{"operation":"document","citation":"CPF 520170003W","title":"NORGASCO INC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-02-10","effective_on":null,"summary":"CLOSED warning letter citing 192.807.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520170003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520170003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520170003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520170003W","body":"Warning Letter involving NORGASCO INC. PHMSA's enforcement data identifies the cited regulation as 192.807. The case was opened on 2017-02-10 and is reported as closed as of 2017-02-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520170003W_Warning Letter_02102017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170003W/520170003W_Warning%20Letter_02102017.pdf\n\n520170003W_Warning Letter_02102017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170003W/520170003W_Warning%20Letter_02102017_text.pdf\n\n520170003W_Warning Letter_02102017_text.pdf\n\nWARNING LETTER\nVIA FED EX – TRACKING # 7784 0116 8389\nFebruary 10, 2017\nMr. Richard Cathriner\nPresident\nNorgasco, Inc.\n4341 B Street, Suite 306\nAnchorage, AK 99503\nCPF 5-2017-0003W\nDear Mr. Cathriner:\nOn November 8-9, 2016, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\nNorgasco Deadhorse Gas Distribution system facilities located in Deadhorse, Alaska. Supporting\noperation and maintenance procedures and implementation records were reviewed on August 15-\n17, 2016 at your Anchorage office.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the\nprobable violation is:\n1. §192.807(a) Record keeping.\nEach operator shall maintain records that demonstrate compliance with this\nsubpart.\n(a) Qualification records shall include:\n(1) Identification of qualified individual(s);\n(2) Identification of the covered tasks the individual is qualified to perform;\n\n\n\n(3) Date(s) of current qualification; and\n(4) Qualification method(s).\n(b) Records supporting an individual's current qualification shall be maintained\nwhile the individual is performing the covered task. Records of prior qualification\nand records of individuals no longer performing covered tasks shall be retained for a\nperiod of five years.\nAt the time of the inspection, the task of installing wax tape protective coating was not part of the\noperator's OQ program. Norgasco’s onsite employees had been installing wax tape coatings in\naccordance with the manufacturer’s guidance; however, the task was not properly identified and\nrecorded as an Operator Qualification standard according 192.807(a). With regard to industry best\npractices for pressure piping, ASME Code B31Q identifies the records requirements for training,\nevaluation, and qualification for any of the operator’s employees performing covered tasks. Said\ncovered tasks are defined by 49 CFR 192.801(b).\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $205,638\nper violation per day the violation persists up to a maximum of $2,056,380 for a related series of\nviolations. For violations occurring between January 4, 2012 and August 1, 2016, the maximum\npenalty may not exceed $200,000 per violation per day, with a maximum penalty not to exceed\n$2,000,000 for a related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement action\nor penalty assessment proceedings at this time. We advise you to correct the item identified in\nthis letter. Failure to do so will result in Norgasco being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2017-0003W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 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 M. Chard (#153457)","truncated":false,"body_characters":4290}