{"operation":"document","citation":"CPF 520180015W","title":"HILCORP ALASKA, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-12-27","effective_on":null,"summary":"CLOSED warning letter citing 192.475(a), 192.709(c), 192.805(h).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520180015w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520180015w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520180015w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520180015W","body":"Warning Letter involving HILCORP ALASKA, LLC. PHMSA's enforcement data identifies the cited regulations as 192.475(a),  192.709(c),  192.805(h). The case was opened on 2018-12-27 and is reported as closed as of 2018-12-27. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520180015W_Region Withdrawal of Item 4_04232019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520180015W/520180015W_Region%20Withdrawal%20of%20Item%204_04232019.pdf\n\n520180015W_Region Withdrawal of Item 4_04232019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520180015W/520180015W_Region%20Withdrawal%20of%20Item%204_04232019_text.pdf\n\n520180015W_Warning Letter_12272018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520180015W/520180015W_Warning%20Letter_12272018.pdf\n\n520180015W_Warning Letter_12272018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520180015W/520180015W_Warning%20Letter_12272018_text.pdf\n\n520180015W_Region Withdrawal of Item 4_04232019_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 23, 2019\nMr. Greg Lalicker\nPresident and COO\nHilcorp Alaska, LLC\n1201 Louisiana Street\nSuite 1400\nHouston, Texas 77002\nCPF 5-2018-0015W\nWithdrawal of Item 4\nDear Mr. Lalicker:\nOn December 27, 2018, Hilcorp Alaska, LLC (Hilcorp) was issued a Warning Letter for the\nCPF number referenced above. This Warning Letter alleged that Hilcorp had committed\nprobable violations of the Pipeline Safety Regulations. Item 4 of the Warning Letter alleged a\nprobable violation of § 192.807. Specifically, the Warning Letter provided as follows:\n4. § 192.807 Recordkeeping.\nEach operator shall maintain records that demonstrate compliance with this\nsubpart.\n(a) Qualification records shall include:\n(1) Identification of qualified individual(s);\n(2) Identification of the covered tasks the individual is qualified to perform;\n(3) Date(s) of current qualification; and\n(4) Qualification method(s).\nThe Operator failed to qualify an employee for mainline valve testing. The Operator provided\nrecords showing that an employee was qualified under procedure 716OP to inspect, maintain,\nand operate valves through 2015. However, the Operator failed to provide records showing\nthat this individual was qualified to perform the covered task on October 4, 2016, when he\nperformed testing of valve SDV-0001.\n\n\n\nPHMSA incorrectly noted October 4, 2016 as the date Valve SDV-0001 was inspected. On\nFebruary 27, 2019, Hilcorp provided by email a NorthStar DOT Valve Inspecton Report for\nValve SDV-0001 dated 9/25/16 as well as operator qualification records for the individual\nwho performed the inspection.\nThis letter is to inform you that PHMSA hereby withdraws item 4 of the Warning Letter.\nSincerely,\nChris Hoidal\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Owens (# 155099)\n2\n\n520180015W_Warning Letter_12272018_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 27, 2018\nMr. Greg Lalicker\nPresident and COO\nHilcorp Alaska, LLC\n1201 Louisiana Street\nSuite 1400\nHouston, Texas 77002\nCPF 5-2018-0015W\nDear Mr. Lalicker:\nFrom March 6 through March 8, 2017, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code\n(U.S.C.), inspected your 10-inch Northstar natural gas pipeline and facilities located in the\nBeaufort Sea and on the North Slope in Alaska.\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 (CFR). The items\ninspected and the probable violations are:\n1. § 192.475 Internal corrosion control: General.\n(a) Corrosive gas may not be transported by pipeline, unless the corrosive effect\nof the gas on the pipeline has been investigated and steps have been taken to\nminimize internal corrosion.\n\n\n\nThe Operator failed to test the gas going into the Northstar pipeline in violation of its\nprocedure and the regulation. Procedure P-192.475 (Gas Internal Corrosion Control\n11/24/2016, Rev 3, p. 2/4 under Procedure Steps) states “[w]here potentially corrosive gas is\nfound as a result of testing, initiate the remedial action prior to the next test.” The Operator\nadmits that they don't test the natural gas nor do they obtain records of the contents of the gas\nfrom the producer.\n2. § 192.709 Transmission lines: Record keeping.\nEach operator shall maintain the following records for transmission lines for the\nperiods specified:\n(a).…\n(c) A record of each patrol, survey, inspection, and test required by subparts L\nand M of this part must be retained for at least 5 years or until the next patrol,\nsurvey, inspection, or test is completed, whichever is longer\nThe operator presented valve inspection records ostensibly for 2015, but they were not\nproperly dated with the year. Retention for the specified time period consistent with the code\nis not possible without a proper date on the valve inspection reports.\n3. § 192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The\nprogram shall include provisions to:…\n(a)….\n(h) After December 16, 2004, provide training, as appropriate, to ensure that\nindividuals performing covered tasks have the necessary knowledge and skills to\nperform the tasks in a manner that ensures the safe operation of pipeline\nfacilities;\nThe Operator failed to properly train individuals to perform covered tasks. On July 8, 2015,\nan employee of the Operator tested two pressure relief valves NS-RV-129 (NS-PSV-2500)\nand NS-RV-295 (PSV-940S-DOT). The Operator provided records that the employee was\nqualified in Inspecting and Testing of Relief Devices between April 2016 and April 2019, but\nno records were provided to show that he was qualified in 2015, when the work was\nperformed. In addition, the records provided by the Operator failed to demonstrate that the\nemployee was qualified to react and respond to Abnormal Operating Conditions. The\nOperator also provided a Pressure Relief Service Valve Report from April 24, 2014 that\nshowed another employee tested PSV 2500, Skid 50, but no operator qualification records for\nthis employee were provided.\n4. § 192.807 Recordkeeping.\nEach operator shall maintain records that demonstrate compliance with this\nsubpart.\n(a) Qualification records shall include:\n2\n\n\n\n(1) Identification of qualified individual(s);\n(2) Identification of the covered tasks the individual is qualified to perform;\n(3) Date(s) of current qualification; and\n(4) Qualification method(s).\nThe Operator failed to qualify an employee for mainline valve testing. The Operator provided\nrecords showing that an employee was qualified under procedure 716OP to inspect, maintain,\nand operate valves through 2015. However, the Operator failed to provide records showing\nthat this individual was qualified to perform the covered task on October 4, 2016, when he\nperformed testing of valve SDV-0001.\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. For violations occurring prior to November 2, 2015, the\nmaximum penalty may not exceed $200,000 per violation per day, with a maximum penalty\nnot 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(s) identified in this letter. Failure to do so will result in Hilcorp\nAlaska, LLC being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2018-0015W. 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,\nChris Hoidal\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Owens (# 155099)\n3","truncated":false,"body_characters":8666}