# HILCORP ALASKA, LLC — Warning Letter

**Citation:** CPF 520155025W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2015-12-23

CLOSED warning letter citing 195.452(j)(3).

## Document text

Warning Letter involving HILCORP ALASKA, LLC. PHMSA's enforcement data identifies the cited regulation as 195.452(j)(3). The case was opened on 2015-12-23 and is reported as closed as of 2015-12-23. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520155025W_Warning Letter_12232015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155025W/520155025W_Warning%20Letter_12232015.pdf

520155025W_Warning Letter_12232015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155025W/520155025W_Warning%20Letter_12232015_text.pdf

520155025W_Warning Letter_12232015_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
December 23, 2015
Mr. Greg Lalicker
President
Hilcorp Alaska, LLC
1201 Louisiana Street, Suite 1400
Houston, Texas 77002
CPF 5-2015-5025W
Dear Mr. Lalicker:
On September 22, 2015 and September 23, 2015, a representative of the Pipeline and
Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United
States Code, inspected your Milne Point facility located near Prudhoe Bay, Alaska.
As a result of the inspection, it appears that Hilcorp Alaska has committed a probable
violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The
items inspected and the probable violation is:
1. §195.452 Pipeline integrity management in high consequence areas.
(j) What is a continual process of evaluation and assessment to maintain a
pipeline's integrity?
(3) Assessment intervals. An operator must establish five-year intervals, not to
exceed 68 months, for continually assessing the line pipe's integrity. An operator
must base the assessment intervals on the risk the line pipe poses to the high
consequence area to determine the priority for assessing the pipeline segments.
An operator must establish the assessment intervals based on the factors
specified in paragraph (e) of this section, the analysis of the results from the last
integrity assessment, and the information analysis required by paragraph (g) of
this section.
Hilcorp Alaska, LLC (Hilcorp) failed to perform an assessment of the stainless steel pipeline
segment as required by §195.452(j)(3). During the inspection of the Milne Point facility



located near Prudhoe Bay, Alaska, it was determined that a segment of stainless steel
pipeline, approximately 600 feet in length, and 12” in diameter, had not been inspected under
§195.452 (j)(3), which requires inspection in high consequence areas “not to exceed 68
months”. This segment is a tie in from Milne Point sales crude pipeline to the
ConocoPhillips Kuparuk sales crude pipeline.
As a result from the PHMSA inspection, Hilcorp proceeded to use guided wave technology
to inspect the 600 feet of above ground pipeline. The results of the guided wave inspection
confirmed no anomalies on the segment. Hilcorp must incorporate this segment into their
integrity management plan as required by §195.452 (j)(3).
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a
related series of violations. For violations occurring prior to January 4, 2012, the maximum
penalty may not exceed $100,000 per violation per day, with a maximum penalty not to
exceed $1,000,000 for a related series of violations. 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 correct
the items identified in this letter. Failure to do so will result in Hilcorp Alaska, LLC being
subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer
to CPF 5-2015-5025W for each document you submit, please provide a copy in electronic
format to PHP-WRADMIN@dot.gov whenever possible. 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).
Sincerely,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 R. Guisinger (#150149)

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/520155025W>
- Source ID: `phmsa-enforcement`
- SHA-256: `a83d3eb44ce823e94fcf428b436c12c47fcab96826f8fc2e31eedecd12b67d52`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T21:20:20.214Z
- Document slug: `phmsa-enforcement-520155025w`

### Source metadata

```json
{
  "cpf": "520155025W",
  "operator": "HILCORP ALASKA, LLC",
  "region": "Western",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.452(j)(3)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
    {
      "name": "520155025W_Warning Letter_12232015.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520155025W/520155025W_Warning%20Letter_12232015.pdf",
      "bytes": 210094,
      "category": "agency_document"
    },
    {
      "name": "520155025W_Warning Letter_12232015_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520155025W/520155025W_Warning%20Letter_12232015_text.pdf",
      "bytes": 9923,
      "category": "agency_document"
    }
  ],
  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "HILCORP ALASKA, LLC"
}
```
