{"operation":"document","citation":"CPF 520177002H","title":"HILCORP ALASKA, LLC — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-04-07","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520177002h.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520177002h.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520177002h","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520177002H","body":"Corrective Action Order involving HILCORP ALASKA, LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2017-04-07 and is reported as closed as of 2017-05-01. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520177002H_Corrective Action Order_04072017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520177002H/520177002H_Corrective%20Action%20Order_04072017.pdf\n\n520177002H_Corrective Action Order_04072017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520177002H/520177002H_Corrective%20Action%20Order_04072017_text.pdf\n\n520177002H_Region Withdrawal of Notice_05012017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520177002H/520177002H_Region%20Withdrawal%20of%20Notice_05012017.pdf\n\n520177002H_Region Withdrawal of Notice_05012017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520177002H/520177002H_Region%20Withdrawal%20of%20Notice_05012017_text.pdf\n\n520177002H_Corrective Action Order_04072017_text.pdf\n\nVIA CERTIFIED MAIL AND FAX TO (907) 777-8301\nApril 7, 2017\nMr. Greg Lalicker\nPresident\nHilcorp Alaska, LLC\n1201 Louisiana St., Suite 1400\nHouston, Texas 77002\nRE: CPF No. 5-2017-7002H\nCorrections to Order\nDear Mr. Lalicker:\nThe Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a Corrective Action Order\n(CAO), CPF No. 5-2017-7002H, to your company on April 6, 2017. After further review, we have found\nwe need to make corrections and have attached a CAO showing those corrections:\nOn Page 3, third paragraph from the bottom – Preliminary finding reference to “in-line\ninspection” was deleted in its entirety and replaced with “pigging” of the Affected Segment.\nOn Page 6, Paragraph 5 – The Required Corrective Actions mandate the daily monitoring to be\ncompleted during “neap” tide, when in fact it should have said during “slack tide during daylight\nhours”.\nAdditionally, an enhanced map of the Anna to Bruce platforms is attached.\nIf you have any questions concerning this letter, please contact Mr. David Hassell, Alaska Office\nOperations Supervisor, at (907) 271-6519.\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 T. Johnson\nMr. David S. Wilkins, Senior Vice President, Hilcorp Alaska, LLC\nMs. Erin McKay, Regulatory Compliance Manager, Hilcorp Alaska, LLC\n\n\n\nApril 7, 2017\nVIA CERTIFIED MAIL AND EMAIL TO: glalicker@hilcorp.com\nMr. Greg Lalicker\nPresident\nHilcorp Alaska, LLC\n1111 Travis Street\nHouston, Texas 77002\nCPF No. 5-2017-7002H\nDear Mr. Lalicker:\nEnclosed please find a Corrective Action Order (CAO) issued by the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), in the above-\nreferenced case. It requires Hilcorp Alaska, LLC, a subsidiary of Hilcorp Energy Company, to\ntake certain corrective actions with respect to its 8-inch sub-sea hazardous liquids pipeline running\nfrom the Anna Platform to the Bruce Platform that experienced a crude oil release on April 1,\n2017, into the Cook Inlet of Alaska.\nService of this CAO is being made by certified mail and facsimile. Service of the CAO by\nelectronic transmission is deemed complete upon transmission and acknowledgement of receipt,\nor as otherwise provided under 49 C.F.R. § 190.5. The terms and conditions of this Order are\neffective upon completion of service.\nSincerely,\nfor Alan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure: CAO, w/ copy of 49 C.F.R. § 190.233\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS\nMr. Chris Hoidal, Region Director, Western Region, OPS\nMs. Erin McKay, Regulatory Compliance Manager, Alaska Integrity Group, Hilcorp\nAlaska, LLC, at emckay@hilcorp.com\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n________________________________________________\nIn the Matter of )\n)\n)\nHilcorp Alaska, LLC, )\na subsidiary of Hilcorp Energy Company, Respondent. )\n)\n)\n_______________________________________________ )\n) CPF No. 5-2017-7002H\nCORRECTIVE ACTION ORDER\nPurpose and Background:\nThis Corrective Action Order (CAO or Order) is being issued under the authority of 49 U.S.C.\n§ 60112 to require Hilcorp Alaska, LLC (Hilcorp or Respondent), to take the necessary\ncorrective actions to protect the public, property, and the environment from potential hazards\nassociated with the release from its 8-inch hazardous liquids subsea pipeline running from\nHilcorp’s Anna Platform to its Bruce Platform in the Cook Inlet, Alaska.1\nOn April 1, 2017, a reportable accident occurred on the portion of Hilcorp’s 8-inch, subsea\npipeline that runs from the Anna Platform to the Bruce Platform (Affected Segment), resulting in\nthe release of an unknown quantity of crude oil (Failure). Hilcorp reported that no injuries or\nfatalities occurred as a result of the Failure and there was no fire or explosion. The Failure\noccurred in a High Consequence Area (HCA) with endangered and threatened species of marine\nlife near the location of the spill.2 The cause of the Failure has not yet been determined.\nPursuant to 49 U.S.C. § 60117, the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety (OPS), initiated an investigation of the Failure. The\npreliminary findings of the agency's ongoing investigation are as follows:\nPreliminary Findings:\n The Granite Point crude oil pipeline facilities include pipelines associated with the Anna\nPlatform, Bruce Platform, Granite Point Platform, and Granit Pointe Tank Farm. The\n1 The Anna to Bruce pipeline is a crude-oil gathering line that is part of Hilcorp’s Granite Point pipeline facilities\nlocated in the Cook Inlet, Alaska.\n2 According to 49 C.F.R. § 195.450, a “High Consequence Area” is (1) a commercially navigable waterway, (2) a\nhigh population area, (3) an “other populated area,” or (4) “an unusually sensitive area,” as more specifically defined\nin § 195.6.\n\n\n\nCPF No. 5-2017-7002H\nPage 3\nFailure is associated with the crude oil pipeline that transports crude oil from the Anna\nPlatform to the Bruce Platform. Once on the Bruce Platform, the Anna crude oil is\ncommingled with the crude oil produced on the Bruce Platform and the commingled\ncrude oil is transported by pipeline from the Bruce Platform to the Granite Point Tank\nFarm.3\n The Affected Segment is a crude-oil pipeline associated with Hilcorp’s Granite Point Tank\nFarm (GPTF) facility. The GPTF includes crude-oil and gas pipelines that serve the\ncompany’s Anna, Bruce, Granite Point, Spark, and Spurr Platforms in Cook Inlet. The\nGPTF is not part of Hilcorp’s Middle Ground Shoal (MGS) Fuel Gas System, which is\ncurrently experiencing an ongoing natural gas leak in another part of the Cook Inlet,\nAlaska and is subject to a separate PHMSA enforcement proceeding.4\n The Affected Segment is approximately 8570 feet in length, and is constructed with\n8.625-inch diameter, Grade B, seamless pipe with a coal tar/enamel coating. The pipe\nwall thickness is 0.593 inch for the offshore pipe and 0.500 inch for the riser pipe. The\nsteel coating is in turn overlaid with a 1.25-inch-thick concrete coating. This segment\nwas installed in 1966. The Maximum Operating Pressure (MOP) of the pipeline is 340\npsig.\n The Affected Segment has a maximum capacity of 461 barrels of crude oil and was\noperating at full capacity at the time of the Failure. The crude oil in the Affected Segment\nis produced and processed on the Anna Platform for crude-oil pipeline transportation.\nThe Anna to Bruce pipeline was operating at 70 psi at the time of the Failure.\n At approximately 11:20 a.m. AKDT (all times are AKDT unless otherwise noted) on\nApril 1, 2017, Hilcorp discovered a discharge of crude oil due to a potential leak on the\nAnna to Bruce pipeline. Hilcorp reported an impact on the Anna Platform and\nimmediately confirmed by visual observation a crude-oil release. Hilcorp reported that\nthe Affected Segment and the Anna Platform were shut in (closed) immediately upon the\nvisual observation of the release. The Bruce Platform is still operating and continues to\nproduce and send processed crude oil to the GPTF facility.\n The accident was initially reported by Hilcorp to the National Response Center at 3:55\np.m. EDT on April 1, 2017 (NRC Report No. 1174601), indicating a release of an\nunknown quantity of crude oil. Hilcorp subsequently reported that the release amount\nwas less than 10 gallons.\n No injuries or fatalities occurred as a result of the Failure and there was no fire or\nexplosion. The Affected Segment is located in an Unusually Sensitive Area with\nendangered and threatened species marine life in and around the location of the Failure.\n3 See Figure 1, Map of the Granite Point crude oil pipeline facilities\n4 See, In the Matter of Hilcorp Alaska, LLC [5-2017-0004S] (available on PHMSA’s website).\n\n\n\nCPF No. 5-2017-7002H\nPage 4\n On April 1, 2017, Hilcorp directed its Oil Spill Removal Organization (OSRO), Cook\nInlet Spill Prevention & Response, Inc. (CISPRI), to mobilize the spill response ship\nPerseverance. Hilcorp also mobilized a helicopter overflight in the area of the\nFailure. The overflight confirmed the presence of a crude-oil sheen. There were\napproximately six different sheens found near the area of the Failure. Most of the sheens\nhad an area of approximately 100 square feet. The leading edge of the sheens was\napproximately 3.5 miles south from the Anna Platform.\n At 1:15 p.m. AKDT on April 2, 2017, Hilcorp began activities to purge the Affected\nSegment of oil and replace it with sea water by the use of a foam pig. The purging\nactivities were completed at 9:20 p.m. on April 2, 2017, and the Affected Segment is now\npurged. ADEC and the USCG had observers on the Anna Platform during the purging of\nthe Affected Segment. PHMSA’s Office of Pipeline Safety Western Region also had an\ninspector present at the Incident Command Site in Nikiski, Alaska.\n On April 2, 2017, at 8:00 a.m., a Unified Command comprised of the USCG, ADEC, and\nHilcorp was established.\n The Affected Segment had an In Line Inspection (ILI) preformed in June 2016. Less than\n20 anomalies were found. The deepest anomaly had metal loss less than 35 percent of the\n0.593” thick pipe wall.\n On April 3, 2017, Hilcorp conducted an additional overflight and reported no observable\noil sheen or wildlife in the area of the Failure. Based on the overflight information from\nApril 2nd and April 3rd, the Unified Command stood down the Incident Command Post\nat 9:00 a.m. on April 3rd 2017.\n On April 3-4, 2017, Hilcorp conducted pigging of the Affected Segment. Hilcorp reported\nthat it sent a cleaning/scraper “pig” followed by a foam pig toward the Bruce Platform,\npast the sub-sea flanges near the Anna Platform. Hilcorp used 100 barrels of filtered\nCook Inlet water to push the pigs past the sub-sea flanges near the Anna Platform.\nHilcorp reported that they are unable to send the pigs the full distance to the Bruce\nPlatform at this time due to the low water-handling capability at the Bruce Platform.\n On April 3-4, 2017, Hilcorp conducted a pressure test on the Affected Segment by\nincreasing the pressure to 340 psig for a period of 24 hours. Hilcorp reported that the\nAffected Segment lost pressure slowly during the test.\n Hilcorp reports that it installed blind flanges on both ends of the Affected Segment. On\nApril 5, 2017, Hilcorp performed a second pressure test on the Affected Segment starting\nat 1:30 a.m. to 337 psig. The pipeline pressure was 335 psig at 6:30 a.m. At\napproximately 8:30 a.m., the pressure was reading 336 psig, seven hours after the test\nbegan. Hilcorp reports that it will prepare to perform an eight-hour hydro test in\naccordance with Federal pipeline safety standards, 49 CFR Part 195, Subpart E.\n\n\n\nCPF No. 5-2017-7002H\nPage 5\n Hilcorp reports that it is developing a plan to return the Affected Segment to service but\nwill wait to see the results of the pressure test before making a determination on returning\nthe line to service.\n Hilcorp reports that is has not yet identified the exact location of the release, its cause, or\nthe exact amount of product released into the environment.\nDetermination of Necessity for Corrective Action Order and Right to Hearing:\nSection 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action\nOrder, after reasonable notice and the opportunity for a hearing, requiring corrective action,\nwhich may include the suspended or restricted use of a pipeline facility, physical inspection,\ntesting, repair, replacement, or other action, as appropriate. The basis for making the\ndetermination that a pipeline facility is hazardous and requiring corrective action is set forth both\nin the above-referenced statute and 49 C.F.R.§ 190.233, a copy of which is enclosed.\nSection 60112, and the regulations promulgated thereunder, provide for the issuance of a\nCorrective Action Order without prior opportunity for notice and hearing upon a finding that\nfailure to issue the Order expeditiously will likely result in serious harm to life, property or the\nenvironment. In such cases, an opportunity for a hearing will be provided as soon as practicable\nafter the issuance of the Order.\nAfter evaluating the foregoing preliminary findings of fact and considering the ongoing\ninvestigation of the Failure, I find that the continued operation of the Affected Segment without\ncorrective measures is or would be hazardous to life, property and the environment.\nAdditionally, after considering the age of the pipe, the circumstances surrounding the Failure, the\nhazardous nature of the product being transported, the pressure required for transporting the\nmaterial, the uncertainties as to the cause of the Failure, the environmental hazards associated\nwith the Failure, the location of the Failure in an HCA, and the ongoing investigations to\ndetermine the cause of the Failure, I find that a failure to issue this Order expeditiously to require\nimmediate corrective action would result in likely serious harm to life, property, and the\nenvironment.\nAccordingly, this Corrective Action Order mandating immediate corrective action is issued\nwithout prior notice and opportunity for a hearing. The terms and conditions of this Order are\neffective upon receipt.\nWithin 10 days of receipt of this Order, Respondent may request a hearing, to be held as soon as\npracticable, by notifying the Associate Administrator for Pipeline Safety in writing, with a copy\nto the Director, Western Region, PHMSA (Director). If a hearing is requested, it will be held\ntelephonically or in-person in Denver, Colorado, unless a different location is expressly agreed to\nin writing by the Director.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective measures that need to be taken. Respondent will be notified of any\n\n\n\nCPF No. 5-2017-7002H\nPage 6\nadditional measures required and amendment of this Order will be considered. To the extent\nconsistent with safety, Respondent will be afforded notice and an opportunity for a hearing prior\nto the imposition of any additional corrective measures.\nRequired Corrective Actions:\nDefinitions:\nAffected Segment – The Affected Segment means Respondent’s 8-inch crude-oil subsea pipeline\nsegment of the Granite Point Tank Farm pipeline facility that runs approximately 1.6 miles from\nthe Anna Platform to the Bruce Platform in the Cook Inlet, Alaska.\nDirector – The Director means the Director, Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety, Western Region.\nFailure Site – The Failure Site means the location on the Affected Segment where the leak\noccurred on April 1, 2017 in Cook Inlet, Alaska.\nPursuant to 49 U.S.C. 60112, I hereby order Hilcorp to immediately take the following corrective\nactions for the Affected Segment:\n1. Shut down of the Affected Segment. Hilcorp must not operate the Affected Segment\nuntil authorized to do so by the Director.\nPressure Test. Within five days of receipt of this Order, Hilcorp must perform a\nhydrostatic pressure test of the Affected Segment during daylight hours that meets the\nrequirements of 49 CFR Part 195 Subpart E. Hilcorp must submit the results of the\nSubpart E pressure test to the Director within three days of completing the pressure test\nrequired by this paragraph. Additionally, prior to the hydrostatic pressure test, Hilcorp\nmust conduct a full volumetric accounting of the displaced oil in the pipeline.\nInspection. Within 25 days of receipt of this Order, Hilcorp must conduct a direct visual\nexamination of the Affected Segment at the point where it exits the Anna Platform leg,\nincluding the interior of the Anna Platform leg, to ensure there has been no physical\ndamage to the pipeline or ancillary connections. Examination of the annulus between the\npipeline and the Anna Platform leg, including sampling for hydrocarbons, shall also be\ncompleted during this time. Hilcorp must submit written results of the visual\nobservations and sampling, including any photographs, videos, or other supporting\ndocumentation, within three days of completion of the inspection required by this\nparagraph.\nReview of Prior ILI Results. Within 14 days of receipt of this Order, Hilcorp must\nconduct a reevaluation of the 2016 ILI survey results on the Affected Segment, including\na review of the ILI vendors' raw data and analysis. Hilcorp must determine if any\nfeatures were present on the Affected Segment that may indicate an integrity-threatening\nanomaly. Hilcorp must submit documentation of this ILI review and analysis to the\nDirector within 21 days of receipt of this Order.\n2. 3. 4.\n\n\n\nCPF No. 5-2017-7002H\nPage 7\n5. Return to Service. Hilcorp must provide a restart plan to the Director for review and\napproval that demonstrates CAO Corrective Items 2-4 above have been completed prior\nto restart. The restart plan must also include a plan to conduct daily monitoring of the\nAffected Segment right-of-way. The daily monitoring shall be conducted during slack\ntide during daylight hours for a period of 30 consecutive days.\n6. Root Cause Failure Analysis. Within 90 days following receipt of this Order, Hilcorp\nmust complete a root cause failure analysis (RCFA) that is supplemented and facilitated\nby an independent third-party vendor acceptable to the Director. The RCFA must\ndocument all contributory factors and the decision-making process. Hilcorp must submit\na final report of the RCFA to the Director. The final report must include findings, any\nlessons learned, and whether the findings and any lessons learned are applicable to other\nlocations within Hilcorp’s Granite Point Tank Farm Platform pipeline systems.\nIn addition to the above Corrective Action Items, PHMSA strongly encourages, but does not\norder, that Respondent take immediate steps to develop and implement a Safety Management\nSystem (SMS) for all its pipeline assets in Cook Inlet and that such a system be fully\nimplemented within one year from the Date of this Order. API 1173 provides pipeline operators\nwith safety management system requirements that, when properly applied, provide an effective\nframework for revealing and managing risk, promoting a learning environment, and continuously\nimproving pipeline safety and integrity.\nThe Director may grant an extension of time for compliance with any of the terms of this Order\nupon a written request timely submitted demonstrating good cause for an extension.\nWith respect to each submission that under this Order requires the approval of the Director, the\nDirector may: (a) approve, in whole or part, the submission; (b) approve the submission on\nspecified conditions; (c) modify the submission to cure any deficiencies; (d) disapprove, in\nwhole or in part, the submission, directing that Respondent modify the submission; or (e) any\ncombination of the above. In the event of approval, approval upon conditions, or modification\nby the Director, Respondent will proceed to take all action required by the submission as\napproved or modified by the Director. If the Director disapproves all or any portion of the\nsubmission, Respondent will correct all deficiencies within the time specified by the Director,\nand resubmit it for approval. If a resubmitted item is disapproved in whole or in part, the\nDirector may again require Respondent to correct the deficiencies in accordance with the\nforegoing procedure, and the Director may otherwise proceed to enforce the terms of this Order.\nBe advised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. § 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. § 552(b).\n\n\n\nCPF No. 5-2017-7002H\nPage 8\nIn your correspondence on this matter, please refer to \"CPF No. 5-2017-7002H” and for each\ndocument you submit, please provide a copy in electronic format whenever possible. The\nactions required by this Order are in addition to and do not waive any requirements that apply to\nRespondent's pipeline system under 49 C.F.R. Parts 190 through 199, under any other order\nissued to Respondent under authority of 49 U.S.C. Chapter 601, or under any other provision of\nFederal or State law.\nRespondent may appeal any decision of the Director to the Associate Administrator for Pipeline\nSafety. Decisions of the Associate Administrator shall be final.\nFailure to comply with this Order may result in the assessment of civil penalties and in referral to\nthe Attorney General for appropriate relief in United States District Court pursuant to\n49 U.S.C. § 60120.\nThe terms and conditions of this Order are effective upon service in accordance with 49 C.F.R.\n§ 190.5.\nApril 7, 2017\n_________________________________ ________________\nfor Alan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n520177002H_Region Withdrawal of Notice_05012017_text.pdf\n\nMay 1, 2017\nVIA FACSIMILE TO (907) 777-8301 AND CERTIFIED MAIL\nMr. Greg Lalicker\nPresident\nHilcorp Alaska, LLC\n1111 Travis Street\nHouston, Texas 77002\nRE: Corrective Action Order CPF No. 5-2017-7002H\nGranite Point Tank Farm Pipeline Facilities (Anna to Bruce Pipeline)\nNotice of Withdrawal\nDear Mr. Lalicker:\nOn April 7, 2017, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued\na Corrective Action Order (CAO) to Hilcorp Alaska, LLC (Hilcorp) for the potential hazards\nassociated with the April 1, 2017 release of crude oil from Hilcorp’s Granite Point Tank Farm\nPipeline Facilities. Hilcorp initially reported to PHMSA that the release was a result of a failure\non the Anna to Bruce crude oil pipeline (Pipeline), which is a component of the Granite Point\nTank Farm Pipeline Facilities, and runs between the Anna Platform and the Bruce Platform in\nthe Cook Inlet, Alaska.\nThe CAO required Hilcorp to perform certain corrective measures with respect to the Pipeline, to\ninclude, a 49 CFR Part 195 Subpart E pressure test of the pipeline; a visual inspection of the\npipeline; review of Hilcorp’s 2016 In-line inspection (ILI) data from the pipeline; completion of\na root cause analysis of the failure; and submission of a restart plan for approval. Hilcorp\ncompleted a Subpart E pressure test of the Pipeline, conducted a visual inspection of the\nPipeline, reviewed the prior ILI data, performed an internal root cause analysis that was\nsubsequently reviewed by an independent third party expert, submitted a restart plan for\napproval, and provided PHMSA with all of the required documentation associated with each of\nthese tasks. On April 27, 2017, PHMSA approved Hilcorp’s restart plan as it relates to pipeline\noperations.\nPHMSA, in conjunction with relevant state and federal authorities, undertook a thorough review\nand analysis of the documentation submitted by Hilcorp in response to the CAO. As a result of\nthis review, PHMSA has determined that the crude oil release of April 1, 2017, was due to\n\n\n\nCPF No. 5-2017-7002H\nPage 2\ncomponents on the Anna Platform, not from the Pipeline or from a pipeline facility subject to\nPHMSA’s regulatory authority. As a result, PHMSA withdraws CAO No. 5-2017-7002H in its\nentirety, effective immediately.\nIf you have any questions concerning this letter, please contact Mr. Alan Mayberry, Associate\nAdministrator for Pipeline Safety, at (202) 366-5124.\nSincerely,\nAlan Mayberry\nAssociated Administrator\nfor Pipeline Safety.\ncc: PHP-60 Compliance Registry\nPHP-500 D. Hassell\nPHP-500 D. Hubbard\nMr. Larry White, Presiding Official\nMr. David S. Wilkins, Senior Vice President, Hilcorp Alaska, LLC\nMs. Erin McKay, Regulatory Compliance Manager, Hilcorp Alaska, LLC\nMr. James Curry, counsel for Hilcorp Alaska, LLC","truncated":false,"body_characters":25195}