{"operation":"document","citation":"CPF 520110020M","title":"BARROW UTILITIES & ELECTRIC CORP — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2011-10-25","effective_on":null,"summary":"CLOSED notice of amendment citing 192.1007, 192.1007(a), 192.1007(b), 192.1007(c), 192.1007(e), 192.1007(f), 192.1011.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520110020m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520110020m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520110020m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520110020M","body":"Notice of Amendment involving BARROW UTILITIES & ELECTRIC CORP. PHMSA's enforcement data identifies the cited regulations as 192.1007,  192.1007(a),  192.1007(b),  192.1007(c),  192.1007(e),  192.1007(f),  192.1011. 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.\n\nOfficial case documents:\n\n520110020M_closure letter_07032012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520110020M/520110020M_closure%20letter_07032012.pdf\n\n520110020M_closure letter_07032012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520110020M/520110020M_closure%20letter_07032012_text.pdf\n\n520110020M_notice of amendment_10252011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520110020M/520110020M_notice%20of%20amendment_10252011.pdf\n\n520110020M_notice of amendment_10252011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520110020M/520110020M_notice%20of%20amendment_10252011_text.pdf\n\n520110020M_operator response_01092012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520110020M/520110020M_operator%20response_01092012.pdf\n\n520110020M_closure letter_07032012_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 3, 2012\nMr. Allen Nesteby\nOperations Superintendent\nBarrow Utilities and Electric Cooperative, Inc.\n1295 Agvik Street\nP.O. Box 449\nBarrow, AK 99723\nCPF 5-2011-0020M\nDear Mr. Nesteby:\nOn September 12-16, 2011, a representative from the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of Barrow Utilities and Electric Cooperative,\nInc. (BUECI) procedures in Barrow, Alaska. As a result of the inspection, BUECI was\nissued a Notice of Amendment on October 25, 2011, which proposed amendment of your\nprocedures.\nBUECI submitted its amended procedures on January 9, 2012. My staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of\nAmendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nDennis Hinnah\nDeputy Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Strawn (#136010)\n\n520110020M_notice of amendment_10252011_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 25, 2011\nMr. Allen Nesteby\nOperations Superintendent\nBarrow Utilities and Electric Cooperative Inc.\n1295 Agvik St.\nP.O. Box 449\nBarrow, AK 99723\nCPF 5-2011-0020M\nDear Mr. Nesteby:\nOn September 12-16, 2011, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected\nBarrow Utilities and Electric Cooperative Inc.’s (BUECI) procedures and records for\nDistribution Integrity Management Program (DIMP) in Barrow, Alaska.\nOn the basis of the inspections, PHMSA has identified the apparent inadequacies found\nwithin BUECI’s DIMP as described below:\n1. §192.1007 What are the required elements of an integrity management plan? A\nwritten integrity management plan must contain procedures for developing and\nimplementing the following elements:\nBUECI must adapt SHRIMP with the basic materials and procedures of operator\nspecific information and procedures such as BUECI’s O&M Manual and incorporate\nthem into the DIMP.\n2. §192.1007 What are the required elements of an integrity management plan? A\nwritten integrity management plan must contain procedures for developing and\nimplementing the following elements:\n\n\n\n(a) Knowledge. An operator must demonstrate an understanding of its gas\ndistribution system developed from reasonably available information.\n(1) Identify the characteristics of the pipeline's design and operations and the\nenvironmental factors that are necessary to assess the applicable threats and\nrisks to its gas distribution pipeline.\n(2) Consider the information gained from past design, operations, and\nmaintenance.\n(3) Identify additional information needed and provide a plan for gaining that\ninformation over time through normal activities conducted on the pipeline (for\nexample, design, construction, operations or maintenance activities).\n(4) Develop and implement a process by which the IM program will be reviewed\nperiodically and refined and improved as needed.\n(5) Provide for the capture and retention of data on any new pipeline installed.\nThe data must include, at a minimum, the location where the new pipeline is\ninstalled and the material of which it is constructed.\nA. BUECI must add detail to the procedure describing the methods and data sources,\nused to gather information and knowledge of the system, from reasonably\navailable sources of information (e.g., subject matter experts consulted; OM&I\nforms, records, system maps).\nB. BUECI must add detail to the procedure(s) describing the methods used for\nidentifying, listing, and collecting (as appropriate) additional data and information\nthat is needed to fill gaps in knowledge and information due to missing,\ninaccurate, or incomplete records.\n3. §192.1007 What are the required elements of an integrity management plan? A\nwritten integrity management plan must contain procedures for developing and\nimplementing the following elements:\n(b) Identify threats. The operator must consider the following categories of\nthreats to each gas distribution pipeline: Corrosion, natural forces, excavation\ndamage, other outside force damage, material, weld or joint failure (including\ncompression coupling), equipment failure, incorrect operation, and other\nconcerns that could threaten the integrity of its pipeline. An operator must\nconsider reasonably available information to identify existing and potential\nthreats. Sources of data may include, but are not limited to, incident and leak\nhistory, corrosion control records, continuing surveillance records, pa-trolling\nrecords, maintenance history, and excavation damage experience.\nBUECI must add detail to the procedure, used to identify existing and potential\nthreats that describe how subject matter expert(s) gathered and input information into\nthe SHRIMP application for the threat assessment.\n2\n\n\n\nThe procedure must detail how BUECI considers all available information for the\nthreat assessment including all leak data, corrosion control inspection, and other\ninspection and maintenance documentation.\n4. §192.1007 What are the required elements of an integrity management plan? A\nwritten integrity management plan must contain procedures for developing and\nimplementing the following elements:\n(c) Evaluate and rank risk. An operator must evaluate the risks associated with\nits distribution pipeline. In this evaluation, the operator must determine the\nrelative importance of each threat and estimate and rank the risks posed to its\npipeline. This evaluation must consider each applicable current and potential\nthreat, the likelihood of failure associated with each threat, and the potential\nconsequences of such a failure. An operator may subdivide its pipeline into\nregions with similar characteristics (e.g., contiguous areas within a distribution\npipeline consisting of mains, services and other appurtenances; areas with\ncommon materials or environmental factors), and for which similar actions\nlikely would be effective in reducing risk.\nA. BUECI must add details to their DIMP to include user validation of the risk\nranking results from the SHRIMP application.\nB. BUECI must enhance their DIMP by providing detailed justification for not\nconsidering subdividing their system into 2 regions (steel and plastic).\nPipelines with similar characteristics that subdivide are likely to be effective in\nreducing risk in order to more accurately address integrity management issues.\nDIMP must be detailed to show the justification that risk is reduced and integrity\nmanagement issues are addressed accurately without subdividing its pipeline into 2\nregions.\n5. §192.1007 What are the required elements of an integrity management plan? A\nwritten integrity management plan must contain procedures for developing and\nimplementing the following elements:\n(e) Measure performance, monitor results, and evaluate effectiveness.\n(i) Number of hazardous leaks either eliminated or repaired as required by\n§192.703(c) of this subchapter (or total number of leaks if all leaks are repaired\nwhen found), categorized by cause;\n(ii) Number of excavation damages;\n(iii) Number of excavation tickets (receipt of information by the underground\nfacility operator from the notification center);\n(iv) Total number of leaks either eliminated or repaired, categorized by cause;\n(v) Number of hazardous leaks either eliminated or repaired as required by\n§192.703(c) (or total number of leaks if all leaks are repaired when found),\ncategorized by material; and\n3\n\n\n\n(vi) Any additional measures the operator determines are needed to evaluate the\neffectiveness of the operator's IM program in controlling each identified threat. (in\nits entirety)\nA. BUECI must modify their DIMP to include procedures for establishing baselines\nfor performance measures from which to monitor effectiveness of its DIMP.\nB. BUECI must modify their DIMP to include requirements for monitoring the\nperformance measure described in §192.1007(e)(1)(v) as “Number of hazardous leaks\neither eliminated or repaired as required by §192.703(c) (or total number of leaks if\nall leaks are repaired when found), categorized by material”.\n6. §192.1007 What are the required elements of an integrity management plan? A\nwritten integrity management plan must contain procedures for developing and\nimplementing the following elements:\n(f) Periodic Evaluation and Improvement. An operator must re-evaluate threats\nand risks on its entire pipe-line and consider the relevance of threats in one\nlocation to other areas. Each operator must determine the appropriate period\nfor conducting complete program evaluations based on the complexity of its\nsystem and changes in factors affecting the risk of failure. An operator must\nconduct a complete program re-evaluation at least every five years. The\noperator must consider the results of the performance monitoring in these\nevaluations.\nBUECI must describe in their DIMP details of how BUECI will conduct a periodic\nevaluation.\n7. §192.1011 What records must an operator keep? An operator must maintain\nrecords demonstrating compliance with the requirements of this subpart for at\nleast 10 years. The records must include copies of superseded integrity\nmanagement plans developed under this subpart.\nA. BUECI must include a procedure in its DIMP with the requirement of 10 year\nretention of certain documents, that are used to demonstrate compliance with 192\nSubpart P, such as BUECI OM&I forms.\nBUECI must show where compliance with 192, subpart P, exists in its procedures\nthat requires certain documentation be retained for 10 years. BUECI documents the\nvarious forms and documentation used in the threat identification section, but does\nnot show where such documentation must be retained for 10 years in accordance with\nthis subpart of the code.\nB. BUECI must modify their DIMP to include a revision log for its DIMP that\nidentifies when significant changes were made and the date of the implementation of\na revised DIMP. A “comments” field should be incorporated into any revision log4\n\n\n\n(or periodic evaluation log) that provides an area for an explanation of decisions\nand/or changes made.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. 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\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). If you do not respond\nwithin 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the\nallegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to\nfind facts as alleged in this Notice without further notice to you and to issue a Final Order.\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged\nin this Notice, you may be ordered to amend your plans or procedures to correct the\ninadequacies (49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that\nyou submit your amended procedures to my office within 45 days of receipt of this Notice.\nThis period may be extended by written request for good cause. Once the inadequacies\nidentified herein have been addressed in your amended procedures, this enforcement action\nwill be closed.\nIt is requested (not mandated) that BUECI maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision\nof plans, procedures) and submit the total to Dennis Hinnah, Deputy Director, Western\nRegion, Pipeline and Hazardous Materials Safety Administration.\nIn correspondence concerning this matter, please refer to CPF 5-2011-0020M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nDennis Hinnah\nDeputy Director, 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. Strawn (#136010)\n5","truncated":false,"body_characters":14024}