{"operation":"document","citation":"CPF 520190001W","title":"NUTAAQ PIPELINE, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-01-10","effective_on":null,"summary":"CLOSED warning letter citing 192.739(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520190001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520190001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520190001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520190001W","body":"Warning Letter involving NUTAAQ PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulation as 192.739(a). The case was opened on 2019-01-10 and is reported as closed as of 2019-01-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520190001W_Warning Letter_01102019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190001W/520190001W_Warning%20Letter_01102019.pdf\n\n520190001W_Warning Letter_01102019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190001W/520190001W_Warning%20Letter_01102019_text.pdf\n\n520190001W_Warning Letter_01102019_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 10, 2019\nMr. David Pascal\nVice President – Operations\nGlacier Oil and Gas Corporation\n601 West 5th Avenue, Suite 310\nAnchorage, Alaska 99501\nCPF 5-2019-0001W\nDear Mr. Pascal:\nBetween August 1 and August 10, 2017, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code\n(U.S.C.), inspected the Badami Gas Transmission pipeline of Nutaaq Pipeline, LLC’s Badami\nGas Transmission line on the North Slope of Alaska. The inspection included field\nexamination of the facilities, operation and maintenance procedures, and records\ndemonstrating implementation of those procedures.\nBased on our inspection findings, PHMSA determined that you have committed probable\nviolations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR).\nThe deficiencies noted and the probable violations are:\n§192.739 Pressure limiting and regulating stations: Inspection and testing.\n(a) Each pressure limiting station, relief device (except rupture discs), and\npressure regulating station and its equipment must be subjected at intervals not\n\n\n\nexceeding 15 months, but at least once each calendar year, to inspections and tests\nto determine that it is—\n(1) In good mechanical condition;\n(2) Adequate from the standpoint of capacity and reliability of operation for the\nservice in which it is employed;\n(3) Except as provided in paragraph (b) of this section, set to control or relieve at\nthe correct pressure consistent with the pressure limits of §192.201(a); and\n(4) Properly installed and protected from dirt, liquids, or other conditions that\nmight prevent proper operation.\nNutaaq did not conduct inspections and tests of the Pressure Safety Valve (PSV) that controls\nor provides overpressure protection for the Badami gas transmission pipeline. The pressure\nrelief for Nutaaq’s Badami gas transmission pipeline is located upstream of the tie-in to and on\nHilcorp’s Endicott natural gas pipeline. Hilcorp operates that PSV. However, at the time of\nthe inspection, Hilcorp had not been testing the PSV, which acts as a relief to protect the\nNutaaq Badami gas transmission line during operations.\nThe Badami pipeline transports “makeup” natural gas to the production facility at Badami. The\npipeline is pressurized to approximately 800 psig and is used intermittently.\nFollowing the inspection, Nutaaq and Hilcorp personnel developed a procedure to inspect the\nPSV upstream of the Badami gas transmission line. Hilcorp provided additional records for the\nPSV demonstrating it was in good mechanical condition, reliable, and adequate from a\ncapacity standpoint. These procedures should ensure that the PSV is properly inspected and\ntested and were incorporated into Nutaaq Procedural Manual for Operations, Maintenance, and\nEmergencies subsequent to the inspection.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to\nexceed $209,002 per violation per day the violation persists, up to a maximum of $2,090,022\nfor a related series of violations. For violations occurring prior to November 2, 2015, the\nmaximum penalty may not exceed $200,000 per violation per day, with a maximum penalty\nnot to exceed $2,000,000 for a related series of violations. We have reviewed the\ncircumstances and supporting documents involved in this case, and have decided not to\nconduct additional enforcement action or penalty assessment proceedings at this time. We\nadvise you to correct the items identified in this letter. Failure to do so will result in Nutaaq\nPipeline, LLC 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 5-2019-0001W. 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 portion\nof your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along\nwith the complete original document you must provide a second copy of the document with\nthe portions you believe qualify for confidential treatment redacted and an explanation of why\n\n\n\nyou believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nChris Hoidal\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 R. Guisinger (#156130)","truncated":false,"body_characters":5162}