{"operation":"document","citation":"CPF 520175008W","title":"HILCORP ALASKA, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-06-02","effective_on":null,"summary":"CLOSED warning letter citing 195.428(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520175008w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520175008w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520175008w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520175008W","body":"Warning Letter involving HILCORP ALASKA, LLC. PHMSA's enforcement data identifies the cited regulation as 195.428(a). The case was opened on 2017-06-02 and is reported as closed as of 2017-06-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520175008W_Warning Letter_06022017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175008W/520175008W_Warning%20Letter_06022017.pdf\n\n520175008W_Warning Letter_06022017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175008W/520175008W_Warning%20Letter_06022017_text.pdf\n\n520175008W_Warning Letter_06022017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL – RETURN RECEIPT REQUESTED\nJune 2, 2017\nMr. Greg Lalicker\nPresident\nHilcorp Alaska, LLC\n1111 Travis Street\nHouston, Texas 77022\nCPF 5-2017-5008W\nDear Mr. Lalicker:\nOn December 15, 2016, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\nEndicott crude oil pipeline facilities located in Deadhorse, Alaska. Prior to that trip,\nsupporting operation and maintenance procedures, and implementation records were reviewed\non November 22 and 23, 2016 at your Anchorage office.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and\nthe probable violation is:\n1. §195.428 Overpressure safety devices and overfill protection systems.\n(a) Except as provided in paragraph (b) of this section, each operator shall, at\nintervals not exceeding 15 months, but at least once each calendar year, or in the\ncase of pipelines used to carry highly volatile liquids, at intervals not to exceed 7\n½ months, but at least twice each calendar year, inspect and test each pressure\nlimiting device, relief valve, pressure regulator, or other item of pressure control\nequipment to determine that it is functioning properly, is in good mechanical\n\n\n\ncondition, and is adequate from the standpoint of capacity and reliability of\noperation for the service in which it is used.\nA review of Hilcorp records revealed that Pressure Safety Valve PSV 1165 had not been\ninspected and tested at the required interval. For the calendar year 2015 there were no records\nshowing that PSV 1165 had been inspected and tested. It should be noted that Hilcorp had\ncorrectly classified PSV 1165 as a regulated overpressure safety device. Previously the\noperator BP had not identified PSV 1165 as a regulated overpressure device.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$205,638 per violation per day the violation persists up to a maximum of $2,056,380 for a\nrelated series of violations. For violations occurring between January 4, 2012 and August 1,\n2016, the maximum penalty may not exceed $200,000 per violation per day, with a maximum\npenalty not to exceed $2,000,000 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 item identified in this letter. Failure to do so will result in Hilcorp\nbeing subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2017-5008W. 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 M. Chard (#153637)\nMs. Erin McKay, Regulatory Compliance Manager, Hilcorp Alaska, LLC","truncated":false,"body_characters":4243}