# NUTAAQ PIPELINE, LLC — Warning Letter

**Citation:** CPF 52023057WL  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2023-12-19

CLOSED warning letter citing 192.161(c).

## Document text

Warning Letter involving NUTAAQ PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulation as 192.161(c). The case was opened on 2023-12-19 and is reported as closed as of 2023-12-19. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

52023057WL_Warning Letter_12192023_(23-265655).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023057WL/52023057WL_Warning%20Letter_12192023_(23-265655).pdf

52023057WL_Warning Letter_12192023_(23-265655)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023057WL/52023057WL_Warning%20Letter_12192023_(23-265655)_text.pdf

52023057WL_Warning Letter_12192023_(23-265655)_text.pdf

WARNING LETTER
VIA ELECTRONIC MAIL TO: DPASCAL@GLACIEROIL.COM
December 19, 2023
Mr. David Pascal
Chief Operating Officer
Nutaaq Pipeline, LLC
188 W. Northern Lights Blvd, Suite 510
Anchorage, AK 99503
CPF 5-2023-057-WL
Dear Mr. Pascal:
On July 31, 2023, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected
Nutaaq Pipeline, LCC’s (Nutaaq or Operator) Badami offshore gas gathering pipeline 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 item inspected
and the probable violation is:
1. § 192.161 Supports and anchors.
(a) . . . .…



(c) Each support or anchor on an exposed pipeline must be made of durable,
noncombustible material and must be designed and installed as follows:...
Nutaaq failed to use durable, noncombustible material as a support or anchor on its exposed
pipeline as required. Specifically, photos presented by the Operator during the inspection
revealed that wood cribbing was used to support the upstream anchors, which is not permitted
pursuant to § 192.161(c).
Therefore, Nutaaq failed to use durable, noncombustible material as an anchor on its pipeline as
required by the pipeline safety regulations.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a
related series of violations. For violation occurring on or after March 21, 2022, and before
January 6, 2023, the maximum penalty may not exceed $239,142 per violation per day the
violation persists, up to a maximum of $2,391,142 for a related series of violations. For violation
occurring on or after May 3, 2021, and before March 21, 2022, the maximum penalty may not
exceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for
a related series of violations. For violation occurring on or after January 11, 2021, and before
May 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation
persists, up to a maximum of $2,225,034 for a related series of violations. For violation
occurring on or after July 31, 2019, and before January 11, 2021, the maximum penalty may not
exceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for
a related series of violations. For violation occurring on or after November 27, 2018, and before
July 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a
maximum penalty not to exceed $2,132,679. 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.
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
Nutaaq Pipeline, LLC 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 5-2023-057-WL. 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).
Sincerely,
Dustin Hubbard
Director, Western Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 J. Gano, C. Dolchok (#23-265655)

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/52023057WL>
- Source ID: `phmsa-enforcement`
- SHA-256: `65db1c3330d79ec24941edd41fa1989657b69638d2ae44885286601332c4b54b`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T02:57:29.024Z
- Document slug: `phmsa-enforcement-52023057wl`

### Source metadata

```json
{
  "cpf": "52023057WL",
  "operator": "NUTAAQ PIPELINE, LLC",
  "region": "Western",
  "pipelineType": "INTRASTATE GAS TRANSMISSION",
  "caseStatus": "CLOSED",
  "citedSections": [
    "192.161(c)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
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      "name": "52023057WL_Warning Letter_12192023_(23-265655).pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/52023057WL/52023057WL_Warning%20Letter_12192023_(23-265655).pdf",
      "bytes": 256894,
      "category": "agency_document"
    },
    {
      "name": "52023057WL_Warning Letter_12192023_(23-265655)_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/52023057WL/52023057WL_Warning%20Letter_12192023_(23-265655)_text.pdf",
      "bytes": 120484,
      "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": "NUTAAQ PIPELINE, LLC"
}
```
