{"operation":"document","citation":"CPF 52023017NOA","title":"NORGASCO INC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2023-03-24","effective_on":null,"summary":"CLOSED notice of amendment citing 192.507(a), 192.605(a), 192.605(b)(5).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52023017noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52023017noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52023017noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52023017NOA","body":"Notice of Amendment involving NORGASCO INC. PHMSA's enforcement data identifies the cited regulations as 192.507(a),  192.605(a),  192.605(b)(5). The case was opened on 2023-03-24 and is reported as closed as of 2024-08-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52023017NOA_Closure Letter_08202024_(21-207466).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023017NOA/52023017NOA_Closure%20Letter_08202024_(21-207466).pdf\n\n52023017NOA_Closure Letter_08202024_(21-207466)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023017NOA/52023017NOA_Closure%20Letter_08202024_(21-207466)_text.pdf\n\n52023017NOA_Notice of Amendment_03242023_(21-207466).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023017NOA/52023017NOA_Notice%20of%20Amendment_03242023_(21-207466).pdf\n\n52023017NOA_Notice of Amendment_03242023_(21-207466)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023017NOA/52023017NOA_Notice%20of%20Amendment_03242023_(21-207466)_text.pdf\n\n52023017NOA_Operator Response to Notice_04212023_(21-207466).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023017NOA/52023017NOA_Operator%20Response%20to%20Notice_04212023_(21-207466).pdf\n\n52023017NOA_Closure Letter_08202024_(21-207466)_text.pdf\n\nVIA ELECTRONIC MAIL TO: ray@norgasco.com\nAugust 20, 2024\nMr. Raymond Latchem\nPresident\nNorgasco, Inc.\n4341 B Street, Suite 306\nAnchorage, AK 99503\nCPF 5-2023-017-NOA\nClosure Letter\nDear Mr. Latchem:\nOn May 7 through 11, 2022, and September 27 through 30, 2022, a representative from the\nPipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of\n49 United States Code, conducted an on-site pipeline safety inspection of Norgasco Inc.\nprocedures in Deadhorse, Alaska. As a result of the inspection, Norgasco Inc. was issued a\nNotice of Amendment on March 24, 2023, which proposed amendment of your procedures.\nNorgasco Inc. submitted its amended procedures on June 21, 2023 and July 25, 2024. My staff\nreviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of\nAmendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 C. Lyon (#21-207466)\nBret Bartholomy, Norgasco, Inc. - bret@norgasco.com\n\n52023017NOA_Notice of Amendment_03242023_(21-207466)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL:\nMarch 24, 2023\nRaymond Latchem - ray@norgasco.com\nPresident\nNorgasco, Inc\n4341 B Street Suite 306\nAnchorage, AK\nCPF 5-2023-017-NOA\nDear Mr. Latchem,\nFrom May 7 through May 11, 2022, and September 27 through September 30, 2022, a\nrepresentative from the Pipeline and Hazardous Materials Safety Administration (PHMSA),\npursuant to Chapter 601 of 49 United States Code inspected Norgasco Inc. (Norgasco or\nOperator), procedures for the natural gas distribution system in Deadhorse, Alaska.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nNorgasco Inc plans or procedures, as described below:\n1. § 192.507 Test requirements for pipelines to operate at a hoop stress less than 30\npercent of SMYS and at or above 100 p.s.i. (689 kPa) gage.\nExcept for service lines and plastic pipelines, each segment of a pipeline that is to be\noperated at a hoop stress less than 30 percent of SMYS and at or above 100 p.s.i.\n(689 kPa) gage must be tested in accordance with the following:\n(a) The pipeline operator must use a test procedure that will ensure discovery of all\npotentially hazardous leaks in the segment being tested.\nNorgasco had insufficient and non-segment specific procedures to pressure/leak test the pipeline\nsegments from the Hilcorp Tie-in at Flow Station 1 (Prudhoe Bay, AK) to Norgasco Skid 1\n1\n\n\n\n(approximately two miles north of Deadhorse, AK), and from Skid 1 to Skid 2 (located in\nDeadhorse, AK), as required by § 192.507(a).\n2. § 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.\nNorgasco’s manual for operations, maintenance, and emergencies (O&M) did not include a\nwritten procedure to operate the bypass on Skid 1. Norgasco’s pipeline was configured so that\nvalves 7, 20, and F310 are required to be operated during the condition of the failure of regulator\nF627 in order to bypass the regulator. To ensure that the downstream pressure limit is not\nexceeded or that the pressure safety valve (PSV) does not relieve during operation of the bypass,\nNorgasco must have a written procedure to ensure the safe operation of the pipeline during\nmanual valve operation.\nIn addition, Norgasco’s O&M manual did not include a written procedure for the operation of\nbypass valve 15. Opening this valve would bypass the pressure-limiting device and would result\nin a PSV release.\nFinally, Norgasco’s O&M manual did not include written procedures to ensure that ice did not\naccumulate around the valve stem in the riser above each underground plastic main-line valve to\nensure the valves were operable. In particular:\n• The Operator did not have a methodology to check if water has accumulated above the\nvalve stem.\n• The Operator did not have a methodology to pump out any water that accumulated via\nintrusion or condensation.\n• The Operator stated they added anti-freeze, but did not have a procedure that reflected\nthis practice of adding anti-freeze to plastic main-line valve access risers to prevent water\npresent from freezing.\n• The Operator did not have a procedure to melt any ice built up above the valve stem.\nEnsuring adequate operation of distribution valves is especially imperative in the unique Arctic\nenvironment of the Operator’s distribution system. During PHMSA’s field inspection, the cover\nfor valve station 2a was frozen to the ground, and the Operator could not remove it to access the\nvalve. The Operator stated that if they needed access to that valve, they would bring a\njackhammer from the shop to break up the ice around the base. This valve was not immediately\noperable.\n\n\n\n3. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) . . . .\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(1) . . . .\n(5) Starting up and shutting down any part of the pipeline in a manner designed to\nassure operation within the MAOP limits prescribed by this part, plus the build-up\nallowed for operation of pressure-limiting and control devices.\nThe Norgasco Operations and Maintenance Manual did not state the allowable PSV build-up\nover MAOP.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. 552(b), along with the complete original document, you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate, as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not\ncontesting this Notice, we propose that you submit your amended procedures to my office within\n90 days of receipt of this Notice. This period may be extended by written request for good\ncause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested that Norgasco Inc. maintain documentation of the safety improvement costs\nassociated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures)\nand submit the total to Dustin Hubbard, Director, Western Region, Pipeline and Hazardous\nMaterials Safety Administration. In correspondence concerning this matter, please refer to CPF\n5-2023-017-NOA, and for each document you submit, please provide a copy in electronic format\nwhenever possible.\n\n\n\nSincerely,\nDUSTIN B\nHUBBARD\nDigitally signed by\nDUSTIN B HUBBARD\nDate: 2023.03.24\n07:47 38 -06'00'\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\nCc: Chris Lyon, PHMSA (21-207466)\nBret Bartholomy, Norgasco, (bret@norgasco.com)","truncated":false,"body_characters":10082}