{"operation":"document","citation":"CPF 520160020W","title":"NORTH SLOPE BOROUGH ENERGY MANAGEMENT — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-10-06","effective_on":null,"summary":"CLOSED warning letter citing 192.465(d), 192.503(a)(1), 192.605(b)(8), 192.625(f), 192.739(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520160020w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520160020w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520160020w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520160020W","body":"Warning Letter involving NORTH SLOPE BOROUGH ENERGY MANAGEMENT. PHMSA's enforcement data identifies the cited regulations as 192.465(d),  192.503(a)(1),  192.605(b)(8),  192.625(f),  192.739(a). The case was opened on 2016-10-06 and is reported as closed as of 2016-10-06. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520160020W_Warning Letter_10062016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160020W/520160020W_Warning%20Letter_10062016.pdf\n\n520160020W_Warning Letter_10062016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160020W/520160020W_Warning%20Letter_10062016_text.pdf\n\n520160020W_Warning Letter_10062016_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 6, 2016\nThe Honorable Harry K. Brower, Jr.\nMayor of the North Slope Borough\nNorth Slope Borough Energy Management\nNuiqsut Utilities Cooperative\nP.O. Box 69\nBarrow, Alaska 99723\nCPF 5-2016-0020W\nDear Mayor Brower:\nOn July 11 through 15, 2016, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected the\nNuiqsut Utility Cooperative (NUC) natural gas distribution system facilities, records, and\nprocedures associated with that system in Nuiqsut, Alaska.\nAs a result of the inspection, it is alleged that the North Slope Borough (NSB) has committed\nprobable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations.\nThe items inspected and the probable violations are:\n1. §192.625 Odorization of gas.\n(f) To assure the proper concentration of odorant in accordance with this\nsection, each operator must conduct periodic sampling of combustible gases using\nan instrument capable of determining the percentage of gas in air at which the\nodor becomes readily detectable\n\n\n\nThe NSB did not use an instrument that is “capable of determining the percentage of gas in air at\nwhich the odor becomes readily detectable.” The current test method employed by NSB consists\nof releasing gas from a fitting, and wafting a gas-in-air mixture to a tester who sniffs the gas with\na combustible gas indicator (CGI) nearby. The tester notes the reading on the CGI when the he\nfirst detects an odor. This method does not ensure that the CGI and the tester are each receiving\nthe same gas-in-air mixture so that the CGI reading correctly corresponds to what the tester was\nsniffing. NSB must conduct sampling using an instrument capable of accurately and consistently\ndetermining the percent gas in air at which odor is readily detectable.\n2. §192.465 External corrosion control: Monitoring.\n(d) Each operator shall take prompt remedial action to correct any deficiencies\nindicated by the monitoring.\nThe NSB did not take prompt remedial action to correct deficiencies noted in their annual\ncathodic protection (CP) monitoring reports. PHMSA reviewed the 2013, 2014, and 2015 CP\nmonitoring reports for this inspection. Many of the same repairs were recommended over\nmultiple years. Specifically:\n•Building 2209’s anode was not functioning in 2013 and 2014.\n•Several of the same test locations did not adequately meet CP criteria in 2013 and\n2014.\n•Risers 2310 and 3310 were shorted to their respective buildings in 2014 and 2015\nThe 2015 Cathodic Protection and Atmospheric Corrosion Monitoring report noted several risers\nand low point drains that did not meet CP criteria, locations with shorts, and damaged coating.\nThe NSB must take prompt remedial action to address the 2015 CP repair recommendations.\n3. §192.503 General Requirements.\n(a) No person may operate a new segment of pipeline, or return to service a\nsegment of pipeline that has been relocated or replaced, until-\n(1) It has been tested in accordance with this subpart and §192.619 to substantiate\nthe maximum allowable operating pressure;\nThe NSB did not conduct a pressure test consistent with Subpart J on piping spools located in the\nPressure Reducing Valve (PRV) station skid. The PRV skid is the location where the\ntransmission pipeline pressure is reduced to distribution pipeline pressure. The NSB operates the\nPRV skid, including valves and regulators within. Short welded piping spools are used within\nthe skid to connect valves, regulators, and other appurtenances. Records indicate that the spools\nwere hydrostatically tested for ten (10) minutes at 997psi or 388psi.\nThe NSB must determine the operating pressure and percent SMYS of each spool and, based on\nthese findings, conduct a pressure test in accordance with 192.503.\n\n\n\n4. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations\n(8) Periodically reviewing the work done by operator personnel to determine the\neffectiveness, and adequacy of the procedures used in normal operation and\nmaintenance and modifying the procedures when deficiencies are found.\nThe NSB did not review work done by operator personnel and incorporate changes into their\nmanual as required. Their O&M manual contains provisions for this process but NSB did not\nproduce documentation demonstrating that it is being implemented. The NSB must implement\nand document the review procedure.\n5. §192.465 External corrosion control: Monitoring.\n(d) Each operator shall take prompt remedial action to correct any deficiencies\nindicated by the monitoring.\nThe NSB has not correctly reported leaks on their annual report required by 191.11(a). They\nhave not been including non-hazardous leaks that cannot be removed by lubrication, adjustment,\nor tightening as \"leaks,\" per instructions on Section C of the annual report. NSB is reportedly\nfiling corrected prior reports. NSB must correctly fill out future annual reports.\n6. §192.739 Pressure limiting and regulating stations: Inspection and testing.\n(a) Each pressure limiting station, relief device (except rupture discs), and Pressure\nregulating station and its equipment must be subjected at intervals not exceeding 15\nmonths, but at least once each calendar year, to inspections and tests to determine\nthat it is-\n(1) In good mechanical condition;\n(2) Adequate from the standpoint of capacity and reliability of operation for the\nservice in which it is employed;\n(3) Except as provided in paragraph (b) of this section, set to control or relieve at\nthe correct pressure consistent with the pressure limits of §192.201(a); and\n(4) Properly installed and protected from dirt, liquids, or other conditions that\nmight prevent proper operation.\n\n\n\nThe NSB did not adequately pressure test the relief valves at the required intervals. Two parallel\npressure safety valves (PSV), PSV 62252A and PSV 62252B, are used for pressure protection\nand are connected so that one can protect the distribution system when the other is removed and\nserviced. Records show that approximately 18 months elapsed between subsequent tests for PSV\n62252A (3/22/14 and 9/8/15). Additionally, NSB indicated that PSV6225B was tested on\nOctober 9, 2014 but was unable to locate the corresponding test records. Therefore, there was a\nperiod which NSB cannot demonstrate that the PSV protecting the system had been tested within\nthe 15 month maximum testing interval as required by regulation. The NSB must test pressure\nlimiting devices at the required intervals and retain records demonstrating the adequacy of the\ndevice for protecting the system.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $205,638\nper violation per day the violation persists up to a maximum of $2,056,380 for a related series of\nviolations. For violation occurring between January 4, 2012 to August 1, 2016, the maximum\npenalty may not exceed $200,000 per violation per day, with a maximum penalty not to exceed\n$2,000,000 for a related series of violations. For violations occurring prior to January 4, 2012,\nthe maximum penalty may not exceed $100,000 per violation per day, with a maximum penalty\nnot to exceed $1,000,000 for a related series of violations. We have reviewed the circumstances\nand supporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct the\nitems identified in this letter. Failure to do so will result in the NSB being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2016-0020W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Gano (#153508)\nPHP-500 D. Hassell (#153508)","truncated":false,"body_characters":9389}