# HILCORP ALASKA, LLC — Warning Letter

**Citation:** CPF 520172002W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2017-12-01

CLOSED warning letter citing 192.479.

## Document text

Warning Letter involving HILCORP ALASKA, LLC. PHMSA's enforcement data identifies the cited regulation as 192.479. The case was opened on 2017-12-01 and is reported as closed as of 2017-12-01. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520172002W_Warning Letter_12012017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520172002W/520172002W_Warning%20Letter_12012017.pdf

520172002W_Warning Letter_12012017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520172002W/520172002W_Warning%20Letter_12012017_text.pdf

520172002W_Warning Letter_12012017_text.pdf

WARNING LETTER
CERTIFIED MAIL – RETURN RECEIPT REQUESTED
December 1, 2017
Mr. Greg Lalicker
President
Hilcorp Alaska, LLC
1111 Travis Street
Houston, Texas 77002
CPF 5-2017-2002W
Dear Mr. Lalicker:
On July 19, 2017, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected the
Hilcorp Alaska, LLC (Hilcorp) Tyonek Gas Transmission Pipeline, located at the pig
receiving facility at the Conoco Phillips LNG plant near Nikiski, Alaska.
As a result of the inspection, it is alleged that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item
inspected and the probable violation is:
1. §192.479 Atmospheric corrosion control: General.
(a) Each operator must clean and coat each pipeline or portion of pipeline that is
exposed to the atmosphere, except pipelines under paragraph (c) of this section.
(b) Coating material must be suitable for the prevention of atmospheric
corrosion.
(c) Except portions of pipelines in offshore splash zones or soil-to-air interfaces,
the operator need not protect from atmospheric corrosion any pipeline for which
the operator demonstrates by test, investigation, or experience appropriate to the
environment of the pipeline that corrosion will—



(1) Only be a light surface oxide; or
(2) Not affect the safe operation of the pipeline before the next scheduled
inspection.
During the field audit, located at the pig receiving facility near the Conoco Phillips LNG
Plant, it was determined that several areas had insufficient coating material and areas of
disbonded coating. The pipeline segment at this location is aboveground uninsulated pipe and
is exposed to the atmosphere. The observed failed coating may lead to further pitting
corrosion if not remediated and recoated.
This finding was discussed with Hilcorp integrity management personnel who stated that the
Tyonek Gas Transmission Pipeline and the tie in with the failed coating was on a remediation
plan and that the failed coating would be addressed following a Hilcorp integrity assessment
to be completed in 2017.
Hilcorp purchased this pipeline asset from Conoco Phillips, Alaska in December 2016 and has
been the operator of the Tyonek Gas Transmission pipeline for less than 1 year.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to
exceed $209,002 per violation per day the violation persists up to a maximum of $2,090,022
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 item
identified in this letter. Failure to do so will result in Hilcorp 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 5-2017-2002W. 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,
Kim West
Acting Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 R. Guisinger (#156054)

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/520172002W>
- Source ID: `phmsa-enforcement`
- SHA-256: `455c6dcef8f3b530023988a8599f02ee747e22af8c91f87eabb566c915b9bdcd`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T21:11:19.576Z
- Document slug: `phmsa-enforcement-520172002w`

### Source metadata

```json
{
  "cpf": "520172002W",
  "operator": "HILCORP ALASKA, LLC",
  "region": "Western",
  "pipelineType": "GAS INTRASTATE OFFSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "192.479"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
    {
      "name": "520172002W_Warning Letter_12012017.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520172002W/520172002W_Warning%20Letter_12012017.pdf",
      "bytes": 92533,
      "category": "agency_document"
    },
    {
      "name": "520172002W_Warning Letter_12012017_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520172002W/520172002W_Warning%20Letter_12012017_text.pdf",
      "bytes": 87907,
      "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"
}
```
