# AMAROQ RESOURCES, LLC — Notice of Amendment

- **operation:** document
- **citation:** CPF 520190011M
- **title:** AMAROQ RESOURCES, LLC — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2019-02-25
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 192.615(a)(1), 192.615(a)(4).
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520190011m
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520190011M
**body:**

Notice of Amendment involving AMAROQ RESOURCES, LLC. PHMSA's enforcement data identifies the cited regulations as 192.615(a)(1),  192.615(a)(4). The case was opened on 2019-02-25 and is reported as closed as of 2020-03-13. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520190011M_Closure Letter_03132020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190011M/520190011M_Closure%20Letter_03132020.pdf

520190011M_Closure Letter_03132020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190011M/520190011M_Closure%20Letter_03132020_text.pdf

520190011M_Notice of Amendment_02252019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190011M/520190011M_Notice%20of%20Amendment_02252019.pdf

520190011M_Notice of Amendment_02252019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190011M/520190011M_Notice%20of%20Amendment_02252019_text.pdf

520190011M_Order Directing Amendment_01072020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190011M/520190011M_Order%20Directing%20Amendment_01072020.pdf

520190011M_Order Directing Amendment_01072020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190011M/520190011M_Order%20Directing%20Amendment_01072020_text.pdf

520190011M_Notice of Amendment_02252019_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
February 25, 2019
Mr. Scott Pfoff
President and CEO
Aurora Exploration LLC
4645 Sweetwater Blvd., Suite 200
Sugarland, Texas 77479
CPF 5-2019-0011M
Dear Mr. Pfoff:
On August 20 through 22, 2018, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected
Aurora Exploration LLC’s (Aurora) procedures for Operations and Maintenance and
Emergency Response in Anchorage, Alaska.
On the basis of the inspection, PHMSA identified the apparent inadequacies within Aurora’s
plans or procedures, as described below:
1. § 192.615 Emergency plans.
(a) Each operator shall establish written procedures to minimize the hazard
resulting from a gas pipeline emergency. At a minimum, the procedures must
provide for the following:
(1) Receiving, identifying, and classifying notices of events which require
immediate response by the operator.



The Operator’s Emergency Response Plan (AG-71-EP-REV1, "ERP”) lacks an adequate
process for receiving, identifying, and classifying notices. The ERP designates who will
receive, identify, and classify notices of events which require immediate response by Aurora.
It states that the first notification of events which need immediate response is “typically the
on-duty Production Supervisor with the Manager of Production Operations and Engineering
as the secondary contact”. However, based on conversations with the operator, these
positions no longer exist within Aurora. The operator failed to update the ERP with the
current position(s)for receiving, identifying, and classifying notices of event which require
immediate response by the operator. The procedure cannot be implemented as written in the
ERP.
2. § 192.615 Emergency plans.
(a) Each operator shall establish written procedures to minimize the hazard
resulting from a gas pipeline emergency. At a minimum, the procedures must
provide for the following:
(1) ….
(4) The availability of personnel, equipment, tools, and materials, as needed at
the scene of an emergency.
The operator's Emergency Response Plans (AG-71-EP-REV1, "ERP") lacks an inventory or
fails to otherwise identify what equipment, tools, and materials would be needed at the scene
of an emergency. The ERP states that "[t]he ERP will present an overview of the personnel
and equipment typically available for immediate callout in the event or (sic) an emergency.
This will include company personnel and equipment, as well as other service providers and
contractors active in the area of operations." However, the ERP does not present an overview
of personnel and equipment available for callout.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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).
2



Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under §190.211. 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 an Order Directing
Amendment. If 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. §
190.206). If you are not contesting this Notice, we propose that you submit your amended
procedures to my office within 60 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 Aurora 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, Acting Director, Western Region, Pipeline
and Hazardous Materials Safety Administration. In correspondence concerning this matter,
please refer to CPF 5-2019-0011M and, for each document you submit, please provide a copy
in electronic format whenever possible.
Sincerely,
Chris Hoidal
Acting Director, Western Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
cc: George Pollock, Senior Operations Consultant, gpollock@aurorapower.com
PHP-60 Compliance Registry
PHP-500 J. Gano (#160487)
3

520190011M_Closure Letter_03132020_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
March 13, 2020
Mr. G. Scott Pfoff
President
Amaroq Resources, LLC
4665 Sweetwater Blvd., Suite 103
Sugar Land, TX 77479
CPF 5-2019-0011M
Closure Letter
Dear Mr. Pfoff:
On August 20 through 22, 2018, 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 Aurora Exploration, LLC’s procedures in Anchorage, Alaska. As a result
of the inspection, Aurora Exploration, LLC was issued a Notice of Amendment (NOA) on February
25, 2019, which proposed amendment of your procedures. Amaroq Resources LLC 1 did not submit
amended procedures to PHMSA within 60 days of the receipt of the NOA and was issued an Order
Directing Amendment on January 7, 2020.
Amaroq Resources, LLC submitted its amended procedures on February 18, 2020. My staff reviewed
the amended procedures, and it appears that the inadequacies outlined in the NOA and Order Directing
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,
Dustin Hubbard
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 Jake Gano (#160487)
1 Amaroq Resources, LLC (formerly Aurora Exploration, LLC) acquired the Nicolai Creek
Pipeline system on the west side of Cook Inlet, Alaska along with the producing assets of the Nicolai
Creek Gas Field out of the bankruptcy proceedings of Aurora Gas, LLC

520190011M_Order Directing Amendment_01072020_text.pdf

January 7, 2020
Mr. G. Scott Pfoff
President and Chief Executive Officer
Amaroq Resources, LLC
4665 Sweetwater Boulevard, Suite 103
Sugar Land, Texas 77479
Re: CPF No. 5-2019-0011M
Dear Mr. Pfoff:
Enclosed please find the Order Directing Amendment issued in the above-referenced case. It
makes findings of inadequate procedures and requires Amaroq Resources, LLC (formerly Aurora
Exploration, LLC), amend certain emergency procedures. When the amendment of procedures
is complete, as determined by the Director, Western Region, this enforcement action will be
closed. Service of the Order Directing Amendment by certified mail is effective upon the date of
mailing as provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Dustin Hubbard, Director, Western Region, Office of Pipeline Safety, PHMSA
CERTIFIED MAIL - RETURN RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Amaroq Resources, LLC, ) CPF No. 5-2019-0011M
)
)
)
Respondent. )
____________________________________)
ORDER DIRECTING AMENDMENT
From August 20, 2018 through August 22, 2018, pursuant to 49 U.S.C. § 60117, a representative
of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline
Safety (OPS), conducted an on-site pipeline safety inspection of Amaroq Resources, LLC’s
(Amaroq or Respondent),1 plans and procedures in Anchorage, Alaska.
As a result of the inspection, the Director, Western Region, OPS (Director), issued to
Respondent, by letter dated February 25, 2019, a Notice of Amendment (NOA). In accordance
with 49 C.F.R. § 190.206, the NOA alleged certain inadequacies in Respondent’s emergency
procedures and proposed requiring Amaroq to amend its procedures to comply with 49 C.F.R.
§ 192.615.
Respondent failed to respond within 30 days of receipt of service of the NOA. Eventually,
Respondent responded on August 12, 2019, well after the 30 day deadline. In its response,
Amaroq did not contest the proposed NOA and further indicated that it would take measures to
correct the identified inadequacies. However, to date, Amaroq has yet to provide OPS with
amended procedures. Such failure to submit a timely response constitutes a waiver of Amaroq’s
right to contest the alleged inadequacies in the NOA and authorizes the Associate Administrator,
without further notice, to find facts as alleged in the NOA and to issue this Order Directing
Amendment.
Accordingly, I find that Amaroq’s procedures are inadequate to ensure safe operation of its
pipeline system. Pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206, Amaroq is ordered
to make the following revisions to its procedures. Respondent must:
1 Prior to the OPS inspection, Aurora Exploration, LLC changed its name to Amaroq Resources, LLC in April
2018. While the Notice of Amendment used the operator’s prior legal name, the legal entity and owner of the
pipeline remains the same.



CPF 5-2019-0011M
Page 2
1. Amend and update its Emergency Response Plan to include the current positions
who receive, identify, and classify notices of events which require immediate
response by the operator, as required by § 192.615.
2. Amend its Emergency Response Plan to provide an overview of personnel and
equipment available for an immediate callout in the event of an emergency.
3. Submit the amended procedures to the Director within 60 days following receipt
of this Order Directing Amendment.
The Director may grant an extension of time to comply with any of the required items upon a
written request timely submitted by the Respondent and demonstrating good cause for an
extension.
Failure to comply with this Order may result in administrative assessment of civil penalties not
to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), for each violation for each
day the violation continues or in referral to the Attorney General for appropriate relief in a
district court of the United States.
Under 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this Order
Directing Amendment to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200
New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to
the Office of Chief Counsel, PHMSA, at the same address, no later than 20 days after receipt of
this Order Directing Amendment by Respondent. Any petition submitted must contain a
statement of the issue(s) and meet all other requirements of 49 C.F.R. § 190.243. The terms of
the order, including corrective action, remain in effect unless the Associate Administrator, upon
request, grants a stay.
The terms and conditions of this Order Directing Amendment are effective upon service in
accordance with 49 C.F.R. § 190.5.
January 7, 2020
___________________________________ ______________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety
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