{"operation":"document","citation":"CPF 52022056WL","title":"ALASKA PIPELINE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-12-13","effective_on":null,"summary":"CLOSED warning letter citing 192.161(c), 192.319(b)(1), 192.735(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52022056wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52022056wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52022056wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52022056WL","body":"Warning Letter involving ALASKA PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 192.161(c),  192.319(b)(1),  192.735(b). The case was opened on 2022-12-13 and is reported as closed as of 2022-12-13. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52022056WL_Warning Letter_12132022_(22-236683).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022056WL/52022056WL_Warning%20Letter_12132022_(22-236683).pdf\n\n52022056WL_Warning Letter_12132022_(22-236683)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022056WL/52022056WL_Warning%20Letter_12132022_(22-236683)_text.pdf\n\n52022056WL_Warning Letter_12132022_(22-236683)_text.pdf\n\nWARNING LETTER\nVIA E-MAIL TO MR. JOHN SIMS\nDecember 13, 2022\nMr. John Sims\nPresident\nAlaska Pipeline Company\n3000 Spenard Road\nBox 190288\nAnchorage, AK 99519\nCPF 5-2022-056-WL\nDear Mr. Sims:\nFrom June 21 through September 1, 2022, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code\n(U.S.C.), inspected your Anchorage and Kenai natural gas transmission pipeline systems in\nAnchorage and the Kenai Peninsula Borough, 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 inspected\nand the probable violations are:\n1. § 192.161 Supports and anchors.\n(a) . . . .\n(c) Each support or anchor on an exposed pipeline must be made of durable,\nnoncombustible material and must be designed and installed as follows:\n. . . .\n\n\n\nAlaska Pipeline Co. (APC) failed to use durable, noncombustible materials for pipeline supports.\nPHMSA observed wood shims, cribbing, and braces used as pipe supports at the City Gate\npipeline pig trap, Gudenwrath Compressor Station pig trap, and Wolf Lake tie-in building during\nthe July and August 2022 inspections.\n2. § 192.319 Installation of pipe in a ditch.\n(a) . . . .\n(b) When a ditch for a transmission line or main is backfilled, it must be backfilled\nin a manner that:\n(1) Provides firm support under the pipe; and\n. . . .\nAPC failed to backfill their excavation at the “Welaka Lake” station in a manner that provided\nadequate support for the pipe. The Welaka Lake Station is where Alaska Pipeline Co.’s Beaver\nCreek transmission pipeline connects to Enstar’s distribution mains. During the August 31, 2022\ninspection, PHMSA observed and photographed evidence of a recent excavation and soil\nsubsidence that was putting excess strain on the pipelines. According to statements made by the\noperator, APC excavated the site in the weeks prior to the inspection to survey the buried\npipeline for the design of an upcoming replacement project. Based on conditions observed during\nthe inspection, it is evident that the materials and practices used to backfill the excavation were\ninadequate to provide firm support under the pipe.\n3. § 192.735 Compressor stations: Storage of combustible materials.\n(a) . . . .\n(b) Aboveground oil or gasoline storage tanks must be protected in accordance with\nNFPA-30 (incorporated by reference, see § 192.7).\nAPC failed to protect their two condensate oil storage tanks at the Gudenwrath \"B\" compressor\nstation from fire hazards consistent with NFPA 30:\n• The tanks did not meet the shell-to-shell spacing requirements per Table 22.4.2.1 of\nNFPA 30. The required minimum shell-to-shell spacing depends on tank design and the\nproduct stored within the tank but, the minimum spacing for any circumstances is 3 feet.\nPhotos taken during the August 29, 2022, site visit show the tanks are approximately six\ninches apart.\n• Tanks’ vent pipes are not properly installed per NFPA 30 section 27.8.1. Photos taken\nduring the August 29, 2022, site visit show that the vents are installed under a roof which\ncan trap flammable vapors and impinge flames.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$239,142 per violation per day the violation persists, up to a maximum of $2,391,142 for a\nrelated series of violations. For violation occurring on or after May 3, 2021, and before March\n21, 2022, the maximum penalty may not exceed $225,134 per violation per day the violation\npersists, up to a maximum of $2,251,334 for a related series of violations. For violation\n\n\n\noccurring on or after January 11, 2021, and before May 3, 2021, the maximum penalty may not\nexceed $222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for\na related series of violations. For violation occurring on or after July 31, 2019, and before\nJanuary 11, 2021, the maximum penalty may not exceed $218,647 per violation per day the\nviolation persists, up to a maximum of $2,186,465 for a related series of violations. For violation\noccurring on or after November 27, 2018 and before July 31, 2019, the maximum penalty may\nnot exceed $213,268 per violation per day, with a maximum penalty not to exceed $2,132,679.\nFor 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\nto exceed $2,090,022\nWe have reviewed the circumstances and supporting documents involved in this case and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the items identified in this letter. Failure to do so will result in\nAlaska Pipeline Co. being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply in your correspondence, please refer to\nCPF 5-2022-056-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document, you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nFor Dustin Hubbard\nDirector, Western Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Gano (#22-236683)\nSteve Cooper, APC (by email)\nRusty Allen, APC (by email)","truncated":false,"body_characters":6533}