# OLIKTOK PIPELINE COMPANY — Warning Letter

**Citation:** CPF 520196006W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2019-07-15

CLOSED warning letter citing 195.208, 195.452(k).

## Document text

Warning Letter involving OLIKTOK PIPELINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.208,  195.452(k). The case was opened on 2019-07-15 and is reported as closed as of 2019-07-15. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520196006W_Operator Response to Notice_08282019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520196006W/520196006W_Operator%20Response%20to%20Notice_08282019.pdf

520196006W_Warning Letter_07152019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520196006W/520196006W_Warning%20Letter_07152019.pdf

520196006W_Warning Letter_07152019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520196006W/520196006W_Warning%20Letter_07152019_text.pdf

520196006W_Warning Letter_07152019_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
July 15, 2019
Mr. Scott Jepsen
President
Oliktok Pipeline Company
P.O. Box 100360
Anchorage, AK 99501
CPF 5-2019-6006W
Dear Mr. Jepsen:
From February 25 through March 1, 2019, and from March 11 through 15, 2019,
representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA),
pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected your Oliktok Pipeline
located on the North Slope of Alaska and related documents in Anchorage, Alaska.
As a result of the inspection, it is alleged that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items
inspected and the probable violations are:
1. § 195.208 Welding of supports and braces.
Supports or braces may not be welded directly to pipe that will be operated at a
pressure of more than 100 p.s.i. (689 kPa) gage.
Oliktok Pipeline, which operates above 100 psig, had supports welded directly to pipe.
PHMSA representatives observed a pipeline support welded directly to the Oliktok Pipeline at
Central Processing Facility 1, downstream of valve MOV-1029 and upstream of the receiver.



2. § 195.452 Pipeline integrity management in high consequence areas.
(a) …
(k) What methods to measure program effectiveness must be used? An operator's
program must include methods to measure whether the program is effective in
assessing and evaluating the integrity of each pipeline segment and in protecting
the high consequence areas. See Appendix C of this part for guidance on methods
that can be used to evaluate a program's effectiveness.
The operator failed to perform, in a timely manner, periodic evaluations of the effectiveness of
its integrity management program in assessing and evaluating the integrity of each pipeline
segment and in protecting the high consequence areas. Specifically, when requested to
provide documentation of periodic evaluations of the effectiveness of its integrity management
program, the operator initially provided performance measures results for 2011, 2012, 2013,
and 2014, and stated that effectiveness evaluations were not conducted for the time periods
between 2015 and 2018. Subsequent to PHMSA’s initial request, the operator performed
evaluations of the effectiveness of its integrity management program for 2015, 2016, 2017,
and 2018, and provided the results to PHMSA at the end of the inspection. As such, the
operator failed to perform periodic evaluations of the effectiveness of its integrity management
program for 2015, 2016, and 2017 in a timely manner.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to
exceed $213,268 per violation per day the violation persists, up to a maximum of $2,132,679
for a related series of violations. For violation occurring on or after November 2, 2015 and
before November 27, 2018, the maximum penalty may not exceed $209,002 per violation per
day, with a maximum penalty not to exceed $2,090,022. For violations occurring prior to
November 2, 2015, the maximum penalty may not exceed $200,000 per violation per day, with
a maximum penalty not to exceed $2,000,000 for a related series of violations. We have
reviewed the circumstances and supporting documents involved in this case, and have decided
not to conduct additional enforcement action or penalty assessment proceedings at this time.
We advise you to correct the items identified in this letter. Failure to do so will result in
Oliktok Pipeline Company being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer
to CPF 5-2019-6006W. 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
2



you believe the redacted information qualifies for confidential treatment under 5 U.S.C.
552(b).
Sincerely,
Dustin B. Hubbard
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: Wes Olson, DOT Program Coordinator
PHP-60 Compliance Registry
PHP-500 T. Johnson/J. Gano (#163103, #163104)
3

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/520196006W>
- Source ID: `phmsa-enforcement`
- SHA-256: `c5ae9358470e8758353b84edd8c228f47ec6a05bf4ae431765fad5196ada5466`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T18:51:52.622Z
- Document slug: `phmsa-enforcement-520196006w`

### Source metadata

```json
{
  "cpf": "520196006W",
  "operator": "OLIKTOK PIPELINE COMPANY",
  "region": "Western",
  "pipelineType": "INTRASTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.208",
    "195.452(k)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 3,
  "attachments": [
    {
      "name": "520196006W_Operator Response to Notice_08282019.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520196006W/520196006W_Operator%20Response%20to%20Notice_08282019.pdf",
      "bytes": 274914,
      "category": "party_submission"
    },
    {
      "name": "520196006W_Warning Letter_07152019.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520196006W/520196006W_Warning%20Letter_07152019.pdf",
      "bytes": 49681,
      "category": "agency_document"
    },
    {
      "name": "520196006W_Warning Letter_07152019_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520196006W/520196006W_Warning%20Letter_07152019_text.pdf",
      "bytes": 113657,
      "category": "agency_document"
    }
  ],
  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "OLIKTOK PIPELINE COMPANY"
}
```
