{"operation":"document","citation":"CPF 520150019W","title":"HILCORP ALASKA, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-12-23","effective_on":null,"summary":"CLOSED warning letter citing 192.479(a), 192.5(a)(2), 192.709(c), 192.745(a), 192.905(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520150019w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520150019w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520150019w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520150019W","body":"Warning Letter involving HILCORP ALASKA, LLC. PHMSA's enforcement data identifies the cited regulations as 192.479(a),  192.5(a)(2),  192.709(c),  192.745(a),  192.905(a). 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.\n\nOfficial case documents:\n\n520150019W_Region Letter to Operator Acknowledging Typographical Error in Notice Letter_01082016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150019W/520150019W_Region%20Letter%20to%20Operator%20Acknowledging%20Typographical%20Error%20in%20Notice%20Letter_01082016.pdf\n\n520150019W_Region Letter to Operator Acknowledging Typographical Error in Notice Letter_01082016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150019W/520150019W_Region%20Letter%20to%20Operator%20Acknowledging%20Typographical%20Error%20in%20Notice%20Letter_01082016_text.pdf\n\n520150019W_Warning Letter_12232015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150019W/520150019W_Warning%20Letter_12232015.pdf\n\n520150019W_Warning Letter_12232015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150019W/520150019W_Warning%20Letter_12232015_text.pdf\n\n520150019W_Region Letter to Operator Acknowledging Typographical Error in Notice Letter_01082016_text.pdf\n\nCERTIFIED MAIL – RETURN RECEIPT REQUESTED\nJanuary 8, 2016\nMr. Greg Laliker\nPresident\nHilcorp Alaska, LLC\n1201 Louisiana St., Suite 1400\nHouston, TX 77002\nRE: CPF 5-2015-0019W\nDear Mr. Laliker:\nOn December 23, 2015, the Pipeline and Hazardous Materials Safety Administration sent you a\nWarning Letter, CPF #5-2015-0019W. Item #5 in the letter cites regulation §192.709(c), which\nis correct. However, the description associated with Item #5 contains a typographical error.\nRegulation §195.709(c) should have been §192.709(c).\nI apologize for any inconvenience this may have caused.\nRespectfully,\nFor Chris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 D. Hassell (#149005)\n\n520150019W_Warning Letter_12232015_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 23, 2015\nMr. Greg Lalicker\nPresident\nHilcorp Alaska, LLC\n1201 Louisiana St., Suite 1400\nHouston, TX 77002\nCPF 5-2015-0019W\nDear Mr. Lalicker:\nOn March 23, 2015, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\nBeluga natural gas transmission pipeline from Kaloa Junction facility near Granite Point to\nBeluga near Kenai, Alaska.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violations are:\n1. §192.905 How does an operator identify a high consequence area?\n(a) General. To determine which segments of an operator's transmission pipeline\nsystem are covered by this subpart, an operator must identify the high\nconsequence areas. An operator must use method (1) or (2) from the definition in\n§192.903 to identify a high consequence area. An operator may apply one method\nto its entire pipeline system, or an operator may apply one method to individual\nportions of the pipeline system. An operator must describe in its integrity\nmanagement program which method it is applying to each portion of the\noperator's pipeline system. The description must include the potential impact\nradius when utilized to establish a high consequence area. (See appendix E.I. for\nguidance on identifying high consequence areas.)\n\n\n\nHilcorp Alaska, LLC (Hilcorp) did not comply with §192.905(a) for identifying the high\nconsequence areas (HCAs). Hilcorp did not properly identify which buildings are intended\nfor human occupancy and how many people occupy the area within the Potential Impact\nRadius (PIR) of the pipeline segment. At the time of the inspection, the records demonstrate\nthat the method used was not properly applied and did not appropriately classify the pipeline\nsegment.\nHilcorp used method 2 to determine HCAs. Subsequently, HCAs were incorrectly eliminated\nthe covered segment of pipeline by the Chugach Power Plant and the Conoco Processing\nFacility based on \"No HCA due to revised class location\". Furthermore, Hilcorp revised a\nclass 3 location unit in this segment to a class 1 location unit. However, Hilcorp could not\nprovide a count of buildings that are intended for human occupancy in the class location unit\nof the pipeline in this area. Hilcorp had determined that 15 people were within the Potential\nImpact Radius (PIR) of pipeline at the Chugach Power Plant. Meanwhile, Hilcorp could not\nprovide the number of people within the Potential Impact Radius (PIR) of pipeline at the\nadjacent Conoco Processing Facility and at other buildings.\n2. §192.5 Class locations.\n(a) This section classifies pipeline locations for purposes of this part. The\nfollowing criteria apply to classifications under this section.\n(2) Each separate dwelling unit in a multiple dwelling unit building is counted as\na separate building intended for human occupancy.\nHilcorp failed to count each separate dwelling unit in a multiple dwelling unit building as a\nseparate building intended for human occupancy in the \"class location unit\" of the Beluga\npipeline as required by §192.5(a)(2). Therefore, Hilcorp failed to identify which buildings\nwere intended for human occupancy in the \"class location unit\" of the pipeline. In addition,\nHilcorp revised the previous class 3 location unit to a class 1 location unit at this section of\nthe Beluga pipeline. The class location unit of the Beluga pipeline near the Chugach Power\nPlant, Conoco processing facility and Conoco Medic appears to have more than 10 buildings.\n3. §192.745 Valve maintenance: Transmission lines.\n(a) Each transmission line valve that might be required during any emergency\nmust be inspected and partially operated at intervals not exceeding 15 months,\nbut at least once each calendar year.\nHilcorp did not comply with §192.745(a) which requires inspecting and operating the\nmainline valve in 2013. At the time of the inspection, it was noted that the mainline\nemergency isolation valves X-009 and X-013 were not inspected and partially operated in\n2013 by Hilcorp. In addition, valve inspection records for the year 2013 did not include any\ninformation regarding the inspections and operation of mainline isolation valves X-009\n(MLV-1) and X-013 (MLV-2).\n\n\n\n4. §192.479 Atmospheric corrosion control: General.\n(a) Each operator must clean and coat each pipeline or portion of pipeline that is\nexposed to the atmosphere, except pipelines under paragraph (c) of this section.\nHilcorp did not comply with §192.479(a) for inspecting each pipeline or portion of pipeline\nfor evidence of atmospheric corrosion. During the field, it was noted that the coating was in\npoor condition and general corrosion was found on above-ground piping at the Beluga\nmetering station and the main line valve #2 (MLV-2 labeled X-009) at milepost 10.0. In\naddition, a pipeline inspection report in January of 2015 noted that the coating was in poor\ncondition and there was light local corrosion. Interviews of Hilcorp personnel revealed that\nthe coating will be repaired or replaced. Therefore, Hilcorp did not adequately maintain\natmospheric coatings to prevent corrosion on their pipelines with a coating.\n5. §192.709 Transmission lines: Record keeping.\nEach operator shall maintain the following records for transmission lines for the\nperiods specified:\n(c) A record of each patrol, survey, inspection, and test required by subparts L\nand M of this part must be retained for at least 5 years or until the next patrol,\nsurvey, inspection, or test is completed, whichever is longer.\nHilcorp did not comply with §195.709(c) for maintaining the patrol and leak survey records\nprior to the year of 2012. Hilcorp acquired the Beluga pipeline from the previous operator in\n2013. However, Hilcorp did not maintain the records for each patrol and leak survey prior to\nthe year of 2012. In addition, it appears that one leak survey was conducted in February 2012.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the maximum\npenalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct\nthe items identified in this letter. Failure to do so will result in Hilcorp Alaska, LLC being\nsubject to additional enforcement action.\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2015-0019W and for each document you submit, please provide a copy in\nelectronic format to PHP-WRADMIN@dot.gov whenever possible. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 D. Hassell (#149005)","truncated":false,"body_characters":9942}