{"operation":"document","citation":"CPF 520195008W","title":"HARVEST ALASKA, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-09-18","effective_on":null,"summary":"CLOSED warning letter citing 195.208, 195.579(c), 195.583(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520195008w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520195008w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520195008w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520195008W","body":"Warning Letter involving HARVEST ALASKA, LLC. PHMSA's enforcement data identifies the cited regulations as 195.208,  195.579(c),  195.583(a). The case was opened on 2019-09-18 and is reported as closed as of 2019-09-18. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520195008W_Warning Letter_09182019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520195008W/520195008W_Warning%20Letter_09182019.pdf\n\n520195008W_Warning Letter_09182019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520195008W/520195008W_Warning%20Letter_09182019_text.pdf\n\n520195008W_Warning Letter_09182019_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 18, 2019\nMr. Greg Lalicker\nChief Executive Officer\nHilcorp Energy Company\n1111 Travis Street\nHouston, Texas 77002\nCPF 5-2019-5008W\nDear Mr. Lalicker:\nOn March 4 through 8 and March 18 through 20, 2019, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.), inspected Harvest Alaska, LLC’s (Harvest)1 North Star and Endicott\nPipeline systems near Prudhoe Bay, Alaska, and associated operational procedures and records\nin Anchorage, 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 Harvest is a wholly-owned subsidiary or Hilcorp Alaska, LLC, which is a wholly-owned subsidiary of Hilcorp\nEnergy Company.\n\n\n\n1. § 195.208 Welding of supports and braces.\nSupports or braces may not be welded directly to pipe that will be operated at a\npressure of more than 100 p.s.i. (689 kPa) gage.\nBraces were directly welded to the pipeline on the upstream and downstream pig traps of the\nEndicott pipeline. The pipeline was operating at less than 100 psig during the site\nvisit. However, the control room operators stated that the line had been operated at greater\nthan 100 psig in the recent past and, based on a review of the piping and instrument diagrams\nand site visit, the pumps are still configured in a way that the pipeline could be pressured to\ngreater than 100 psi.\n2. § 195.579 What must I do to mitigate internal corrosion?\n(a) ….\n(c) Removing pipe. Whenever you remove pipe from a pipeline, you must inspect\nthe internal surface of the pipe for evidence of corrosion. If you find internal\ncorrosion requiring corrective action under §195.585, you must investigate\ncircumferentially and longitudinally beyond the removed pipe (by visual\nexamination, indirect method, or both) to determine whether additional corrosion\nrequiring remedial action exists in the vicinity of the removed pipe.\nIn late 2016 through early 2017, Harvest replaced piping at the metering facilities at\ndownstream end of the NorthStar and Endicott pipelines, between these pipelines' pig receivers\nand Pump Station 1. This project included hot taps, a stoppled section of the pipeline, and\nremoved spools of the pipeline. For this project, Harvest removed piping and exposed internal\nsurfaces of the pipeline (for example, on the hot tap coupons), but failed to inspect the internal\nsurfaces for evidence of internal corrosion.\n3. § 195.583 What must I do to monitor atmospheric corrosion control?\n(a) You must inspect each pipeline or portion of pipeline that is exposed to the\natmosphere for evidence of atmospheric corrosion, as follows:\nIf the pipeline is located: Onshore Then the frequency of inspection is:\nAt least once every 3 calendar years,\nbut with intervals not exceeding 39\nmonths.\nOffshore At least once each calendar year, but\nwith intervals not exceeding 15\nmonths.\n2\n\n\n\nHarvest failed to inspect each portion of a pipeline that is exposed to the atmosphere for\nevidence of corrosion at the required intervals. Specifically:\n For the North Star pipeline, the valve at Pt. Storkenson (Valve SDV-0011) was\ninspected for atmospheric corrosion on March 17, 2014 and on March 7, 2018, which\nexceeds the maximum 39-month inspection interval. Harvest personnel stated that they\ninspect the valve at Pt. Storkenson as part of their annual walking speed survey, but the\nannual walking speed survey inspections are not equivalent to atmospheric\ncorrosion inspections (for example, the walking speed survey records do not\ndemonstrate that the insulation blanket at the valve are removed for the purposes of\ninspections).\n For the Endicott Pipeline, the March 8, 2018 Atmospheric Corrosion Inspection report\nstates that all areas of the pipeline that are exposed to the atmosphere were inspected\n(e.g. valves, PSVs) but the prior inspection reports do not demonstrate that has been the\npractice. Harvest personnel provided visual right-of-way inspection reports that\nshowed the general condition of the pipeline (for example, noting mechanical damage\nto the jacketing) but did not show that pipeline facilities (e.g. valves, PSVs) were\ninspected for atmospheric corrosion. Therefore, inspection records do not demonstrate\nthat the pipeline was adequately inspected for atmospheric corrosion prior to March 8,\n2018.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to\nexceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465\nfor a related series of violations. For violation occurring on or after November 27, 2018 and\nbefore July 31, 2019, the maximum penalty may not exceed $213,268 per violation per day,\nwith a maximum penalty not to exceed $2,132,679. For violation occurring on or after\nNovember 2, 2015 and before November 27, 2018, the maximum penalty may not exceed\n$209,002 per violation per day, with a maximum penalty not to exceed $2,090,022. For\nviolations occurring prior to November 2, 2015, the maximum penalty may not exceed\n$200,000 per violation per day, with a maximum penalty not to exceed $2,000,000 for a\nrelated series of violations.\nWe have reviewed the circumstances and supporting documents involved in this case, and\nhave decided not to conduct additional enforcement action or penalty assessment proceedings\nat this time. We advise you to correct the items identified in this letter. Failure to do so will\nresult in Hilcorp Energy Company 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 5-2019-5008W. 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 portion\nof your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along\nwith the complete original document you must provide a second copy of the document with\n3\n\n\n\nthe portions you believe qualify for confidential treatment redacted and an explanation of why\nyou believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Gano (#163211, #161716)\nRichard Novcaski, Vice President, Harvest Alaska, LLC, 3800 Centerpoint Drive,\nSuite 1400, Anchorage, Alaska 99503\nBen Wasson, Hilcorp Alaska (Via Email)\n4","truncated":false,"body_characters":7362}