# CONOCOPHILLIPS ALASKA NATURAL GAS CORP. — Warning Letter

- **operation:** document
- **citation:** CPF 520163001W
- **title:** CONOCOPHILLIPS ALASKA NATURAL GAS CORP. — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2016-05-10
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 193.2719(a)(1), 193.2719(a)(2).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520163001w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520163001w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520163001w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520163001W
**body:**

Warning Letter involving CONOCOPHILLIPS ALASKA NATURAL GAS CORP.. PHMSA's enforcement data identifies the cited regulations as 193.2719(a)(1),  193.2719(a)(2). The case was opened on 2016-05-10 and is reported as closed as of 2016-05-10. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520163001W_Warning Letter_05102016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520163001W/520163001W_Warning%20Letter_05102016.pdf

520163001W_Warning Letter_05102016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520163001W/520163001W_Warning%20Letter_05102016_text.pdf

520163001W_Warning Letter_05102016_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
May 10, 2016
Mr. Peter A. Micciche
Superintendent, Integrated Projects
ConocoPhillips Alaska, Inc.
P.O. Box 66
Kenai, Alaska 99611
Revised CPF 5-2016-3001W
Dear Mr. Micciche:
It was brought to our attention that the Warning Letter mailed to you on April 11, 2016,
referenced Subpart J which is incorrect. We have modified the letter (below) to show the
correct Subpart, which is Subpart H.
On October 20-22, 2015, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) inspected your Liquefied Natural Gas (LNG) facilities near Kenai,
Alaska. Our inspectors also examined your operation, maintenance, security, and emergency
response procedures and records.
As a result of the inspection by PHMSA, it appears that you have committed a probable
violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations, Part 193.
The items inspected and probable violation is:
1. §193.2719 Training: records.
(a) Each operator shall maintain a system of records which-
(1) Provide evidence that the training programs required by this subpart have
been implemented; and
(2) Provide evidence that personnel have undergone and satisfactorily completed
the required training programs.
Per §193.2719 (a) of Subpart H, ConocoPhillips Alaska personnel were unable to provide
training records for security personnel who worked security shifts at the LNG dock area in
2015. Initial training records were given to PHMSA for the security officer who was working



the duty hours, but the retraining records required by Subpart H, 193.2715 (b) were not
provided for the officer at the time of the inspection.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a
related series of violations. For violations occurring prior to January 4, 2012, the maximum
penalty may not exceed $100,000 per violation per day, with a maximum penalty not to
exceed $1,000,000 for a related series of violations. Also, for LNG facilities, an additional
penalty of not more than $50,000 for each violation may be imposed. 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
ConocoPhillips 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 5-2016-3001W. 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,
For Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 R. Guisinger (#151065)
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