{"operation":"document","citation":"CPF 520156004W","title":"ENI US OPERATING CO, INC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-10-14","effective_on":null,"summary":"CLOSED warning letter citing 195.402(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520156004w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520156004w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520156004w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520156004W","body":"Warning Letter involving ENI US OPERATING CO, INC. PHMSA's enforcement data identifies the cited regulation as 195.402(a). The case was opened on 2015-10-14 and is reported as closed as of 2015-10-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520156004W_warning letter_10142015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520156004W/520156004W_warning%20letter_10142015.pdf\n\n520156004W_warning letter_10142015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520156004W/520156004W_warning%20letter_10142015_text.pdf\n\n520156004W_warning letter_10142015_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 14, 2015\nMr. Scot Childress\nOperations Manager-AK\nENI US Operating Co. Inc.\n3800 Centerpoint Drive, Suite 300\nAnchorage, AK 99503\nCPF 5-2015-6004W\nDear Mr. Childress:\nOn July 29, 2015 and July 30, 2015, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) inspected ENI US Operating Co. Inc.’s (ENI) records and\nfacilities located near Prudhoe Bay, Alaska.\nAs a result of the inspection by PHMSA, it appears that you have committed a probable\nviolation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The\nitems inspected and the probable violation is:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities\nand handling abnormal operations and emergencies. This manual shall be\nreviewed at intervals not exceeding 15 months, but at least once each calendar\nyear, and appropriate changes made as necessary to insure that the manual is\neffective. This manual shall be prepared before initial operations of a pipeline\nsystem commence, and appropriate parts shall be kept at locations where\noperations and maintenance activities are conducted.\n\n\n\nPer §195.402(a), ENI must review their operations and maintenance manual within a\nrequired time frame of once each calendar year but should not exceed 15 months. This\nreview must also include the ENI Operator Qualification (OQ) manual. During the inspection\nit was determined that although the Operations and Maintenance manual had been reviewed\nannually, ENI’s OQ manual had not been reviewed since 2010. ENI must review, update,\nand document the review of their OQ manual according to part 195.402(a), once per calendar\nyear and not to exceed 15 months.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the maximum\npenalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a related series of violations. We have reviewed the circumstances\nand supporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct\nthe items identified in this letter. Failure to do so will result in ENI being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2015-6004W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C.\n552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 5 U.S.C. 552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 R. Guisinger (#150800)","truncated":false,"body_characters":4122}