# ENI US OPERATING CO, INC — Warning Letter

- **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:** Not available
- **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.

Official case documents:

520166014W_Warning Letter_12142016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520166014W/520166014W_Warning%20Letter_12142016.pdf

520166014W_Warning Letter_12142016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520166014W/520166014W_Warning%20Letter_12142016_text.pdf

520166014W_Warning Letter_12142016_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
December 14, 2016
Mr. Franco Picciani
VP Technical Services
Eni US Operating Co. Inc.
1200 Smith Street, Suite 1700
Houston, TX 77002
CPF 5-2016-6014W
Dear Mr. Picciani:
On November 9, 10, 17, and 18, 2016, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States
Code, inspected your Nikaitchuq Oil Pipeline on the Alaska North Slope, and operational
records associated with that pipeline in Anchorage, Alaska.
As a result of the inspection, it is alleged that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and
the probable violation is:
1. §195.505 Qualification program.
Each operator shall have and follow a written qualification program. The
program shall include provisions to:
b) Ensure through evaluation that individuals performing covered tasks are
qualified;



Eni US Operating Co., Inc. (Eni) did not adequately ensure that individuals performing
covered tasks were qualified. PHMSA reviewed operator qualification (OQ) records and
found that individuals performing valve maintenance and right-of-way patrols had not been
qualified prior to conducting those tasks. Eni stated that other instances of individuals
performing covered tasks who were not properly qualified would likely be found should
PHMSA request more records. Eni stated that they are in the process of adopting new OQ
database software, but had not completed its implementation prior to the 2016 inspection.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
$205,638 per violation per day the violation persists up to a maximum of $2,056,380 for a
related series of violations. For violation occurring between January 4, 2012 to August 1,
2016, 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. 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. 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 item identified in this letter. Failure to do so will
result in Eni 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 5-2016-6014W. 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,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 J. Gano (#153546)
Mr. Craig Keppers, Facility Engineer, Eni US Operating Co. Inc., 3800 Centerpoint
Drive, Suite 300 Anchorage, Alaska 99503
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