{"operation":"document","citation":"CPF 52023019NOPV","title":"ENI US OPERATING CO, INC — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2023-12-27","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.310(b)(7), 195.402(a), 195.420(a), 195.452(f)(3), 195.452(h)(1), 195.452(l)(1)(ii), 195.503(a), 195.503(b), 195.505(h), 195.555.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52023019nopv.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52023019nopv.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52023019nopv","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52023019NOPV","body":"Notice of Probable Violation involving ENI US OPERATING CO, INC. PHMSA's enforcement data identifies the cited regulations as 195.310(b)(7),  195.402(a),  195.420(a),  195.452(f)(3),  195.452(h)(1),  195.452(l)(1)(ii),  195.503(a),  195.503(b),  195.505(h),  195.555. The case was opened on 2023-12-27 and is reported as closed as of 2026-02-04. Proposed civil penalty: $65,900. Assessed civil penalty: $61,100. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52023019NOPV_Closure Letter_02042026_(22-236528).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023019NOPV/52023019NOPV_Closure%20Letter_02042026_(22-236528).pdf\n\n52023019NOPV_Closure Letter_02042026_(22-236528)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023019NOPV/52023019NOPV_Closure%20Letter_02042026_(22-236528)_text.pdf\n\n52023019NOPV_Consent Agreement and Order_10142025_(22-236528).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023019NOPV/52023019NOPV_Consent%20Agreement%20and%20Order_10142025_(22-236528).pdf\n\n52023019NOPV_Consent Agreement and Order_10142025_(22-236528)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023019NOPV/52023019NOPV_Consent%20Agreement%20and%20Order_10142025_(22-236528)_text.pdf\n\n52023019NOPV_Operator Response to Notice_01252024_(22-236528).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023019NOPV/52023019NOPV_Operator%20Response%20to%20Notice_01252024_(22-236528).pdf\n\n52023019NOPV_PCP PCO_12272023_(22-236528).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023019NOPV/52023019NOPV_PCP%20PCO_12272023_(22-236528).pdf\n\n52023019NOPV_PCP PCO_12272023_(22-236528)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023019NOPV/52023019NOPV_PCP%20PCO_12272023_(22-236528)_text.pdf\n\n52023019NOPV_Consent Agreement and Order_10142025_(22-236528)_text.pdf\n\nOctober 14, 2025\nVIA ELECTRONIC MAIL TO: Massimo.insulla@eni.com;\nlsaugier@hilcorp.com\nMassimo Insulla\nPresident and Chief Executive Officer\nEni US Operating Co., Inc.\n1200 Smith Street, Suite 1700\nHouston, Texas 77002\nLuke Saugier\nSenior Vice President\nHilcorp Alaska, LLC\n3800 Centerpoint Drive, Suite 1400\nAnchorage, Alaska 99503\nCPF No. 5-2023-019-NOPV\nDear Mr. Insulla and Mr. Saugier:\nEnclosed please find a Consent Order incorporating the terms of the Consent Agreement between\nthe Pipeline and Hazardous Materials Safety Administration (PHMSA), Eni US Operating Co.,\nInc., and Hilcorp Alaska, LLC, which was executed on October 7, 2025. Service of the Consent\nOrder and Consent Agreement by electronic mail is deemed effective upon the date of transmission\nand acknowledgement of receipt, or as otherwise provided under 49 CFR § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nLinda Daugherty\nActing Associate Administrator\nfor Pipeline Safety\nEnclosure: Consent Order and Consent Agreement\ncc: Dustin Hubbard, Director, Western Region, Office of Pipeline Safety, PHMSA\nAnthony Neiser, Esq., Eni US Operating Co. Inc., Anthony.Neiser@eni.com\n\n\n\nD. Hobie Temple, Esq., Hilcorp Alaska, LLC, hobie.temple@hilcorp.com\nJames Curry, Esq., Babst Calland, jcurry@babstcalland.com\nCONFIRMATION OF RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nEni US Operating Co., Inc., ) CPF No. 5-2023-019-NOPV\nRespondent, )\nAnd )\n)\n)\n)\n)\nHilcorp Alaska, LLC. )\n____________________________________)\nCONSENT ORDER\nBy letter dated December 27, 2023, pursuant to 49 CFR § 190.207, the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), issued a Notice of\nProbable Violation, Proposed Civil Penalty, and Proposed Compliance Order (Notice) to Eni US\nOperating Co., Inc. (Eni or Respondent) after an inspection of its then owned Nikaitchuq\nhazardous liquid pipeline assets located in Prudhoe Bay, Alaska (Subject Facilities).\nEni responded to the Notice via letter dated January 25, 2024 (Response). In its Response, Eni\ndid not contest the underlying violations alleged in the Notice, but did contest the assessment of\na civil penalty. Eni provided two supplemental replies to the Notice regarding the proposed\ncompliance order via letters dated March 22, 2024 (Supplemental Response) and June 21, 2024\n(Second Supplemental Response).\nHilcorp Alaska, LLC (Hilcorp Alaska or Company) acquired the Subject Facilities from Eni on\nNovember 1, 2024. Since then, Hilcorp Alaska and PHMSA have met on two occasions to\ndiscuss the Notice and potential actions to address the proposed compliance order items not\nsatisfied through Eni’s Supplemental Responses. As a result of those discussions, PHMSA, Eni,\nand Hilcorp Alaska (collectively, the Parties) have agreed to a Consent Agreement by which\nPHMSA makes findings of violations as alleged in the Notice, Eni will pay a civil penalty in the\namount of $61,100, and Hilcorp Alaska will complete certain compliance actions.\nAccordingly, the Consent Agreement is hereby approved and incorporated by reference into this\nConsent Order issued pursuant to section 190.219. Eni and Hilcorp Alaska are hereby ordered to\ncomply with the terms of the Consent Agreement pursuant to its terms. Pursuant to 49 U.S.C.\n§ 60101, et seq., failure to comply with this Consent Order may result in the assessment of civil\npenalties as set forth in 49 U.S.C. § 60122 and 49 CFR § 190.223, or in referral to the Attorney\nGeneral for appropriate relief in a district court of the United States.\n\n\n\nThe terms and conditions of this Consent Order are effective upon service in accordance with\n49 CFR § 190.5.\n______________________ ______________________\nLinda Daugherty Date Issued\nActing Associate Administrator\nfor Pipeline Safety\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\n)\nIn the Matter of )\n)\nEni US Operating Co., Inc., ) CPF No. 5-2023-019-NOPV\nRespondent, )\n)\nAnd )\n)\nHilcorp Alaska, LLC. )\n____________________________________)\nCONSENT AGREEMENT\nFrom April 25, through April 29, 2022, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of\nTitle 49, United States Code (U.S.C.), conducted an on-site pipeline safety inspection of the\nNikaitchuq hazardous liquid pipeline assets located in Prudhoe Bay, Alaska (Subject Facilities),\nthen owned and operated by Eni US Operating Co. Inc. (Eni or Respondent).1\nAs a result of the inspection, the Director, Western Region, OPS (Director), issued to Eni, by\nletter dated December 27, 2023, a Notice of Probable Violation, Proposed Civil Penalty, and\nProposed Compliance Order (Notice), which also included two warnings pursuant to 49 CFR §\n190.205. In accordance with 49 CFR § 190.207, the Notice proposed finding that Eni committed\nviolations of seven provisions of 49 CFR Part 195 (Items 3, 4, 5, 6, 7, 8, 9), proposed ordering\nRespondent to take certain measures to correct the alleged violations, and proposed assessing a\ncivil penalty of $65,900 for the alleged violation in Item 4. Other probable violations (Items 1,\n2) were brought as warnings and Eni was advised to correct the probable violations or face\npotential future enforcement action.\nEni responded to the Notice by letter dated January 25, 2024 (Response). In its Response, Eni\ndid not contest the alleged underlying violations, but did contest the assessment of a civil\npenalty. Eni also provided additional information regarding each Item. Eni submitted\ndocumentation to PHMSA demonstrating its progress on the Proposed Compliance Order (PCO)\nitems in a supplemental response dated March 22, 2024 (Supplemental Response). Eni\nsubmitted another response addressing Items 3, 4, and 5 of the PCO on June 21, 2024 (Second\nSupplemental Response). Since acquiring the subject assets from Eni, Hilcorp Alaska, LLC\n1 Hilcorp Alaska, LLC acquired the Subject Facilities on November 1, 2024.\n\n\n\n(Hilcorp Alaska or Company) and PHMSA have met on two occasions to discuss the Notice and\npotential actions to address the compliance order items that had not been satisfied through the\nSupplemental Responses. As a result of this correspondence and discussions, and as explained in\nmore detail below, PHMSA, Eni and Hilcorp Alaska (collectively, the Parties) have agreed to a\nConsent Agreement by which PHMSA makes findings of violation for each of the Items alleged\nin the Notice, Eni will pay a civil penalty of $61,100, and Hilcorp Alaska will complete certain\ncompliance actions.\nHaving agreed that settlement of this proceeding will avoid further administrative proceedings or\nlitigation and will serve the public interest by promoting safety and protection of the\nenvironment, pursuant to 49 U.S.C. § 60101, et seq. and 49 CFR Part 190, and upon consent and\nagreement, the Parties hereby agree as follows:\nI. General Provisions\n1. Respondent acknowledges that as the former operator of the pipeline facilities\nsubject to the Notice, Respondent and the pipeline facilities referenced in the Notice are subject\nto the jurisdiction of the Federal pipeline safety laws, 49 U.S.C. § 60101, et seq., and the\nregulations and administrative orders issued thereunder. For purposes of this Consent\nAgreement (Agreement), Respondent acknowledges that it received proper notice of PHMSA’s\naction in this proceeding and that the Notice states claims upon which relief may be granted\npursuant to 49 U.S.C. § 60101, et seq., and the regulations and orders issued thereunder.\n2. Hilcorp Alaska acknowledges that as the current operator of the Subject Facilities,\nthe Company and the pipeline facilities referenced in the Notice are subject to the jurisdiction of\nthe Federal pipeline safety laws, 49 U.S.C. § 60101, et seq., and the regulations and\nadministrative orders issued thereunder.\n3. The Parties agree that all warnings and findings of violation in this Agreement are\nmade as to Eni, as the operator of the Subject Facilities at the time the allegations occurred. The\nParties further agree that findings as to Hilcorp Alaska are limited to its obligations to satisfy the\ncompliance terms in Section V of this Agreement.\n4. After Respondent and Hilcorp Alaska return this signed Agreement to PHMSA,\nthe Agency’s representative will present it to the Acting Associate Administrator for Pipeline\nSafety, recommending that the Acting Associate Administrator adopt the terms of this Agreement\nby issuing an administrative order (Consent Order) incorporating the terms of this Agreement.\nThe terms of this Agreement constitute an offer of settlement until accepted by the Acting\nAssociate Administrator. Once accepted, the Acting Associate Administrator will issue a Consent\nOrder incorporating the terms of this Agreement.\n5. Respondent and Hilcorp Alaska consent to the issuance of the Consent Order and\nhereby waive any further procedural requirements with respect to its issuance. Respondent and\nHilcorp Alaska waive all rights to contest the adequacy of notice, or the validity of the Consent\nOrder or this Agreement, including all rights to administrative or judicial hearings or appeals,\nexcept for the Dispute Resolution provisions set forth herein.\n\n\n\n6. This Agreement shall apply to and be binding upon PHMSA, Respondent, and\nHilcorp Alaska and their respective officers, directors, and employees, and their successors,\nassigns, or other entities or persons otherwise bound by law. Respondent and Hilcorp Alaska\nagree to provide copies of this Agreement and any incorporated work plans and schedules to all\ntheir officers, employees, and agents whose duties might reasonably include compliance with\nthis Agreement.\n7. This Agreement constitutes the final, complete, and exclusive agreement and\nunderstanding between the Parties with respect to the settlement embodied in this Agreement.\nThe Parties acknowledge that there are no representations, agreements or understandings relating\nto settlement other than those expressly contained in this Agreement, except that the terms of this\nAgreement may be construed by reference to the Notice.\n8. Nothing in this Agreement affects or relieves Hilcorp Alaska of its responsibility\nto comply with all applicable requirements of the Federal pipeline safety laws, 49 U.S.C. §\n60101, et seq., and the regulations and orders issued thereunder. Nothing in this Agreement\nalters PHMSA's right of access, entry, inspection, and information gathering or PHMSA's\nauthority to bring enforcement actions against Hilcorp Alaska pursuant to the Federal pipeline\nsafety laws, the regulations and orders issued thereunder, or any other provision of Federal or\nState law.\n9. For all transfers of ownership or operating responsibility of Hilcorp Alaska’s\npipeline assets referenced in the Notice, Hilcorp Alaska will provide a copy of this Agreement to\nthe prospective transferee at least 30 days prior to such transfer. Hilcorp Alaska will provide\nwritten notice of the transfer to the Director no later than 60 days after the transfer occurs.\n10. This Agreement does not waive or modify any Federal, State, or local laws or\nregulations that are applicable to Hilcorp Alaska’s pipeline systems. This Agreement is not a\npermit, or a modification of any permit, under any Federal, State, or local laws or regulations.\nHilcorp Alaska remains responsible for achieving and maintaining compliance with all\napplicable Federal, State, and local laws, regulations, and permits.\n11. This Agreement does not create rights in, or grant any cause of action to, any third\nparty not party to this Agreement. The U.S. Department of Transportation is not liable for any\ninjuries or damages to persons or property arising from acts or omissions of the Parties, or their\nofficers, employees, or agents conducting the work required by this Agreement. Respondent and\nHilcorp Alaska agree to hold harmless the U.S. Department of Transportation, its officers,\nemployees, agents, and representatives from any and all causes of action arising from any acts or\nomissions of Respondent and Hilcorp Alaska or their contractors in carrying out any work\nrequired by this Agreement.\n12. Except as set forth herein, this Agreement does not constitute a finding of\nviolation of any other federal law or regulation and may not be used in any civil proceeding of\nany kind as evidence or proof of any fact, fault or liability, or as evidence of a violation of any\nlaw, rule, regulation, or requirement, except in a proceeding to enforce the provisions of this\nAgreement or in future PHMSA enforcement actions.\n\n\n\nII. Warning Items as to Eni:\n13. Item 1 - 49 CFR §§ 195.310(b)(2),(4), and (7): The Notice alleged that Eni failed\nto maintain proper documentation of a hydrotest performed in 2021. Eni did not contest this\nItem in its Response. This Item was brought as a Warning Item and does not constitute a finding\nof violation. Respondent accepts the warning as alleged in the Notice.\n14. Item 2 - 49 CFR § 195.402(a): The Notice alleged that Eni did not adequately\ndocument review of its O&M manual. Eni did not contest this Item in its Response. This Item\nwas brought as a Warning Item and does not constitute a finding of violation. Respondent\naccepts the warning as alleged in the Notice.\n15. For Warning Items 1 and 2, if OPS finds a violation of these provisions in a\nsubsequent inspection, Hilcorp Alaska may be subject to future enforcement action.\nIII. Findings of Violation as to Eni:\n16. Item 3 - 49 CFR § 195.420(a): The Notice alleged that Eni failed to properly\nmaintain a pair of shut down valves on the 10-inch sales oil pipeline and the 2-inch diesel\npipeline (KPP01-SDV-12021 and D2P03-SDV-53601, respectively). Eni did not contest the\nallegation of violation in Item 3 of the Notice. As such, PHMSA finds that Eni violated 49 CFR\n§ 195.420(a). After the acquisition, Hilcorp Alaska conducted inspections and maintenance of\nboth valves. The Company provided records of these recent inspections and maintenance\nactivities to demonstrate that these valves have been inspected and are in good working order.\nHilcorp Alaska has satisfactorily fulfilled the requirements of the proposed compliance order for\nthis Item. No further action is necessary as it relates to this Item.\n17. Item 4 - 49 CFR § 195.452(f)(3): The Notice alleged that Eni failed to integrate\nall available information in its 2021 risk analysis for the 2-inch diesel line and 10-inch sales oil\nline, prepared in relation to its Integrity Management Program. Eni did not contest this\nallegation of violation. As such, PHMSA finds that Eni violated 49 CFR § 195.452(f)(3). Eni\nlater submitted updated risk analysis information, which PHMSA found adequate to satisfy the\nrequirements of the related PCO. No further compliance action is necessary as it relates to this\nItem.\n18. Item 5 - 49 CFR § 195.452(h)(1): The Notice alleged that Eni failed to take\nprompt action to address an anomalous condition on its 10-inch sales line. Specifically, the\nNotice alleged that the line was at times partially submerged at a cased road crossing and subject\nto potential corrosion as a result. Eni did not contest this allegation of violation. As such,\nPHMSA finds that Eni violated 49 CFR § 195.452(h)(1).\n19. Item 6 – 49 CFR § 195.452(I)(1)(ii): The Notice alleged that Eni failed to\ndocument certain decisions and analysis it made with respect to recommended preventative and\nmitigative measures when implementing its Integrity Management Program. Eni did not contest\nthis allegation of violation. As such, PHMSA finds that Eni violated 49 CFR § 195.452(I)(1)(ii).\n\n\n\nEni submitted updated information on its Integrity Management Program, which PHMSA found\nadequate to satisfy the requirements of the related PCO. No further compliance action is\nnecessary as it relates to this Item.\n20. Item 7 – 49 CFR §§ 195.503(a) and (b): The Notice alleged that Eni failed to\nensure through evaluation that individuals performing certain valve-related covered tasks were\nqualified. Eni did not contest this allegation of violation. As such, PHMSA finds that Eni\nviolated 49 CFR §§ 195.503(a) and (b). Eni submitted updated operator qualification\ninformation, which PHMSA found adequate to satisfy the requirements of the related PCO. No\nfurther compliance action is necessary as it relates to this Item.\n21. Item 8 – 49 CFR § 195.505(h): The Notice alleged that Eni qualified personnel\nwithout adequate documentation to demonstrate adherence to its procedure for completing\noperator qualification evaluations remotely. Eni did not contest this allegation of violation. As\nsuch, PHMSA finds that Eni violated 49 CFR § 195.505(h). Eni submitted additional and\nclarifying information on its operator qualification program, which PHMSA found adequate to\nsatisfy the requirements of the related PCO. No further compliance action is necessary as it\nrelates to this Item.\n22. Item 9 – 49 CFR § 195.555: The Notice alleged that Eni failed to require and\nverify that supervisors maintain a thorough knowledge of their corrosion control procedures. Eni\ndid not contest this allegation of violation. As such, PHMSA finds that Eni violated 49 CFR §\n195.555. Eni submitted signed records documenting the required knowledge base of supervisors,\nwhich PHMSA found adequate to satisfy the requirements of the related PCO. No further\ncompliance action is necessary as it relates to this Item.\n23. Item 3, 4, 5, 6, 7, 8, and 9 will be considered by PHMSA as prior offenses in any\nfuture PHMSA enforcement action taken against Eni.\nIV. Civil Penalty as to Eni:\n24. Item 4 - 49 CFR § 195.452(f)(3): The Notice also proposed a civil penalty of\n$65,900 for the alleged violation in Item 4. PHMSA later adjusted the penalty to $61,100 due to\na change in policy.2 While Eni originally contested the proposed civil penalty, for the purposes\nof this Agreement Eni agrees to pay the adjusted civil penalty of $61,100.\n25. Eni will pay a total civil penalty in the amount of $61,100 pursuant to the\npayment instructions of 49 CFR § 190.227(a), to be paid in full no later than 30 days from the\nEffective Date of this Agreement.\n2 PHMSA, via letter dated June 3, 2025, notified Eni and Hilcorp Alaska that its new proposed civil penalty\ncalculation policy reduces the proposed civil penalty from $65,900 to $61,100.\n\n\n\nV. Compliance Terms as to Hilcorp Alaska:\n26. Item 5 - 49 CFR § 195.452(h)(1): The Notice proposed certain compliance order\nactions to address the non-compliance alleged in the Notice. Hilcorp Alaska and PHMSA\ndiscussed this Item and Hilcorp Alaska provided additional information regarding the subject\npipeline crossing. Hilcorp Alaska agrees to undertake the following corrective measures\nregarding this Item.\ni. Within ten (10) business days of entry of the Settlement Agreement, prepare a\nsummary report, using conservative assumptions and data from relevant operational\nexperience on the 10-inch sales line and other similar North Slope pipelines,\nestimating the corrosion growth rates for potential external features at the 10-inch\nsales line crossing.\nii. Include an evaluation of the external corrosion threat on the 10-inch sales line at the\ncrossing in its next risk analysis prepared pursuant to the Integrity Management\nprogram. Within the evaluation, indicate if any recent seasonal flooding was\nobserved and the duration of time the water was contacting the pipeline. Within\nninety (90) days of completion of that risk analysis, provide a summary of the results,\nspecifically with regard to the external corrosion threat at the crossing.\niii. Within sixty (60) days of providing the summary report in paragraph (ii), provide a\nreport indicating whether the findings of the risk analysis warrant any adjustment of\nthe ILI assessment interval for the 10-inch sales line, currently planned for June 2027.\nVI. Enforcement:\n27. This Agreement is subject to all enforcement authorities available to PHMSA\nunder 49 U.S.C. § 60101, et seq., and 49 CFR Part 190, including administrative civil penalties\nunder 49 U.S.C. § 60122, of up to $272,926 per violation for each day the violation continues and\nreferral of the case to the Attorney General for judicial enforcement, if PHMSA determines that\nRespondent or Hilcorp Alaska has not complied with its respective obligations under this\nAgreement in accordance with the determinations made by the Director, or in accordance with\ndecisions of the Associate Administrator if resolved pursuant to the Dispute Resolution process\nherein. In no event will a Party be subject to enforcement actions or penalties related to the\nfailure of the other Party to fulfill its obligations under this Agreement. The maximum civil\npenalty amounts are adjusted annually for inflation. See 49 CFR § 190.223. All corrective\nmeasures and associated schedules set forth or referenced in Section V (Compliance Terms) are\nautomatically incorporated into this Agreement and are enforceable in the same manner.\nVII. Review and Approval Process:\n28. With respect to any submission under Section V (Compliance Terms) of this\nAgreement that requires the approval of the Director, the Director may: (a) approve, in whole or\nin part, the submission; (b) approve the submission on specified, reasonable conditions; (c)\ndisapprove, in whole or in part, the submission; or (d) any combination of the foregoing. If the\nDirector approves, approves in part, or approves with conditions, Hilcorp Alaska will take all\n\n\n\nactions as approved by the Director, subject to Hilcorp Alaska’s right to invoke the dispute\nresolution procedures with respect to any conditions the Director identifies. If the Director\ndisapproves all or any portion of the submission, the Director will provide the Parties written\nnotice of the deficiencies. Hilcorp Alaska will correct all deficiencies within the time specified\nby the Director and resubmit for approval.\nVIII. Dispute Resolution:\n29. The Director and the Parties will informally attempt to resolve any disputes\narising under this Agreement, including any decision of the Director under the terms of Section\nV (Compliance Terms). If the Parties and the Director are unable to informally resolve the\ndispute within 15 calendar days after the dispute is first raised, in writing, to the Director, the\nParties may submit a written request for a determination resolving the dispute from the Associate\nAdministrator. Such request must be made in writing and provided to the Director, counsel for\nthe Western Region, and to the Associate Administrator, no later than 10 calendar days from the\n15-day deadline for informal resolution referenced in this paragraph. Along with its request, the\nParties must provide the Associate Administrator with all information it believes is relevant to\nthe dispute. Decisions of the Associate Administrator under this paragraph will constitute final\nagency action. The existence of a dispute and PHMSA’s consideration of matters placed in\ndispute will not excuse, toll, or suspend any term or timeframe for completion of any work to be\nperformed under this Agreement during the pendency of the dispute resolution process, except as\nagreed by the Director or Associate Administrator in writing.\nIX. Effective Date:\n30. The term “Effective Date,” as used herein, is the date on which the Consent Order\nis issued by the Associate Administrator incorporating the terms of this Agreement.\nX. Recordkeeping and Information Disclosure:\n31. Unless otherwise required in this Agreement, Hilcorp Alaska agrees to maintain\nrecords demonstrating compliance with all requirements of this Agreement for a period of at\nleast five (5) years following completion of all work to be performed, unless a longer period of\ntime is required pursuant to 49 CFR parts 190-199. For any reports, plans, or other deliverables\nrequired to be submitted to PHMSA pursuant to this Agreement, Hilcorp Alaska may assert a\nclaim of business confidentiality or other protections applicable to the release of information by\nPHMSA, covering part or all of the information required to be submitted to PHMSA pursuant to\nthis Agreement in accordance with 49 CFR Part 7. Hilcorp Alaska must mark the claim of\nconfidentiality in writing on each page and include a statement specifying the grounds for each\nclaim of confidentially. PHMSA determines release of any information submitted pursuant to\nthis Agreement in accordance with 49 CFR Part 7, the Freedom of Information Act, 5 U.S.C. §\n552, DOT and PHMSA policies, and other applicable regulations and Executive Orders.\nXI. Modification:\n32. The terms of this Agreement may be modified by mutual agreement of the Parties.\nSuch modifications must be in writing and signed by PHMSA, Respondent, and Hilcorp Alaska.\n\n\n\nXII. Termination:\n33. This Agreement will remain in effect until the Civil Penalty in Section IV and the\nCompliance Terms in Section V are satisfied, as determined by the Director. The Agreement\nshall not terminate until the Director confirms, in writing, that the Agreement is terminated in\naccordance with this paragraph. Nothing in this Agreement prevents Eni and Hilcorp Alaska\nfrom completing any of their obligations earlier than the deadlines provided for in this\nAgreement.\nXIII. Ratification:\n34. The Parties’ undersigned representatives certify that they are fully authorized to\nenter into the terms and conditions of this Agreement and to execute and legally bind such party\nto this document.\n35. The Parties hereby agree to all findings, conditions, and terms of this Agreement.\n[Signature Lines on Following Page]\n\n\n\nFor Hilcorp Alaska:\n___________________________________\nLuke Saugier, Senior Vice President\n________________________\nDate\nFor Eni:\n___________________________________\nMassimo Insulla, President and CEO\n________________________\nDate\nFor PHMSA:\n________________________________________\nDirector, Western Region, Office of Pipeline Safety\n________________________\nDate\n\n52023019NOPV_Closure Letter_02042026_(22-236528)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nVIA ELECTRONIC MAIL TO: Massimo.Insulla@eni.com;\nlsaugier@hilcorp.com\nMassimo Insulla\nPresident and Chief Executive Officer\nEni US Operating Co., Inc.\n1200 Smith Street, Suite 1700\nHouston, Texas 77002\nLuke Saugier\nSenior Vice President\nHilcorp Alaska, LLC\n3800 Centerpoint Drive, Suite 1400\nAnchorage, AK 99503\n12300 W. Dakota Ave., Suite 340\nLakewood, CO 80228\nCPF 5-2023-019-NOPV\nClosure Letter\nDear Mr. Insulla and Mr. Saugier:\nOn October 14, 2025, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued to Eni US Operating Co., Inc and Hilcorp Alaska, LLC a Consent Agreement in the\nabove-referenced case. This Order included a Compliance Order and Civil Penalty assessment.\nBased on our review of the documentation you provided and confirmation of payment of the\ncivil penalty, it has been determined that both entities have complied with the terms of this\nOrder.\nAccordingly, this case is now closed, and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nDustin Hubbard\nDirector, Western Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n\n\n\ncc: PHP-60 Compliance Registry\nPHP-500 M. Yeager (22-236528)","truncated":false,"body_characters":29537}