{"operation":"document","citation":"CPF 52021019CAO","title":"HILCORP ALASKA, LLC — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-04-03","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52021019cao.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52021019cao.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52021019cao","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52021019CAO","body":"Corrective Action Order involving HILCORP ALASKA, LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2021-04-03 and is reported as closed as of 2022-11-28. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52021019CAO_Amended Corrective Action Order_04062021_(21-209244).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021019CAO/52021019CAO_Amended%20Corrective%20Action%20Order_04062021_(21-209244).pdf\n\n52021019CAO_Amended Corrective Action Order_04062021_(21-209244)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021019CAO/52021019CAO_Amended%20Corrective%20Action%20Order_04062021_(21-209244)_text.pdf\n\n52021019CAO_Closure Letter_11282022_(21-209244).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021019CAO/52021019CAO_Closure%20Letter_11282022_(21-209244).pdf\n\n52021019CAO_Closure Letter_11282022_(21-209244)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021019CAO/52021019CAO_Closure%20Letter_11282022_(21-209244)_text.pdf\n\n52021019CAO_Corrective Action Order_04032021_(21-209244).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021019CAO/52021019CAO_Corrective%20Action%20Order_04032021_(21-209244).pdf\n\n52021019CAO_Corrective Action Order_04032021_(21-209244)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021019CAO/52021019CAO_Corrective%20Action%20Order_04032021_(21-209244)_text.pdf\n\n52021019CAO_Amended Corrective Action Order_04062021_(21-209244)_text.pdf\n\nVIA ELECTRONIC MAIL TO:\nMr. Greg Lalicker\nChief Executive Officer\nHilcorp Energy Company\n1111 Travis Street\nHouston, Texas 77002\nCPF No. 5-2021-019-CAO\nDear Mr. Lalicker:\nEnclosed please find an Amended Corrective Action Order (ACAO or Amended Order) issued\nby the Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety, in the\nabove-referenced case. It requires Hilcorp Alaska, LLC, (Hilcorp or Respondent), a subsidiary\nof Hilcorp Energy Company, to take certain corrective actions with respect to a natural gas leak\non its 8-inch Middle Ground Shoal (MGS) Fuel Gas System A Pipeline (MGS-A) that failed on\nor about April 1, 2021, within the Upper Cook Inlet, Alaska, on a subsea segment of the MGS-A\npipeline between the MGS onshore facility and “A” Platform.\nService of the ACAO by e-mail is deemed complete upon transmission and acknowledgement of\nreceipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms and conditions of this\nAmended Order are effective upon completion of service.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure: ACAO\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS\nMr. Dustin Hubbard, Director, Western Region, OPS\nMr. David S. Wilkins, Senior Vice President, Hilcorp Alaska (via email)\nMr. Ben Wasson, Hilcorp Alaska (via email)\nCONFIRMATION OF RECEIPT REQUESTED\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 )\nHilcorp Alaska, LLC, )\n)\n)\n)\nRespondent. )\n____________________________________)\nCPF No. 5-2021-019-CAO\nAMENDED CORRECTIVE ACTION ORDER\nPurpose and Background\nThis Amended Corrective Action Order (ACAO or Amended Order) is being issued by the\nPipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS), under the authority of 49 U.S.C. § 60112 to require Hilcorp Alaska, LLC (Hilcorp or\nRespondent) to take the necessary corrective actions to protect the public, property, and the\nenvironment from potential hazards associated with a release from its 8-inch Middle Ground\nShoal (MGS) Fuel Gas System A Pipeline (MGS-A) in the Upper Cook Inlet, Alaska.1 This\nAmended Order finds that continued operation of the subsea segment of Respondent’s 8-inch\nMGS-A pipeline between the MGS onshore facility and “A” Platform (Affected Segment),\nwithout corrective action, is or would be hazardous to life, property, or the environment and\nrequires Respondent to take immediate action to ensure its safe operation.\nAt approximately 4:25 PM AKDT (Alaska time), on April 1, 2021, Hilcorp determined that their\n8-inch MGS-A natural gas pipeline was leaking, resulting in an ongoing release of an unknown\nquantity of natural gas into the waters of the Cook Inlet, Alaska (Failure or Incident). The\nFailure occurred within the Upper Cook Inlet, Alaska, on a subsea segment of the MGS-A\npipeline between the MGS onshore facility and the “A” Platform. As measured along the\npipeline alignment, the pipeline failure is approximately 6 miles from the MGS onshore facility\nand 1 mile from the “A” Platform. Mainline block valves for this pipeline segment are located at\nthe MGS onshore facility and “A” Platform. The MGS-A pipeline transports fuel gas from the\nMGS onshore facility to the two offshore platforms. The cause of the Failure has not yet been\n1 Hilcorp’s MGS fuel gas system provides utility gas to the offshore Platforms A and C utilizing gas from the East\nCook Inlet Gas Gathering System (ECIGGS) (ECIGGS is a PHMSA-regulated natural gas transmission system).\nThe MGS pipeline system begins at the 3-inch tie-in to the ECIGGS pipeline on Wik Road in Nikiski, Alaska. The\npipeline passes through Station O (201 Meter) and the MGS onshore facility before the subsea portion to the\nplatforms. The line includes 2-inch, 4-inch, 6-inch and 8-inch diameters. The offshore (subsea) portion the MGS\nfuel gas system is identified as the “A” Pipeline. The “A” Pipeline begins at the onshore facility and is routed to the\n“A” Platform and from the “A” Platform it is routed to the “C” Platform. The “A” Pipeline is 8-inch diameter and\nwas converted to gas service from oil service in 2005.\n\n\n\nCPF No. 5-2021-019-CAO\nPage 2\ndetermined. The Failure occurred in an ecologically sensitive area and presents a serious risk to\nthe environment due to the presence of several endangered and threatened species. A Corrective\nAction Order (CAO), CPF. No. 5-2021-019-CAO, was issued on April 3, 2021. This ACAO\namends that order.\nPursuant to 49 U.S.C. § 60117, PHMSA is continuing to investigate the Failure. The preliminary\nfindings of the agency’s ongoing investigation are as follows:\nPreliminary Findings\n At approximately 4:25 PM AKDT (Alaska time), on April 1, 2021, Hilcorp\ndetermined that their 8-inch MGS-A natural gas pipeline was leaking, resulting in an\nongoing release of natural gas into the waters of the Cook Inlet, Alaska. The Incident\nwas discovered when Hilcorp was informed by a helicopter pilot in the area that gas\nbubbles were observed on the surface of the waters of the Cook Inlet, Alaska near an\noffshore platform.\n Hilcorp reported the Incident to the NRC at approximately 9:20 PM EDT (5:20 PM\nAKDT). As a result of the Incident, Hilcorp reduced the pressure to the pipeline from\n200 psig to approximately 140 psig. Hilcorp stated to PHMSA that it intended to\nfurther reduce the pressure to 70 psig, and that the investigation was ongoing.\nHilcorp further stated that dispatching personnel to the site was being evaluated due\nto safety precautions during winter conditions. As a result of receiving the CAO on\nApril 3, 2021, Hilcorp further reduced the pressure to 64 psig\n There were no fires, injuries, fatalities, or evacuations associated with the Incident.\n The MGS-A pipeline is an 8-inch nominal diameter transmission pipeline with 0.594\"\nwall thickness. The pipeline is Grade B seamless pipe with X-Tru Coat and one-inch\nconcrete weight coating. The portion of the MGS-A pipeline running from the MGS\nshore facility to the \"A Platform\" and the portion running from the \"A Platform\" to\n\"C\" Platform were installed in 1965 and 1967, respectively\n Hilcorp Alaska, LLC (OPID: 32645) purchased oil and gas facilities located in\nNikiski, Alaska from XTO Energy, Inc. (OPID: 31178) on September 1, 2015. This\npurchase included the MGS-A pipeline.\n The product being transported by the \"A Pipeline\" is transmission-quality natural gas\n(98.67% methane). The pipeline operates continuously and has a normal operating\npressure range of 150-200 psig. The pipeline was converted from liquid service to\ngas service in 2005.\n Several state and federal agencies, including the Alaska Department of\nEnvironmental Conservation (ADEC) and the National Oceanic and Atmospheric\nAdministration (NOAA), National Marine Fisheries Service (NMFS), have expressed\n\n\n\nCPF No. 5-2021-019-CAO\nPage 3\nconcerns to PHMSA regarding damage to marine life in the Cook Inlet as a result of\nmethane release into the water. The Cook Inlet is designated as an environmentally\nsensitive area due to the presence of several endangered marine mammals. Species\nlikely to be present in upper Cook Inlet include Cook Inlet beluga whale (Endangered\nSpecies Act [ESA]-listed as endangered), western Distinct Population Segment (DPS)\nSteller sea lion (ESA-listed as endangered), Mexico DPS humpback whale (ESA-\nlisted as threatened), harbor seals, killer whales, Hawaii DPS humpback whales,\nharbor porpoise, and Dall’s porpoise. The Southwest Alaska DPS Northern sea otter\n(ESA-listed as threatened) is known to occur in lower Cook Inlet. The discharge\nlocation is within designated Critical Habitat for Cook Inlet beluga whales. Cook\nInlet beluga whales are likely utilizing offshore waters in upper Cook Inlet during\nwinter and will concentrate near forage fish locations as those populations arrive.\n Regarding risks associated with water craft, the United States Coast Guard (USCG)\nestimates that the risk to life and property would likely increase as the ice dissipates.\nThe USCG continues its Very High Frequency radio broadcast to mariners describing\nthe gas leak, its location, and specific requests to mitigate the risk. At this time, the\nUSCG has not implemented a safety zone around the leak location; however, if\nnecessary it could. An identified risk condition related to the leaking pipeline itself is\nthat the leak could get worse and the pipeline potentially mechanically fail if the leak\nwas caused by outside forces, e.g. vibration, vortex shedding, abrasion, excessive\nbending, and or rock impingement.\n PHMSA has reviewed information from Hilcorp and various state and Federal\nagencies regarding the various alternatives for responding to the Failure. These\nalternatives include: (a) immediate repair of the Affected Segment; (b) continued\noperation of the Affected Segment until it can be safely repaired; and (c) shutting in\nthe Affected Segment until it can be safely repaired. Hilcorp has indicated it believes\nthe safest alternative is to continue operating the Affected Segment, at reduced\npressure until it can be safely repaired.\n PHMSA acknowledges from assertions made by Hilcorp that immediate repair of the\nleak would pose an extreme risk to personnel during the current cold weather\nconditions where diving operations are required to access, investigate, and repair the\nAffected Segment.\n On April 2, 2021, Hilcorp stated to PHMSA that the risks associated with shutting in\nthe MGS-A pipeline until it can be safely repaired include a potential crude-oil spill\nin Cook Inlet. According to Hilcorp, the MGS-A pipeline fuels boilers and powers\nthe platforms. Hilcorp stated that it could not continue providing a flow of water to\nthe crude-oil line, the MGS-B pipeline, which lies directly next to the Affected\nSegment and which could freeze during colder temperatures due to such low-or no-\nflow conditions. This could potentially cause a breach in the MGS-B pipeline and a\npotential oil spill into the waters of the Cook Inlet. Hilcorp stated that it would not be\npossible to mobilize alternative heat sources to the platform in order to shut down the\n\n\n\nCPF No. 5-2021-019-CAO\nPage 4\npipeline prior to conducting a temporary repair. Based on this information, PHMSA\nissued a CAO on April 3, 2021 that did not require Hilcorp to perform an immediate\nshut down of the pipeline. Rather, the CAO required Hilcorp to reduce pressure to no\ngreater than 65 psig on the entire length of the MGS-A pipeline, and complete a\ntemporary repair within 15 days of the issuance of the CAO, or shut down the\npipeline pursuant if that deadline could not be met.\n On April 3, 2021, Hilcorp reported an abnormal operating condition (AOC) to\nPHMSA regarding a change to conditions on the MGS-A pipeline. Hilcorp reported\nthat at approximately 1:21 PM AKDT, a pressure drop and increase in flow was\nobserved. As a result of the AOC, Hilcorp shut in the MGS-A pipeline, and the\npipeline was blocked at approximately 1:30 PM AKDT. Hilcorp further reported that\nby the evening of April 3, 2021, it was able to locate heaters on other local projects\nthat it planned to bring onsite to assist in freeze protection. In addition, Hilcorp\nreported that it was bringing additional heaters onsite to assist in the freeze protection\nwhile the MGS-A pipeline is shut in.\n On April 3, 2021, Hilcorp reported that the CISPRI Endeavour vessel mobilized from\nHomer to Nikiski, AK and will remain in the area to conduct observations for sheen\nor damage to wildlife, as needed.\n On April 5, 2021, Hilcorp provided another update to PHMSA as follows: daily\noverflights to search for sheen or bubbles on the surface of the water were continuing;\nthe MGS-A pipeline remained shut in; Hilcorp was continuing to flow water down\nthe MGS-B pipeline for freeze protection; heaters were mobilized to the platform; and\npreparations were being made for a temporary repair.\n Hilcorp provided a leak estimate to PHMSA after the CAO was issued. Hilcorp’s\ninitial calculation of the leak was estimated to be 75 to 150 MCFD. This estimate\nwas noted to be preliminary in nature and based on 70 psig, approximate water-depth\nof 100 feet, and estimated 0.25-inch size hole.\n PHMSA recognizes that the majority of the MGS pipeline system is located within\nthe waters of the Upper Cook Inlet, which is known for extreme tides (average tides\nof 20 feet, maximum tides of 35 feet, and currents in excess of 5 to 7 knots) and the\npresence of dynamic sea ice conditions.\n Hilcorp plans to perform a multi-beam sonar survey to locate the leak and evaluate\nthe adjacent seabed condition on Tuesday April 6, 2021.\n Hilcorp has further indicated to PHMSA that the company cannot access the Affected\nSegment until the ice clears, at which time diving operations can safely be conducted\nto access, investigate, and repair the leak. According to Hilcorp, they will attempt to\nget divers in the area of the Failure by Wednesday, April 7, 2021. Hilcorp has\n\n\n\nCPF No. 5-2021-019-CAO\nPage 5\nindicated that it has temporary clamps that it may utilize as a temporary repair while\nthey prepare plans for a permanent repair. The serviceability of the pipeline will\nremain impaired until at least this time.\n This is the fifth leak on the MGS-A since June 2014. The four previous leaks were in\nJune 2014 and August 2014, during ice-free conditions; December 2016 thru May\n2017 during ice conditions; and 2019, when a leak was found by divers performing an\ninspection of the pipeline. Four of the leaks were determined to be caused by rocks\ncontacting the pipeline in areas where the pipeline was not continuously supported by\nthe seabed. The leak in 2019 was caused by corrosion/weld discontinuity. The rocks\ncontacting the pipeline deteriorated the steel pipe wall by abrasion, resulting from\nrelative movement between the pipeline and rocks contacting the pipeline. All prior\nleaks were repaired by installation of bolt-on, split-sleeve clamps. The 2014 leaks\nwere 42 yards apart, the 2016/2017 leak was approximately 2/3 mile from the\nprevious two leaks, and the current leak is in the general vicinity of the 2014 leaks.\n Vortex-induced vibrations of subsea pipelines within the Cook Inlet have been a\nknown integrity threat for years. Subsea pipeline operators in Cook Inlet typically\nmonitor subsea pipelines annually to identify pipeline spans that are unsupported by\nthe seabed and, if necessary, provide additional pipeline supports within these areas.\nIt is believed that vortex-induced vibrations are one of the motive forces responsible\nfor the relative movement between pipeline and rocks contacting the pipeline in areas\nwhere the pipeline is unsupported by the seabed.\n PHMSA Consent agreement (5-2017-0004S), issued to Respondent in 2017 as a\nresult of a leak on the MGS-A pipeline, included corrective measures that required\nintegration of ILI assessment results and sonar inspection results. The integration of\ndata identified several locations along the Affected Segment that met agreed upon\nintervention criteria resulting in pipeline repairs or other mitigation actions. Repairs\nand other mitigation actions included application of a pipeline clamp, coating repairs,\nand pipeline protection and stabilization.\n Respondent’s MGS-A pipeline is subject to the pipeline safety laws in 49 U.S.C.\nchapter 601 and 49 C.F.R. part 192.\nDetermination of Necessity for Corrective Action Order and Right to Hearing\nSection 60112 of title 49, United States Code, authorizes PHMSA to determine that a pipeline\nfacility is or would be hazardous to life, property, or the environment and if there is a likelihood\nof serious harm, to expeditiously order the operator of the facility to take necessary corrective\naction, including suspended or restricted use of the facility, physical inspection, testing, repair,\nreplacement, or other appropriate action. An order issued expeditiously must provide an\nopportunity for a hearing as soon as practicable after the order is issued.\n\n\n\nCPF No. 5-2021-019-CAO\nPage 6\nIn deciding whether to issue an order, PHMSA must consider the following, if relevant: (1) the\ncharacteristics of the pipe and other equipment used in the pipeline facility, including the age,\nmanufacture, physical properties, and method of manufacturing, constructing, or assembling the\nequipment; (2) the nature of the material the pipeline facility transports, the corrosive and\ndeteriorative qualities of the material, the sequence in which the material is transported, and the\npressure required for transporting the material; (3) the aspects of the area in which the pipeline\nfacility is located, including climatic and geologic conditions and soil characteristics; (4) the\nproximity of the area in which the hazardous liquid pipeline facility is located to environmentally\nsensitive areas; (5) the population density and population and growth patterns of the area in\nwhich the pipeline facility is located; (6) any recommendation of the National Transportation\nSafety Board made under another law; and (7) any other factors PHMSA may consider as\nappropriate.\nAfter evaluating the foregoing preliminary findings of fact, and having considered the age of the\npipeline, the hazardous nature of the materials transported, the significant history of leaks\nassociated with the MGS-A pipeline, the location of the leak in a critical habitat for endangered\nspecies, the extreme tidal influence in the waters of the Cook Inlet, the threat to commercial\nnavigation, the design of Respondent’s system that depends on a continued heat source to protect\nthe MGS-B crude oil pipeline from freezing and causing further potential harm to the\nenvironment, the AOC that occurred subsequent to the issuance of the CAO, which resulted in\nHilcorp immediately shutting in the Affected Segment, notwithstanding its prior representations\nto PHMSA that it could not do so safely due to the inability to obtain heaters quickly enough to\nmaintain freeze protection, and the likelihood that similar conditions conducive to vortex-\ninduced vibrations exist on the MGS-A pipeline, I find that continued operation of the Affected\nSegment, as defined below, without corrective measures is or would be hazardous to life,\nproperty, or the environment, and that failure to issue this Amended Order expeditiously would\nresult in the likelihood of serious harm.\nAccordingly, this Amended Order mandating immediate corrective action is issued expeditiously\nwithout prior notice and opportunity for a hearing. The terms and conditions of this Amended\nOrder are effective 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. If a hearing is requested, it will be held in accordance\nwith 49 C.F.R. § 190.211.\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\nadditional measures required and, if appropriate, PHMSA will consider amending this Amended\nOrder. To the extent consistent with safety, Respondent will be afforded notice and an\nopportunity for a hearing prior to the imposition of any additional corrective measures.\n\n\n\nCPF No. 5-2021-019-CAO\nPage 7\nRequired Corrective Actions\nDefinitions:\nAffected Segment – The “Affected Segment” means Hilcorp’s 8-inch MGS-A pipeline\nbetween the MGS onshore facility and “A” Platform.\nDirector – The Director, Western Region, PHMSA, OPS, 12300 West Dakota Avenue, Suite\n110, Lakewood, CO, 80228\nDay – Calendar day.\nPursuant to 49 U.S.C. 60112, I hereby order Respondent to immediately take the following\ncorrective actions:\n1. Shutdown of the Affected Segment. The Affected Segment was shut in on April 3, 2021.\nThe Affected Segment must remain shut in and may not be operated until authorized to be\nrestarted by the Director in accordance with the terms of this Amended Order. Gas pressure\nmay be allowed to temporarily go up to 65 psi during sonar scan and diver operations to\nidentify the leak. Hilcorp must keep the affected segment shut-in while sonar scan and\ndiver operations are not being conducted. Upon identification of the leak Hilcorp must\nimmediately commence shutdown operations of the line and isolate and block-in the\nAffected Segment from any and all gas sources.\n2. Restart Plan. Prior to resuming operation of the Affected Segment, develop and submit a\nwritten Restart Plan to the Director for prior approval.\na. b. The Director may approve the Restart Plan incrementally without approving the\nentire plan, but the Affected Segment cannot resume operation until the Restart Plan is\napproved in its entirety.\nOnce approved by the Director, the Restart Plan will be incorporated by reference\ninto this Amended Order.\nc. d. e. f. g. h. The Restart Plan must provide for adequate patrolling of the Affected Segment during\nthe restart process.\nThe Restart Plan must require that the pressure is not to exceed 65 psig until\noperation at a higher pressure has been approved by the Director.\nThe Restart Plan must specify a day-light restart and include advance\ncommunications with local emergency response officials.\nThe Restart Plan must provide for a repair plan for the Affected Segment.\nThe Restart Plan must also include documentation of the completion of all mandated\nactions, and a management of change plan to ensure that all procedural modifications\nare incorporated into Hilcorp’s O&M procedures manual.\nThe Restart Plan must provide for hydrostatic pressure testing of the Affected\n\n\n\nCPF No. 5-2021-019-CAO\nPage 8\n3. Segment.\nReturn to Service. After the Director approves the Restart Plan, Hilcorp may return the\nAffected Segment to service subject to the approved restart plans requirements.\n4. The Affected Segment must be temporarily repaired by April 17, 2021, and permanently\nrepaired by May 1, 2021. Hilcorp must ensure diving operations can safely be conducted to\naccess, investigate, and repair the leak.\n5. Hilcorp must notify the Director by telephone within one hour of a confirmed discovery of\nany abnormal operating conditions, as defined in Part 192, or other issues regarding the\nsafe operation of the Affected Segment at any time, 24 hours a day/7 days a week, after the\nissuance of this Amended Order. In the event the Director is unavailable, Hilcorp must\nnotify the Alaska Operations Supervisor, PHMSA, within the time requirement set forth in\nthis paragraph.\n6. Hilcorp must develop and implement a \"Pipeline Leak Inspection and Repair Plan\" for the\nAffected Segment. Hilcorp must submit a temporary repair plan within 5 days from the date\nof this Amended Order, if it chooses to perform a temporary repair, and a permanent repair\nplan within 20 days from the date of this Amended Order. Once approved by the Director,\nthe plan(s) is/are incorporated by reference into this Amended Order. Respondent must\ncomplete the actions specified in the plan according to its timeline.\n7. Hilcorp must develop and implement an “Inspection Plan\" for the Affected Segment.\nHilcorp must submit the plan to the Director for approval no later than 45 days from the\nissuance of the Amended Order. At a minimum, the plan must include the high-resolution\nside-scan sonar inspection, or equivalent technology, and inline inspection. Once approved\nby the Director, the plan is incorporated by reference into this Amended Order.\nRespondent must complete the actions specified in the plan according to its timeline.\n8. Removal of Pressure Restriction.\na. b. The Director may allow the removal or modification of the pressure restriction upon a\nwritten request from Respondent demonstrating that modifying or restoring the\nAffected Segment to its pre-failure operating pressure is justified based on a reliable\nengineering analysis showing that the pressure increase is safe considering all known\ndefects, anomalies, and operating parameters of the pipeline.\nThe Director may allow the temporary removal or modification of the pressure\nrestrictions upon a written request from Respondent demonstrating that temporary\nmitigative and preventive measures are implemented prior to and during the\ntemporary removal or modification of the pressure restriction. The Director's\ndetermination will be based on the failure cause and provision of evidence that\npreventative and mitigative actions taken by the operator provide for the safe\noperation of the Affected Segment during the temporary removal or modification of\nthe pressure restriction. Appeals of determinations by the Director in this regard will\nbe decided by the Associate Administrator for Pipeline Safety.\n\n\n\nCPF No. 5-2021-019-CAO\nPage 9\n9. Root Cause Failure Analysis. Within 120 days following receipt of this Amended Order,\nRespondent must complete a root cause failure analysis (RCFA) and submit a final report\nof this RCFA to the Director. The RCFA must be supplemented or facilitated by an\nindependent third-party and must document the decision-making process and all factors\ncontributing to the failure. Respondent must obtain prior approval from the Director of\nRespondent’s selection of the independent third-party. The final report must include\nfindings and any lessons learned and whether the findings and lessons learned are\napplicable to other locations within Respondent’s pipeline system.\n10. Replacement Plan Work (RP).\na. b. Within 45 days following the issuance of this Amended Order, Respondent must\nsubmit to the Director for approval a Replacement Work Plan (RP) for replacement of\nthe Affected Segment.\nOnce approved by the Director, the RP is incorporated by reference into this\nAmended Order.\nc. The Respondent must complete the replacement of the Affected Segment, as described\nin the approved RP, within 365 days of the date of this Amended Order.\n11. CAO Documentation Report (CDR). Respondent must create and revise, as necessary, a\nCAO Documentation Report (CDR). When Respondent has concluded all the items in this\nAmended Order it will submit the final CDR in its entirety to the Director. This will allow\nthe Director to complete a thorough review of all actions taken by Respondent with regard\nto this Amended Order prior to approving the closure of this Amended Order. The intent is\nfor the CDR to summarize all activities and documentation associated with this Amended\nOrder in one document.\na. b. The Director may approve the CDR incrementally without approving the entire CDR.\nOnce approved by the Director, the CDR will be incorporated by reference into this\nAmended Order.\nc. The CDR must include, but is not necessarily limited to, the following:\ni. Table of Contents;\nii. iii. Summary of the Incident and the response activities;\nSummary of pipe data, material properties and all prior assessments of the\nAffected Segment;\niv. Summary of all tests, inspections, assessments, evaluations, and analysis required\nby the Amended Order;\nv. vi. Summary of the RCFA with all root causes as required by the Amended Order;\nDocumentation of all actions taken by Respondent to implement the RP, the\nresults of those actions, and the inspection and repair criteria used;\nvii. Documentation of any revisions to the RP including those necessary to\nincorporate the results of actions undertaken pursuant to this Amended Order and\n\n\n\nCPF No. 5-2021-019-CAO\nPage 10\nwhenever necessary to incorporate new information obtained during the failure\ninvestigation and remedial activities;\ni. ii. Lessons learned while completing this Amended Order;\nA path forward describing specific actions Respondent will take on its entire\npipeline system as a result of the lessons learned from work on this Amended\nOrder; and\niii. Appendices (if required).\nOther Requirements:\n12. Approvals. With respect to each submission that under this Amended Order requires the\napproval of the Director, the Director may: (a) approve, in whole or part, the submission;\n(b) approve the submission on specified conditions; (c) modify the submission to cure any\ndeficiencies; (d) disapprove in whole or in part, the submission, directing that Respondent\nmodify the submission, or (e) any combination of the above. In the event of approval,\napproval upon conditions, or modification by the Director, Respondent shall proceed to\ntake all action required by the submission as approved or modified by the Director. If the\nDirector disapproves all or any portion of the submission, Respondent must correct all\ndeficiencies within the time specified by the Director, and resubmit it for approval.\n13. Extensions of Time. The Director may grant an extension of time for compliance with any\nof the terms of this Amended Order upon a written request timely submitted demonstrating\ngood cause for an extension.\n14. Reporting. Respondent must submit quarterly reports to the Director that: (1) include all\navailable data and results of the testing and evaluations required by this Amended Order;\nand (2) describe the progress of the repairs or other remedial actions being undertaken.\nThe first quarterly report is due on July 12, 2021. The Director may change the interval for\nthe submission of these reports.\n15. Documentation of the Costs. It is requested that Respondent maintain documentation of\nthe costs associated with implementation of this CAO. Include in each monthly report\nsubmitted, the to-date total costs associated with: (1) preparation and revision of\nprocedures, studies, and analyses; (2) physical changes to pipeline infrastructure, including\nrepairs, replacements, and other modifications; and (3) environmental remediation, if\napplicable.\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. 5-2021-019-CAO\nPage 11\nIn your correspondence on this matter, please refer to “CPF No. 5-2021-019-CAO” and for each\ndocument you submit, please provide a copy in electronic format whenever possible. The\nactions required by this Amended Order are in addition to and do not waive any requirements\nthat apply to Respondent’s pipeline system under 49 C.F.R. Parts 190 through 199, under any\nother order issued to Respondent under authority of 49 U.S.C. Chapter 601, or under any other\nprovision of Federal or State law.\nRespondent may appeal in writing any decision of the Director to the Associate Administrator\nfor Pipeline Safety. Decisions of the Associate Administrator shall be final.\nFailure to comply with this Amended Order may result in the assessment of civil penalties and in\nreferral to the Attorney General for appropriate relief in United States District Court pursuant to\n49 U.S.C. § 60120.\nThe terms and conditions of this Amended Order are effective upon service in accordance with\n49 C.F.R.\n§ 190.5.\n_________________________________ ________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n52021019CAO_Closure Letter_11282022_(21-209244)_text.pdf\n\nVIA E-MAIL TO MR. GREG LALICKER\nNovember 28, 2022\nMr. Greg Lalicker\nChief Executive Officer\nHilcorp Energy Company\n1111 Travis Street\nHouston, Texas 77002\nRE: Amended Corrective Action Order CPF No. 5-2021-019-CAO\nMiddle Ground Shoal Fuel Gas System - Request for Closure\nDear Mr. Lalicker:\nOn April 6, 2021, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued\nan Amended Corrective Action Order (ACAO) requiring Hilcorp Alaska, LLC, (Hilcorp or\nRespondent), a subsidiary of Hilcorp Energy Company, to take certain corrective actions with\nrespect to a natural gas leak on its 8-inch Middle Ground Shoal (MGS) Fuel Gas System A\nPipeline (MGS-A) that failed on or about April 1, 2021, within the Upper Cook Inlet, Alaska, on\na subsea segment of the MGS-A pipeline between the MGS onshore facility and “A” Platform.\nThe ACAO required Hilcorp to shut down the MGS-A pipeline, repair the pipeline before\nrestarting it, and replace the MGS-A pipeline within one year of the date the ACAO was issued.\nSince that time, Hilcorp determined that it is not currently commercially viable to replace the\npipeline, as required by the ACAO, and instead Hilcorp proposed to permanently abandon the\nMGS-A pipeline without replacement. PHMSA agreed that by permanently abandoning the\nMGS-A pipeline, Hilcorp has mitigated known integrity threats of the MGS-A pipeline system\nconsistent with the intent of the ACAO. PHMSA received notice that Hilcorp permanently\nabandoned the MGS-A pipeline in September 2022.\nOn September 29, 2022, Hilcorp provided the CAO Documentation Report (CDR). The CDR\nwas the last outstanding item of the ACAO. The CDR summarized actions taken by Hilcorp in\nresponse to the ACAO and describes how Hilcorp has integrated lessons learned from the failure,\nincluding the results of the Root Cause Failure Analysis, into their programs and procedures.\nBecause Hilcorp has abandoned the MGS-A pipeline system and provided all documentation\nrequired by the ACAO, I have determined that the terms of the ACAO have been completed and\naccordingly, the referenced ACAO is terminated. Thank you for your cooperation in this matter.\n\n\n\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Gano (#21-209244)\nBen Wasson, Hilcorp Alaska (via email)\nCindy Monnin, Hilcorp Alaska (via email)\n\n52021019CAO_Corrective Action Order_04032021_(21-209244)_text.pdf\n\nVIA ELECTRONIC MAIL TO:\nMr. Greg Lalicker\nChief Executive Officer\nHilcorp Energy Company\n1111 Travis Street\nHouston, Texas 77002\nCPF No. 5-2021-019-CAO\nDear Mr. Lalicker:\nEnclosed please find a Corrective Action Order (CAO or Order) issued by the Pipeline and\nHazardous Materials Safety Administration, Office of Pipeline Safety, in the above-referenced\ncase. It requires Hilcorp Alaska, LLC, (Hilcorp or Respondent), a subsidiary of Hilcorp Energy\nCompany, to take certain corrective actions with respect to a natural gas leak on its 8-inch\nMiddle Ground Shoal (MGS) Fuel Gas System A Pipeline (MGS-A) that failed on or about April\n1, 2021, within the Upper Cook Inlet, Alaska, on a subsea segment of the MGS-A pipeline\nbetween the MGS onshore facility and “A” Platform.\nService of the CAO by e-mail is deemed complete upon transmission and acknowledgement of\nreceipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms and conditions of this\nOrder are effective upon completion of service.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure: CAO\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS\nMr. Dustin Hubbard, Director, Western Region, OPS\nMr. David S. Wilkins, Senior Vice President, Hilcorp Alaska (via email)\nMr. Ben Wasson, Hilcorp Alaska (via email)\nCONFIRMATION OF RECEIPT REQUESTED\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 )\nHilcorp Alaska, LLC, )\n)\n)\n)\nRespondent. )\n____________________________________)\nCPF No. 5-2021-019-CAO\nCORRECTIVE ACTION ORDER\nPurpose and Background\nThis Corrective Action Order (CAO or Order) is being issued by the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), under the authority\nof 49 U.S.C. § 60112 to require Hilcorp Alaska, LLC (Hilcorp or Respondent) to take the\nnecessary corrective actions to protect the public, property, and the environment from potential\nhazards associated with a release from its 8-inch Middle Ground Shoal (MGS) Fuel Gas System\nA Pipeline (MGS-A) in the Upper Cook Inlet, Alaska.1 This Order finds that continued\noperation of the subsea segment of Respondent’s 8-inch MGS-A pipeline between the MGS\nonshore facility and “A” Platform (Affected Segment), without corrective action, is or would be\nhazardous to life, property, or the environment and requires Respondent to take immediate action\nto ensure its safe operation.\nAt approximately 4:25 PM AKDT (Alaska time), on April 1, 2021, Hilcorp determined that their\n8-inch MGS-A natural gas pipeline was leaking, resulting in an ongoing release of an unknown\nquantity of natural gas into the waters of the Cook Inlet, Alaska (Failure or Incident). The\nFailure occurred within the Upper Cook Inlet, Alaska, on a subsea segment of the MGS-A\npipeline between the MGS onshore facility and the “A” Platform. As measured along the\npipeline alignment, the pipeline failure is approximately 6 miles from the MGS onshore facility\nand 1 mile from the “A” Platform. Mainline block valves for this pipeline segment are located at\nthe MGS onshore facility and “A” Platform. The MGS-A pipeline transports fuel gas from the\nMGS onshore facility to the two offshore platforms. The cause of the Failure has not yet been\n1 Hilcorp’s MGS fuel gas system provides utility gas to the offshore Platforms A and C utilizing gas from the East\nCook Inlet Gas Gathering System (ECIGGS) (ECIGGS is a PHMSA-regulated natural gas transmission system).\nThe MGS pipeline system begins at the 3-inch tie-in to the ECIGGS pipeline on Wik Road in Nikiski, Alaska. The\npipeline passes through Station O (201 Meter) and the MGS onshore facility before the subsea portion to the\nplatforms. The line includes 2-inch, 4-inch, 6-inch and 8-inch diameters. The offshore (subsea) portion the MGS\nfuel gas system is identified as the “A” Pipeline. The “A” Pipeline begins at the onshore facility and is routed to the\n“A” Platform and from the “A” Platform it is routed to the “C” Platform. The “A” Pipeline is 8-inch diameter and\nwas converted to gas service from oil service in 2005.\n\n\n\nCPF No. 5-2021-019-CAO\nPage 2\ndetermined. The Failure occurred in an ecologically sensitive area and presents a serious risk to\nthe environm","truncated":true,"body_characters":63704}