NORTH SLOPE BOROUGH ENERGY MANAGEMENT — Notice of Amendment

party submissionOfficial PDF520200011M_Operator Response to Notice_12022020.pdf#

520200011M_Closure Letter_12102020_text.pdf, page 1Official PDFVIA E-MAIL TO THE HONORABLE HARRY K. BROWER, JR. December 10, 2020 The Honorable Harry K. Brower, Jr., Mayor Mayor of the North Slope Borough North Slope Borough Energy Management P.O. Box 69 Utqiagvik, Alaska 99723 CPF 5-2020-0011M Closure Letter Dear Mayor Brower: On December 9 through 13, 2019, and March 10, 2020, representatives 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 (NSBEM) procedures for operations, maintenance, and integrity management of the Barrow (Utqiagvik) and Nuiqsut natural gas pipelines in the North Slope Borough, Alaska. NSBEM submitted its amended procedures on December 2, 2020. My 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. 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 (#166676)#

520200011M_Notice of Amendment_11182020_text.pdf, page 1Official PDFNOTICE OF AMENDMENT VIA E-MAIL TO THE HONORABLE HARRY K BROWER, JR. November 18, 2020 The Honorable Harry K. Brower, Jr., Mayor Mayor of the North Slope Borough North Slope Borough Energy Management P.O. Box 69 Utqiagvik, Alaska 99723 CPF 5-2020-0011M Dear Mayor Brower: On December 9 through 13, 2019, and March 10, 2020, representatives 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 (NSBEM) procedures for operations, maintenance, and integrity management of the Barrow pipeline in Utqiagvik and Nuiqsut natural gas pipelines in the North Slope Borough, Alaska. On the basis of the inspection, PHMSA has identified an apparent inadequacy found within NSBEM’s plans or procedures, as described below: 1. §192.935 What additional preventive and mitigative measures must an operator take?#

520200011M_Notice of Amendment_11182020_text.pdf, page 2(a) General requirements… (b) Third party damage and outside force damage— (1) Third party damage. An operator must enhance its damage prevention program, as required under §192.614 of this part, with respect to a covered segment to prevent and minimize the consequences of a release due to third party damage. Enhanced measures to an existing damage prevention program include, at a minimum— … (iv) Monitoring of excavations conducted on covered pipeline segments by pipeline personnel. If an operator finds physical evidence of encroachment involving excavation that the operator did not monitor near a covered segment, an operator must either excavate the area near the encroachment or conduct an above ground survey using methods defined in NACE SP0502 (incorporated by reference, see §192.7). An operator must excavate, and remediate, in accordance with ANSI/ASME B31.8S and §192.933 any indication of coating holidays or discontinuity warranting direct examination. Section 10.2.2.2 of the operator's integrity management procedure stated that unreported construction activity would initiate an investigation. However, it did not state the code requirement that if an operator finds physical evidence of encroachment involving excavation that the operator did not monitor near a covered segment, an operator must either excavate the area near the encroachment or conduct an above ground survey using methods defined in NACE SP0502. 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). 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 2#

520200011M_Notice of Amendment_11182020_text.pdf, page 3plans 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 90 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 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 Dustin Hubbard, Director, Western Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 5-2020-0011M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Dustin Hubbard 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 Jake Gano (#166676) 3#