# ALYESKA PIPELINE SERVICE CO — Warning Letter

**Citation:** CPF 520175020W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2017-08-10

CLOSED warning letter citing 195.402(a).

## Document text

Warning Letter involving ALYESKA PIPELINE SERVICE CO. PHMSA's enforcement data identifies the cited regulation as 195.402(a). The case was opened on 2017-08-10 and is reported as closed as of 2017-08-10. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520175020W_Warning Letter_08102017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175020W/520175020W_Warning%20Letter_08102017.pdf

520175020W_Warning Letter_08102017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175020W/520175020W_Warning%20Letter_08102017_text.pdf

520175020W_Warning Letter_08102017_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
August 10, 2017
Mr. Thomas Barrett
President & CEO
Alyeska Pipeline Service Company
PO Box 196660
Anchorage, AK 99519
CPF 5-2017-5020W
Dear Mr. Barrett:
On November 3, 2016, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your
Alyeska Pipeline Service Company (APSC) facilities located at Pump Station Number Nine,
11 miles south of Delta Junction, Alaska on the Richardson Highway.
As a result of the inspection, it is alleged that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item
inspected and the probable violation is:
1. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a
manual of written procedures for conducting normal operations and
maintenance activities and handling abnormal operations and emergencies. This
manual shall be reviewed at intervals not exceeding 15 months, but at least once
each calendar year, and appropriate changes made as necessary to insure that
the manual is effective. This manual shall be prepared before initial operations of



a pipeline system commence, and appropriate parts shall be kept at locations
where operations and maintenance activities are conducted.
During the records review of quarterly tank inspection tasks completed for Pump Station Nine
crude relief tank, TK-190, it became evident that the Third Quarter 2016 inspection was not
conducted in accordance with APSC Safe Operating Procedure 3.5.17 (Procedure). The
September 2016 APSC work order #161022976 reflects that no tank level measurements were
recorded as required by the Procedure.
A review of the previous and the subsequent inspections verified that the Third Quarter 2016
inspection documentation error was a singular occurrence and was not a systemic or recurring
issue. The subsequent inspection was conducted and recorded per the APSC Procedure.
As of April 27, 2017, under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a
civil penalty not to exceed $209,002 per violation per day the violation persists up to a
maximum of $2,090,022 for a related series of violations. We have reviewed the
circumstances and supporting documents involved in this case, and have decided not to
conduct additional enforcement action or penalty assessment proceedings at this time. We
advise you to correct the item identified in this letter. Failure to do so will result in Alyeska
Pipeline Service Company being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer
to CPF 5-2017-5020W. Be advised that all material you submit in response to this
enforcement action is subject to being made publicly available. If you believe that any
portion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),
along with the complete original document you must provide a second copy of the document
with the portions you believe qualify for confidential treatment redacted and an explanation of
why you believe the redacted information qualifies for confidential treatment under 5 U.S.C.
552(b).
Sincerely,
Kim West
Acting Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 M. Chard (#153634)
Mr. Rod Hanson, Sr. Vice-President, Operations & Maintenance, Alyeska
2

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/520175020W>
- Source ID: `phmsa-enforcement`
- SHA-256: `4130b91a5b50c29ef50dba0006e3ca882007234011ee1a7bfe09fb6179451e90`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T13:58:28.365Z
- Document slug: `phmsa-enforcement-520175020w`

### Source metadata

```json
{
  "cpf": "520175020W",
  "operator": "ALYESKA PIPELINE SERVICE CO",
  "region": "Western",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.402(a)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
    {
      "name": "520175020W_Warning Letter_08102017.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520175020W/520175020W_Warning%20Letter_08102017.pdf",
      "bytes": 90899,
      "category": "agency_document"
    },
    {
      "name": "520175020W_Warning Letter_08102017_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520175020W/520175020W_Warning%20Letter_08102017_text.pdf",
      "bytes": 84213,
      "category": "agency_document"
    }
  ],
  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "ALYESKA PIPELINE SERVICE CO"
}
```
