# ALYESKA PIPELINE SERVICE CO — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 520085002
- **title:** ALYESKA PIPELINE SERVICE CO — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2008-04-01
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.116(e), 195.401(b), 195.406(b), 195.428(a), 195.438, 195.573(c), 195.573(e), 195.579(c).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520085002.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520085002.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520085002
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520085002
**body:**

Notice of Probable Violation involving ALYESKA PIPELINE SERVICE CO. PHMSA's enforcement data identifies the cited regulations as 195.116(e),  195.401(b),  195.406(b),  195.428(a),  195.438,  195.573(c),  195.573(e),  195.579(c). The case was opened on 2008-04-01 and is reported as closed as of 2011-06-20. Proposed civil penalty: $112,000. Assessed civil penalty: $112,000. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520085002_amended NOPV PCP PCO_10152008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085002/520085002_amended%20NOPV%20PCP%20PCO_10152008.pdf

520085002_amended nopv pcp pco_10152008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085002/520085002_amended%20nopv%20pcp%20pco_10152008_text.pdf

520085002_closure letter_06202011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085002/520085002_closure%20letter_06202011.pdf

520085002_closure letter_06202011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085002/520085002_closure%20letter_06202011_text.pdf

520085002_Final Order_03212011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085002/520085002_Final%20Order_03212011.pdf

520085002_Final Order_03212011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085002/520085002_Final%20Order_03212011_text.pdf

520085002_NOPV PCP PCO_04012008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085002/520085002_NOPV%20PCP%20PCO_04012008.pdf

520085002_nopv pcp pco_04012008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085002/520085002_nopv%20pcp%20pco_04012008_text.pdf

520085002_operator response_05222008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085002/520085002_operator%20response_05222008.pdf

520085002_closure letter_06202011_text.pdf

VIA UPS : 1Z WR2 588 03 9135 5258
June 20, 2011
Mr. Mike Joynor
Senior Vice President
Oil Movements, Engineering and Pipeline
Alyeska Pipeline Service Company
900 East Benson Blvd.
P.O. Box 196660
Anchorage, AK 99519-6660
CPF 5-2008-5002
Dear Mr. Joynor:
On March 21, 2010, the Pipeline and Hazardous Materials Safety Administration (PHMSA)
issued to Alyeska Pipeline Service Company (Alyeska) a Final Order in the above-referenced
case. This Order included a Compliance Order and Civil Penalty assessment. Based on our
review of the documentation you provided and confirmation of payment of the civil penalty
paid on April 4, 2011, it has been determined that you have complied with the terms of this
Order.
Accordingly, this case is now closed and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
Dennis Hinnah
Duty Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 B. Flanders (#118831)

520085002_nopv pcp pco_04012008_text.pdf

o
U S. Department
of Transportation
Pipeline and
Hazardous Materials Safety
Administration
12300 W Dakota Ave, Suite 110
Lakewood, CO 80228
NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPLIANCE ORDER
CERTIFIED MAIL - RETURN RECEIPT RE UESTED
April 1, 2008
Mr. Jim Johnson
Pipeline Vice President
Alyeska Pipeline Service Company
900 East Benson Blvd.
P. O. Box 196606
Anchorage, AK 99519
CPF 5-2008-5002
Dear Mr. Johnson;
On July 8 to 13, 2007, 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 (ASPC) pipeline segment between Pump Station 1 and Milepost
126 near Prudhoe Bay, Alaska.
As a result of the inspection, it appears that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the
probable violations are:
1. $195. 116 Valves.
(e) Each valve other than a check valve must be equipped with a
means for clearly indicating the position of the valve (open, closed, etc. ).



During the inspection, MGV 10A was found without a valve position indicator.
Evidence: Photograph of MGV 10A without valve position indicator.
2. $195. 401 General requirements.
(b) Whenever an operator discovers any condition that could adversely affect the
safe operation of its pipeline system, it shall correct it within a reasonable time.
However, if the condition is of such a nature that it presents an immediate hazard
to persons or property, the operator may not operate the affected part of the system
until it has corrected the unsafe condition.
A structural (non-pressure containment) sleeve was installed in 1990 at Mile Post (MP)
57. 785, due to internal corrosion. Alyeska is operating the pipeline with an
indeterminate amount of remaining pipe wall thickness under this sleeve. Alyeska did
not correct this condition within a reasonable time even though a commitment to cut out
and replace was made for 2007,
A 15-foot structural (non-pressure containment) sleeve was installed in 1990 at MP
57. 785 due to internal corrosion, Alyeska monitored the corrosion at this location with
Ultrasonic Testing (UT) pigs to determine the depth of corrosion until 2001. At that
time, Alyeska determined that wax was blocking the ability of the UT pig to accurately
predict the corrosion depth. In 2004, a Magnetic flux pig was run and it also was unable
to accurately assess the corrosion depth. Alyeska is operating the pipeline with an
indeterminate amount of remaining pipe wall thickness under a sleeve design that cannot
contain pressure. Alyeska did not correct this condition within a reasonable time, This
issue was reported to Alyeska in January 2006 and APSC management committed to
PHMSA they would cut out this sleeve in 2007. Alyeska has now postponed this work
until 2008 or 2009. This is not correction of a condition within a reasonable time.
Evidence;
1. '
Safety Related Condition Report 890028 Report listing internal corrosion as the
cause, with maximum pit depth. 177.
2. Alyeska as built data base, listing 15 foot structural sleeve. (Not a pressure
containing sleeve. A structural sleeve will not stop crude oil from leaking onto the
ground, when the internal corrosion eats through the pipe wall).
3. Alyeska repair procedure for internal corrosion requires a pressure containing sleeve
or replacement of pipe.
4. UT Pig data 1994-2001. (2001 pig having trouble with wax at Station 305116. 6).
5. 2003 BJ MFL Pig did not report any corrosion at sleeve, due to the additional metal
thickness of the sleeve.



$195. 406 Maximum operating pressure.
(b) No operator may permit the pressure in a pipeline during surges or other
variations from normal operations to exceed 110 percent of the operating pressure
limit established under paragraph (a) of this section. Each operator must provide
adequate controls and protective equipment to control the pressure within this
limit.
Alyeska's Sadlerochit meter piping at Pump Station 1 has a maximum operating
pressure (MOP) of 275 psig (150 ANSI class, ) and BP's incoming piping to the meter
has a MOP up to 740 psig (300 ANSI class). BP's surge report stated that BP's
maximum discharge pressure has been limited by pressure shutdown switches at GC-1,
FS-1 and FS-3, Alyeska must provide adequate controls and protective equipment to
control the pressure within the maximum operating pressure. If BP switches are utilized,
they must be maintained as DOT critical safety devices. Alyeska's "OM-1, Procedural
Manual for Operations, Maintenance and Emergencies, " Section 7 does not indicate that
Alyeska must test and maintain these pressure switches,
Evidence:
l. In Alyeska's response to request for specific information, it is stated that Alyeska
meter runs WOA & EOA (Sadlerochit oil) has a MOP of 275 psig.
2. BP's surge analysis report, Executive Summary, states that the high pressure
switches are DOT critical safety devices,
3. OM-1 section 2, surge pressure control, does not list high pressure switches at GC2,
FS1, and FS3.
$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 Kuparuk piping has a MOP of 1180 psig, while the Kuparuk pipeline system
has a MOP of 1440 psig. Alyeska has installed a pressure transmitter (31-PT-013A) to
protect the 1180 psig piping from overpressure. Alyeska's "OM-1, Procedural Manual
for Operations, Maintenance and Emergencies, " Section 7 does not address this pressure
transmitter or list it as required for testing. Alyeska presented records at Pump Station 1
of performing calibration of this pressure transmitter, indicating that transmitters were
calibrated annually.



Evidence:
l. In Alyeska's response to request for specific information, it states that Alyeska's
incoming Kuparuk pipe has a MOP 1180 psig, while Kuparuk's incoming pipeline
has an MOP of 1415 psig.
2. Pressure transmitter calibration sheets for 2005, 2006.
3. OM-1 Section 7, does not list 31-PT-013A as a pressure-controlling device.
$195. 573 What must I do to monitor external corrosion control?
(a) Protected pipelines. You must do the following to determine whether cathodic
protection required by this subpart complies with Sec. 195. 571:
(1) Conduct tests on the protected pipeline at least once each calendar year, but
with intervals not exceeding 15 months. However, if tests at those intervals are
impractical for separately protected short sections of bare or ineffectively coated
pipelines, testing may be done at least once every 3 calendar years, but with
intervals not exceeding 39 months.
(e) Corrective action. You must correct any identified deficiency in corrosion
control as required by Sec. 195. 401(b).
An area (MP 12. 2-13. 2) of the pipeline was found to have inadequate cathodic protection
(CP). These low CP readings were confirmed by Close Interval Surveys conducted in
2003, 2004, 2005, and 2006. This low CP area was further confirmed by 2002-2006-
coupon readings. This section of the pipeline did not meet criteria set forth in section
195. 571. This area of low CP levels was reported on a 2002 inspection (see PHMSA
Final Order, CPF 5-2003-5002).
Evidence;
1. 2003-2006 CIS, Below -850 mil volt.
2. 2001-, 2006 Coupon survey, Below -850 mil volt and -100 mv shift.
3. Final Order CPF 5-2003-5002, page 3, Item 6, First allegation.
$195. 573 What must I do to monitor external corrosion control?
(c) Rectifiers and other devices. You must electrically check for proper
performance each device in the first column at the frequency stated in the second
column.



Device
Rectifier. .
Check fre uenc
At least six times each calendar year,
but with intervals not exceeding 2 Ii
months
Reverse current switch.
Diode.
Interference bond whose failure would
'eo ardize structural rotection
Other interference bond . . . . . . . . . . . . , . . . . . . . . . .
At least once each calendar year, but
with intervals not exceeding 15
months.
(e) Corrective action. You must correct any identified deficiency in corrosion
control as required by Sec. 195. 401(b).
A rectifier powered by wind (31 EE 125) was installed in October 2003 at MP 12, 5.
Records indicated that the rectifier was only performing correctly on 11 occasions out of
the 35 scheduled readings taken between October 2003 and July 2007.
Evidence:
1. Rectifier readings 2003-2007, When operational, the output should be in the range of
5 volts and 1 amp.
2. Final Order CPF 5-2003-5002, page 3, Item 6, First allegation.
$195. 438 Smoking or open flames.
Each operator shall prohibit smoking and open flames in each pump station area
and each breakout tank area where there is a possibility of the leakage of a
flammable hazardous liquid or of the presence of flammable vapors.
During the inspection, "No Smoking" signs were missing or faded at the following valve
locations CKV 5, 8, 9, 10, 14, 16, 17, 18, 22, and MGV 5A andlOA.
$195. 579 What must I do to mitigate internal corrosion?
(c) Removing pipe. Whenever you remove pipe from a pipeline, you must inspect
the internal surface of the pipe for evidence of corrosion. If you find internal
corrosion requiring corrective action under Sec. 195. 585, you must investigate
circumferentially and longitudinally beyond the removed pipe (by visual
examination, indirect method, or both) to determine whether additional corrosion
requiring remedial action exists in the vicinity of the removed pipe.
Alyeska has removed piping associated with the Endicott meter run. Alyeska did not
provide an inspection report for this pipe for internal corrosion,



Pro osed Civil Penalt
Under 49 United States Code, $ 60122, you are subject to a civil penalty not to exceed $100, 000
for each violation for each day the violation persists up to a maximum of $1, 000, 000 for any
related series of violations. The Compliance Officer has reviewed the circumstances and
supporting documentation involved in the above probable violations and has recommended that
you be preliminarily assessed a civil penalty of $112, 000. 00 as follows:
Item Number PENALTY
$56, 000
$56, 000
Warnin Items
With respect to Items 7 and 8, 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 promptly correct this item. Be advised
that failure to do so may result in Alyeska Pipeline Service Company being subject to additional
enforcement action.
Pro osed Com liance Order
With respect to Items I, 2, 3, and 4 pursuant to 49 United States Code $ 60118, the Pipeline and
Hazardous Materials Safety Administration proposes to issue a Compliance Order to Alyesk~
Pipeline Service Company. Please refer to the Proposed Compliance Order, which is enclosed
and made a part of this Notice.
Res onse to this Notice
Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators
in Compliance 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 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). If you do not respond within 30 days
of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this
Notice and authorizes the Associate Administrator for Pipehne Safety to find facts as alleged in
this Notice without further notice to you and to issue a Final Order.



In your correspondence on this matter, please refer to CPF 5-200S-5002 and for each document
you submit, please provide a copy in electronic format whenever possible.
Sincerely,
Chris oidal
Director, Western Region
Pipehne and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 B. Flanders (0118831)
Enclosures' Proposed Compliance Order
Response Options for Pipeline Operators in Compliance Proceedings



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code $ 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Alyeska Pipeline Service Company a
Compliance Order incorporating the following remedial requirements to require that the
Alyeska Pipeline Service Company complies with the pipeline safety regulations:
1. In regard to Item Number 1 of the Notice pertaining to the missing valve position
indicator on MV 10A, Alyeska Pipeline Service Company shall install a valve
position indicator on MV 10A,
In regard to Item Number 2 of the Notice pertaining to the structural sleeve at
MP 57. 785, Alyeska Pipeline Service Company shall remove and inspect the
internal corrosion inside the pipe under the sleeve during the pump station ¹ 2
pipe replacement now scheduled for 2008. PHMSA shall be notified immediately
if this sleeve is not removed in 2008.
In regard to Item Number 3 of the Notice pertaining to the pressure shutdown
switches at GC-I, FS-1 and FS-3, Alyeska shall maintain these pressure
shutdown switches as DOT critical safety devices or shall install adequate
pressure control equipment within its own facihties at Pump Station 1.
Alyeska Pipeline Service Company shall revise "OM-1, Procedural Manual for
Operations, Maintenance Atmospheric Corrosion and Emergencies", Section 7,
to indicate that these pressure shutdown switches are DOT critical safety devices
or to reflect any additional pressure control equipment Alyeska installs at its own
facilities at Pump Station 1. Alyeska shall also arrange to have such pressure
shutdown switches and any additional pressure control equipment tested annually
and shall maintain and make available to PHMSA the records of such testing.
In regard to Item Number 4 of the Notice pertaining to the pressure transmitter
(31-PT-013A) on the Kuparuk pipeline incoming line to Alyeska. This pressure
transmitter shall be maintained as DOT critical safety devices.
Alyeska Pipeline Service Company shall revise "OM-1, Procedural Manual for
Operations, Maintenance and Emergencies", Section 7, to indicate that these
pressure shutdown switches are DOT critical safety devices. Alyeska shall also
conduct annual tests of these pressure shutdown switches and shall maintain and
make available to PHMSA the records of such testing.
Alyeska Pipeline Service Company shall complete the above-listed requirements,
and submit documentation of such completion within 180 days of receipt of the
Final Order.



Alyeska Pipeline Service Company shall maintain documentation of the safety
improvement costs associated with fulfilling this Compliance Order and submit
the total to Chris Hoidal, Director, Western, Pipeline and Hazardous Materials
Safety Administration. Costs shall be reported in two categories: 1) total cost
associated with preparation/revision of plans, procedures, studies and analyses,
and 2) total cost associated with replacements, additions and other changes to
pipeline infrastructure.

520085002_amended nopv pcp pco_10152008_text.pdf

U S. Department
of Transpottahon
Pipelline and
Hazardous Matsrialls Safety
Admirtistmtiiort
12300 W Dakota Ave, Suite 110
Lakewood, CO 80228
October 15, 2008
Mr Kevin Hostler
President
Alyeska Pipehne Service Company
900 East Benson Blvd
P. O. Box 196660
Anchorage, AIZ 99519-6660
Bear Mr. Hostler
On April 1, 2008, I issued a Notice of Probable Violation, Proposed Civil Penalty, and Proposed
Comphance Order to Alyeska regarding probable violations found during last year's inspection of
the facihties between Pump Station 1 and Milepost 126 When the Proposed Order was written,
two corrective items were inadvertently omitted I am resubmitting that letter in its entirety below
along with the revisions in underhned itahcs Because we are amending this Proposed Order,
Alyeska will have another 30 days to respond
On July 8 to 13, 2007, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Alyeska
Pipehne Service Company's (ASPC) pipehne segment between Pump Station 1 and Milepost 126
near Prudhoe Bay, Alaska.
As a result of the inspection, it appears that you have committed probable violations of the
Pipehne Safety Regulations, Title 49, Code of Federal Regulations The items inspected and the
probable violations are



During the inspection, MGV 10A was found without a valve position nidicator
Evidence: Photograph of MGV 10A without valve position indicator
A structural (non-pressure containment) sleeve was installed kn 1990 at Mile Post (MP)
57. 785, due to mternal corrosion. Alyeska is operating the pipehne with an indeterminate
amount of remaining pipe wall thickness under this sleeve. Alyeska did not correct this
condition withm a reasonable time even though a commitment to cut out and replace was
made for 2007.
A 15-foot structural (non-pressure containment) sleeve was installed in 1990 at MP 57. 785
due to internal corrosion. Alyeska monitored the corrosion at this location with Ultrasonic
Testing (UT) pigs to determine the depth of corrosion until 2001 At that time, Alyeska
determmed that wax was blocking the abihty of the UT pig to accurately predict the
corrosion depth In 2004, a Magnetic flux pig was run and it also was unable to accurately
assess the corrosion depth Alyeska is operating the pipehne with an indetermmate amount
of remaining pipe wall thickness under a sleeve design that cannot contaui pressure.
Alyeska dhd not correct this condition within a reasonable time This issue was reported to
Alyeska kn January 2006 and APSC management committed to PHMSA they would cut
out this sleeve in 2007 Alyeska has now postponed this work until 2008 or 2009 This is
not correction of a condition withm a reasonable time
Evidence:
1 Safety Related Condition Repokt 890028 Report hsting internal corrosion as the cause,
with maximum pit depth. 177
2 Alyeska as built data base, hsting 15 foot structural sleeve. (Not a pressure containing
sleeve A structural sleeve will not stop crude oil from leaking onto the ground, when
the internal corrosion eats through the pipe wall)
3 Alyeska repair procedure for internal corrosion requires a pressure containing sleeve or
replacement of pipe
4. UT Pig data 1994-2001 (2001 pig having trouble with wax at Station 305116 6)



5 2003 BJ MFL Pig did not report any corrosion at sleeve, due to the additional metal
thicloiess of the sleeve
Alyeska's Sadlerochit meter pipmg at Pump Station 1 has a maximum operating pressure
(MOP) of 275 psig (150 ANSI class, ) and BP's nicomnig piping to the meter has a MOP
up to 740 psig (300 ANSI class). BP's surge report stated that BP's maximum discharge
pressure has been hmited by pressure shutdown switches at GC-1, FS-1 and FS-3
Alyeska must provide adequate controls and protective equipment to control the pressure
within the maximum operating pressure If BP switches are utihzed, they must be
maintained as DOT critical safety devices. Alyeska's "OM-1, Procedural Manual for
Operations, Manitenance and Emergencies, " Section 7 does not indicate that Alyeska must
test and maintain these pressure switches
1. In Alyeska's response to request for specific information, it is stated that Alyesk@
meter runs WOA A EOA (Sadlerochit oil) has a MOP of 275 psig
2. BP's surge analysis report, Executive Summary, states that the high pressure switches
are DOT critical safety devices.
3 OM-1 section 2, surge pressure control, does not hst high pressure switches at GC2,
FS1, and FS3
(a) Except as provided in paragraph (b) of this section, each operator shaW, at
intervals not exceeding 15 months, but at least once each calendar year, or in the case
of pipehnes used to carry highly voiiatile hqmds, at intervals not to exceed 7/2 months,
but at least twice each calendar year, inspect and test each pressure hmiting 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 Kuparuk piping has a MOP of 1180 psig, while the Kuparuk pipehne system has
a MOP of 1440 psig Alyeska has installed a pressure transmitter (31-PT-013A) to protect
the 1180 psig pipnig from overpressure Alyeska's "OM-1, Procedural Manual for
Operations, Maintenance and Emergencies, " Section 7 does not address this pressure
transmitter or hst it as required for testing Alyeska presented records at Pump Station 1 of



performing cahbration of this pressure transmitter, mdicating that transmitters were
cahbrated annually
1. In Alyeska's response to request for specific information, it states that Alyeska's
incoming Ikuparuk pipe has a MOP 1180 psig, while I&uparuk's mcommg pipehne has
an MOP of 1415 psig
2 Pressure transmitter calibration sheets for 2005, 2006
3 OM-1 Section 7, does not list 31-PT-013A as a pressure-controlhng device
An area (MP 12 2-13 2) of the pipehne was found to have madequate cathodic protection
(CP) These low CP readmgs were confirmed by Close Interval Surveys conducted m
2003, 2004, 2005, and 2006 This low CP area was further confirmed by 2002-2006
coupon readings This section of the pipehne did not meet criteria set forth in section
195 571. This area of low CP levels was reported on a 2002 inspection (see PHMSA Final
Order, CPF 5-2003-5002)
1 2003-2006 CIS, Below -850 mil volt.
2 2001-2006 Coupon survey, Below -850 rnil volt and -100 mv shift
3 Fmal Order CPF 5-2003-5002, page 3, Item 6, First allegation
(c) Rectifiers aud othe~ devices. You must electricaily check for proper performance
each device iu the first column at the frequency stated iu the second column.



At least six times each calendar year,
but vvith intervals not exceeding 2 I/~
months
A rectifier powered by wmd (31 EE 125) was installed in October 2003 at MP 12 5
Records indicated that the rectifier was only performing correctly on 11 occasions out of
the 35 scheduled readings taken between October 2003 and July 2007
1 Rectifier readings 2003-2007 When operational, the output should be in the range of 5
volts and 1 amp.
2 Final Order CPF 5-2003-5002, page 3, Item 6, First allegation
During the inspection, "No Smoking" signs were missing or faded at the following valve
locations CKV 5, 8, 9, 10, 14, 16, 17, 18, 22, and MGV 5A andlOA
)195. 579 What must I do to mitigate internal corrosion'
(c) Removing pipe. Whenever you remove pipe from a pipehne, you must inspect the
internal surface of the pipe for evidence of corrosion. If you find internal corrosion
requiring corrective action under Sec. 195. 585, you must investigate circumferentially
and longitudinally beyond the removed pipe (by visual examination, indirect method,
or both) to determine whether additional corrosion requiring remedial action exists
in the vicinity of the removed pipe.
Alyeska has removed piping associated with the Endicott meter run Alyeska did not
provide an inspection report for this pipe for internal corrosion



Pro osed Civil Penalt
Under 49 United States Code, ) 60122, you are subject to a civil penalty not to exceed $100, 000
for each violation for each day the violation persists up to a maximum of $1, 000, 000 for any
related series of violations The Comphance Officer has reviewed the circumstances and
supporting documentation involved m the above probable violations and has recommended that
you be prehminarily assessed a civil penalty of $112, 000. 00 as follows
Item Number PENALTY
$56, 000
$56, 000
Warmn Items
With respect to Items 7 and 8, we have reviewed the circumstances and supporting documents
involved m this case and have decided not to conduct additional enforcement action or penalty
assessment proceedings at this time We advise you to promptly correct this item. Be advised that
failure to do so may result in Alyeska Pipeline Service Company being subject to additional
enforcement action
Pro osed Com hance Order
With respect to Items 1, 2, 3, 4, 5 and 6 pursuant to 49 United States Code ( 60118, the Pipehne
and Hazardous Materials Safety Admmistration proposes to issue a Comphance Order to Alaska
Pipehne Service Company Please refer to the Proposed Conzpliance Order, which is enclosed
and made a part of this Notice
Res onse to this Notice
Enclosed as part of this Notice is a document entitled Response Options for Pipehne Operators in
Comp&ance ProceeCings 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 beheve that any portion of your responsive material quahfies 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 beheve quahfy for confidential
treatment redacted and an explanation of why you beheve the redacted information quahfies for
confidential treatment under 5 U S. C 552(b) If you do not respond within 30 days of receipt of
this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and
authorizes the Associate Administrator for Pipehne Safety to find facts as alleged in this Notice
without further notice to you and to issue a Final Order,



In your correspondence on this matter, please refer to CPF 5-2008-5002 and for each document
you submit, please provide a copy in electronic format whenever possible
Smcerely,
Chris Hoidal
Director, Western Region
Pipehne and Hazardous Materials Safety Admmistration
cc PHP-60 Comphance Registry
PHP-500 8 Flanders {0118831)
Enclosures Proposed Compliance Order
Response Options for Pipeline Operators in Compliance Proceedings



Pursuant to 49 United States Code ( 60118, the Pipeline and Hazardous Materials Safety
Admmistration (PHMSA) proposes to issue to Alyeska Pipehne Service Company a Comphance
Order incorporating the following remedial requirements to require that the Alyeska Pipelme
Service Company comphes with the pipeline safety regulations
In regard to Item Number 1 of the Notice pertaining to the missing valve position
indicator on MV 10A Alyeska Pipehne Service Company shall mstall a valve
position indicator on MV 10A
In regard to Item Number 2 of the Notice pertainmg to the structural sleeve at MP
57. 785, Alyeska Pipeline Service Company shall remove and inspect the internal
corrosion inside the pipe under the sleeve during the pump station ¹ 2 pipe
replacement now scheduled for 2008 PHMSA shall be notified immediately if this
sleeve is not removed m 2008
In regard to Item Number 3 of the Notice pertaining to the pressure shutdown
switches at GC-1, FS-1 and FS-3. Alyeska shall maintain these pressure shutdown
switches as DOT critical safety devices or shall install adequate pressure control
equipment within its own facihties at Pump Station 1
Alyeska Pipelme Service Company shall revise "OM-1, Procedural Manual for
Operations, Maintenance Atmospheric Corrosion and Emergencies", Section '1, to
indicate that these pressure shutdown switches are DOT critical safety devices or to
reflect any additional pressure control equipment Alyeska installs at its own
facihties at Pump Station 1. Alyeska shall also arrange to have such pressure
shutdown switches and any additional pressure control equipment tested annually
and shall maintain and make available to PHMSA the records of such testing
4 In regard to Item Number 4 of the Notice peitaining to the pressure transmitter
(31-PT-013A) on the Kuparuk pipehne mcommg line to Alyeska This pressure
transmitter shall be maintained as DOT critical safety devices
Alyeska Pipehne Service Company shall revise "OM-1, Procedural Manual for
Operations, Maintenance and Emergencies", Section 7, to indicate that these
pressure shutdown switches are DOT critical safety devices Alyeska shall also
conduct annual tests of these pressure shutdown switches and shall maintam and
make available to PHMSA the records of such testing.
5 In re ard to Item Number 5 o the Notice ertainin to the low cathodic rotection
levels on the i eline between MP 12 2-13 2 This section o the i eline must be
rovided cathodic rotection levels that meet criteria set orth in $195 571



6 In re ard to Item Number 6 o the Notice ertainin to the wind- owered recti ier
3I EE I25 located at MP I2 5 The recti ier at that location must be re aired so
that it cathodzcall rotects the tar eted i eline se ment and that an o eratin
de iciencies noted dunn t$ze bzmonthl recti ier readin s are rom tl re aired as
~ve mred b g~i95 401 b
7 Alyeska Pipehne Service Company shall complete the above-listed requirements,
and submit documentation of such completion within 180 days of receipt of the
Final Order
8 Alyeska Pipehne Service Company shall maintain documentation of the safety
improvement costs associated with fulfilhng this Comphance Order and submit the
total to Chris Hoidal, Director, Western, Pipehne and Hazardous Materials Safety
Administration Costs shall be reported in two categories 1) total cost associated
with preparation/revision of plans, procedures, studies and analyses, and 2) total
cost associated with replacements, additions and other changes to pipeline
infrastructure

520085002_Final Order_03212011_text.pdf

MAR 21 2011
Mr. Mike Joynor
Senior Vice President
Alyeska Pipeline Service Company
900 East Benson Blvd.
P.O. Box 196660
Anchorage, AK 99519
Re: CPF No. 5-2008-5002
Dear Mr. Joynor:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation, assesses a civil penalty of $112,000, and withdraws one of the allegations of violation.
It further specifies actions that need to be taken by Alyeska Pipeline Service Company to comply
with the pipeline safety regulations.
The penalty payment terms are set forth in the Final Order. When the civil penalty has been paid
and the terms of the compliance order completed, as determined by the Director, Western
Region, this enforcement action will be closed. Service of the Final Order by certified mail is
deemed effective upon the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Chris Hoidal, Director, Western Region, PHMSA
Mr. Dennis Hinnah, Deputy Director, Western Region, PHMSA
Ms. Sheila Doody Bishop, Esq., Counsel for Alyeska Pipeline Service Company
CERTIFIED MAIL – RETURN RECEIPT REQUESTED [7009 1410 0000 2472 2858]



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
__________________________________________
)
In the Matter of )
)
Alyeska Pipeline Service Company, ) CPF No. 5-2008-5002
)
Respondent. )
)
FINAL ORDER
From July 8 to July 13, 2007, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline and
Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),
conducted an on-site pipeline safety inspection of the facilities and records of Alyeska Pipeline
Service Company (Alyeska or Respondent). Specifically, OPS inspected Alyeska’s facilities
between Pump Station #1 and Mile Post (MP) 1 near Prudhoe Bay, Alaska. Alyeska is the
operator of the Trans Alaska Pipeline System (TAPS), an 800-mile-long hazardous liquid
pipeline system that transports crude oil from production facilities at Prudhoe Bay to a marine
terminal in Valdez, Alaska.1 Approximately 200 miles of the TAPS is considered a High
Consequence Area (HCA) on the North Slope of Alaska.
As a result of the inspection, the Director, Western Region, OPS (Director), issued to Alyeska,
by letter dated April 1, 2008, a Notice of Probable Violation, Proposed Civil Penalty, and
Proposed Compliance Order. Subsequently, on October 15, 2008, OPS amended its Notice to
include two additional proposed corrective measures. Alyeska was granted an additional 30 days
to respond to the Amended Notice.2
In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Respondent had
committed various violations of 49 C.F.R. Part 195, that a civil penalty of $112,000 be assessed
for the alleged violations, and that Respondent be required to take certain measures to correct the
alleged violations. The Notice also proposed finding that Respondent had committed certain
other probable violations of 49 C.F.R. Part 195, and warned Respondent to take appropriate
corrective action to address them or be subject to future enforcement action.
Alyeska responded to the Notice by letters dated April 22, 2008, May 22, 2008, and November
18, 2008 (collectively, Response). Respondent contested one of the alleged violations, provided
1 http://www.alyeska-pipe.com (last accessed on Feb. 14, 2010).
2 All references to “Notice” in this Final Order will refer to the Amended Notice issued on October 15, 2008.



2
an explanation of its actions regarding the other allegations, and requested that PHMSA
withdraw certain items listed in the proposed compliance order. Respondent did not request a
hearing and therefore has waived its right to one.
FINDINGS OF VIOLATION
In its Response, Alyeska did not contest the following allegations in the Notice that it violated 49
C.F.R. Part 195:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.116(e), which states:
§ 195.116 Valves.
following….
Each valve installed in a pipeline system must comply with the
(e) Each valve other than a check valve must be equipped with a
means for clearly indicating the position of the valve (open, closed, etc.).
The Notice alleged that Alyeska violated 49 C.F.R. § 195.116(e) by failing to equip each valve
with a means for clearly indicating the position of the valve. Specifically, the Notice alleged that
during the inspection, MGV 10A, a manual gate valve, was found without a valve position
indicator. OPS attached pictures to the Pipeline Safety Violation Report documenting the
missing indicator. Alyeska did not contest this allegation of violation and stated that it had
scheduled the installation of the valve position indicator. Accordingly, based upon a review of
all of the evidence, I find that Respondent violated 49 C.F.R. § 195.116(e) by failing to maintain
a valve position indicator on MGV 10A.
Item 2: The Notice alleged that Respondent violated 49 C.F.R. §195.401 (b), which states:
§ 195.401 General requirements.
(a) ….
(b) Whenever an operator discovers any condition that could
adversely affect the safe operation of its pipeline system, it shall correct it
within a reasonable time. However, if the condition is of such a nature
that it presents an immediate hazard to persons or property, the operator
may not operate the affected part of the system until it has corrected the
unsafe condition.
The Notice alleged that Alyeska violated 49 C.F.R. § 195.401(b) by failing to correct a condition
that could adversely affect the safe operation of its pipeline system within a reasonable time.
Specifically, the Notice alleged that due to internal corrosion Respondent installed a 15-foot non-
pressure containment sleeve at MP 57.785 in 1989. The operator continued to operate the
pipeline segment with the sleeve in place, even though an indeterminate amount of remaining
pipe wall thickness existed under the sleeve. Such a condition could adversely affect the safe
operation of TAPS because this type of structural sleeve will not stop crude oil from leaking onto
the ground when internal corrosion has weakened the pipe wall. Alyeska was notified of this
issue in January 2007 and scheduled work to repair it in 2007 and again in 2008. Respondent did



3
not correct this condition within a reasonable time. Alyeska did not contest this allegation of
violation but requested that the OPS withdraw the proposed compliance order, as discussed
below. Accordingly, based upon a review of all of the evidence, I 
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