{"operation":"document","citation":"CPF 520160001W","title":"HILCORP ALASKA, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-01-13","effective_on":null,"summary":"CLOSED warning letter citing 192.739(a)(1), 192.739(a)(2), 192.743(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520160001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520160001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520160001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520160001W","body":"Warning Letter involving HILCORP ALASKA, LLC. PHMSA's enforcement data identifies the cited regulations as 192.739(a)(1),  192.739(a)(2),  192.743(a). The case was opened on 2016-01-13 and is reported as closed as of 2016-01-13. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520160001W_Warning Letter_01132016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160001W/520160001W_Warning%20Letter_01132016.pdf\n\n520160001W_Warning Letter_01132016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160001W/520160001W_Warning%20Letter_01132016_text.pdf\n\n520160001W_Warning Letter_01132016_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 13, 2016\nMr. Greg Lalicker\nPresident\nHilcorp Alaska, LLC\n1201 Louisiana Street, Ste. 1400\nHouston, Texas 77002\nCPF 5-2016-0001W\nDear Mr. Lalicker:\nOn March 23-27, 2015, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected\nthe Hilcorp Alaska, LLC’s (Hilcorp’s) Operations and Maintenance manual, Department of\nTransportation (DOT) Operator Qualifications program, records, Control Room\nManagement program and Beluga pipeline specific Operations Manual for the pipeline\nfrom Kaloa Junction facility near Granite Point to Beluga, 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\nand the probable violations are:\n1. §192.739 Pressure limiting and regulating stations: Inspection and testing.\n(a) Each pressure limiting station, relief device (except rupture discs), and\npressure regulating station and its equipment must be subjected at intervals\nnot exceeding 15 months, but at least once each calendar year, to inspections\nand tests to determine that it is—\n(1) In good mechanical condition;\n\n\n\n(2) Adequate from the standpoint of capacity and reliability of operation for\nthe service in which it is employed;\nHilcorp did not perform an inspection or test on their relief device X-028 to determine that\nit is in good mechanical condition and adequate in capacity and reliability of operation\nwithin the required intervals. Hilcorp did not perform the required inspection and testing\nof relief device X-028 in 2013 or 2014.a Hilcorp had a record for the inspection and\ntesting of relief device for February 2015.\n2. §192.743 Pressure limiting and regulating stations: Capacity of relief devices.\n(a) Pressure relief devices at pressure limiting stations and pressure regulating\nstations must have sufficient capacity to protect the facilities to which they are\nconnected. Except as provided in § 192.739(b), the capacity must be consistent\nwith the pressure limits of § 192.201(a). This capacity must be determined at\nintervals not exceeding 15 months, but at least once each calendar year, by\ntesting the devices in place or by review and calculations.\nHilcorp did not determine the capacity as required for their X-028 relief device once each\ncalendar year not to exceed fifteen months. Hilcorp did not have records for their capacity\ndetermination for 2013 or 2014.\nIn February 2015, Hilcorp determined their pressure relief device X-028 at Kaloa Junction\ndid not have sufficient capacity to protect the facilities to which it was connected. An\naudit performed by third-party contractor found that the relief device was not capable of\nprotecting the facilities to which they were connected. Hilcorp replaced the relief device\non April 9, 2015.\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\nmaximum penalty may not exceed $100,000 per violation per day, with a maximum\npenalty not to exceed $1,000,000 for a related series of violations. We have reviewed the\ncircumstances and supporting documents involved in this case, and have decided not to\nconduct additional enforcement action or penalty assessment proceedings at this time. We\nadvise you to correct the items identified in this letter. Failure to do so will result in\nHilcorp being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please\nrefer to CPF 5-2016-0001W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C.\n2\na Hilcorp purchased the Beluga pipeline in February 2013.\n\n\n\n552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential\ntreatment 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 (#149002)\nMr. Richard Novcaski, Vice President and Alaska Operations Manager for Harvest\nAlaska, LLC\n3","truncated":false,"body_characters":5347}