# NORGASCO INC — Warning Letter

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

Official case documents:

520170003W_Warning Letter_02102017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170003W/520170003W_Warning%20Letter_02102017.pdf

520170003W_Warning Letter_02102017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170003W/520170003W_Warning%20Letter_02102017_text.pdf

520170003W_Warning Letter_02102017_text.pdf

WARNING LETTER
VIA FED EX – TRACKING # 7784 0116 8389
February 10, 2017
Mr. Richard Cathriner
President
Norgasco, Inc.
4341 B Street, Suite 306
Anchorage, AK 99503
CPF 5-2017-0003W
Dear Mr. Cathriner:
On November 8-9, 2016, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your
Norgasco Deadhorse Gas Distribution system facilities located in Deadhorse, Alaska. Supporting
operation and maintenance procedures and implementation records were reviewed on August 15-
17, 2016 at your Anchorage office.
As a result of the inspection, it is alleged that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the
probable violation is:
1. §192.807(a) Record keeping.
Each operator shall maintain records that demonstrate compliance with this
subpart.
(a) Qualification records shall include:
(1) Identification of qualified individual(s);
(2) Identification of the covered tasks the individual is qualified to perform;



(3) Date(s) of current qualification; and
(4) Qualification method(s).
(b) Records supporting an individual's current qualification shall be maintained
while the individual is performing the covered task. Records of prior qualification
and records of individuals no longer performing covered tasks shall be retained for a
period of five years.
At the time of the inspection, the task of installing wax tape protective coating was not part of the
operator's OQ program. Norgasco’s onsite employees had been installing wax tape coatings in
accordance with the manufacturer’s guidance; however, the task was not properly identified and
recorded as an Operator Qualification standard according 192.807(a). With regard to industry best
practices for pressure piping, ASME Code B31Q identifies the records requirements for training,
evaluation, and qualification for any of the operator’s employees performing covered tasks. Said
covered tasks are defined by 49 CFR 192.801(b).
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 violations occurring between January 4, 2012 and 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. 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 Norgasco 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 5-2017-0003W. 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 M. Chard (#153457)
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