HILCORP ALASKA, LLC — Notice of Amendment

party submissionOfficial PDF520150016M_Operator Response to Notice_12042015.pdf#

520150016M_Closure Letter_12232015_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED December 23, 2015 Mr. David S. Wilkins Senior Vice President of Alaska Hilcorp Alaska, LLC 3800 Centerpoint Dr., Suite 1400 Anchorage, Alaska 99503 CPF 5-2015-0016M Dear Mr. Wilkins: On March 23, 2015, 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 Hilcorp Alaska procedures in Anchorage, Alaska. As a result of the inspection, Hilcorp Alaska was issued a Notice of Amendment on November 3, 2015, which proposed amendment of procedures. Hilcorp Alaska submitted its amended procedures on December 4, 2015. My staff has 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, For Chris Hoidal Director, Western Region Pipeline and Hazardous Materials Safety Administration cc: PHP-60 Compliance Registry PHP-500 D. Hassell (#149002)#

520150016M_Notice of Amendment_11032015_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED November 3, 2015 Mr. David S. Wilkins Senior Vice President of Alaska Hilcorp Alaska, LLC 3800 Centerpoint Dr., Suite 1400 Anchorage, Alaska 99503 CPF 5-2015-0016M Dear Mr. Wilkins: On March 23, 2015, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Hilcorp’s Operations and Maintenance manual, Department Of Transportation (DOT) Operator Qualifications program, records, Control Room Management program and Beluga pipeline specific Operations Manual for the pipeline from Kaloa Junction facility near Granite Point to Beluga. On the basis of the inspection, PHMSA identified an apparent inadequacy within Hilcorp’s plans or procedures, as described below: 1. §192. 615 Emergency plans. (b) Each operator shall: (1) Furnish its supervisors who are responsible for emergency action a copy of that portion of the latest edition of the emergency procedures established under paragraph (a) of this section as necessary for compliance with those procedures. (2) Train the appropriate operating personnel to assure that they are knowledgeable of the emergency procedures and verify that the training is effective. (3) Review employee activities to determine whether the procedures were effectively followed in each emergency. Hilcorp did not establish adequate written procedures for verifying the effectiveness of its emergency plan training for operating personnel. Hilcorp procedures did not ensure that their operating personnel are knowledgeable of their emergency procedures.#

520150016M_Notice of Amendment_11032015_text.pdf, page 2Response 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 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 Hilcorp maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Chris Hoidal, Director, Western Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 5-2015-0016M and, for each document you submit, please provide a copy in electronic format to PHP-WRADMIN@dot.gov whenever possible. Sincerely, For Chris Hoidal, 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 D. Hassell (#149002)#