Northwest Pipeline Corp's quarterly report documenting problems, including those identified by landowners, & corrective actions taken during post construction of the Grays Harbor Expansion Proj during 8/1/04 - 10/31/04.

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Trans Alaska Pipeline System, et al. ) Docket Nos. OR89-2-016, et al. STATE OF ALASKA BEFORE THE REGULATORY COMMISSION OF ALASKA Trans Alaska Pipeline System ) Docket Nos. P-89-2, et al. Quality Bank Proceedings ) Consolidated EXCEPTIONS OF FLINT HILLS RESOURCES ALASKA, LLC TO THE INITIAL DECISION OF THE ADMINISTRATIVE LAW JUDGES, AND MEMORANDUM IN SUPPORT THEREOF Pursuant to Rule 711 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission, 18 C.F.R. 385.711, Flint Hills Resources Alaska, LLC (hereinafter Flint Hills Resources or FHR) hereby submits its exceptions to the Initial Decision of the Administrative Law Judges in this combined proceeding, along with its memorandum of authorities in support thereof. I. BACKGROUND On April 1, 2004, Flint Hills Resources acquired in an asset transaction from Williams Alaska Petroleum, Inc. (Williams) the Williams refinery located at North Pole, Alaska, as well as refined products terminals in Fairbanks and Anchorage. The North Pole refinery receives crude oil for processing from the Trans Alaska Pipeline (TAPS) and is therefore directly impacted by the TAPS Quality Bank mechanism. By reason of the acquisition of the North Pole refinery, FHR now has an ongoing interest in 1 the Quality Bank issues raised in the above-captioned proceedings. From April 1, 2004 forward, the resolution of these issues will have a direct economic impact on FHR, and FHR was therefore allowed to intervene in these proceedings. See Order dated April 20, 2004. II. STATEMENT OF THE CASE This is the latest in a series of contested proceedings involving the TAPS Quality Bank, which disputes have occupied the time of the participants, the Commissions, and the Court of Appeals for the District of Columbia (D.C. Circuit) for more than 15 years. At issue in this round are the details of the methodology to be used to value the Quality Bank resid cut and the effective date for that value, the valuation methodology and effective date of the West Coast Quality Bank heavy distillate cut, the valuation methodology and effective date for the West Coast Quality Bank naphtha cut, the valuation methodology and effective date for the West Coast Quality Bank vacuum gas oil (VGO) cut, and various issues over claims for reparations and/or refunds. Extensive hearings were held before Judges Silverstein and Wilson, and on August 31, 2004, Judge Silverstein issued his Initial Decision, 1 which was adopted without change or modification by the ...