving ALYESKA PIPELINE SERVICE CO. PHMSA's enforcement data identifies the cited regulation as 195.402(c)(3). The case was opened on 2022-06-03 and is reported as closed as of 2022-09-09. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52022031NOA_Closure Letter_09092022_(21-203026).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022031NOA/52022031NOA_Closure%20Letter_09092022_(21-203026).pdf\n\n52022031NOA_Closure Letter_09092022_(21-203026)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022031NOA/52022031NOA_Closure%20Letter_09092022_(21-203026)_text.pdf\n\n52022031NOA_Notice of Amendment_06032022_(21-203026).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022031NOA/52022031NOA_Notice%20of%20Amendment_06032022_(21-203026).pdf\n\n52022031NOA_Notice of Amendment_06032022_(21-203026)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022031NOA/52022031NOA_Notice%20of%20Amendment_06032022_(21-203026)_text.pdf\n\n52022031NOA_Operator Response to Notice_07292022_(21-203026).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022031NOA/52022031NOA_Operator%20Response%20to%20Notice_07292022_(21-203026).pdf\n\n52022031NOA_Notice of Amendment_06032022_(21-203026)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA E-MAIL TO MS. DANIKA YEAGER\nJune 3, 2022\nMs. Danika Yeager\nInterim President\nAlyeska Pipeline Company\nP.O. Box 196660\nAnchorage, AK 99519\nCPF 5-2022-031-NOA\nDear Ms. Yeager:\nFrom April 26 to April 30, 2021, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Alyeska\nPipeline Company’s (Alyeska) procedures for an integrated inspection of the Trans-Alaska\nPipeline (TAPS) in Anchorage, Alaska.\nOn the basis of the inspection, PHMSA has identified an apparent inadequacy found within\nAlyeska’s plans or procedures, as described below:\n1. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . . .\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(1) . . . .\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n\n\n\nAlyeska’s procedure MP-166-3.25 Atmospheric Corrosion Inspection and Monitoring\n(Procedure) described the inspection and monitoring of crude oil piping exposed to the\natmosphere to detect and control atmospheric corrosion. The procedure was inadequate to assure\nthe safe operation of its pipeline facilities. Specifically, Alyeska’s Procedure failed to include a\nprocess by which it could give “particular attention to pipe at soil-to-air interfaces, under thermal\ninsulation, under disbonded coatings, at pipe supports, in splash zones, at deck penetrations, and\nin spans over water” in order to monitor atmospheric corrosion control, as required by §\n195.583(b).\nAlyeska’s Procedure stated, in relevant part as follows, “[t]he Crude Mainline and Fuel Gas\nPipeline ILI fulfills the atmospheric corrosion control inspection requirements for the 48” Crude\nand 8”/10” Fuel Gas pipelines. All above grade appurtenances are not inspected during ILI and\ntherefore must be visually inspected per this procedure.”\nAn In-Line Inspection (ILI) alone is inadequate to fulfill the requirements of § 195.583, as an ILI\nis unable to assess the condition of the pipe “at soil-to-air interfaces, under thermal insulation,\nunder disbonded coatings, at pipe supports, in splash zones, at deck penetrations, and in spans\nover water”.\nAlyeska must amend its Procedure to ensure compliance with the requirements of § 195.583.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not\ncontesting this Notice, we propose that you submit your amended procedures to my office within\n90 days of receipt of this Notice. This period may be extended by written request for good\ncause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\n\n\n\nIt is requested (not mandated) that Alyeska maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Dustin Hubbard, Director, Western Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please\nrefer to CPF 5-2022-031-NOA and, for each document you submit, please provide a copy in\nelectronic format whenever possible.\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 G. St. Pierre (#21-203026)\nAllison Iversen, HSEC Director, APSC (via email)\nAlyssa Sweet, Regulatory Affairs Manager, APSC (via email)\n\n52022031NOA_Closure Letter_09092022_(21-203026)_text.pdf\n\nVIA E-MAIL TO MS. ELIZABETH HAINES\nSeptember 9, 2022\nMs. Elizabeth Haines\nInterim President\nAlyeska Pipeline Service Company\nP.O. Box 196660\nAnchorage, AK 99519\nCPF 5-2022-031-NOA\nClosure Letter\nDear Ms. Haines:\nFrom April 26 to April 30, 2021, a representative from the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to chapter 601 of 49 United States Code, inspected Alyeska Pipeline\nService Company’s (Alyeska) procedures for an integrated inspection of the Trans-Alaska Pipeline. As a\nresult of the inspection, Alyeska was issued a Notice of Amendment on June 3, 2022, which proposed\namendment of your procedures.\nAlyeska submitted its amended procedures on July 29, 2022. My staff reviewed the amended procedures,\nand it appears that the inadequacies outlined in this Notice of Amendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you for your\ncooperation.\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 G. St. Pierre (#21-203026)\nAllison Iversen, HSEC Director, Alyeska (via email)\nJanine Boyette, Senior Compliance Manager, Alyeska (via email)","truncated":false,"body_characters":7785}