{"operation":"document","citation":"CPF 520172002W","title":"HILCORP ALASKA, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-12-01","effective_on":null,"summary":"CLOSED warning letter citing 192.479.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520172002w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520172002w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520172002w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520172002W","body":"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.\n\nOfficial case documents:\n\n520172002W_Warning Letter_12012017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520172002W/520172002W_Warning%20Letter_12012017.pdf\n\n520172002W_Warning Letter_12012017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520172002W/520172002W_Warning%20Letter_12012017_text.pdf\n\n520172002W_Warning Letter_12012017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL – RETURN RECEIPT REQUESTED\nDecember 1, 2017\nMr. Greg Lalicker\nPresident\nHilcorp Alaska, LLC\n1111 Travis Street\nHouston, Texas 77002\nCPF 5-2017-2002W\nDear Mr. Lalicker:\nOn July 19, 2017, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected the\nHilcorp Alaska, LLC (Hilcorp) Tyonek Gas Transmission Pipeline, located at the pig\nreceiving facility at the Conoco Phillips LNG plant near Nikiski, Alaska.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item\ninspected and the probable violation is:\n1. §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.\n(b) Coating material must be suitable for the prevention of atmospheric\ncorrosion.\n(c) Except portions of pipelines in offshore splash zones or soil-to-air interfaces,\nthe operator need not protect from atmospheric corrosion any pipeline for which\nthe operator demonstrates by test, investigation, or experience appropriate to the\nenvironment of the pipeline that corrosion will—\n\n\n\n(1) Only be a light surface oxide; or\n(2) Not affect the safe operation of the pipeline before the next scheduled\ninspection.\nDuring the field audit, located at the pig receiving facility near the Conoco Phillips LNG\nPlant, it was determined that several areas had insufficient coating material and areas of\ndisbonded coating. The pipeline segment at this location is aboveground uninsulated pipe and\nis exposed to the atmosphere. The observed failed coating may lead to further pitting\ncorrosion if not remediated and recoated.\nThis finding was discussed with Hilcorp integrity management personnel who stated that the\nTyonek Gas Transmission Pipeline and the tie in with the failed coating was on a remediation\nplan and that the failed coating would be addressed following a Hilcorp integrity assessment\nto be completed in 2017.\nHilcorp purchased this pipeline asset from Conoco Phillips, Alaska in December 2016 and has\nbeen the operator of the Tyonek Gas Transmission pipeline for less than 1 year.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to\nexceed $209,002 per violation per day the violation persists up to a maximum of $2,090,022\nfor a related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement\naction or penalty assessment proceedings at this time. We advise you to correct the item\nidentified in this letter. Failure to do so will result in Hilcorp being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2017-2002W. 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. 552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nKim West\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 R. Guisinger (#156054)","truncated":false,"body_characters":4369}