{"operation":"document","citation":"CPF 52025013NOA","title":"ALYESKA PIPELINE SERVICE CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2025-04-25","effective_on":null,"summary":"OPEN notice of amendment citing 195.402(c)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52025013noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52025013noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52025013noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52025013NOA","body":"Notice of Amendment involving ALYESKA PIPELINE SERVICE CO. PHMSA's enforcement data identifies the cited regulation as 195.402(c)(3). The case was opened on 2025-04-25 and is reported as open. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52025013NOA_Notice of Amendment_04252025_(24-298502).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025013NOA/52025013NOA_Notice%20of%20Amendment_04252025_(24-298502).pdf\n\n52025013NOA_Notice of Amendment_04252025_(24-298502)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025013NOA/52025013NOA_Notice%20of%20Amendment_04252025_(24-298502)_text.pdf\n\n52025013NOA_Operator Response to Notice and Request Hearing and Request Informal Conference-Request Case File-Statement of Issues_07252025_(24-298502).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025013NOA/52025013NOA_Operator%20Response%20to%20Notice%20and%20Request%20Hearing%20and%20Request%20Informal%20Conference-Request%20Case%20File-Statement%20of%20Issues_07252025_(24-298502).pdf\n\n52025013NOA_PHC Hearing Rescheduled_04172026_(24-298502).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025013NOA/52025013NOA_PHC%20Hearing%20Rescheduled_04172026_(24-298502).pdf\n\n52025013NOA_PHC Hearing Rescheduled_04172026_(24-298502)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025013NOA/52025013NOA_PHC%20Hearing%20Rescheduled_04172026_(24-298502)_text.pdf\n\n52025013NOA_PHC Hearing Scheduled_12182025_(24-298502).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025013NOA/52025013NOA_PHC%20Hearing%20Scheduled_12182025_(24-298502).pdf\n\n52025013NOA_PHC Hearing Scheduled_12182025_(24-298502)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025013NOA/52025013NOA_PHC%20Hearing%20Scheduled_12182025_(24-298502)_text.pdf\n\n52025013NOA_PHC Hearing Scheduled_12182025_(24-298502)_text.pdf\n\n1200 New Jersey Avenue, SE\nU.S. Department Washington, DC 20590\nof Transportation\nPipeline and\nHazardous Materials\nSafety Administration\nDecember 18, 2025\nVIA EMAIL TO: JCurry@babstcalland.com, Kathleen.Mailtland@dot.gov et al.\nMr. James Curry, Esq.\nCounsel for Alyeska Pipeline Service Company\nBabst Calland\n505 9th Street, NW, Ste. 602\nWashington, DC 20004\nMs. Kathleen Maitland, Esq.\nCounsel for the Agency\nPipeline and Hazardous Materials Safety Administration (PHMSA)\n1200 New Jersey Ave., S.E.\nWashington, DC 20590\nRe: PHMSA CPF No.: 5-2025-010-NOPV, 5-2025-013-NOA, Alyeska Pipeline\nService Company, Notice of Hearing and Order Regarding Prehearing Statement\nDear Ms. Maitland and Mr. Curry,\nIn accordance with 49 C.F.R. § 190.211, a hearing will be held regarding the Notice of\nProbable Violation and Proposed Compliance Order and Notice of Amendment issued\nby PHMSA in the above referenced case. The hearing will take place on May 6, 2026,\nbeginning at 9:30 a.m. Eastern Time. The hearing will be held at DOT Headquarters:\n1200 New Jersey Ave, S.E.\nWashington, DC\n20590\nAdditional instructions for accessing the DOT Headquarters building will be provided\nlater.\nEach party is directed to submit to the presiding official and the other party by email a\npre-hearing statement, due no later than April 22, 2026, including the following\ninformation:\n1. A statement of facts\n\n\n\nPage 2\n2. A list of all agreed upon facts\n3. Defenses and arguments\n4. A witness list including a description and anticipated length of each witness’\nanticipated testimony. The description must be sufficient to show how the\nanticipated testimony may prove or disprove a fact significant to the case.\n5. A copy of all exhibits with an index identifying the documents. All exhibits must\nbe marked for identification in the lower right corner of each page. Documents\nalready in the case file need not be included.\nThe parties must confer regarding item 2 above. Failure to submit items 4 and 5 above\nmay result in disallowance of that evidence at the hearing. The parties may supplement\ntheir hearing exhibits or witness list with fair notice to the other party and the presiding\nofficial.\nA brief pre-hearing conference may be held 7-10 days prior to the hearing if the\npresiding official deems it appropriate.\nThe presiding official strongly recommends that a court reporter transcribe the hearing.\nIf Respondent elects to transcribe the hearing, Respondent should notify the presiding\nofficial (with copy to the other party) as soon as practicable.\nThe Agency is required to be represented by counsel for these proceedings.\nRegards,\nDolores Francis\nPresiding Official\n\n52025013NOA_Notice of Amendment_04252025_(24-298502)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: john.kurz@alyeska-pipeline.com\nApril 25, 2025\nMr. John Kurz\nPresident and CEO\nAlyeska Pipeline Service Company\nPO Box 196660, MS 502\nAnchorage, Alaska 99519\nCPF 5-2025-013-NOA\nDear Mr. Kurz:\nFrom April 22 through April 26, 2024 and May 8 through May 10, 2024, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of\n49 United States Code (U.S.C.), inspected Alyeska Pipeline Service Company’s (APSC)\nprocedures for operation and maintenance of the Trans-Alaska Pipeline System (TAPS) in\nAnchorage, Alaska.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nAPSC’s plans or procedures, as described below:\n1. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a)…\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(1)…\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n\n\n\nAPSC’s procedures were inadequate to maintain pipeline safety. Specifically, APSC failed to\nprepare procedures for inspecting and testing each item of pressure control and each\noverpressure safety device on the TAPS as required by § 195.428(a). Section 195.428(a) states,\nin part, that operators must “inspect and test each pressure limiting device, relief valve, pressure\nregulator, or other item of pressure control equipment to determine that it is functioning properly,\nis in good mechanical condition, and is adequate from the standpoint of capacity and reliability\nof operation for the service in which it is used.” However, PHMSA inspectors observed that\nAPSC’s Procedural Manual for Operations, Maintenance and Emergencies (OM-1” Ed.3 Rev.\n30) and the specific procedures cross-referenced within the OM-1 described the processes for\ninspection and testing of relief valves only. Relief valves are only one of several components\nsubject to the inspection and function testing requirements of 195.428(a).\nFurther, during the inspection, PHMSA observed APSC’s OM-1 lacked a process for inspection\nand testing items of pressure control and overpressure protection associated with TAP’s Safety\nInstrument Pressure Protection System (SIPPS). APSC described SIPPS as an instrumented\nsystem controlling pipeline pressure by adjusting the setpoints of the variable speed controls on\nthe pump stations’ pumping units and providing overpressure protection by initiating pipeline\nshutdown processes. Any device that is used in systems or processes that determine the\noperating pressure of the pipeline is an “other item of pressure control” subject to the\nrequirements of § 195.428(a), as is any device used to shut down the pipeline or slow the pump\nspeeds for overpressure protection purposes.\nIn addition, APSC’s regulated breakout tanks at Pump Station 1 (PS1) and the Valdez Marine\nTerminal are equipped with gas blanketing systems. Control valves and instruments associated\nwith the gas blanketing systems determine the pressure in the tanks’ head space and therefore are\nitems of pressure control. Because these tanks are regulated breakout tanks, the gas blanketing\nsystems are pressure control systems subject to the requirements of § 195.428(a). During the\ninspection, APSC provided a worksheet showing its process for calibrating the pressure control\nequipment on breakout tanks at PS1. However, this process was not cross-referenced within\nOM-1, nor was it being completed at the intervals required by § 195.428(a).\nFinally, the OM-1 listed TAPS relief valves in “Table 4. Overpressure Safety Devices Requiring\nAnnual Inspection and Testing (Reference 49 CFR 195.428(a)).” However, during the\ninspection PHMSA found valves that must be included in the list, had not been included.\nSpecifically, PSV 35-0209D and PSV 35-0209S, both located around the Tank 150 suction\npump, are TAPS pressure control equipment that must be included on Table 4, but were\nobserved to be missing.\nTherefore, APSC must revise its procedures include processes for inspecting and testing each\nitem of pressure control and each overpressure safety device on the TAPS as required by §\n195.428(a).\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nEnforcement Proceedings.\n\n\n\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. § 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 5 U.S.C. § 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not\ncontesting this Notice, we propose that you submit your amended procedures to my office within\n30 days of receipt of this Notice. This period may be extended by written request for good\ncause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested (not mandated) that Alyeska Pipeline Service Company maintain documentation\nof the safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Dustin Hubbard, Director,\nWestern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 5-2025-013-NOA and, for each document you\nsubmit, please provide a copy in electronic format whenever possible.\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 J. Gano (#24-298502)\nMelanie Osborne, APSC HSEC Director - APSCGovtLetters@alyeska-pipeline.com\nJanine Boyette, APSC Sr. Compliance Manager - janine.boyette@alyeska-pipeline.com\n\n52025013NOA_PHC Hearing Rescheduled_04172026_(24-298502)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials\nSafety Administration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nApril 17, 2026\nVIA EMAIL TO: JCurry@babstcalland.com, Kathleen.Mailtland@dot.gov et al.\nMr. James Curry, Esq.\nCounsel for Alyeska Pipeline Service Company\nBabst Calland\n505 9th Street, NW, Ste. 602\nWashington, DC 20004\nMs. Kathleen Maitland, Esq.\nCounsel for the Agency\nPipeline and Hazardous Materials Safety Administration (PHMSA)\n1200 New Jersey Ave., S.E.\nWashington, DC 20590\nRe: PHMSA CPF No.: 5-2025-010-NOPV, 5-2025-013-NOA, Alyeska Pipeline\nService Company, Notice of Hearing and Order Regarding Prehearing Statement\nDear Ms. Maitland and Mr. Curry,\nIn accordance with 49 C.F.R. § 190.211, a hearing will be held regarding the Notice of\nProbable Violation and Proposed Compliance Order and Notice of Amendment issued\nby PHMSA in the above referenced case. The hearing will take place on July 29,\n2026, beginning at 9:30 a.m. Eastern Time. The hearing will be held at DOT\nHeadquarters:\n1200 New Jersey Ave, S.E.\nWashington, DC\n20590\nAdditional instructions for accessing the DOT Headquarters building will be provided\nlater.\nEach party is directed to submit to the presiding official and the other party by email a\npre-hearing statement, due no later than July 15, 2026, including the following\ninformation:\n\n\n\nPage 2\n1. A statement of facts\n2. A list of all agreed upon facts\n3. Defenses and arguments\n4. A witness list including a description and anticipated length of each witness’\nanticipated testimony. The description must be sufficient to show how the\nanticipated testimony may prove or disprove a fact significant to the case.\n5. A copy of all exhibits with an index identifying the documents. All exhibits must\nbe marked for identification in the lower right corner of each page. Documents\nalready in the case file need not be included.\nThe parties must confer regarding item 2 above. Failure to submit items 4 and 5 above\nmay result in disallowance of that evidence at the hearing. The parties may supplement\ntheir hearing exhibits or witness list with fair notice to the other party and the presiding\nofficial.\nA brief pre-hearing conference may be held 7-10 days prior to the hearing if the\npresiding official deems it appropriate.\nThe presiding official strongly recommends that a court reporter transcribe the hearing.\nIf Respondent elects to transcribe the hearing, Respondent should notify the presiding\nofficial (with copy to the other party) as soon as practicable.\nThe Agency is required to be represented by counsel for these proceedings.\nRegards,\nDolores Francis\nPresiding Official","truncated":false,"body_characters":14444}