{"operation":"document","citation":"PI-79-028","title":"Alaska Pipeline Office — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1979-08-10","effective_on":null,"summary":"PI-79-028 response to Alaska Pipeline Office concerning 195.1, 195.402, 195.422.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-79-028.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-79-028.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-79-028","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1979/PI79028.pdf","body":"<<<PAGE 1>>>\n\nAugust 10, 1979\nMr. Morris J. Turner\nAuthorized Officer\nAlaska Pipeline Office\nBox 30\n701 C Street\nAnchorage, Alaska 99513\nDear Mr. Turner:\nThis is in answer to your letter of July 23, 1979, (P001.400217)\nto Mr. Lloyd Ulrich in which you request our Office to determine\nif certain pipe conditions and possible Alyeska actions are in\naccordance with the Department's liquid pipeline safety\nregulations contained in 49 CFR Part 195. These conditions and\nactions relate to the failures experienced on the Trans-Alaska\ncrude oil pipeline which were discovered on June 10, 1979, at\nAtigun Pass and on June 15, 1979, at Milepost 734 near Pump\nStation 12.\nEach of your questions regarding certain pipe conditions are\nanswered in turn, with reference to specific sections of Part 195\nwhich are pertinent to the courses of action cited in your\nletter.\n1. \"Deformed (buckled) pipe sections with no sleeve\nrepairs.\" Section 195.402 states:\n\"(b) No carrier may operate or maintain its pipeline\nsystems at a level of safety lower than that\nrequired by this subpart and the procedures it is\nrequired to establish under paragraph (a) of this\nsection\".\n\"(c) Whenever a carrier discovers any condition that\ncould adversely affect the safe operation of its\npipeline system it shall correct it within a\nreasonable time. However, if the condition is of\nsuch a nature that it presents an immediate hazard\nto persons or property, the carrier may not\noperate the affected part of the system until it\nhas corrected the unsafe condition.\"\nIn the design of the pipeline, Alyeska developed stress\ncriteria that took into account all credible live and\ndead loads and occasional loads (such as earthquakes)\nto which the pipeline could be subjected. To provide\nan acceptable level of safety under these criteria,\nwhen the buried pipe is subject to design contingency\nloadings (design contingency earthquake and/or\ndal\\195\\1\\79-08-10\n1\n\n<<<PAGE 2>>>\n\n2. settlement), the highest allowable stress established\nfor the buried pipe was 1.15 SMYS. These design loads\nwere exceeded in the buckled area.\nContinuing to operate the buckled section of the\npipeline would not be in accordance with ?195.402(b)\nbecause the deformation that has occurred materially\naltered the mechanical properties of the pipe,\nweakening it which would thereby provide a level of\nsafety lower than that required by this subpart and the\nallowable stress established by Alyeska. Because the\ndeformed pipeline could adversely affect the safe\noperation of the pipeline system, ?195.402(c) requires\nthat the condition must be corrected within a\nreasonable time.\n\"Deformed (buckled) pipe sections with 'Alyeska's'\nsplit sleeve installed.\"\nIn addition to the possible violation cited under 1.\nabove, ?195.118(c) states:\n\"The fitting must be suitable for the intended\nservice and be at least as strong as the pipe and\nother fittings in the pipeline system to which it\nis attached.\"\nDuring meetings following each failure which were\nconducted to discuss cause and remedial actions, we\nwere told by Alyeska personnel that \"Alyeska's\" split\nsleeves installed over the two buckles were fabricated\nfor the sole purpose of providing temporary\nreinforcment [sic] at the buckled area. The sleeves\nwere not designed using proven engineering analytical\nprocedures nor the design substantiated by a rigorous\ntesting program. Therefore, since these sleeves have\nnot been shown to be suitable for the intended service,\ncontinuing to operate the deformed pipe sections with\nAlyeska's split sleeve installed would not be in\naccordance with ?195.118(c).\nSection 195.422(a) states:\n\"Each carrier shall, in repairing its pipeline\nsystems, insure that the repairs are made in a\nsafe manner and are made so as to prevent damage\nto persons or property.\"\nFor reasons stated in comments about ?195.118(c) above,\ndal\\195\\1\\79-08-10\n2\n\n<<<PAGE 3>>>\n\nwe are not assured that the repairs were made in a safe\nmanner.\n3. 4. \"Operating the pipeline with deformed sections repaired\nwith 'Alyeska's' split sleeve through two seasonal\nchanges (10 to 11 months) before permanent repairs are\nmade.\"\nSection 195.402(c) requires that any condition that\ncould adversely affect the safe operation of the\npipeline shall be corrected within a reasonable time.\nWe would like to have additional information from\nAlyeska, as well as the opinion of the Alaska Pipeline\nOffice, concerning what would be a reasonable time to\nmake these repairs, taking into account the short\nAlaska construction season and adverse winter\nenvironmental conditions. We will assess this\ninformation in determining if 10-11 months would be a\nreasonable time to make these repairs.\n\"Operating the pipeline indefinitely wi th deformed pipe\nand 'Alyeska's' split sleeve installed as a final\npermanent repair.\nFor the several reasons relating to the pertinent\nsections of Part 195 cited earlier, the operation of\nthe \"pipeline indefinitely with deformed pipe and\n'Alyeska's' split sleeve installed as a final permanent\nrepair\" is not in accordance with the Federal pipeline\nsafety standards contained in 49 CFR Part 195 absent\ndata showing that these split sleeves are suitable for\nthe intended service.\nAlthough the interpretation s above respond to your\nspecific questions, as you know, Dr. Robert L. Paullin,\nAssociate Director for Operations and Enforcement,\nMaterials Transportation Bureau, wrote Mr. W.M. Witten\non August 7, 1979, requesting that a metallurgical\nexamination of the failed pipe sections be conducted.\nThis metallurgical examination would require the\nremoval of the failed sections of pipe. We would\nappreciate receiving from Alyeska the requested\nadditional technical details concerning repair\nproposals and also knowing the opinion of the Alaska\nPipeline Office relative to appropriate courses of\naction and schedule for repairs.\nSincerely,\ndal\\195\\1\\79-08-10\n3\n\n<<<PAGE 4>>>\n\nCesar DeLeon\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\nJuly 23, 1979\nMr. Lloyd W. Ulrich\nOffice of Pipeline Safety Operations\nU.S. Department of Transportation Materials Transportation Bureau 2100 2nd Street S.W. Washington, D.C. 20590 Repairs\nSubject: Operating TAPS\nwith Deformed Pipe Sec-\ntions & Temporary Leak\nDear Mr. Ulrich:\nReferences: 1. APSC Ltr. No. 79-1112-G, dtd 6/20/79,\n\"Investigation of Atigun Pass Oil Spill of\n6/10/79, to OPSO\n2. Your telephone conversation on 7/10/79 with\nMr. Donald Keyes, Technical Program Manager\nThis letter confirms our telephone request to evaluate applicable\nDepartment of Transportation regulations and industry codes\nconcerning operating the Trans-Alaska Pipeline with deformed pipe\nsections as repaired in accordance with Alyeska's Maintenance and\nRepair Manual, which was forwarded to your office (Reference 1).\nSpecifically, your assistance is requested to determine if the\nfollowing pipe conditions are in accordance with Department of\nTransportation regulations on safe operations:\n1. Deformed (buckled) pipe sections with no sleeve\nrepairs.\n2. Deformed (buckled) pipe sections with \"Alyeska's\" split\nsleeve installed.\n3. Operating the pipeline with deformed sections repaired\nwith \"Alyeska's\" split sleeve through two seasonal\nchanges (10 to 11 months) before permanent repairs are\nmade.\n4. Operating the pipeline indefinitely with deformed pipe\nand \"Alyeska's\" split sleeve installed as a final\npermanent repair.\ndal\\195\\1\\79-08-10\n4\n\n<<<PAGE 5>>>\n\nIf any of the above pipeline conditions can be considered within\nreasonable compliance of Department of Transportation regulations\non safe operations, what additional data and surveillance\nactivities should be provided by Alyeska?\nSincerely yours,\nMorris J. Turner\nAuthorized Officer\ndal\\195\\1\\79-08-10\n5","truncated":false,"body_characters":7719}