{"operation":"document","citation":"CPF 520100003W","title":"NORTH SLOPE BOROUGH ENERGY MANAGEMENT — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-01-04","effective_on":null,"summary":"CLOSED warning letter citing 192.465(a), 192.605(a), 192.705(b), 192.706, 192.739(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520100003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520100003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520100003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520100003W","body":"Warning Letter involving NORTH SLOPE BOROUGH ENERGY MANAGEMENT. PHMSA's enforcement data identifies the cited regulations as 192.465(a),  192.605(a),  192.705(b),  192.706,  192.739(a). The case was opened on 2010-01-04 and is reported as closed as of 2010-01-04. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520100003W_warning letter_01042010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520100003W/520100003W_warning%20letter_01042010.pdf\n\n520100003W_warning letter_01042010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520100003W/520100003W_warning%20letter_01042010_text.pdf\n\n520100003W_warning letter_01042010_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 4, 2010\nThe Honorable Edward S. Itta\nMayor\nNorth Slope Borough\nP.O. Box 69\nBarrow, Alaska 99723\nCPF 5-2010-0003W\nDear Mayor Itta:\nBetween October 26 and 28, 2009, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected the North Slope\nBoroughs (NSB) procedures, records and facilities in Barrow, Alaska.\nAs a result of the inspection, it appears that you have committed probable violations of the Pipeline Safety\nRegulations, Title 49, Code of Federal Regulations. The items inspected and the probable violations are:\n1. §192.465 External corrosion control: Monitoring.\n(a) Each pipeline that is under cathodic protection must be tested at least once each\ncalendar year, but with intervals not exceeding 15 months, to determine whether the cathodic\nprotection meets the requirements of §192.463.\nThe NSB failed to provide any records of pipe-to-soil monitoring at intervals of 1 per year not to exceed\n15 months on the Barrow transmission line.\n\n\n\n2. §192.605 Procedural manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of written\nprocedures for conducting operations and maintenance activities and for emergency response.\nFor transmission lines, the manual must also include procedures for handling abnormal\noperations. This manual must be reviewed and updated by the operator at intervals not\nexceeding 15 months, but at least one each calendar year. This manual must be prepared\nbefore operations of a pipeline system commence. Appropriate parts of the manual must be\nkept at locations where operations and maintenance activities are conducted.\nThe NSB failed to provide a manual of written procedures for conducting operations and maintenance\nactivities and for emergency response for the Barrow transmission line. The NSB did submit an O&M\nmanual that was written for the Nuiqsut pipeline. Many of the same procedures that apply to the Nuiqsut\ngas pipeline also apply to the Barrow gas transmission pipeline. However, many procedures cannot be\nwritten in a generic form and must be site specific to the Barrow gas pipeline.\n3. §192.705 Transmission lines: Patrolling.\n(a) Each operator shall have a patrol program to observe surface conditions on and adjacent to\nthe transmission line right-of-way for indications of leaks, construction activity, and other\nfactors affecting safety and operation.\n(b) The frequency of patrols is determined by the size of the line, the operating pressures, the\nclass location, terrain, weather, and other relevant factors, but intervals between patrols may\nnot be longer than prescribed in the following table:\nMaximum interval between patrols\nClass loca-\ntion of line\nAt highway and rail-\nroad crossing At all other places\n3............... 4 ½ months; but at least\nfour times each\ncalendar year.\n7 ½ months; but at least\ntwice each calendar\nyear.\n(c) Methods of patrolling include walking, driving, flying or other appropriate means of\ntraversing the right-of-way.\nThe NSB failed to provide records of patrolling at intervals of 2 per year not to exceed 7 ½ months in the\nClass 3 locations on the Barrow transmission line.\n4. §192.706 Transmission lines: Leakage surveys\nLeakage surveys of a transmission line must be conducted at intervals not exceeding 15 months,\nbut at least once each calendar year.\nThe NSB failed to provide any records of leak surveys at intervals of 1 per year not to exceed 15 months\nin the Class 3 locations on the Barrow transmission line. The transmission line is odorized.\n5. §192.739 Pressure limiting and regulating stations: Inspection and testing.\n2\n\n\n\n(a) Each pressure limiting station, relief device (except rupture discs), and Pressure regulating\nstation and its equipment must be subjected at intervals not exceeding 15 months, but at least\nonce each calendar year, to inspections and tests to determine that it is–\n(1) In good mechanical condition;\n(2) Adequate from the standpoint of capacity and reliability of operation for the service in\nwhich it is employed;\n(3) Except as provided in paragraph (b) of this section, set to control or relieve at the correct\npressure consistent with the pressure limits of §192.201(a); and\n(4) Properly installed and protected from dirt, liquids, or other conditions that might prevent\nproper operation.\nThe NSB failed to provide records for PCV-214A, PCV-214B, PCV-237A, PCV-237B, PCV-1 and PCV-\n2 for the year 2008 at the Primary and Secondary gas handling facilities.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000 for each\nviolation for each day the violation persists up to a maximum of $1,000,000 for any related series of\nviolations. We have reviewed the circumstances and supporting documents involved in this case, and\nhave decided not to conduct additional enforcement action or penalty assessment proceedings at this time.\nWe advise you to correct the item(s) identified in this letter. Failure to do so will result in the North\nSlope Borough being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2010-0003W and send all responses to my attention at 222 W. 7th Ave. #200, PO Box 37,\nAnchorage, Alaska 99513. For each document you submit, please provide a copy in electronic format\nwhenever possible. Be advised that all material you submit in response to this enforcement action is\nsubject to being made publicly available. If you believe that any portion of your responsive material\nqualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for confidential\ntreatment redacted and an explanation of why you believe the redacted information qualifies for\nconfidential treatment under 5 U.S.C. 552(b).\nSincerely,\nDennis Hinnah\nDeputy Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Strawn (#127263)\nMarvin Olson, Director, North Slope Borough\n3","truncated":false,"body_characters":6980}