{"operation":"document","citation":"CPF 520166014W","title":"ENI US OPERATING CO, INC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-12-14","effective_on":null,"summary":"CLOSED warning letter citing 195.505(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520166014w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520166014w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520166014w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520166014W","body":"Warning Letter involving ENI US OPERATING CO, INC. PHMSA's enforcement data identifies the cited regulation as 195.505(b). The case was opened on 2016-12-14 and is reported as closed as of 2016-12-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520166014W_Warning Letter_12142016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520166014W/520166014W_Warning%20Letter_12142016.pdf\n\n520166014W_Warning Letter_12142016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520166014W/520166014W_Warning%20Letter_12142016_text.pdf\n\n520166014W_Warning Letter_12142016_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 14, 2016\nMr. Franco Picciani\nVP Technical Services\nEni US Operating Co. Inc.\n1200 Smith Street, Suite 1700\nHouston, TX 77002\nCPF 5-2016-6014W\nDear Mr. Picciani:\nOn November 9, 10, 17, and 18, 2016, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States\nCode, inspected your Nikaitchuq Oil Pipeline on the Alaska North Slope, and operational\nrecords associated with that pipeline in Anchorage, Alaska.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and\nthe probable violation is:\n1. §195.505 Qualification program.\nEach operator shall have and follow a written qualification program. The\nprogram shall include provisions to:\nb) Ensure through evaluation that individuals performing covered tasks are\nqualified;\n\n\n\nEni US Operating Co., Inc. (Eni) did not adequately ensure that individuals performing\ncovered tasks were qualified. PHMSA reviewed operator qualification (OQ) records and\nfound that individuals performing valve maintenance and right-of-way patrols had not been\nqualified prior to conducting those tasks. Eni stated that other instances of individuals\nperforming covered tasks who were not properly qualified would likely be found should\nPHMSA request more records. Eni stated that they are in the process of adopting new OQ\ndatabase software, but had not completed its implementation prior to the 2016 inspection.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$205,638 per violation per day the violation persists up to a maximum of $2,056,380 for a\nrelated series of violations. For violation occurring between January 4, 2012 to August 1,\n2016, the maximum penalty may not exceed $200,000 per violation per day, with a maximum\npenalty not to exceed $2,000,000 for a related series of violations. For violations occurring\nprior to January 4, 2012, the maximum penalty may not exceed $100,000 per violation per\nday, with a maximum penalty not to exceed $1,000,000 for a related series of violations. We\nhave reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at\nthis time. We advise you to correct the item identified in this letter. Failure to do so will\nresult in Eni being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2016-6014W. 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. 552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Gano (#153546)\nMr. Craig Keppers, Facility Engineer, Eni US Operating Co. Inc., 3800 Centerpoint\nDrive, Suite 300 Anchorage, Alaska 99503","truncated":false,"body_characters":4160}