{"operation":"document","citation":"CPF 520190012W","title":"AMAROQ RESOURCES, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-02-25","effective_on":null,"summary":"CLOSED warning letter citing 192.179(c), 192.465(c), 192.475(b), 192.481(a), 192.481(c), 192.605(a), 192.705(b), 192.706, 192.739(a), 192.745(a), 192.807(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520190012w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520190012w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520190012w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520190012W","body":"Warning Letter involving AMAROQ RESOURCES, LLC. PHMSA's enforcement data identifies the cited regulations as 192.179(c),  192.465(c),  192.475(b),  192.481(a),  192.481(c),  192.605(a),  192.705(b),  192.706,  192.739(a),  192.745(a),  192.807(b). The case was opened on 2019-02-25 and is reported as closed as of 2019-02-25. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520190012W_Warning Letter_02252019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190012W/520190012W_Warning%20Letter_02252019.pdf\n\n520190012W_Warning Letter_02252019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190012W/520190012W_Warning%20Letter_02252019_text.pdf\n\n520190012W_Warning Letter_02252019_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 25, 2019\nMr. Scott Pfoff\nPresident and CEO\nAurora Exploration LLC\n4645 Sweetwater Blvd., Suite 200\nSugarland, Texas 77479\nCPF 5-2019-0012W\nDear Mr. Pfoff:\nOn August 20 through 22, 2018, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected\nAurora Exploration, LLC’s (Aurora’s) Nicolai Creek Pipeline System in west side of Cook Inlet,\nAlaska.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. § 192.179 Transmission line valves.\n(a) .…\n(c) Each section of a transmission line, other than offshore segments, between main\nline valves must have a blowdown valve with enough capacity to allow the\ntransmission line to be blown down as rapidly as practicable. Each blowdown\ndischarge must be located so the gas can be blown to the atmosphere without hazard\nand, if the transmission line is adjacent to an overhead electric line, so that the gas is\ndirected away from the electrical conductors.\n\n\n\nThe 6-inch Nicolai Creek South B pipeline lacks appropriate blow-down valves required by\n§ 192.179(c). Although the segment could be blown down through the pig traps, this is not\nadequate to minimize the hazards during blow-down. Other valves installed on the segment are\nsmall diameter valves for instruments (e.g. pressure gauges) which are not sufficient in size to\nblow-down the pipe as quickly as practicable and do not discharge in locations that minimize the\nhazards of blow-down.\n2. § 192.465 External corrosion control: Monitoring.\n(a) .…\n(c) Each reverse current switch, each diode, and each interference bond whose\nfailure would jeopardize structure protection must be electrically checked for proper\nperformance six times each calendar year, but with intervals not exceeding 21∕2\nmonths. Each other interference bond must be checked at least once each calendar\nyear, but with intervals not exceeding 15 months.\nThe operator failed to inspect each impressed current power source six times per calendar year at\nintervals not exceeding 2-1/2 months. The Nicolai Creek pipeline system’s impressed current\npower source is from a bond to another operator’s pipeline. Records indicate that the operator\ntested this bond on the following dates: 6/11/18; 4/10/18; 2/12/18, 4/2/17; 2/7/17; 10/14/16, and\n8/15/16.\n3. § 192.475 Internal corrosion control: General\n(a) .…\n(b) Whenever any pipe is removed from a pipeline for any reason, the internal\nsurface must be inspected for evidence of corrosion. If internal corrosion is found—\n(1) The adjacent pipe must be investigated to determine the extent of internal\ncorrosion;\n(2) Replacement must be made to the extent required by the applicable paragraphs\nof §§192.485, 192.487, or 192.489; and\n(3) Steps must be taken to minimize the internal corrosion.\nThe operator failed to inspect the internal surface of the pipe whenever pipe was removed as\nrequired by § 192.475(b). The operator stated that in 2015 a new pig trap was installed on the\nNicolai Creek South B Pipeline and during that time the internal surfaces of the pipeline were\nexposed. However, the operator failed to conduct (or failed to document) an evaluation of the\ninterior of the pipeline for internal corrosion.\n4. § 192.481 Atmospheric corrosion control: Monitoring.\n(a) Each operator must inspect each pipeline or portion of pipeline that is exposed to\nthe atmosphere for evidence of atmospheric corrosion, as follows:\n2\n\n\n\nIf the pipeline is\nlocated:\nThen the frequency of inspection is:\nOnshore\nAt least once every 3 calendar years, but with intervals not\nexceeding 39 months\nOffshore\nAt least once each calendar year, but with intervals not\nexceeding 15 months\nThe operator failed to conduct atmospheric corrosion inspections as required by\n§ 192.481(a). The operator stated that they had not conducted atmospheric corrosion inspections,\nwhich is consistent with their lack of records.\n5. § 192.481 Atmospheric corrosion control: Monitoring.\n(a) .…\n(c) If atmospheric corrosion is found during an inspection, the operator must\nprovide protection against the corrosion as required by § 192.479.\nThe operator failed to remediate atmospheric corrosion and general coating failures as required by\n§ 192.481(c). During the inspection, PHMSA observed external corrosion and coating failures on\nthe insulated piping spools at the pigging facility where the Nicolai Creek South A (4-inch)\npipeline ends and the Nicolai Creek South B (6-inch) pipeline begins.\n6. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least once each\ncalendar year. This manual must be prepared before operations of a pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\nThe operator failed to review and update their procedures for operations and maintenance\nactivities and emergency response at intervals not exceeding 15 months, but at least once each\ncalendar year:\n• Operations and Maintenance tasks are described in a series of procedures. The\noperator's officials approved these various procedures in late 2014 through early 2015.\nFor example, the procedure AG-15-OM-Rev1 “Valve Inspection & Maintenance” was\napproved by the two Production Supervisors and the Manager of Production\nOperations and Engineering on 1/29/15, 12/18/14, and 12/18/14 respectively. Since\nthen, the operator has not documented a review or revision of these procedures.\nDuring the inspection, the operator stated that they have not reviewed or updated the\nprocedures, which is consistent with the lack of records.\n• Company officials approved Emergency Response Plan (AG-71-EP-REV1, \"ERP\") in\nlate 2014 through early 2015. The ERP was approved by the two Production\n3\n\n\n\nSupervisors and the Manager of Production Operations and Engineering on 1/29/15,\n12/18/14, and 12/18/14 respectively. Since then, the operator has not documented a\nreview or revision of the plan. During the inspection, the operator stated that they\nhave not reviewed or updated the procedures, which is consistent with the lack of\nrecords.\n7. § 192.705 Transmission lines: Patrolling.\n(a) .…\n(b) The frequency of patrols is determined by the size of the line, the operating\npressures, the class location, terrain, weather, and other relevant factors, but\nintervals between patrols may not be longer than prescribed in the following table:\nMaximum interval between patrols\nClass location\nof line\nAt highway and railroad At all other places\ncrossings\n1, 2\n71∕2 months; but at least twice 15 months; but at least once each\neach calendar year calendar year.\n3\n41∕2 months; but at least four 71∕2 months; but at least twice each\ntimes each calendar year calendar year.\n4\n41∕2 months; but at least four 41∕2 months; but at least four times\ntimes each calendar year each calendar year.\nThe operator failed to adequately document patrols of the pipeline surface at the required\nintervals. The operator stated that field personnel regularly patrol the right of way and surfaces\nadjacent to the pipeline, but that they only document the patrols annually in conjunction with their\nannual leakage survey. The operator provided records of the patrol and leakage survey for 2016\nand 2018, but the operator stated they did not conduct the required patrol in the 2017 calender\nyear.\n8. § 192.706 Transmission lines: Leakage surveys.\nLeakage surveys of a transmission line must be conducted at intervals not exceeding\n15 months, but at least once each calendar year. However, in the case of a\ntransmission line which transports gas in conformity with § 192.625 without an odor\nor odorant, leakage surveys using leak detector equipment must be conducted—\n(a) In Class 3 locations, at intervals not exceeding 71∕2 months, but at least twice each\ncalendar year; and\n(b) In Class 4 locations, at intervals not exceeding 41∕2 months, but at least four times\neach calendar year.\nThe operator failed to conduct leakage surveys at intervals not exceeding 15 months, but at least\nonce per calendar year. The operator completed and documented leakage surveys in March of\n2016 and 2018 but failed to do so in 2017. The operator stated they did not conduct the required\nleakage survey in the 2017 calender year.\n4\n\n\n\n9. § 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 the\ncorrect 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.\nThe operator failed to inspect and test each pressure relief device at intervals not exceeding 15\nmonths, but at least once each calendar year. The operator stated during the inspection that it is\ntheir practice to replace pressure safety valves (PSVs) instead of testing and repairing them, but\nthe operator had no records showing that replacement or inspection/testing had ever been\ndone. The operator also could not specify which PSVs protect each pipeline segment and are\nsubject to the requirements of 192.739.\n10. § 192.745 Valve maintenance: Transmission lines.\n(a) Each transmission line valve that might be required during any emergency must\nbe inspected and partially operated at intervals not exceeding 15 months, but at least\nonce each calendar year.\nThe operator failed to identify which valves are \"emergency valves\" that need to be maintained in\naccordance with 192.745. Their O&M Procedure (AG-15-OM-Rev 1) states that \"[t]he Manager\nof Production Operations and Engineering shall determine which valves may be required in an\nemergency.\" However, during the inspection, the operator was unable to produce a list or valve\nmaintenance worksheet or otherwise identify which valves are subject to\n§ 192.745. The operator stated that field personnel occasionally service valves but they are not\ndoing so in accordance with a documented process and have not produced records of such\nservices.\n11. § 192.807 Recordkeeping.\nEach operator shall maintain records that demonstrate compliance with this\nsubpart.\n(a) .…\n(b) Records supporting an individual's current qualification shall be maintained\nwhile the individual is performing the covered task. Records of prior qualification\nand records of individuals no longer performing covered tasks shall be retained for a\nperiod of five years.\nThe operator failed to retain records of individuals performing tasks for a period of five\nyears. When PHMSA requested Operator Qualification (OQ) records during the inspection, the\n5\n\n\n\noperator stated that the vendor that previously provided OQ training and associated record\nkeeping refused to release the records.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$213,268 per violation per day the violation persists, up to a maximum of $2,132,679 for a related\nseries of violations. For violations occurring on or after November 2, 2015 and before November\n27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum\npenalty not to exceed $2,090,022. For violations occurring prior to November 2, 2015, the\nmaximum penalty may not exceed $200,000 per violation per day, with a maximum penalty not to\nexceed $2,000,000 for a related series of violations. We have reviewed the circumstances and\nsupporting 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 Aurora Exploration, LLC being\nsubject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2019-0012W. 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 the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nChris Hoidal\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: George Pollock, Senior Operations Consultant, gpollock@aurorapower.com\nPHP-60 Compliance Registry\nPHP-500 J. Gano (#160487)\n6","truncated":false,"body_characters":14402}