# HILCORP ALASKA, LLC — Corrective Action Order

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

Official case documents:

52021019CAO_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

52021019CAO_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

52021019CAO_Closure Letter_11282022_(21-209244).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021019CAO/52021019CAO_Closure%20Letter_11282022_(21-209244).pdf

52021019CAO_Closure Letter_11282022_(21-209244)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021019CAO/52021019CAO_Closure%20Letter_11282022_(21-209244)_text.pdf

52021019CAO_Corrective Action Order_04032021_(21-209244).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021019CAO/52021019CAO_Corrective%20Action%20Order_04032021_(21-209244).pdf

52021019CAO_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

52021019CAO_Amended Corrective Action Order_04062021_(21-209244)_text.pdf

VIA ELECTRONIC MAIL TO:
Mr. Greg Lalicker
Chief Executive Officer
Hilcorp Energy Company
1111 Travis Street
Houston, Texas 77002
CPF No. 5-2021-019-CAO
Dear Mr. Lalicker:
Enclosed please find an Amended Corrective Action Order (ACAO or Amended Order) issued
by the Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety, in the
above-referenced case. It requires Hilcorp Alaska, LLC, (Hilcorp or Respondent), a subsidiary
of Hilcorp Energy Company, to take certain corrective actions with respect to a natural gas leak
on its 8-inch Middle Ground Shoal (MGS) Fuel Gas System A Pipeline (MGS-A) that failed on
or about April 1, 2021, within the Upper Cook Inlet, Alaska, on a subsea segment of the MGS-A
pipeline between the MGS onshore facility and “A” Platform.
Service of the ACAO by e-mail is deemed complete upon transmission and acknowledgement of
receipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms and conditions of this
Amended Order are effective upon completion of service.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure: ACAO
cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS
Mr. Dustin Hubbard, Director, Western Region, OPS
Mr. David S. Wilkins, Senior Vice President, Hilcorp Alaska (via email)
Mr. Ben Wasson, Hilcorp Alaska (via email)
CONFIRMATION OF RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Hilcorp Alaska, LLC, )
)
)
)
Respondent. )
____________________________________)
CPF No. 5-2021-019-CAO
AMENDED CORRECTIVE ACTION ORDER
Purpose and Background
This Amended Corrective Action Order (ACAO or Amended Order) is being issued by the
Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
(OPS), under the authority of 49 U.S.C. § 60112 to require Hilcorp Alaska, LLC (Hilcorp or
Respondent) to take the necessary corrective actions to protect the public, property, and the
environment from potential hazards associated with a release from its 8-inch Middle Ground
Shoal (MGS) Fuel Gas System A Pipeline (MGS-A) in the Upper Cook Inlet, Alaska.1 This
Amended Order finds that continued operation of the subsea segment of Respondent’s 8-inch
MGS-A pipeline between the MGS onshore facility and “A” Platform (Affected Segment),
without corrective action, is or would be hazardous to life, property, or the environment and
requires Respondent to take immediate action to ensure its safe operation.
At approximately 4:25 PM AKDT (Alaska time), on April 1, 2021, Hilcorp determined that their
8-inch MGS-A natural gas pipeline was leaking, resulting in an ongoing release of an unknown
quantity of natural gas into the waters of the Cook Inlet, Alaska (Failure or Incident). The
Failure occurred within the Upper Cook Inlet, Alaska, on a subsea segment of the MGS-A
pipeline between the MGS onshore facility and the “A” Platform. As measured along the
pipeline alignment, the pipeline failure is approximately 6 miles from the MGS onshore facility
and 1 mile from the “A” Platform. Mainline block valves for this pipeline segment are located at
the MGS onshore facility and “A” Platform. The MGS-A pipeline transports fuel gas from the
MGS onshore facility to the two offshore platforms. The cause of the Failure has not yet been
1 Hilcorp’s MGS fuel gas system provides utility gas to the offshore Platforms A and C utilizing gas from the East
Cook Inlet Gas Gathering System (ECIGGS) (ECIGGS is a PHMSA-regulated natural gas transmission system).
The MGS pipeline system begins at the 3-inch tie-in to the ECIGGS pipeline on Wik Road in Nikiski, Alaska. The
pipeline passes through Station O (201 Meter) and the MGS onshore facility before the subsea portion to the
platforms. The line includes 2-inch, 4-inch, 6-inch and 8-inch diameters. The offshore (subsea) portion the MGS
fuel gas system is identified as the “A” Pipeline. The “A” Pipeline begins at the onshore facility and is routed to the
“A” Platform and from the “A” Platform it is routed to the “C” Platform. The “A” Pipeline is 8-inch diameter and
was converted to gas service from oil service in 2005.



CPF No. 5-2021-019-CAO
Page 2
determined. The Failure occurred in an ecologically sensitive area and presents a serious risk to
the environment due to the presence of several endangered and threatened species. A Corrective
Action Order (CAO), CPF. No. 5-2021-019-CAO, was issued on April 3, 2021. This ACAO
amends that order.
Pursuant to 49 U.S.C. § 60117, PHMSA is continuing to investigate the Failure. The preliminary
findings of the agency’s ongoing investigation are as follows:
Preliminary Findings
 At approximately 4:25 PM AKDT (Alaska time), on April 1, 2021, Hilcorp
determined that their 8-inch MGS-A natural gas pipeline was leaking, resulting in an
ongoing release of natural gas into the waters of the Cook Inlet, Alaska. The Incident
was discovered when Hilcorp was informed by a helicopter pilot in the area that gas
bubbles were observed on the surface of the waters of the Cook Inlet, Alaska near an
offshore platform.
 Hilcorp reported the Incident to the NRC at approximately 9:20 PM EDT (5:20 PM
AKDT). As a result of the Incident, Hilcorp reduced the pressure to the pipeline from
200 psig to approximately 140 psig. Hilcorp stated to PHMSA that it intended to
further reduce the pressure to 70 psig, and that the investigation was ongoing.
Hilcorp further stated that dispatching personnel to the site was being evaluated due
to safety precautions during winter conditions. As a result of receiving the CAO on
April 3, 2021, Hilcorp further reduced the pressure to 64 psig
 There were no fires, injuries, fatalities, or evacuations associated with the Incident.
 The MGS-A pipeline is an 8-inch nominal diameter transmission pipeline with 0.594"
wall thickness. The pipeline is Grade B seamless pipe with X-Tru Coat and one-inch
concrete weight coating. The portion of the MGS-A pipeline running from the MGS
shore facility to the "A Platform" and the portion running from the "A Platform" to
"C" Platform were installed in 1965 and 1967, respectively
 Hilcorp Alaska, LLC (OPID: 32645) purchased oil and gas facilities located in
Nikiski, Alaska from XTO Energy, Inc. (OPID: 31178) on September 1, 2015. This
purchase included the MGS-A pipeline.
 The product being transported by the "A Pipeline" is transmission-quality natural gas
(98.67% methane). The pipeline operates continuously and has a normal operating
pressure range of 150-200 psig. The pipeline was converted from liquid service to
gas service in 2005.
 Several state and federal agencies, including the Alaska Department of
Environmental Conservation (ADEC) and the National Oceanic and Atmospheric
Administration (NOAA), National Marine Fisheries Service (NMFS), have expressed



CPF No. 5-2021-019-CAO
Page 3
concerns to PHMSA regarding damage to marine life in the Cook Inlet as a result of
methane release into the water. The Cook Inlet is designated as an environmentally
sensitive area due to the presence of several endangered marine mammals. Species
likely to be present in upper Cook Inlet include Cook Inlet beluga whale (Endangered
Species Act [ESA]-listed as endangered), western Distinct Population Segment (DPS)
Steller sea lion (ESA-listed as endangered), Mexico DPS humpback whale (ESA-
listed as threatened), harbor seals, killer whales, Hawaii DPS humpback whales,
harbor porpoise, and Dall’s porpoise. The Southwest Alaska DPS Northern sea otter
(ESA-listed as threatened) is known to occur in lower Cook Inlet. The discharge
location is within designated Critical Habitat for Cook Inlet beluga whales. Cook
Inlet beluga whales are likely utilizing offshore waters in upper Cook Inlet during
winter and will concentrate near forage fish locations as those populations arrive.
 Regarding risks associated with water craft, the United States Coast Guard (USCG)
estimates that the risk to life and property would likely increase as the ice dissipates.
The USCG continues its Very High Frequency radio broadcast to mariners describing
the gas leak, its location, and specific requests to mitigate the risk. At this time, the
USCG has not implemented a safety zone around the leak location; however, if
necessary it could. An identified risk condition related to the leaking pipeline itself is
that the leak could get worse and the pipeline potentially mechanically fail if the leak
was caused by outside forces, e.g. vibration, vortex shedding, abrasion, excessive
bending, and or rock impingement.
 PHMSA has reviewed information from Hilcorp and various state and Federal
agencies regarding the various alternatives for responding to the Failure. These
alternatives include: (a) immediate repair of the Affected Segment; (b) continued
operation of the Affected Segment until it can be safely repaired; and (c) shutting in
the Affected Segment until it can be safely repaired. Hilcorp has indicated it believes
the safest alternative is to continue operating the Affected Segment, at reduced
pressure until it can be safely repaired.
 PHMSA acknowledges from assertions made by Hilcorp that immediate repair of the
leak would pose an extreme risk to personnel during the current cold weather
conditions where diving operations are required to access, investigate, and repair the
Affected Segment.
 On April 2, 2021, Hilcorp stated to PHMSA that the risks associated with shutting in
the MGS-A pipeline until it can be safely repaired include a potential crude-oil spill
in Cook Inlet. According to Hilcorp, the MGS-A pipeline fuels boilers and powers
the platforms. Hilcorp stated that it could not continue providing a flow of water to
the crude-oil line, the MGS-B pipeline, which lies directly next to the Affected
Segment and which could freeze during colder temperatures due to such low-or no-
flow conditions. This could potentially cause a breach in the MGS-B pipeline and a
potential oil spill into the waters of the Cook Inlet. Hilcorp stated that it would not be
possible to mobilize alternative heat sources to the platform in order to shut down the



CPF No. 5-2021-019-CAO
Page 4
pipeline prior to conducting a temporary repair. Based on this information, PHMSA
issued a CAO on April 3, 2021 that did not require Hilcorp to perform an immediate
shut down of the pipeline. Rather, the CAO required Hilcorp to reduce pressure to no
greater than 65 psig on the entire length of the MGS-A pipeline, and complete a
temporary repair within 15 days of the issuance of the CAO, or shut down the
pipeline pursuant if that deadline could not be met.
 On April 3, 2021, Hilcorp reported an abnormal operating condition (AOC) to
PHMSA regarding a change to conditions on the MGS-A pipeline. Hilcorp reported
that at approximately 1:21 PM AKDT, a pressure drop and increase in flow was
observed. As a result of the AOC, Hilcorp shut in the MGS-A pipeline, and the
pipeline was blocked at approximately 1:30 PM AKDT. Hilcorp further reported that
by the evening of April 3, 2021, it was able to locate heaters on other local projects
that it planned to bring onsite to assist in freeze protection. In addition, Hilcorp
reported that it was bringing additional heaters onsite to assist in the freeze protection
while the MGS-A pipeline is shut in.
 On April 3, 2021, Hilcorp reported that the CISPRI Endeavour vessel mobilized from
Homer to Nikiski, AK and will remain in the area to conduct observations for sheen
or damage to wildlife, as needed.
 On April 5, 2021, Hilcorp provided another update to PHMSA as follows: daily
overflights to search for sheen or bubbles on the surface of the water were continuing;
the MGS-A pipeline remained shut in; Hilcorp was continuing to flow water down
the MGS-B pipeline for freeze protection; heaters were mobilized to the platform; and
preparations were being made for a temporary repair.
 Hilcorp provided a leak estimate to PHMSA after the CAO was issued. Hilcorp’s
initial calculation of the leak was estimated to be 75 to 150 MCFD. This estimate
was noted to be preliminary in nature and based on 70 psig, approximate water-depth
of 100 feet, and estimated 0.25-inch size hole.
 PHMSA recognizes that the majority of the MGS pipeline system is located within
the waters of the Upper Cook Inlet, which is known for extreme tides (average tides
of 20 feet, maximum tides of 35 feet, and currents in excess of 5 to 7 knots) and the
presence of dynamic sea ice conditions.
 Hilcorp plans to perform a multi-beam sonar survey to locate the leak and evaluate
the adjacent seabed condition on Tuesday April 6, 2021.
 Hilcorp has further indicated to PHMSA that the company cannot access the Affected
Segment until the ice clears, at which time diving operations can safely be conducted
to access, investigate, and repair the leak. According to Hilcorp, they will attempt to
get divers in the area of the Failure by Wednesday, April 7, 2021. Hilcorp has



CPF No. 5-2021-019-CAO
Page 5
indicated that it has temporary clamps that it may utilize as a temporary repair while
they prepare plans for a permanent repair. The serviceability of the pipeline will
remain impaired until at least this time.
 This is the fifth leak on the MGS-A since June 2014. The four previous leaks were in
June 2014 and August 2014, during ice-free conditions; December 2016 thru May
2017 during ice conditions; and 2019, when a leak was found by divers performing an
inspection of the pipeline. Four of the leaks were determined to be caused by rocks
contacting the pipeline in areas where the pipeline was not continuously supported by
the seabed. The leak in 2019 was caused by corrosion/weld discontinuity. The rocks
contacting the pipeline deteriorated the steel pipe wall by abrasion, resulting from
relative movement between the pipeline and rocks contacting the pipeline. All prior
leaks were repaired by installation of bolt-on, split-sleeve clamps. The 2014 leaks
were 42 yards apart, the 2016/2017 leak was approximately 2/3 mile from the
previous two leaks, and the current leak is in the general vicinity of the 2014 leaks.
 Vortex-induced vibrations of subsea pipelines within the Cook Inlet have been a
known integrity threat for years. Subsea pipeline operators in Cook Inlet typically
monitor subsea pipelines annually to identify pipeline spans that are unsupported by
the seabed and, if necessary, provide additional pipeline supports within these areas.
It is believed that vortex-induced vibrations are one of the motive forces responsible
for the relative movement between pipeline and rocks contacting the pipeline in areas
where the pipeline is unsupported by the seabed.
 PHMSA Consent agreement (5-2017-0004S), issued to Respondent in 2017 as a
result of a leak on the MGS-A pipeline, included corrective measures that required
integration of ILI assessment results and sonar inspection results. The integration of
data identified several locations along the Affected Segment that met agreed upon
intervention criteria resulting in pipeline repairs or other mitigation actions. Repairs
and other mitigation actions included application of a pipeline clamp, coating repairs,
and pipeline protection and stabilization.
 Respondent’s MGS-A pipeline is subject to the pipeline safety laws in 49 U.S.C.
chapter 601 and 49 C.F.R. part 192.
Determination of Necessity for Corrective Action Order and Right to Hearing
Section 60112 of title 49, United States Code, authorizes PHMSA to determine that a pipeline
facility is or would be hazardous to life, property, or the environment and if there is a likelihood
of serious harm, to expeditiously order the operator of the facility to take necessary corrective
action, including suspended or restricted use of the facility, physical inspection, testing, repair,
replacement, or other appropriate action. An order issued expeditiously must provide an
opportunity for a hearing as soon as practicable after the order is issued.



CPF No. 5-2021-019-CAO
Page 6
In deciding whether to issue an order, PHMSA must consider the following, if relevant: (1) the
characteristics of the pipe and other equipment used in the pipeline facility, including the age,
manufacture, physical properties, and method of manufacturing, constructing, or assembling the
equipment; (2) the nature of the material the pipeline facility transports, the corrosive and
deteriorative qualities of the material, the sequence in which the material is transported, and the
pressure required for transporting the material; (3) the aspects of the area in which the pipeline
facility is located, including climatic and geologic conditions and soil characteristics; (4) the
proximity of the area in which the hazardous liquid pipeline facility is located to environmentally
sensitive areas; (5) the population density and population and growth patterns of the area in
which the pipeline facility is located; (6) any recommendation of the National Transportation
Safety Board made under another law; and (7) any other factors PHMSA may consider as
appropriate.
After evaluating the foregoing preliminary findings of fact, and having considered the age of the
pipeline, the hazardous nature of the materials transported, the significant history of leaks
associated with the MGS-A pipeline, the location of the leak in a critical habitat for endangered
species, the extreme tidal influence in the waters of the Cook Inlet, the threat to commercial
navigation, the design of Respondent’s system that depends on a continued heat source to protect
the MGS-B crude oil pipeline from freezing and causing further potential harm to the
environment, the AOC that occurred subsequent to the issuance of the CAO, which resulted in
Hilcorp immediately shutting in the Affected Segment, notwithstanding its prior representations
to PHMSA that it could not do so safely due to the inability to obtain heaters quickly enough to
maintain freeze protection, and the likelihood that similar conditions conducive to vortex-
induced vibrations exist on the MGS-A pipeline, I find that continued operation of the Affected
Segment, as defined below, without corrective measures is or would be hazardous to life,
property, or the environment, and that failure to issue this Amended Order expeditiously would
result in the likelihood of serious harm.
Accordingly, this Amended Order mandating immediate corrective action is issued expeditiously
without prior notice and opportunity for a hearing. The terms and conditions of this Amended
Order are effective upon receipt.
Within 10 days of receipt of this Order, Respondent may request a hearing, to be held as soon as
practicable, by notifying the Associate Administrator for Pipeline Safety in writing, with a copy
to the Director, Western Region, PHMSA. If a hearing is requested, it will be held in accordance
with 49 C.F.R. § 190.211.
After receiving and analyzing additional data in the course of this investigation, PHMSA may
identify other corrective measures that need to be taken. Respondent will be notified of any
additional measures required and, if appropriate, PHMSA will consider amending this Amended
Order. To the extent consistent with safety, Respondent will be afforded notice and an
opportunity for a hearing prior to the imposition of any additional corrective measures.



CPF No. 5-2021-019-CAO
Page 7
Required Corrective Actions
Definitions:
Affected Segment – The “Affected Segment” means Hilcorp’s 8-inch MGS-A pipeline
between the MGS onshore facility and “A” Platform.
Director – The Director, Western Region, PHMSA, OPS, 12300 West Dakota Avenue, Suite
110, Lakewood, CO, 80228
Day – Calendar day.
Pursuant to 49 U.S.C. 60112, I hereby order Respondent to immediately take the following
corrective actions:
1. Shutdown of the Affected Segment. The Affected Segment was shut in on April 3, 2021.
The Affected Segment must remain shut in and may not be operated until authorized to be
restarted by the Director in accordance with the terms of this Amended Order. Gas pressure
may be allowed to temporarily go up to 65 psi during sonar scan and diver operations to
identify the leak. Hilcorp must keep the affected segment shut-in while sonar scan and
diver operations are not being conducted. Upon identification of the leak Hilcorp must
immediately commence shutdown operations of the line and isolate and block-in the
Affected Segment from any and all gas sources.
2. Restart Plan. Prior to resuming operation of the Affected Segment, develop and submit a
written Restart Plan to the Director for prior approval.
a. b. The Director may approve the Restart Plan incrementally without approving the
entire plan, but the Affected Segment cannot resume operation until the Restart Plan is
approved in its entirety.
Once approved by the Director, the Restart Plan will be incorporated by reference
into this Amended Order.
c. d. e. f. g. h. The Restart Plan must provide for adequate patrolling of the Affected Segment during
the restart process.
The Restart Plan must require that the pressure is not to exceed 65 psig until
operation at a higher pressure has been approved by the Director.
The Restart Plan must specify a day-light restart and include advance
communications with local emergency response officials.
The Restart Plan must provide for a repair plan for the Affected Segment.
The Restart Plan must also include documentation of the completion of all mandated
actions, and a management of change plan to ensure that all procedural modifications
are incorporated into Hilcorp’s O&M procedures manual.
The Restart Plan must provide for hydrostatic pressure testing of the Affected



CPF No. 5-2021-019-CAO
Page 8
3. Segment.
Return to Service. After the Director approves the Restart Plan, Hilcorp may return the
Affected Segment to service subject to the approved restart plans requirements.
4. The Affected Segment must be temporarily repaired by April 17, 2021, and permanently
repaired by May 1, 2021. Hilcorp must ensure diving operations can safely be conducted to
access, investigate, and repair the leak.
5. Hilcorp must notify the Director by telephone within one hour of a confirmed discovery of
any abnormal operating conditions, as defined in Part 192, or other issues regarding the
safe operation of the Affected Segment at any time, 24 hours a day/7 days a week, after the
issuance of this Amended Order. In the event the Director is unavailable, Hilcorp must
notify the Alaska Operations Supervisor, PHMSA, within the time requirement set forth in
this paragraph.
6. Hilcorp must develop and implement a "Pipeline Leak Inspection and Repair Plan" for the
Affected Segment. Hilcorp must submit a temporary repair plan within 5 days from the date
of this Amended Order, if it chooses to perform a temporary repair, and a permanent repair
plan within 20 days from the date of this Amended Order. Once approved by the Director,
the plan(s) is/are incorporated by reference into this Amended Order. Respondent must
complete the actions specified in the plan according to its timeline.
7. Hilcorp must develop and implement an “Inspection Plan" for the Affected Segment.
Hilcorp must submit the plan to the Director for approval no later than 45 days from the
issuance of the Amended Order. At a minimum, the plan must include the high-resolution
side-scan sonar inspection, or equivalent technology, and inline inspection. Once approved
by the Director, the plan is incorporated by reference into this Amended Order.
Respondent must complete the actions specified in the plan according to its timeline.
8. Removal of Pressure Restriction.
a. b. The Director may allow the removal or modification of the pressure restriction upon a
written request from Respondent demonstrating that modifying or restoring the
Affected Segment to its pre-failure operating pressure is justified based on a reliable
engineering analysis showing that the pressure increase is safe considering all known
defects, anomalies, and operating parameters of the pipeline.
The Director may allow the temporary removal or modification of the pressure
restrictions upon a written request from Respondent demonstrating that temporary
mitigative and preventive measures are implemented prior to and during the
temporary removal or modification of the pressure restriction. The Director's
determination will be based on the failure cause and provision of evidence that
preventative and mitigative actions taken by the operator provide for the safe
operation of the Affected Segment during the temporary removal or modification of
the pressure restriction. Appeals of determinations by the Director in this regard will
be decided by the Associate Administrator for Pipeline Safety.



CPF No. 5-2021-019-CAO
Page 9
9. Root Cause Failure Analysis. Within 120 days following receipt of this Amended Order,
Respondent must complete a root cause failure analysis (RCFA) and submit a final report
of this RCFA to the Director. The RCFA must be supplemented or facilitated by an
independent third-party and must document the decision-making process and all factors
contributing to the failure. Respondent must obtain prior approval from the Director of
Respondent’s selection of the independent third-party. The final report must include
findings and any lessons learned and whether the findings and lessons learned are
applicable to other locations within Respondent’s pipeline system.
10. Replacement Plan Work (RP).
a. b. Within 45 days following the issuance of this Amended Order, Respondent must
submit to the Director for approval a Replacement Work Plan (RP) for replacement of
the Affected Segment.
Once approved by the Director, the RP is incorporated by reference into this
Amended Order.
c. The Respondent must complete the replacement of the Affected Segment, as described
in the approved RP, within 365 days of the date of this Amended Order.
11. CAO Documentation Report (CDR). Respondent must create and revise, as necessary, a
CAO Documentation Report (CDR). When Respondent has concluded all the items in this
Amended Order it will submit the final CDR in its entirety to the Director. This will allow
the Director to complete a thorough review of all actions taken by Respondent with regard
to this Amended Order prior to approving the closure of this Amended Order. The intent is
for the CDR to summarize all activities and documentation associated with this Amended
Order in one document.
a. b. The Director may approve the CDR incrementally without approving the entire CDR.
Once approved by the Director, the CDR will be incorporated by reference into this
Amended Order.
c. The CDR must include, but is not necessarily limited to, the following:
i. Table of Contents;
ii. iii. Summary of the Incident and the response activities;
Summary of pipe data, material properties and all prior assessments of the
Affected Segment;
iv. Summary of all tests, inspections, assessments, evaluations, and analysis required
by the Amended Order;
v. vi. Summary of the RCFA with all root causes as required by the Amended Order;
Documentation of all actions taken by Respondent to implement the RP, the
results of those actions, and the inspection and repair criteria used;
vii. Documentation of any revisions to the RP including those necessary to
incorporate the results of actions undertaken pursuant to this Amended Order and



CPF No. 5-2021-019-CAO
Page 10
whenever necessary to incorporate new information obtained during the failure
investigation and remedial activities;
i. ii. Lessons learned while completing this Amended Order;
A path forward describing specific actions Respondent will take on its entire
pipeline system as a result of the lessons learned from work on this Amended
Order; and
iii. Appendices (if required).
Other Requirements:
12. Approvals. With respect to each submission that under this Amended Order requires the
approval of the Director, the Director may: (a) approve, in whole or part, the submission;
(b) approve the submission on specified conditions; (c) modify the submission to cure any
deficiencies; (d) disapprove in whole or in part, the submission, directing that Respondent
modify the submission, or (e) any combination of the above. In the event of approval,
approval upon conditions, or modification by the Director, Respondent shall proceed to
take all action required by the submission as approved or modified by the Director. If the
Director disapproves all or any portion of the submission, Respondent must correct all
deficiencies within the time specified by the Director, and resubmit it for approval.
13. Extensions of Time. The Director may grant an extension of time for compliance with any
of the terms of this Amended Order upon a written request timely submitted demonstrating
good cause for an extension.
14. Reporting. Respondent must submit quarterly reports to the Director that: (1) include all
available data and results of the testing and evaluations required by this Amended Order;
and (2) describe the progress of the repairs or other remedial actions being undertaken.
The first quarterly report is due on July 12, 2021. The Director may change the interval for
the submission of these reports.
15. Documentation of the Costs. It is requested that Respondent maintain documentation of
the costs associated with implementation of this CAO. Include in each monthly report
submitted, the to-date total costs associated with: (1) preparation and revision of
procedures, studies, and analyses; (2) physical changes to pipeline infrastructure, including
repairs, replacements, and other modifications; and (3) environmental remediation, if
applicable.
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).



CPF No. 5-2021-019-CAO
Page 11
In your correspondence on this matter, please refer to “CPF No. 5-2021-019-CAO” and for each
document you submit, please provide a copy in electronic format whenever possible. The
actions required by this Amended Order are in addition to and do not waive any requirements
that apply to Respondent’s pipeline system under 49 C.F.R. Parts 190 through 199, under any
other order issued to Respondent under authority of 49 U.S.C. Chapter 601, or under any other
provision of Federal or State law.
Respondent may appeal in writing any decision of the Director to the Associate Administrator
for Pipeline Safety. Decisions of the Associate Administrator shall be final.
Failure to comply with this Amended Order may result in the assessment of civil penalties and in
referral to the Attorney General for appropriate relief in United States District Court pursuant to
49 U.S.C. § 60120.
The terms and conditions of this Amended Order are effective upon service in accordance with
49 C.F.R.
§ 190.5.
_________________________________ ________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety

52021019CAO_Closure Letter_11282022_(21-209244)_text.pdf

VIA E-MAIL TO MR. GREG LALICKER
November 28, 2022
Mr. Greg Lalicker
Chief Executive Officer
Hilcorp Energy Company
1111 Travis Street
Houston, Texas 77002
RE: Amended Corrective Action Order CPF No. 5-2021-019-CAO
Middle Ground Shoal Fuel Gas System - Request for Closure
Dear Mr. Lalicker:
On April 6, 2021, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued
an Amended Corrective Action Order (ACAO) requiring Hilcorp Alaska, LLC, (Hilcorp or
Respondent), a subsidiary of Hilcorp Energy Company, to take certain corrective actions with
respect to a natural gas leak on its 8-inch Middle Ground Shoal (MGS) Fuel Gas System A
Pipeline (MGS-A) that failed on or about April 1, 2021, within the Upper Cook Inlet, Alaska, on
a subsea segment of the MGS-A pipeline between the MGS onshore facility and “A” Platform.
The ACAO required Hilcorp to shut down the MGS-A pipeline, repair the pipeline before
restarting it, and replace the MGS-A pipeline within one year of the date the ACAO was issued.
Since that time, Hilcorp determined that it is not currently commercially viable to replace the
pipeline, as required by the ACAO, and instead Hilcorp proposed to permanently abandon the
MGS-A pipeline without replacement. PHMSA agreed that by permanently abandoning the
MGS-A pipeline, Hilcorp has mitigated known integrity threats of the MGS-A pipeline system
consistent with the intent of the ACAO. PHMSA received notice that Hilcorp permanently
abandoned the MGS-A pipeline in September 2022.
On September 29, 2022, Hilcorp provided the CAO Documentation Report (CDR). The CDR
was the last outstanding item of the ACAO. The CDR summarized actions taken by Hilcorp in
response to the ACAO and describes how Hilcorp has integrated lessons learned from the failure,
including the results of the Root Cause Failure Analysis, into their programs and procedures.
Because Hilcorp has abandoned the MGS-A pipeline system and provided all documentation
required by the ACAO, I have determined that the terms of the ACAO have been completed and
accordingly, the referenced ACAO is terminated. Thank you for your cooperation in this matter.



Sincerely,
Dustin Hubbard
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 J. Gano (#21-209244)
Ben Wasson, Hilcorp Alaska (via email)
Cindy Monnin, Hilcorp Alaska (via email)

52021019CAO_Corrective Action Order_04032021_(21-209244)_text.pdf

VIA ELECTRONIC MAIL TO:
Mr. Greg Lalicker
Chief Executive Officer
Hilcorp Energy Company
1111 Travis Street
Houston, Texas 77002
CPF No. 5-2021-019-CAO
Dear Mr. Lalicker:
Enclosed please find a Corrective Action Order (CAO or Order) issued by the Pipeline and
Hazardous Materials Safety Administration, Office of Pipeline Safety, in the above-referenced
case. It requires Hilcorp Alaska, LLC, (Hilcorp or Respondent), a subsidiary of Hilcorp Energy
Company, to take certain corrective actions with respect to a natural gas leak on its 8-inch
Middle Ground Shoal (MGS) Fuel Gas System A Pipeline (MGS-A) that failed on or about April
1, 2021, within the Upper Cook Inlet, Alaska, on a subsea segment of the MGS-A pipeline
between the MGS onshore facility and “A” Platform.
Service of the CAO by e-mail is deemed complete upon transmission and acknowledgement of
receipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms and conditions of this
Order are effective upon completion of service.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure: CAO
cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS
Mr. Dustin Hubbard, Director, Western Region, OPS
Mr. David S. Wilkins, Senior Vice President, Hilcorp Alaska (via email)
Mr. Ben Wasson, Hilcorp Alaska (via email)
CONFIRMATION OF RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Hilcorp Alaska, LLC, )
)
)
)
Respondent. )
____________________________________)
CPF No. 5-2021-019-CAO
CORRECTIVE ACTION ORDER
Purpose and Background
This Corrective Action Order (CAO or Order) is being issued by the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), under the authority
of 49 U.S.C. § 60112 to require Hilcorp Alaska, LLC (Hilcorp or Respondent) to take the
necessary corrective actions to protect the public, property, and the environment from potential
hazards associated with a release from its 8-inch Middle Ground Shoal (MGS) Fuel Gas System
A Pipeline (MGS-A) in the Upper Cook Inlet, Alaska.1 This Order finds that continued
operation of the subsea segment of Respondent’s 8-inch MGS-A pipeline between the MGS
onshore facility and “A” Platform (Affected Segment), without corrective action, is or would be
hazardous to life, property, or the environment and requires Respondent to take immediate action
to ensure its safe operation.
At approximately 4:25 PM AKDT (Alaska time), on April 1, 2021, Hilcorp determined that their
8-inch MGS-A natural gas pipeline was leaking, resulting in an ongoing release of an unknown
quantity of natural gas into the waters of the Cook Inlet, Alaska (Failure or Incident). The
Failure occurred within the Upper Cook Inlet, Alaska, on a subsea segment of the MGS-A
pipeline between the MGS onshore facility and the “A” Platform. As measured along the
pipeline alignment, the pipeline failure is approximately 6 miles from the MGS onshore facility
and 1 mile from the “A” Platform. Mainline block valves for this pipeline segment are located at
the MGS onshore facility and “A” Platform. The MGS-A pipeline transports fuel gas from the
MGS onshore facility to the two offshore platforms. The cause of the Failure has not yet been
1 Hilcorp’s MGS fuel gas system provides utility gas to the offshore Platforms A and C utilizing gas from the East
Cook Inlet Gas Gathering System (ECIGGS) (ECIGGS is a PHMSA-regulated natural gas transmission system).
The MGS pipeline system begins at the 3-inch tie-in to the ECIGGS pipeline on Wik Road in Nikiski, Alaska. The
pipeline passes through Station O (201 Meter) and the MGS onshore facility before the subsea portion to the
platforms. The line includes 2-inch, 4-inch, 6-inch and 8-inch diameters. The offshore (subsea) portion the MGS
fuel gas system is identified as the “A” Pipeline. The “A” Pipeline begins at the onshore facility and is routed to the
“A” Platform and from the “A” Platform it is routed to the “C” Platform. The “A” Pipeline is 8-inch diameter and
was converted to gas service from oil service in 2005.



CPF No. 5-2021-019-CAO
Page 2
determined. The Failure occurred in an ecologically sensitive area and presents a serious risk to
the environm
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