ENI US OPERATING CO, INC — Notice of Amendment

party submissionOfficial PDF520195011M_Operator Response to Notice_12102019.pdf#

520195011M_Closure Letter_04162020_text.pdf, page 1Official PDFVIA E-MAIL TO MR. LUCA PELLICCIOTTA April 16, 2020 Mr. Luca Pellicciotta Vice President, Technical Services Eni US Operating Co., Inc. 1200 Smith Street, Suite 1700 Houston TX 77002 CPF 5-2019-5011M Closure Letter Dear Mr. Pellicciotta: From March 4 through 8, 2019 and March 19, 2019, a representative from the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site pipeline safety inspection of Eni US Operating Co., Inc.’s procedures for Control Room management on the North Slope of Alaska and in Anchorage, Alaska. As a result of the inspection, Eni US Operating Co., Inc. was issued a Notice of Amendment on November 12, 2019, which proposed amendment of your procedures. Eni US Operating Co., Inc. submitted its amended procedures on March 16 and 31, 2020. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Dustin Hubbard Director, Western Region Pipeline and Hazardous Materials Safety Administration cc: PHP-60 Compliance Registry PHP-500 J. Owens (# 164788) Larry Burgess (via electronic mail) David Hart (via electronic mail) Craig Keppers (via electronic mail) Rich Vicente (via electronic mail) Marty Slade (via electronic mail)#

520195011M_Notice of Amendment_11122019_text.pdf, page 1Official PDFNOTICE OF AMENDMENT 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 5-2019-5011M Dear Mr. Pellicciotta: From March 4 through 8, 2019 and March 19, 2019, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Eni US Operating Co., Inc.’s (Eni or Operator) procedures for Control Room Management on the North Slope of Alaska and in Anchorage, Alaska. On the basis of the inspection, PHMSA has identified the apparent inadequacies found within Eni US Operating Co., Inc.’s plans or procedures, as described below:#

520195011M_Notice of Amendment_11122019_text.pdf, page 21. § 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; Eni’s Control Room Management Program procedures (version 1.0, dated 2/10/2019) were inadequate because they lacked a listing of abnormal operating conditions likely to occur simultaneously or in sequence, and lacked training in responding to the identified abnormal operating conditions likely to occur simultaneously or in sequence. 2. § 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) …. (2) Use of a computerized simulator or non-computerized (tabletop) method for training controllers to recognize abnormal operating conditions; Eni’s Control Room Management Program procedures (version 1.0, dated 2/10/2019) were inadequate because they failed to require the use of a computerized simulator or non- computerized (tabletop) method for training controllers to recognize abnormal operating conditions. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings. Please refer to this document and note the response options. 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 2#

520195011M_Notice of Amendment_11122019_text.pdf, page 3you 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). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that Eni US Operating Co., Inc. maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Dustin Hubbard, Director, Western Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 5-2019-5011M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Dustin Hubbard Director, Western Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings 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) 3#