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Alyeska objects to federal fine, defends anti-corrosion efforts
Alyeska Pipeline Service Co. is resisting a proposed federal fine stemming from a highly disruptive oil spill in January 2011 at Pump Station 1 on Alaska’s North Slope.
Alyeska calls the $145,000 civil penalty excessive, and says regulators haven’t given the company enough credit for its efforts to combat corrosion, which caused the leak.
The Pipeline and Hazardous Materials Safety Administration, an agency of the U.S. Department of Transportation, hit Alyeska on Aug. 1 with a “notice of probable violation.”
In proposing the $145,000 fine, PHMSA faulted Alyeska for failure to take adequate steps to mitigate internal corrosion in certain parts of the trans-Alaska pipeline system.
Alyeska lodged its objections to the enforcement action in a Nov. 4 written response to PHMSA.
Pipeline shutdowns Alyeska is an Anchorage-based consortium that operates the 800-mile pipeline on behalf of owners BP, ConocoPhillips, ExxonMobil and Chevron.
On Jan. 8, 2011, crude oil leaked in the booster pump room at Pump Station 1, located at the start of the pipeline at Prudhoe Bay.
Alyeska notes that no one was injured, and the oil leak didn’t damage the environment.
But the spill forced two extended shutdowns of the pipeline as workers rallied to pinpoint the source of the leak and make repairs. The winter shutdowns were risky; icing and other problems can develop on the pipeline if the warm oil doesn’t keep moving.
The oil leak was traced to a failed manifold. Alyeska contractor Det Norske Veritas did a root cause analysis and concluded the cause of the leak was “microbiologically influenced corrosion.”
Allegation disputed Alyeska, by 2008, was aware of internal corrosion in deadlegs and low-flow piping, but failed to adequately mitigate it, PHMSA charged.
In its response, Alyeska disputes that allegation. The company outlines a number of steps taken to fight corrosion.
In 2008, Alyeska says it contracted with an expert, Baker Petrolite, to perform a corrosivity study of the crude oil flowing through the pipeline system. The testing showed the oil did not contain hazardous levels of hydrogen sulfide or carbon dioxide.
“However, it did note that water in the crude oil contained potential corrosion causing bacteria,” Alyeska says.
The study recommended biocide treatment and corrosion inhibitors to control microbial corrosion in areas of laminar, or nonturbulent, flow.
Alyeska says it used the results of the corrosivity study to optimize its corrosion inhibition and biocide treatment programs.
Subsequently, the company says it hired Baker Hughes to help improve the effectiveness of the internal corrosion inhibitor program. The Baker Hughes analysis included “a bacterial kill study comparing multiple biocides.”
Alyeska says it began biocide treatments in pump station facility piping in February 2011, and is regularly monitoring bacteria levels across the pipeline system.
All along the way, Alyeska says it kept PHMSA and other regulators informed on its anti-corrosion work.
Alyeska further says it continues to remove deadlegs and bring facility piping above ground, under a consent agreement it signed with PHMSA in August 2011.
Deadlegs are sections of piping that have been isolated and no longer carry liquid or gas. Inactive piping, or segments with only occasional or low flows, can be sources of trouble.
Alyeska says it has been working with new technologies to inspect previously inaccessible piping. These technologies include robotic crawler pigs, devices that can move through piping to look for problems.
Alyeska recently inspected some facility piping at Pump Station 10, and at the Valdez Marine Terminal, using a robotic crawler pig fitted with ultrasonic equipment, its response to PHMSA says.
Alyeska is asking the agency to reduce the $145,000 civil penalty. It cites several examples in which other companies were fined less for similar violations. One company recently received a notice of probable violation for an accident in which an employee was injured, yet the proposed penalty was only $100,000, Alyeska says.
“The probable violation in Alyeska’s case does not include a release of crude or other event that adversely impacted the environment or any injury to personnel,” Alyeska says. “In fact, no harm occurred.”
In addition to the $145,000 fine, PHMSA proposed a “compliance order” requiring Alyeska to, among other things, “optimize procedures for microbiological monitoring, especially effectiveness in deadlegs and low flow areas.”
Alyeska is asking PHMSA to drop the compliance order, arguing it already has taken the measures called for in the order.
—Wesley Loy
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