# HILCORP ALASKA, LLC — Warning Letter

- **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:** Not available
- **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.

Official case documents:

520175008W_Warning Letter_06022017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175008W/520175008W_Warning%20Letter_06022017.pdf

520175008W_Warning Letter_06022017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175008W/520175008W_Warning%20Letter_06022017_text.pdf

520175008W_Warning Letter_06022017_text.pdf

WARNING LETTER
CERTIFIED MAIL – RETURN RECEIPT REQUESTED
June 2, 2017
Mr. Greg Lalicker
President
Hilcorp Alaska, LLC
1111 Travis Street
Houston, Texas 77022
CPF 5-2017-5008W
Dear Mr. Lalicker:
On December 15, 2016, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your
Endicott crude oil pipeline facilities located in Deadhorse, Alaska. Prior to that trip,
supporting operation and maintenance procedures, and implementation records were reviewed
on November 22 and 23, 2016 at your Anchorage office.
As a result of the inspection, it is alleged that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and
the probable violation is:
1. §195.428 Overpressure safety devices and overfill protection systems.
(a) Except as provided in paragraph (b) of this section, each operator shall, at
intervals not exceeding 15 months, but at least once each calendar year, or in the
case of pipelines used to carry highly volatile liquids, at intervals not to exceed 7
½ months, but at least twice each calendar year, inspect and test each pressure
limiting device, relief valve, pressure regulator, or other item of pressure control
equipment to determine that it is functioning properly, is in good mechanical



condition, and is adequate from the standpoint of capacity and reliability of
operation for the service in which it is used.
A review of Hilcorp records revealed that Pressure Safety Valve PSV 1165 had not been
inspected and tested at the required interval. For the calendar year 2015 there were no records
showing that PSV 1165 had been inspected and tested. It should be noted that Hilcorp had
correctly classified PSV 1165 as a regulated overpressure safety device. Previously the
operator BP had not identified PSV 1165 as a regulated overpressure device.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
$205,638 per violation per day the violation persists up to a maximum of $2,056,380 for a
related series of violations. For violations occurring between January 4, 2012 and August 1,
2016, the maximum penalty may not exceed $200,000 per violation per day, with a maximum
penalty not to exceed $2,000,000 for a related series of violations. We have reviewed the
circumstances and supporting documents involved in this case, and have decided not to
conduct additional enforcement action or penalty assessment proceedings at this time. We
advise you to correct the item identified in this letter. Failure to do so will result in Hilcorp
being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer
to CPF 5-2017-5008W. Be advised that all material you submit in response to this
enforcement action is subject to being made publicly available. If you believe that any
portion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),
along with the complete original document you must provide a second copy of the document
with the portions you believe qualify for confidential treatment redacted and an explanation of
why you believe the redacted information qualifies for confidential treatment under 5 U.S.C.
552(b).
Sincerely,
Kim West
Acting Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 M. Chard (#153637)
Ms. Erin McKay, Regulatory Compliance Manager, Hilcorp Alaska, LLC
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