ALYESKA PIPELINE SERVICE CO — Notice of Amendment

party submissionOfficial PDF52025013NOA_Operator Response to Notice and Request Hearing and Request Informal Conference-Request Case File-Statement of Issues_07252025_(24-298502).pdf#

52025013NOA_PHC Hearing Scheduled_12182025_(24-298502)_text.pdf, page 1Official PDF1200 New Jersey Avenue, SE U.S. Department Washington, DC 20590 of Transportation Pipeline and Hazardous Materials Safety Administration December 18, 2025 VIA EMAIL TO: JCurry@babstcalland.com, Kathleen.Mailtland@dot.gov et al. Mr. James Curry, Esq. Counsel for Alyeska Pipeline Service Company Babst Calland 505 9th Street, NW, Ste. 602 Washington, DC 20004 Ms. Kathleen Maitland, Esq. Counsel for the Agency Pipeline and Hazardous Materials Safety Administration (PHMSA) 1200 New Jersey Ave., S.E. Washington, DC 20590 Re: PHMSA CPF No.: 5-2025-010-NOPV, 5-2025-013-NOA, Alyeska Pipeline Service Company, Notice of Hearing and Order Regarding Prehearing Statement Dear Ms. Maitland and Mr. Curry, In accordance with 49 C.F.R. § 190.211, a hearing will be held regarding the Notice of Probable Violation and Proposed Compliance Order and Notice of Amendment issued by PHMSA in the above referenced case. The hearing will take place on May 6, 2026, beginning at 9:30 a.m. Eastern Time. The hearing will be held at DOT Headquarters: 1200 New Jersey Ave, S.E. Washington, DC 20590 Additional instructions for accessing the DOT Headquarters building will be provided later. Each party is directed to submit to the presiding official and the other party by email a pre-hearing statement, due no later than April 22, 2026, including the following information: 1. A statement of facts#

52025013NOA_PHC Hearing Scheduled_12182025_(24-298502)_text.pdf, page 2Page 2 2. A list of all agreed upon facts 3. Defenses and arguments 4. A witness list including a description and anticipated length of each witness’ anticipated testimony. The description must be sufficient to show how the anticipated testimony may prove or disprove a fact significant to the case. 5. A copy of all exhibits with an index identifying the documents. All exhibits must be marked for identification in the lower right corner of each page. Documents already in the case file need not be included. The parties must confer regarding item 2 above. Failure to submit items 4 and 5 above may result in disallowance of that evidence at the hearing. The parties may supplement their hearing exhibits or witness list with fair notice to the other party and the presiding official. A brief pre-hearing conference may be held 7-10 days prior to the hearing if the presiding official deems it appropriate. The presiding official strongly recommends that a court reporter transcribe the hearing. If Respondent elects to transcribe the hearing, Respondent should notify the presiding official (with copy to the other party) as soon as practicable. The Agency is required to be represented by counsel for these proceedings. Regards, Dolores Francis Presiding Official#

52025013NOA_Notice of Amendment_04252025_(24-298502)_text.pdf, page 1Official PDFNOTICE OF AMENDMENT VIA ELECTRONIC MAIL TO: john.kurz@alyeska-pipeline.com April 25, 2025 Mr. John Kurz President and CEO Alyeska Pipeline Service Company PO Box 196660, MS 502 Anchorage, Alaska 99519 CPF 5-2025-013-NOA Dear Mr. Kurz: From April 22 through April 26, 2024 and May 8 through May 10, 2024, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected Alyeska Pipeline Service Company’s (APSC) procedures for operation and maintenance of the Trans-Alaska Pipeline System (TAPS) in Anchorage, Alaska. As a result of the inspection, PHMSA has identified the apparent inadequacies found within APSC’s plans or procedures, as described below: 1. § 195.402 Procedural manual for operations, maintenance, and emergencies. (a)… (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: (1)… (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part.#

52025013NOA_Notice of Amendment_04252025_(24-298502)_text.pdf, page 2APSC’s procedures were inadequate to maintain pipeline safety. Specifically, APSC failed to prepare procedures for inspecting and testing each item of pressure control and each overpressure safety device on the TAPS as required by § 195.428(a). Section 195.428(a) states, in part, that operators must “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.” However, PHMSA inspectors observed that APSC’s Procedural Manual for Operations, Maintenance and Emergencies (OM-1” Ed.3 Rev. 30) and the specific procedures cross-referenced within the OM-1 described the processes for inspection and testing of relief valves only. Relief valves are only one of several components subject to the inspection and function testing requirements of 195.428(a). Further, during the inspection, PHMSA observed APSC’s OM-1 lacked a process for inspection and testing items of pressure control and overpressure protection associated with TAP’s Safety Instrument Pressure Protection System (SIPPS). APSC described SIPPS as an instrumented system controlling pipeline pressure by adjusting the setpoints of the variable speed controls on the pump stations’ pumping units and providing overpressure protection by initiating pipeline shutdown processes. Any device that is used in systems or processes that determine the operating pressure of the pipeline is an “other item of pressure control” subject to the requirements of § 195.428(a), as is any device used to shut down the pipeline or slow the pump speeds for overpressure protection purposes. In addition, APSC’s regulated breakout tanks at Pump Station 1 (PS1) and the Valdez Marine Terminal are equipped with gas blanketing systems. Control valves and instruments associated with the gas blanketing systems determine the pressure in the tanks’ head space and therefore are items of pressure control. Because these tanks are regulated breakout tanks, the gas blanketing systems are pressure control systems subject to the requirements of § 195.428(a). During the inspection, APSC provided a worksheet showing its process for calibrating the pressure control equipment on breakout tanks at PS1. However, this process was not cross-referenced within OM-1, nor was it being completed at the intervals required by § 195.428(a). Finally, the OM-1 listed TAPS relief valves in “Table 4. Overpressure Safety Devices Requiring Annual Inspection and Testing (Reference 49 CFR 195.428(a)).” However, during the inspection PHMSA found valves that must be included in the list, had not been included. Specifically, PSV 35-0209D and PSV 35-0209S, both located around the Tank 150 suction pump, are TAPS pressure control equipment that must be included on Table 4, but were observed to be missing. Therefore, APSC must revise its procedures include processes for inspecting and testing each item of pressure control and each overpressure safety device on the TAPS as required by § 195.428(a). Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement Proceedings.#

52025013NOA_Notice of Amendment_04252025_(24-298502)_text.pdf, page 3Please 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). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under § 190.211. 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 an Order Directing Amendment. If 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. § 190.206). If you are not contesting this Notice, we propose that you submit your 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 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 Dustin Hubbard, Director, Western Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 5-2025-013-NOA and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Dustin Hubbard Director, Western Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings cc: PHP-60 Compliance Registry PHP-500 J. Gano (#24-298502) Melanie Osborne, APSC HSEC Director - APSCGovtLetters@alyeska-pipeline.com Janine Boyette, APSC Sr. Compliance Manager - janine.boyette@alyeska-pipeline.com#

52025013NOA_PHC Hearing Rescheduled_04172026_(24-298502)_text.pdf, page 1Official PDFU.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 April 17, 2026 VIA EMAIL TO: JCurry@babstcalland.com, Kathleen.Mailtland@dot.gov et al. Mr. James Curry, Esq. Counsel for Alyeska Pipeline Service Company Babst Calland 505 9th Street, NW, Ste. 602 Washington, DC 20004 Ms. Kathleen Maitland, Esq. Counsel for the Agency Pipeline and Hazardous Materials Safety Administration (PHMSA) 1200 New Jersey Ave., S.E. Washington, DC 20590 Re: PHMSA CPF No.: 5-2025-010-NOPV, 5-2025-013-NOA, Alyeska Pipeline Service Company, Notice of Hearing and Order Regarding Prehearing Statement Dear Ms. Maitland and Mr. Curry, In accordance with 49 C.F.R. § 190.211, a hearing will be held regarding the Notice of Probable Violation and Proposed Compliance Order and Notice of Amendment issued by PHMSA in the above referenced case. The hearing will take place on July 29, 2026, beginning at 9:30 a.m. Eastern Time. The hearing will be held at DOT Headquarters: 1200 New Jersey Ave, S.E. Washington, DC 20590 Additional instructions for accessing the DOT Headquarters building will be provided later. Each party is directed to submit to the presiding official and the other party by email a pre-hearing statement, due no later than July 15, 2026, including the following information:#

52025013NOA_PHC Hearing Rescheduled_04172026_(24-298502)_text.pdf, page 2Page 2 1. A statement of facts 2. A list of all agreed upon facts 3. Defenses and arguments 4. A witness list including a description and anticipated length of each witness’ anticipated testimony. The description must be sufficient to show how the anticipated testimony may prove or disprove a fact significant to the case. 5. A copy of all exhibits with an index identifying the documents. All exhibits must be marked for identification in the lower right corner of each page. Documents already in the case file need not be included. The parties must confer regarding item 2 above. Failure to submit items 4 and 5 above may result in disallowance of that evidence at the hearing. The parties may supplement their hearing exhibits or witness list with fair notice to the other party and the presiding official. A brief pre-hearing conference may be held 7-10 days prior to the hearing if the presiding official deems it appropriate. The presiding official strongly recommends that a court reporter transcribe the hearing. If Respondent elects to transcribe the hearing, Respondent should notify the presiding official (with copy to the other party) as soon as practicable. The Agency is required to be represented by counsel for these proceedings. Regards, Dolores Francis Presiding Official#