# ALYESKA PIPELINE SERVICE CO — Notice of Amendment

- **operation:** document
- **citation:** CPF 520115015M
- **title:** ALYESKA PIPELINE SERVICE CO — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2011-06-22
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 195.440(b), 195.440(f).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520115015m.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520115015m.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520115015m
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520115015M
**body:**

Notice of Amendment involving ALYESKA PIPELINE SERVICE CO. PHMSA's enforcement data identifies the cited regulations as 195.440(b),  195.440(f). The case was opened on 2011-06-22 and is reported as closed as of 2011-10-07. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520115015M_closure letter_10072011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520115015M/520115015M_closure%20letter_10072011.pdf

520115015M_closure letter_10072011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520115015M/520115015M_closure%20letter_10072011_text.pdf

520115015M_notice of amendment_06222011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520115015M/520115015M_notice%20of%20amendment_06222011.pdf

520115015M_notice of amendment_06222011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520115015M/520115015M_notice%20of%20amendment_06222011_text.pdf

520115015M_operator response_07202011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520115015M/520115015M_operator%20response_07202011.pdf

520115015M_notice of amendment_06222011_text.pdf

NOTICE OF AMENDMENT
VIA UPS: (1Z WR2 588 03 9441 4894)
June 22, 2011
Mr. Mike Joynor
Senior Vice President
Alyeska Pipeline Service Company
900 E. Benson Blvd.
P.O. Box 196606
Anchorage, Alaska 99519
CPF 5-2011-5015M
Dear Mr. Joynor:
On June 1-2, 2011, a representative 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 and records for its Public
Awareness Program in Anchorage, Alaska.
On the basis of that inspection, PHMSA has identified the following apparent inadequacies
found within Alyeska’s plans and/or procedures, as described below:
1. §195.440 Public Awareness
(b) The operator's program must follow the general program recommendations
of API RP 1162 and assess the unique attributes and characteristics of the
operator's pipeline and facilities.
A) Alyeska’s Public Awareness Program (PAP) does not contain a written statement of
management commitment. Alyeska’s PAP must be amended to meet the requirements of
Management Support, section 2.5 of API 1162.



B) Alyeska’s PAP does not identify the program administrator by name or by position, but
only as a corporate communications representative. Alyeska’s PAP must be amended to
meet the requirements of Program Documentation, section 7.1 (c) of API 1162.
C) Alyeska has conducted annual audits, but did not document the topics reviewed.
Alyeska’s PAP must be amended to meet the requirements of Program Documentation,
section 7.1 (g) of API 1162.
D) Alyeska has conducted annual audits, but has not identified and documented the
members of the self assessment team. Alyeska’s PAP must be amended to meet the
requirements of Focus Groups, Appendix E of API 1162.
2. §195.440 Public Awareness
(f) The program and the media used must be as comprehensive as necessary to
reach all areas in which the operator transports hazardous liquid or carbon
dioxide.
A) Alyeska states in section 5.2.1 of the PAP, “API recommends 660 to 1000 feet on either
side of the pipeline. However, the coverage area should be expanded or contracted
specific to the particular pipeline, location, and potential impact consequences”
. In
discussions with Alyeska personnel, they described that they are identifying the affected
public by 60 feet on either side of the pipeline. Alyeska must amend section 5.2.1,
Affected Public, to indicate what Alyeska will use to determine affected public.
B) In discussions with Alyeska personnel, they described that at this time, the affected
public is being identified only in the North Star Borough. Alyeska must amend its PAP
to include other residential areas along the Right of Way (Delta Junction, Glennallen,
Valdez etc.)
C) In discussions with Alyeska personnel, they described that the affected public is being
identified and communicated through Right of Way Use Guideline (RUG) mailings.
Alyeska must amend the PAP to include information about RUG mailings.
D) In the past, Alyeska has not communicated with excavators through mailings, but relied
upon newspapers and magazines ads. Alyeska must amend the PAP to include
information to excavators through mailings.
2



Response 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 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 Pipeline Safety to
find facts as alleged in this Notice without further notice to you and to issue a Final Order.
If, after opportunity for a hearing, your plans or procedures are found inadequate as alleged
in this Notice, you may be ordered to amend your plans or procedures to correct the
inadequacies (49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that
you submit your amended procedures to my office within 90 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 your amended procedures, this enforcement action
will be closed.
It is requested (not mandated) that Alyeska Pipeline Service Company maintain
documentation of the safety improvement costs associated with fulfilling this Notice of
Amendment (preparation/revision of plans, procedures) and submit the total to Dennis
Hinnah, Deputy Director, Western Region, Pipeline and Hazardous Materials Safety
Administration. In correspondence concerning this matter, please refer to CPF 5-2011-
5015M and send all documents to our office at 188 W. Northern Lights Blvd., Suite 520,
Anchorage, AK 99503. For each document you submit, please provide a copy in electronic
format whenever possible.
Sincerely,
Dennis Hinnah
Deputy Director, Western Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
cc: PHP-60 Compliance Registry
PHP-500 B. Flanders (#134623)
3

520115015M_closure letter_10072011_text.pdf

October 7, 2011
Mr. Joseph P. Robertson
Regulatory Affairs Director
Alyeska Pipeline Service Company
900 E. Benson Blvd.
P.O. Box 196606
Anchorage, Alaska 99519
CPF 5-2011-5015M
Dear Mr. Robertson:
On June 1-2, 2011, a representative from the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an
on-site pipeline safety inspection of Alyeska Pipeline Service Company’s Public Awareness
Program procedures in Anchorage, Alaska. As a result of the inspection, Alyeska Pipeline
Service Company was issued a Notice of Amendment on June 22, 2011, which proposed
amendment of your procedures.
Alyeska Pipeline Service Company submitted its amended procedures on September 26,
2011. My staff reviewed the amended procedures, and it appears that the inadequacies
outlined in this Notice of Amendment have been corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank
you for your cooperation.
Sincerely,
Dennis Hinnah
Deputy Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 B. Flanders
- **truncated:** false
- **body characters:** 8115
