NUTAAQ PIPELINE, LLC — Warning Letter

52023057WL_Warning Letter_12192023_(23-265655)_text.pdf, page 1Official PDFWARNING LETTER VIA ELECTRONIC MAIL TO: DPASCAL@GLACIEROIL.COM December 19, 2023 Mr. David Pascal Chief Operating Officer Nutaaq Pipeline, LLC 188 W. Northern Lights Blvd, Suite 510 Anchorage, AK 99503 CPF 5-2023-057-WL Dear Mr. Pascal: On July 31, 2023, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected Nutaaq Pipeline, LCC’s (Nutaaq or Operator) Badami offshore gas gathering pipeline in Anchorage, Alaska. As a result of the inspection, it is alleged that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and the probable violation is: 1. § 192.161 Supports and anchors. (a) . . . .…#

52023057WL_Warning Letter_12192023_(23-265655)_text.pdf, page 2(c) Each support or anchor on an exposed pipeline must be made of durable, noncombustible material and must be designed and installed as follows:... Nutaaq failed to use durable, noncombustible material as a support or anchor on its exposed pipeline as required. Specifically, photos presented by the Operator during the inspection revealed that wood cribbing was used to support the upstream anchors, which is not permitted pursuant to § 192.161(c). Therefore, Nutaaq failed to use durable, noncombustible material as an anchor on its pipeline as required by the pipeline safety regulations. Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related series of violations. For violation occurring on or after March 21, 2022, and before January 6, 2023, the maximum penalty may not exceed $239,142 per violation per day the violation persists, up to a maximum of $2,391,142 for a related series of violations. For violation occurring on or after May 3, 2021, and before March 21, 2022, the maximum penalty may not exceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related series of violations. For violation occurring on or after January 11, 2021, and before May 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for a related series of violations. For violation occurring on or after July 31, 2019, and before January 11, 2021, the maximum penalty may not exceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related 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. 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 Nutaaq Pipeline, LLC being subject to additional enforcement action.#

52023057WL_Warning Letter_12192023_(23-265655)_text.pdf, page 3No reply to this letter is required. If you choose to reply in your correspondence, please refer to CPF 5-2023-057-WL. 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, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration cc: PHP-60 Compliance Registry PHP-500 J. Gano, C. Dolchok (#23-265655)#