{"operation":"document","citation":"CPF 520155025W","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 195.452(j)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520155025w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520155025w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520155025w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520155025W","body":"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.\n\nOfficial case documents:\n\n520155025W_Warning Letter_12232015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155025W/520155025W_Warning%20Letter_12232015.pdf\n\n520155025W_Warning Letter_12232015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155025W/520155025W_Warning%20Letter_12232015_text.pdf\n\n520155025W_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 Street, Suite 1400\nHouston, Texas 77002\nCPF 5-2015-5025W\nDear Mr. Lalicker:\nOn September 22, 2015 and September 23, 2015, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code, inspected your Milne Point facility located near Prudhoe Bay, Alaska.\nAs a result of the inspection, it appears that Hilcorp Alaska has committed a probable\nviolation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The\nitems inspected and the probable violation is:\n1. §195.452 Pipeline integrity management in high consequence areas.\n(j) What is a continual process of evaluation and assessment to maintain a\npipeline's integrity?\n(3) Assessment intervals. An operator must establish five-year intervals, not to\nexceed 68 months, for continually assessing the line pipe's integrity. An operator\nmust base the assessment intervals on the risk the line pipe poses to the high\nconsequence area to determine the priority for assessing the pipeline segments.\nAn operator must establish the assessment intervals based on the factors\nspecified in paragraph (e) of this section, the analysis of the results from the last\nintegrity assessment, and the information analysis required by paragraph (g) of\nthis section.\nHilcorp Alaska, LLC (Hilcorp) failed to perform an assessment of the stainless steel pipeline\nsegment as required by §195.452(j)(3). During the inspection of the Milne Point facility\n\n\n\nlocated near Prudhoe Bay, Alaska, it was determined that a segment of stainless steel\npipeline, approximately 600 feet in length, and 12” in diameter, had not been inspected under\n§195.452 (j)(3), which requires inspection in high consequence areas “not to exceed 68\nmonths”. This segment is a tie in from Milne Point sales crude pipeline to the\nConocoPhillips Kuparuk sales crude pipeline.\nAs a result from the PHMSA inspection, Hilcorp proceeded to use guided wave technology\nto inspect the 600 feet of above ground pipeline. The results of the guided wave inspection\nconfirmed no anomalies on the segment. Hilcorp must incorporate this segment into their\nintegrity management plan as required by §195.452 (j)(3).\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\nand supporting 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.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2015-5025W for each document you submit, please provide a copy in electronic\nformat to PHP-WRADMIN@dot.gov whenever possible. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If\nyou believe that any portion of your responsive material qualifies for confidential treatment\nunder 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for\nconfidential 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 R. Guisinger (#150149)","truncated":false,"body_characters":4680}