# ENI US OPERATING CO, INC — Warning Letter

- **operation:** document
- **citation:** CPF 520195010W
- **title:** ENI US OPERATING CO, INC — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2019-11-12
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.446(c)(3), 195.446(e)(5), 195.446(h).
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520195010w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520195010W
**body:**

Warning Letter involving ENI US OPERATING CO, INC. PHMSA's enforcement data identifies the cited regulations as 195.446(c)(3),  195.446(e)(5),  195.446(h). The case was opened on 2019-11-12 and is reported as closed as of 2019-11-12. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520195010W_Warning Letter_11122019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520195010W/520195010W_Warning%20Letter_11122019.pdf

520195010W_Warning Letter_11122019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520195010W/520195010W_Warning%20Letter_11122019_text.pdf

520195010W_Warning Letter_11122019_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
November 12, 2019
Mr. Luca Pellicciotta
Vice President, Technical Services
Eni US Operating Co., Inc.
1200 Smith Street, Suite 1700
Houston TX 77002
CPF 5-2019-5010W
Dear Mr. Pellicciotta:
From March 4 through 8, 2019, and on March 19, 2019, a representative of the Pipeline and
Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States
Code (U.S.C.), inspected Eni US Operating Co., Inc.’s (Eni) Nikaitchuq Oil Transit Line and Offshore
Diesel Fuel Supply Line on the North Slope of Alaska.
As a result of the inspection, it is alleged that Eni has committed probable violations of the Pipeline
Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected and the
probable violations are:
1. § 195.446 Control room management.
(a) .…
(c) Provide adequate information. Each operator must provide its controllers with the
information, tools, processes and procedures necessary for the controllers to carry out
the roles and responsibilities the operator has defined by performing each of the
following:
(3) Test and verify an internal communication plan to provide adequate means for
manual operation of the pipeline safely, at least once each calendar year, but at intervals
not to exceed 15 months;



Eni did not test or verify the documented internal communication plan for manual operation of the
pipeline. Eni was unable to provide testing or verification records.
2. § 195.446 Control room management.
(a) ….
(e) Alarm management. Each operator using a SCADA system must have a written
alarm management plan to provide for effective controller response to alarms. An
operator's plan must include provisions to:
(5) Monitor the content and volume of general activity being directed to and required of
each controller at least once each calendar year, but at intervals not exceeding 15
months, that will assure controllers have sufficient time to analyze and react to incoming
alarms;
Eni did not perform an analysis to determine if controllers performance is currently adequate. Eni was
unable to provide records demonstrating annual compliance of an analysis to determine if controllers’
performance was adequate.
3. § 195.446 Control room management.
(a) ….
(h) Training. Each operator must establish a controller training program and review
the training program content to identify potential improvements at least once each
calendar year, but at intervals not to exceed 15 months. An operator's program must
provide for training each controller to carry out the roles and responsibilities defined by
the operator. In addition, the training program must include the following elements:
(1) Responding to abnormal operating conditions likely to occur simultaneously or in
sequence;
(2) Use of a computerized simulator or non-computerized (tabletop) method for training
controllers to recognize abnormal operating conditions;
(3) Training controllers on their responsibilities for communication under the
operator's emergency response procedures;
(4) Training that will provide a controller a working knowledge of the pipeline system,
especially during the development of abnormal operating conditions;
(5) For pipeline operating setups that are periodically, but infrequently used, providing
an opportunity for controllers to review relevant procedures in advance of their
application; and
(6) Control room team training and exercises that include both controllers and other
individuals, defined by the operator, who would reasonably be expected to operationally
collaborate with controllers (control room personnel) during normal, abnormal or
emergency situations. Operators must comply with the team training requirements
under this paragraph no later than January 23, 2018.
Eni failed to review the controller training program content to identify potential improvements at least
once each calendar year, but at intervals not to exceed 15 months. Eni was unable to provide records
that demonstrated that the review occurred annually.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related
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series of violations. For violation occurring on or after November 27, 2018 and before July 31, 2019,
the maximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to
exceed $2,132,679. For violation occurring on or after November 2, 2015 and before November 27,
2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum penalty
not to exceed $2,090,022. For violations occurring prior to November 2, 2015, 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 items identified in this letter.
Failure to do so will result in Eni US Operating Co., Inc. 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
5-2019-5010W. 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,
Dustin Hubbard
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 J. Owens (# 164788)
Craig Keppers (via electronic mail)
Rich Vicente (via electronic mail)
Marty Slade (via electronic mail)
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