# ALYESKA PIPELINE SERVICE CO — Notice of Amendment

- **operation:** document
- **citation:** CPF 520075042M
- **title:** ALYESKA PIPELINE SERVICE CO — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2007-11-27
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 195.266, 195.402(a), 195.402(c), 195.402(c)(10), 195.404(a)(2), 195.404(a)(3), 195.406(a)(1), 195.422(b), 195.428(a), 195.432(b), 195.452(i)(2), 195.49, 195.54, 195.555, 195.561, 195.563(a), 195.567(c).
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520075042m.md
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520075042M
**body:**

Notice of Amendment involving ALYESKA PIPELINE SERVICE CO. PHMSA's enforcement data identifies the cited regulations as 195.266,  195.402(a),  195.402(c),  195.402(c)(10),  195.404(a)(2),  195.404(a)(3),  195.406(a)(1),  195.422(b),  195.428(a),  195.432(b),  195.452(i)(2),  195.49,  195.54,  195.555,  195.561,  195.563(a),  195.567(c). The case was opened on 2007-11-27 and is reported as closed as of 2009-05-27. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520075042M_notice of amendment_11272007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075042M/520075042M_notice%20of%20amendment_11272007.pdf

520075042m_notice of amendment_11272007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075042M/520075042m_notice%20of%20amendment_11272007_text.pdf

520075042M_operator_response_03262008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075042M/520075042M_operator_response_03262008.pdf

520075042m_notice of amendment_11272007_text.pdf

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U. S. Department
of Transportation
Pipeline and
Hazardous Materials Safety
Administration
12300 W Dakota Ave, Suite 110
Lakewood, CO 80228
NOTICE OF AMENDMENT
VIA FEDEX AND FACSIMILE to 907 787-8330
November 27, 2007
Mr. Jim Johnson
Pipehne Vice President
Alyeska Pipeline Service Company
900 East Benson Blvd.
P. O. Box 196660
Anchorage, AK 99519-6660
CPF 5-2007-5042M
Dear Mr. Johnson:
On April 10-14, August 9-24, September 11-15, and October 16-20, 2006 representatives of
the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter
601 of 49 United States Code, inspected Alyeska Pipeline Service Company's (Alyeska)
procedures for reporting, construction, corrosion control, integrity management and operation
and maintenance in Anchorage and Fairbanks, Alaska.
PHMSA also investigated a series of pipehne failures that occurred on TAPS in December
2006 and January 2007. The first of these mcidents occurred on December 12, 2006, in
connection with Alyeska's operation of a scraper pig (Pig ¹ 67) between Pump Station 4 (PS4)
and PS9 on TAPS. Alyeska reported that the scraper pig was destroyed when it was pushed
mto the Mainhne Unit (MLU) strainer at PS7. This Notice of Amendment (NOA) addresses
the Pig ¹67 failure. The other failures are described and addressed in the companion Notice of
Probable Violation (NOPV) in this case. See 5-2007-5041.



On the basis of these inspections and mvestigations, PHMSA has identified apparent
inadequacies in Alyeska's plans and procedures, as described below:
$195. 422 Pipeline Repairs.
(b) No operator may use any pipe, valve, or fitting, for replacement in repairing
pipeline facilities, unless it is designed and constructed as required by this part.
Alyeska's procedures for operations, maintenance, repairs and construction of its pipeline
facihties are inadequate because they do not indicate which editions of standards and/or codes
are to be used. For example, Alyeska procedure, WP-3. 1, General Welding and Brazing
Requirements references API 1104 and ASME Section IX standards, but the procedure does
not specify the edition that is to be used. Part 195 incorporates by reference specific editions
of standards and codes Alyeska must amend its procedures to refer to the specific editions
referenced by Part 195.
$195. 49 Annual report
Beginning no later than June 15, 2005, each operator must annually complete and
submit DOT form RSPA F 7000-1. 1 for each type of hazardous liquid pipeline
facility operated at the end of the previous year. A separate report is required for
crude oil, HVL (including anhydrous ammonia), petroleum products, and carbon
dioxide pipelines. Operators are encouraged, but not required, to file an annual
report by June 15, 2004, for calendar year 2003.
Alyeska's OM-1 Section 9 procedures for making reports and notifications to the Government
are inadequate because they do not include a process for submittal of annual reports. Alyeska
must amend its OM-1 Section 9 procedures to include a process for submittal of annual reports
in accordance with )195. 49.
3. $195. 54 Accident reports.
(b) Whenever an operator receives any changes in the information reported or
additions to the original report on DOT Form 7000-1, it shall file a supplemental
report within 30 days.
Alyeska's OM-1 9 3. 5. 2 procedure for submitting accident reports is in adequate because it
does not require Alyeska to submit any changes in the information reported or additions to the
original DOT Form 7000-1 within 30 days. Alyeska's procedure states that changes or
additions ~ma be submitted within 30 days. Alyeska must amend its OM-1 9. 3. 5. 2 procedure
to indicate that changes shall be submitted within 30 days via the fihng of a supplemental
report.
4. $195. 266 Construction records.
A complete record that shows the following must be maintained by the operator
involved for the life of each pipeline facility:



(a) The total number of girth welds and the number nondestructively tested,
including the number rejected and the disposition of each rejected weld.
(b) The amount, location, and cover of each size of pipe installed.
(c) The location of each crossing of another pipeline.
(d) The location of each buried utility crossing.
(e) The location of each overhead crossing.
(f) The location of each valve and corrosion test station.
Alyeska's OM-1 10. 3. 1. 1 procedure for complying with construction and repair record
keepmg requirements is inadequate because it only explains that Alyeska has kept all records
m the past, rather than what Alyeska does m the present, and will do m the future, to retam
current girth weld records. Alyeska must amend its OM-1 10. 3. 1. 1 procedure to indicate that
all current and future girth weld records will be retamed
$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
commence, and appropriate parts shall be kept at locations where operations and
maintenance activities are conducted.
Alyeska's OM-1 procedures are inadequate because, in several instances, rather than setting
forth specific provisions on how Alyeska will comply with Part 195, the procedures simply
reference Part 195 as guidance. For example, Alyeska's OM-1 9. 3. 2. 1 procedure for reporting
Safety Related Conditions provides that the DOT report shall be submitted accordmg to the
requirements of 49 C. F R. 195. Alyeska must amend its OM-1 procedures to mclude specific
provisions for comphance with applicable Part 195 regulations. Alyeska may not simply refer
readers of OM-1 to Part 195 for guidance.
6. $195. 402 Procedural manual for operations, maintenance, and emergencies.
(c) Maintenance and normal operations. The manual required by paragraph (a)
of this section must include procedures for the following to provide safety during
maintenance and normal operations:
(4) Determining which pipeline facilities are located in areas that would
require an immediate response by the operator to prevent hazards to the
public if the facilities failed or malfunctioned.
(6) Minimizing the potential for hazards identified under paragraph (c)(4)
of this section and the possibility of recurrence of accidents analyzed under
paragraph (c)(5) of this section.



Alyeska's OM-1 procedures are madequate because they do not give guidance or refer to
guidance to minimize the hazards to the pubhc identified under (c)(4). Alyeska must amend
its OM-1 procedures to include provisions to give guidance or refer to guidance to minimize
the potentials for hazards as identified under (c)(4).
$195. 402 Procedural manual for operations, maintenance, and emergencies.
(c) Maintenance and normal operations. The manual required by paragraph (a)
of this section must include procedures for the following to provide safety during
maintenance and normal operations:
(10) Abandoning pipeline facilities, including safe disconnection from an
operating pipeline system, purging of combustibles, and sealing abandoned
facilities left in place to minimize safety and environmental hazards. For
each abandoned offshore pipeline facility or each abandoned onshore
pipeline facility that crosses over, under or through commercially
navigable waterways the last operator of that facility must file a report
upon abandonment of that facility in accordance with $195. 59 of this part.
Alyeska's OM-6. 7. 1 procedure for abandonmg pipeline facilities is inadequate because it does
not provide guidance or reference a procedure for purging combustibles &om abandoned
facihties. Alyeska must amend OM-6. 7. 1 to include procedures on how combustibles are to
be purged from a pipeline facility
8. $195. 404 Maps and Records.
(a) Each operator shall maintain current maps and records of its pipeline systems
that include at least the following information;
(2) All crossings of public roads, railroads, rivers, buried utilities, and
foreign pipelines.
Alyeska's OM-1 10. 3. 1. 1 procedures regarding the maintenance of maps and records of
pipeline crossings, utilities and other pipeline data are inadequate because they do not indicate
that this data is available on the Alyeska intranet website. Alyeska indicated that this
mformation was in fact available to all company employees on the website. Alyeska must
amend OM-1 10. 3. 1. 1 to indicate that this data is available on Alyeska's intranet website.
9. $195. 404 Maps and Records.
(a) Each operator shall maintain current maps and records of its pipeline systems
that include at least the following information;
(3) The maximum operating pressure of each pipeline.



Alyeska's OM-1 10. 3. 1. 1 procedure is inadequate because it does not indicate where the
official record of the MOP of TAPS resides. Alyeska must amend OM-1 10. 3. 1 1 to mdicate
the location of the official record of MOP.
10. $195. 406 Maximum operating pressure.
(a) Except for surge pressures and other variations from normal operations, no
operator may operate a pipeline at a pressure that exceeds any of the following:
(1) The internal design pressure of the pipe determined in accordance with
5195. 106.
Alyeska's OM-1 1. 7 procedures are inadequate because they do not provide or reference the
design formula used for determining the design pressure and do not provide the design factors.
Alyeska's OM-1 1. 7 includes in the definition of MOP, "the maximum internal pressure of the
pipe as determined by the design factor from the applicable code, the nominal wall thickness
and the specified minimum yield strength for the pipe. "
11. $195. 428 Overpressure safety devices and overfill protection systems
(a) Except as provided in paragraph (b) of this section, each operator shall, at
intervals not exceeding 15 months, but at least once each calendar year, or in the
case of pipelines used to carry highly volatile liquids, at intervals not to exceed 7/i
months, but at least twice each calendar year, inspect and test each pressure
limiting device, relief valve, pressure regulator, or other item of pressure control
equipment to determine that it is functioning properly, is in good mechanical
condition, and is adequate from the standpoint of capacity and reliability of
operation for the service in which it is used.
Alyeska's OM-1 Section 7. 1 procedures are inadequate because they do not list the pressure
transmitters that send signals to Alyeska's Operations Control Center (OCC) as pressure
control equipment. These devices are considered pressure control equipment and are sub]ect
to the requirements of $195. 428.
Alyeska's OM-1 Section 7 procedures, including Table 7. 1, are also inadequate because they
do not list a number of mainhne speed controllers that are used to prevent pipeline
overpressure While some of these speed controllers are listed m OM-1 2. 4. 1, they are not
listed m Section 7 or Table 7. 1 Alyeska must Amend OM-1 Section 7, including table 7. 1, to
include the Following overpressure devices: PIC-X01 Suction Pressure Controller; PIC-X03,
Suction Pressure Rate of Rise, PIC-X04, Suction Pressure Relief Controller; PSH-X04,
Suction Pressure Relief Switch; PIC-X02, Discharge Pressure Speed Controller; PIC-X05,
Discharge Pressure Rehef Controller; and PSH-X05, Discharge Pressure Rehef Switch.
12. $195. 428 Overpressure safety devices and overfill protection systems



(a) Except as provided in paragraph (b) of this section, each operator shall, at
intervals not exceeding 15 months, but at least once each calendar year, or in the
case of pipelines used to carry highly volatile liquids, at intervals not to exceed 7/i
months, but at least twice each calendar year, inspect and test each pressure
limiting device, relief valve, pressure regulator, or other item of pressure control
equipment to determine that it is functioning properly, is in good mechanical
condition, and is adequate from the standpoint of capacity and reliability of
operation for the service in which it is used.
Alyeska's OM-1 procedures for inspectmg and testing thermal relief valves are madequate
because they state that the valves must be inspected annually under ASME B31. 4 and not once
each calendar year, not to exceed 15 months, as required under Part 195. Alyeska must amend
OM-1 to reflect the specific time mterval requirement provided by (195. 428(a).
13. $195. 432 Breakout tanks.
(b) Each operator shall inspect the physical integrity of in-service atmospheric
and low-pressure steel aboveground breakout tanks according to section 4 of API
Standard 653. However, if structural conditions prevent access to the tank
bottom, the bottom integrity may be assessed according to a plan included in the
operations and maintenance manual under $195. 402(c)(3).
Alyeska's OM-1 Section 7. 3. 5 and 12. 8. 1 procedures are inadequate because they neither
include nor reference clear guidance for the internal inspections that must be performed
according to (195. 432 and Section 6 of API 653 as referenced therein. Alyeska must amen/
OM-1 Sections 7. 3. 5 and 12. 8. 1 to include or reference guidance on internal inspections in
accordance with Section 6 of API 653.
14. $195. 432 Breakout tanks.
(b) Each operator shall inspect the physical integrity of in-service atmospheric
and low-pressure steel aboveground breakout tanks according to section 4 of API
Standard 653. However, if structural conditions prevent access to the tank
bottom, the bottom integrity may be assessed according to a plan included in the
operations and maintenance manual under $195. 402(c)(3).
Alyeska's OM-1 Section 7. 3 5 and 12. 8. 1 procedures are inadequate because they do not
require that the actual mternal inspection mterval shall be set to ensure that the bottom plate
minimum thickness at the next inspection shall not be less than the values listed in Section 6 of
API 653. Alyeska must amend OM-1 Section 7. 3. 5 and 12. 8. 1 to include or reference
guidance on setting inspection intervals in accordance with Section 6 of API Standard 653.



15. $195. 555 What are the qualifications for supervisors?
You must require and verify that supervisors maintain a thorough knowledge of that
portion of the corrosion control procedures established under Sec. 195. 402(c)(3) for
which they are responsible for insuring compliance.
Alyeska's OM-1 Section 12 2 procedures are inadequate because they do not include or
reference a method for insuring and documenting that corrosion control supervisors have a
thorough knowledge of corrosion control procedures for which they are responsible Alyeska
must amend OM-1 Section 12. 2 to include or reference a method for insuring and
documenting that corrosion control supervisors have a thorough knowledge of corrosion
control procedures for which they are responsible.
16. $195. 561 When must I inspect pipe coating used for external corrosion control?
(a) You must inspect all external pipe coating required by Sec. 195. 557 just prior
to lowering the pipe into the ditch or submerging the pipe.
(b) You must repair any coating damage discovered.
Alyeska's OM-1 coating procedures are inadequate because they do not state that the hohday
inspection and repair procedures reside under the individual coating specifications, such as
Specification B-420, etc. Alyeska must amend OM-1 to state that the hohday inspection and
repair procedures reside under the individual coating specifications.
17. $195. 563 Which pipelines must have cathodic protection?
(a) Each buried or submerged pipeline that is constructed, relocated, replaced, or
otherwise changed after the applicable date in Sec. 195. 401(c) must have cathodic
protection. The cathodic protection must be in operation not later than 1 year
after the pipeline is constructed, relocated, replaced, or otherwise changed, as
applicable.
Alyeska's OM-1 procedures are madequate because they do not require that cathodic
protection must be applied to a pipehne within one year of construction as required by
)195. 563(a). Alyeska must amend OM-1 to reflect the specific requirements of )195. 563(a).
18. $195. 563 Which pipelines must have cathodic protection?
(a) Each buried or submerged pipeline that is constructed, relocated, replaced, or
otherwise changed after the applicable date in Sec. 195. 401(c) must have cathodic
protection. The cathodic protection must be in operation not later than 1 year
after the pipeline is constructed, relocated, replaced, or otherwise changed, as
applicable.



Alyeska's OM-1 procedures are inadequate because they do not include or reference guidance
for pipehnes that have been converted under $195. 5, as required by $195. 563(a). Alyeska
must amend OM-1 to reflect the specific requirements of $195. 563(a)
19. $195. 567 Which pipelines must have test leads and what must I do to install and
maintain the leads?
(c) Maintenance. You must maintain the test lead wires in a condition that
enables you to obtain electrical measurements to determine whether cathodic
protection complies with Sec. 195. 571.
Alyeska's OM-1 Section 12. 5 procedures are inadequate because they do not require that test
lead repairs be completed as soon as possible to ensure cathodic protection measurements can
be made as required under Part 195. Alyeska must amend OM-1 Section 12. 5 to require that
test lead repairs are completed as soon as possible.
20. $195. 452(i) 8'hat preventive and mitigative measures must an operator take to
protect the high consequence area?
(1) General requirements. An operator must take measures to prevent and
mitigate the consequences of a pipeline failure that could affect a high
consequence area. These measures include conducting a risk analysis of the
pipeline segment to identify additional actions to enhance public safety or
environmental protection . . .
(2) Risk analysis criteria. In identifying the need for additional preventive and
mitigative measures, an operator must evaluate the likelihood of a pipeline release
occurring and how a release could affect the high consequence area. This
determination must consider all relevant risk factors, including, but not limited to:
(i) Terrain surrounding the pipeline segment, including drainage systems such as
small streams and other smaller waterways that could act as a conduit to the high
consequence area; (ii) Elevation profile; (iii) Characteristics of the product
transported; (iv) Amount of product that could be released; (v) Possibility of a
spillage in a farm field following the drain tile into a waterway; (vi) Ditches along
side a roadway the pipeline crosses; (vii) Physical support of the pipeline segment
such as by a cable suspension bridge; (viii) Exposure of the pipeline to operating
pressure exceeding established maximum operating pressure.
Alyeska's procedures for risk analysis are inadequate because they underestimate
segment risk and may be sensitive to segment length assumptions:
a. Risk ranking of pipehne segments is, in part, a function of segment length. Given
that risk ranking is based on numeric likelihood criteria, short segment lengths have the
potential to artificially lower the likelihood classification. Alyeska must perform
further analysis to understand if the segmentation approach artificially results in some
segments being classified as category 4 (no P&M evaluations required) or other higher
risk categories.



b. The current segment risk ranking only considers the worst case risk of the three
considered release sizes — small, medium, large. As each of these cases is possible,
actual segment risk is the sum of the respective release cases. This may increase the
number of segments classified as risk categories 1-3, which require the evaluation of
P&M measures (and/or increase the number of segments in the higher risk categories
1-2).
Alyeska must revise its procedures to comply with 195. 452
21. $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.
(c) Maintenance and normal operations. The manual required by paragraph (a)
of this section must include procedures for the following to provide safety during
maintenance and normal operations:
(3) Operating, maintaining, and repairing the pipeline system in accordance with
each of the requirements of this subpart and subpart H of this part.
Alyeska's pigging procedures did not address the risks associated with passing a
scraper pig through Pump Station 7 (PS7) with the piping configuration in place at the
time of the pig ruu. Alyeaka'a procedure (OCC-2. 10, Rev 8, dated 08/23/06), ~Sera er
Pi s: Launchin Passin and Receivin and SAFE procedure, 3. 4. 14. -07, Rev 2,
10/25/05, Manual i assa e at PS 7) did not adequately address the risks associated
with passing a scraper pig through Pump Station piping. Alyeska's pigging procedures
were not updated as a result of new information. For example, Alyeska had data that
indicated that certain pig bars were missing from PS7. Alyeska did not modify its
pigging procedure to reflect the risks of losing a pig into the Mainhne Unit as a result
of the missing pig bars.
The cleaning pig launched from PS4 December 16, 2006 did not arrive at PS9 as
scheduled. Alyeska indicated that the cleaning pig was forced mto the Mainhne Unit
(MLU) strainer at PS7. Alyeska offered a root cause analysis that asserted that:
a The center pig bar at the PS07 S2 branch connection was missing. The report
confirms that in 2005, when check valve CKV67A was installed, photographic
evidence showed that the middle pig bar at the S2 branch connection was missing.
b. The newly installed mainhne CKV67A clapper at PS7 was not raised during the
Pig ¹ 67 run. This check valve installation was not identified in Alyeska's pig
passing procedures. Since the cleaning pig incident at PS7, Alyeska has revised its
procedure for launching, passing, and receiving scraper pigs. The new procedure
now requires the clapper on CKV 67A to be raised whenever a pig is passing PS7



Alyeska has also revised its procedure for launching, passing, and receiving
scraper pigs. The new procedure now requires the pump house at PS07 to be in the
"isolate configuration" during all pig runs.
PHMSA believes that if the pig bars had been properly installed in 2005 and the procedures
for raising the clapper on check valve and isolating the pumps had been in place for the pig run
the incident would not have occurred. Alyeska must amend its pigging procedures to
adequately address the risks presented by changes in the pipeline environment that could affect
safety during pig runs
Res onse to this Notice
This Notice is provided pursuant to 49 U. S. C. ) 60108(a) and 49 C. F. R. ) 190. 237. Enclosed
as part of this Notice is a document entitled Response Options for Pipehne Operators in
Comphance Proceedings. Please refer to this document and note the response options. 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 quahfy for
confidential treatment redacted and an explanation of why you beheve the redacted
information qualifies for confidential treatment under 5 U. S. C. $ 552(b). Failure to respond
within 30 days of receipt of this Notice will waive Alyeska's right to contest the allegations in
this Notice and authorize the Associate Administrator for Pipeline Safety to find facts as
alleged in this Notice without further notice to Alyeska and to issue a Final Order.
If, after opportunity for a hearing, Alyeska's plans or procedures are found inadequate as
alleged in this Notice, Alyeska may be ordered to amend its plans or procedures to correct the
inadequacies (49 C. F R $ 190. 237) If Alyeska is not contesting this Notice, we propose that
you submit Alyeska's amended procedures to my office within 30 days of receipt of this
Notice. This period may be extended by written request for good cause. Once the
inadequacies identified herein have been addressed in Alyeska's amended procedures, this
enforcement action will be closed.
In correspondence concerning this matter, please refer to CPF 5-2007-5042M, for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipehne Operators in Comphance Proceedings
10



O
U S. Department
of Transportation
Pipeline and
Hazardous Materials Safety
Administration
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12300 W Dakota Ave, Suite 110
Lakewood, CO 80228
VIA FEDEX AND FACSIMILE to 907 787-8330
November 27, 2007
Mr. Jim Johnson
Pipehne Vice President
Alyeska Pipeline Service Company
900 East Benson Blvd.
P. O. Box 196660
Anchorage, AK 99519-6660
CPF 5-2007-5041
CPF 5-2007-5042M
Dear Mr. Johnson.
This letter transmits notices of two enforcement actions brought by the Pipehne and Hazardous
Materials Safety Administration (PHMSA) against Alyeska Pipeline Service Company, as
operator of the Trans Alaska Pipeline System (TAPS). The enclosed Notice of Proposed
Violation and Notice of Amendment recite proposed findings based on inspections and
incident investigations conducted by PHMSA in 2006 and 2007. On the basis of these
findings, PHMSA alleges specified violations of the Federal Pipehne Safety Regulations, 49
C. F. R. Part 195, and proposes to assess civil penalties and require specific corrective actions,
including development and implementation of revised safety procedures.
Without prejudice to Alyeska's right to a hearing, this will acknowledge the parties' ongoing
discussions concerning actions Alyeska has taken to correct certain deficiencies cited by
PHMSA and prevent future violations. Beginning last spring, PHMSA also has been working
with Alyeska on development of broader risk-management procedures and controls. With an
eye to future conditions and challenges, we expect this "Unified Plan" to address management
processes, m addition to engmeering and mamtenance, and to prescribe standards in excess of



PHMSA's minimum regulatory requirements, We are encouraged by Alyeska's most recent
progress and look forward to workmg with you to advance development and implementation
of the Unified Plan.
Sincerely,
Chris oidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
Enclosures: Notice of Probable Violation and Proposed Civil Penalty CPF 5-2007-5041
Proposed Compliance Order CPF 5-2007-5041
Notice of Amendment CPF 5-2007-5042M
Response Options for Pipeline Operators in Compliance Proceedings
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