# NORTH SLOPE BOROUGH ENERGY MANAGEMENT — Notice of Amendment

- **operation:** document
- **citation:** CPF 520150021M
- **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:** 2015-12-29
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 192.285(a)(2), 192.605(a), 192.605(b)(1), 192.605(b)(9), 192.615(b)(2).
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520150021m.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520150021m
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520150021M
**body:**

Notice of Amendment involving NORTH SLOPE BOROUGH ENERGY MANAGEMENT. PHMSA's enforcement data identifies the cited regulations as 192.285(a)(2),  192.605(a),  192.605(b)(1),  192.605(b)(9),  192.615(b)(2). The case was opened on 2015-12-29 and is reported as closed as of 2016-10-11. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520150021M_Closure Letter_10112016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150021M/520150021M_Closure%20Letter_10112016.pdf

520150021M_Closure Letter_10112016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150021M/520150021M_Closure%20Letter_10112016_text.pdf

520150021M_Notice of Amendment_12292015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150021M/520150021M_Notice%20of%20Amendment_12292015.pdf

520150021M_Notice of Amendment_12292015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150021M/520150021M_Notice%20of%20Amendment_12292015_text.pdf

520150021M_Operator Response to Notice_03112016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150021M/520150021M_Operator%20Response%20to%20Notice_03112016.pdf

520150021M_Closure Letter_10112016_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
October 11, 2016
The Honorable Harry K. Brower
Mayor of the North Slope Borough
North Slope Borough Energy Management
Nuiqsut Utilities Cooperative
P.O. Box 69
Barrow, AK 99723
CPF 5-2015-0021M
Closure Letter
Dear Mayor Brower:
Between August 26, 2015 and September 17, 2015 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 Energy
Management’s procedures in Nuiqsut, Alaska. As a result of the inspection, North Slope Borough
Energy Management was issued a Notice of Amendment on December 29, 2015 which proposed
amendment of your procedures.
North Slope Borough Energy Management submitted its amended procedures on September 16,
2016 and September 30, 2016 (email). PHMSA 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.
Sincerely,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 Dave Hassell (#149012)

520150021M_Notice of Amendment_12292015_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
December 29, 2015
The Honorable Charlotte E. Brower
Mayor of North Slope Borough
North Slope Borough Energy Management
Nuiqsut Utilities Cooperative
P.O. Box 69
Barrow, Alaska 99723
CPF 5-2015-0021M
Dear Mayor Brower:
Between August 26, 2015 and September 17, 2015, a representative of the Pipeline and
Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United
States Code, inspected North Slope Borough Energy Management’s Operations and
Maintenance (O&M) Manual in Nuiqsut, Alaska.
On the basis of the inspection, PHMSA has identified the apparent inadequacies within North
Slope Borough Energy Management plans or procedures, as described below:
1. §192.605 Procedural manual for operations, maintenance, and emergencies
(a) General. Each operator shall prepare and follow for each pipeline, a manual
of written procedures for conducting operations and maintenance activities and
for emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed
and updated by the operator at intervals not exceeding 15 months, but at least
one each calendar year. This manual must be prepared before operations of a
pipeline system commence. Appropriate parts of the manual must be kept at
locations where operations and maintenance activities are conducted.
North Slope Borough Energy Management (NSBEM) did not establish adequate written
procedures as required by §192.605(a). At the time of the inspection, NSBEM’s Gas



Operations and Maintenance (O&M) Manual required notification of the construction of ten
(10) or more miles of Hazardous Liquid Pipeline. It is our understanding that NSBEM is a
natural gas distribution system and NSBEM does not operate a hazardous liquid pipeline. As a
result, NSBEM must modify the procedures in the O&M Manual to include the notification
for construction of ten (10) or more miles of new gas pipeline as required by
§191.22(c)(1)(ii).
2. §192.605 Procedural manual for operations, maintenance, and emergencies.
(b) Maintenance and normal operations. The manual required by paragraph (a)
of this section must include procedures for the following, if applicable, to provide
safety during maintenance and operations.
(9) Taking adequate precautions in excavated trenches to protect personnel from
the hazards of unsafe accumulations of vapor or gas, and making available when
needed at the excavation, emergency rescue equipment, including a breathing
apparatus and, a rescue harness and line.
NSBEM did not establish adequate written procedures for taking adequate precautions in
excavated trenches to protect personnel as required by §192.605(b) (9). At the time of the
inspection, NSBEM’s Gas Operations and Maintenance (O&M) Manual did not include the
procedures for taking adequate precautions in excavated trenches to protect personnel from
the hazards of unsafe accumulations of vapor or gas. Procedures did not require that
emergency rescue equipment, including a breathing apparatus and, a rescue harness and line
were available when needed at the excavation. As a result, NSBEM must modify the
procedures in the O&M Manual to specifically address the emergency rescue equipment in
the event the area must be excavated.
3. §192.615 Emergency plans.
(b) Each operator shall:
(2) Train the appropriate operating personnel to assure that they are
knowledgeable of the emergency procedures and verify that the training is
effective.
NSBEM did not establish adequate written Emergency procedures for training its personnel as
required by §192.615(b) (2). At the time of the inspection, NSBEM’s Gas Operations and
Maintenance (O&M) Manual did not include the requirements for training appropriate
operating personnel to assure that they are knowledgeable of the emergency procedures and to
verify that the training is effective. As a result, NSBEM must modify the procedures in the
O&M Manual to address this issue.
4. §192.605 Procedural manual for operations, maintenance, and emergencies
(b) Maintenance and normal operations. The manual required by paragraph (a)



of this section must include procedures for the following, if applicable, to provide
safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in accordance with each of
the requirements of this subpart and Subpart M of this part.
NSBEM did not establish adequate written procedures for operating, maintaining, and
repairing the pipeline as required by §192.605(b) (1). At the time of the inspection, NSBEM did
not include procedures requiring that taps on a pipelines under pressure (hot taps) be
performed by qualified personnel as required by §192.627. As a result, NSBEM must modify
the procedures in the O&M Manual to address this issue.
5. §192.605 Procedural manual for operations, maintenance, and emergencies
(b) Maintenance and normal operations. The manual required by paragraph (a)
of this section must include procedures for the following, if applicable, to provide
safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in accordance with each of
the requirements of this subpart and Subpart M of this part.
NSBEM did not establish adequate written procedures for operating, maintaining, and
repairing the pipeline as required by §192.605(b) (1). At the time of the inspection, NSBEM
did not include the test requirements for reinstating service lines as required by §192.725. As a
result, NSBEM must modify the procedures in the O&M Manual to require that reinstated
service lines be pressure tested.
6. §192.285 Plastic pipe. Qualifying persons to make joints.
(a) No person may make a plastic pipe joint unless that person has been qualified
under the applicable joining procedure by:
(2) Making a specimen joint from pipe sections joined according to the
procedure that passes the inspection and test set forth in paragraph (b) of this
section.
NSBEM did not establish adequate written procedures for qualifying persons to make joints
as required by §192.285(a) (2). At the time of the inspection, NSBEM did not include
procedures requiring that personnel making joints in plastic pipelines are qualified to the
joining procedure. Procedures for making a plastic pipe joint referenced the Operator
Qualification (OQ) covered task of GT40-General Pipeline Repair Procedures. The covered
task is for metal pipelines and not relevant to making plastic pipe joints. As a result, NSBEM
must modify the procedures to address this issue.
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
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 30 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 the North Slope Borough Energy Management maintain
documentation of the safety improvement costs associated with fulfilling this Notice of
Amendment (preparation/revision of plans, procedures) and submit the total to Chris Hoidal,
Director, Western Region, Pipeline and Hazardous Materials Safety Administration. In
correspondence concerning this matter, please refer to CPF 5-2015-0021M and, for each
document you submit, please provide a copy in electronic format to
PHP-WRADMIN@dot.gov whenever possible.
Sincerely,
Chris Hoidal,
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 D. Hassell (#149012)
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