{"operation":"document","citation":"CPF 520195011M","title":"ENI US OPERATING CO, INC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-11-12","effective_on":null,"summary":"CLOSED notice of amendment citing 195.446(h)(1), 195.446(h)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520195011m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520195011m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520195011m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520195011M","body":"Notice of Amendment involving ENI US OPERATING CO, INC. PHMSA's enforcement data identifies the cited regulations as 195.446(h)(1),  195.446(h)(2). The case was opened on 2019-11-12 and is reported as closed as of 2020-04-16. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520195011M_Closure Letter_04162020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520195011M/520195011M_Closure%20Letter_04162020.pdf\n\n520195011M_Closure Letter_04162020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520195011M/520195011M_Closure%20Letter_04162020_text.pdf\n\n520195011M_Notice of Amendment_11122019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520195011M/520195011M_Notice%20of%20Amendment_11122019.pdf\n\n520195011M_Notice of Amendment_11122019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520195011M/520195011M_Notice%20of%20Amendment_11122019_text.pdf\n\n520195011M_Operator Response to Notice_12102019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520195011M/520195011M_Operator%20Response%20to%20Notice_12102019.pdf\n\n520195011M_Closure Letter_04162020_text.pdf\n\nVIA E-MAIL TO MR. LUCA PELLICCIOTTA\nApril 16, 2020\nMr. Luca Pellicciotta\nVice President, Technical Services\nEni US Operating Co., Inc.\n1200 Smith Street, Suite 1700\nHouston TX 77002\nCPF 5-2019-5011M\nClosure Letter\nDear Mr. Pellicciotta:\nFrom March 4 through 8, 2019 and March 19, 2019, a representative from the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States\nCode, conducted an on-site pipeline safety inspection of Eni US Operating Co., Inc.’s procedures\nfor Control Room management on the North Slope of Alaska and in Anchorage, Alaska. As a\nresult of the inspection, Eni US Operating Co., Inc. was issued a Notice of Amendment on\nNovember 12, 2019, which proposed amendment of your procedures.\nEni US Operating Co., Inc. submitted its amended procedures on March 16 and 31, 2020. My\nstaff reviewed the amended procedures, and it appears that the inadequacies outlined in this\nNotice of Amendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Owens (# 164788)\nLarry Burgess (via electronic mail)\nDavid Hart (via electronic mail)\nCraig Keppers (via electronic mail)\nRich Vicente (via electronic mail)\nMarty Slade (via electronic mail)\n\n520195011M_Notice of Amendment_11122019_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 12, 2019\nMr. Luca Pellicciotta\nVice President, Technical Services\nEni US Operating Co., Inc.\n1200 Smith Street, Suite 1700\nHouston TX 77002\nCPF 5-2019-5011M\nDear Mr. Pellicciotta:\nFrom March 4 through 8, 2019 and March 19, 2019, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code, inspected Eni US Operating Co., Inc.’s (Eni or Operator) procedures for Control\nRoom Management on the North Slope of Alaska and in Anchorage, Alaska.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nEni US Operating Co., Inc.’s plans or procedures, as described below:\n\n\n\n1. § 195.446 Control room management.\n(a) ….\n(h) Training. Each operator must establish a controller training program and\nreview the training program content to identify potential improvements at least\nonce each calendar year, but at intervals not to exceed 15 months. An operator's\nprogram must provide for training each controller to carry out the roles and\nresponsibilities defined by the operator. In addition, the training program must\ninclude the following elements:\n(1) Responding to abnormal operating conditions likely to occur simultaneously\nor in sequence;\nEni’s Control Room Management Program procedures (version 1.0, dated 2/10/2019) were\ninadequate because they lacked a listing of abnormal operating conditions likely to occur\nsimultaneously or in sequence, and lacked training in responding to the identified abnormal\noperating conditions likely to occur simultaneously or in sequence.\n2. § 195.446 Control room management.\n(a) ….\n(h) Training. Each operator must establish a controller training program and\nreview the training program content to identify potential improvements at least\nonce each calendar year, but at intervals not to exceed 15 months. An operator's\nprogram must provide for training each controller to carry out the roles and\nresponsibilities defined by the operator. In addition, the training program must\ninclude the following elements:\n(1) ….\n(2) Use of a computerized simulator or non-computerized (tabletop) method for\ntraining controllers to recognize abnormal operating conditions;\nEni’s Control Room Management Program procedures (version 1.0, dated 2/10/2019) were\ninadequate because they failed to require the use of a computerized simulator or non-\ncomputerized (tabletop) method for training controllers to recognize abnormal operating\nconditions.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document\n2\n\n\n\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in\nthis Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as\nalleged in this Notice without further notice to you and to issue an Order Directing\nAmendment. If your plans or procedures are found inadequate as alleged in this Notice, you\nmay be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. §\n190.206). If you are not contesting this Notice, we propose that you submit your amended\nprocedures to my office within 30 days of receipt of this Notice. This period may be extended\nby written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that Eni US Operating Co., Inc. maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Dustin Hubbard, Director,\nWestern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 5-2019-5011M and, for each document you\nsubmit, please provide a copy in electronic format whenever possible.\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 J. Owens (# 164788)\nCraig Keppers (via electronic mail)\nRich Vicente (via electronic mail)\nMarty Slade (via electronic mail)\n3","truncated":false,"body_characters":7884}