# NORTH SLOPE BOROUGH ENERGY MANAGEMENT — Notice of Amendment

- **operation:** document
- **citation:** CPF 520110017M
- **title:** NORTH SLOPE BOROUGH ENERGY MANAGEMENT — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2011-10-25
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 192.616(a), 192.616(b), 192.616(c).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520110017m.json
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520110017m
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520110017M
**body:**

Notice of Amendment involving NORTH SLOPE BOROUGH ENERGY MANAGEMENT. PHMSA's enforcement data identifies the cited regulations as 192.616(a),  192.616(b),  192.616(c). The case was opened on 2011-10-25 and is reported as closed as of 2012-07-03. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520110017M_closure letter_07032012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520110017M/520110017M_closure%20letter_07032012.pdf

520110017M_closure letter_07032012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520110017M/520110017M_closure%20letter_07032012_text.pdf

520110017M_notice of amendment_10252011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520110017M/520110017M_notice%20of%20amendment_10252011.pdf

520110017M_notice of amendment_10252011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520110017M/520110017M_notice%20of%20amendment_10252011_text.pdf

520110017M_operator response_03232012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520110017M/520110017M_operator%20response_03232012.pdf

520110017M_notice of amendment_10252011_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
October 25, 2011
Mr. Kent Grinage
Director of Public Works
North Slope Borough
P.O. Box 1120
Barrow, Alaska 99723
CPF 5-2011-0017M
Dear Mr. Grinage:
On October 5, 2011, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected
North Slope Borough’s (NSB) procedures for Public Awareness Program (PAP) in Barrow,
Alaska.
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
North Slope Borough’s plans or procedures, as described below:
1. §192.616 Public Awareness
(a) Except for an operator of a master meter or petroleum gas system covered
under paragraph (j) of this section, each pipeline operator must develop and
implement a written continuing public education program that follows the
guidance provided in the American Petroleum Institute's (API) Recommended
Practice (RP) 1162 (incorporated by reference,
NSB’s PAP does not contain a written statement of management commitment.
NSB’s PAP must be amended to meet the requirements of Management Support,
section 2.5 of API 1162.
2. §192.616 Public Awareness
(b) The operator's program must follow the general program recommendations



of API RP 1162 and assess the unique attributes and characteristics of the
operator's pipeline and facilities
NSB’s PAP does not capture the unique hazards associated with non-odorized natural
gas being transported in the Nuiqsut Transmission Line.
3. §192.616 Public Awareness
(c) The operator must follow the general program recommendations, including
baseline and supplemental requirements of API RP 1162, unless the operator
provides justification in its program or procedural manual as to why compliance
with all or certain provisions of the recommended practice is not practicable and
not necessary for safety.
A. NSB’s PAP does not include the public officials in the Nuiqsut System Program
or justify why they were not included.
B. NSB’s PAP does list the frequency of contact with stakeholders for the
distribution system.
C. NSB’s PAP indicates that NSB is a member of the Alaska One Call system. This
was not the case at the time of inspection. NSB’s PAP must state how line locates and
leaks are to be reported.
D. NSB’s PAP does not specify how annual audits will be conducted and evaluated.
E. NSB’s PAP does not specify how 4 year program evaluations will be conducted
and evaluated.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. 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
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). 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 a Final Order.
If, after opportunity for a hearing, 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
2



inadequacies (49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that
you submit your amended procedures to my office within 90 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 North Slope Borough maintain documentation of the
safety improvement costs associated with fulfilling this Notice of Amendment
(preparation/revision of plans, procedures) and submit the total to Dennis Hinnah, Deputy
Director, Western Region, Pipeline and Hazardous Materials Safety Administration. In
correspondence concerning this matter, please refer to CPF 5-2011-0017M and, for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
Dennis Hinnah
Deputy 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 B. Flanders (#135837)
3

520110017M_closure letter_07032012_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
July 3, 2012
Mr. Kenneth Ufkin
Manager Fuel/Gas Fields
North Slope Borough
P.O. Box 69
Barrow, Alaska 99723
CPF 5-2011-0017M
Dear Mr. Ufkin:
On October 5, 2011, 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 North Slope Borough’s (NSB) procedures for Public
Awareness Program (PAP) in Barrow, Alaska. As a result of the inspection, North Slope
Borough was issued a Notice of Amendment on October 25, 2011, which proposed
amendment of your procedures.
North Slope Borough submitted its amended procedures on June 27, 2012. 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,
Dennis Hinnah
Deputy Director, Western Region
Pipeline and Hazardous Materials Safety Administration
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