# TITAN ALASKA LNG — Notice of Amendment

**Citation:** CPF 520170014M  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2017-08-30

CLOSED notice of amendment citing 192.605(b)(1), 192.805(a), 192.805(b).

## Document text

Notice of Amendment involving TITAN ALASKA LNG. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(1),  192.805(a),  192.805(b). The case was opened on 2017-08-30 and is reported as closed as of 2017-10-30. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520170014M_Closure Letter_10302017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170014M/520170014M_Closure%20Letter_10302017.pdf

520170014M_Closure Letter_10302017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170014M/520170014M_Closure%20Letter_10302017_text.pdf

520170014M_Notice of Amendment_08302017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170014M/520170014M_Notice%20of%20Amendment_08302017.pdf

520170014M_Notice of Amendment_08302017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170014M/520170014M_Notice%20of%20Amendment_08302017_text.pdf

520170014M_Operator Response To Notice_10052017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170014M/520170014M_Operator%20Response%20To%20Notice_10052017.pdf

520170014M_Notice of Amendment_08302017_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL- RETURN RECEIPT REQUESTED
August 30, 2017
Mr. Daniel W. Britton
President/CEO
Titan Alaska LNG
3408 International Street
Fairbanks, AK 99701
CPF 5-2017-0014M
Dear Mr. Britton:
On March 13 through 15, 2017 representatives of the Pipeline and Hazardous Materials
Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,
inspected Titan Alaska LNG procedures for valve inspection and maintenance.
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
Titan’s plans or procedures, as described below:
1. §192.605 Procedural manual for operations, maintenance, and emergencies.
(b) Maintenance and normal operations. The manual required by paragraph (a)
of this section must include procedures for the following, if applicable, to provide
safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in accordance with each of
the requirements of this subpart and subpart M of this part.



While reviewing Titan 's documentation for the annual inspection of transmission valves, it
became evident that the valve maintenance procedures were not adequate to comply with
192.605(b)(1). Maintenance and operation procedures to ensure proper inspection and
maintenance of transmission valves are required by Subpart M, §192.745. Procedures must
ensure the valves that might be required during an emergency are inspected and partially
operated. Inspection and maintenance tasks defined by these revised procedures must be
recorded per 192.603(b).
2. §192.805(b) Qualification program.
Each operator shall have and follow a written qualification program. The
program shall include provisions to:
(a) Identify covered tasks;
(b) Ensure through evaluation that individuals performing covered tasks are
qualified;
During the records review for both valve maintenance and corrosion control, it became
evident that the valve inspection and maintenance tasks, and painting tasks were not currently
covered in Titan’s Operator Qualification (OQ) procedures as required by 192.805. Both
Valve Inspection and Maintenance as well as Painting/Coating application meet the
requirements of covered tasks and should be included in your OQ procedures.
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 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 45 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.
2



It is requested (not mandated) that Titan Alaska LNG maintain documentation of the safety
improvement costs associated with fulfilling this Notice of Amendment (preparation/revision
of plans, procedures) and submit the total to Kim West, Acting Director, Western Region,
Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this
matter, please refer to CPF 5-2017-0014M and, for each document you submit, please
provide a copy in electronic format whenever possible.
Sincerely,
Kim West
Acting 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 M. Chard (#155026)
3

520170014M_Closure Letter_10302017_text.pdf

VIA FED EX – TRACKING NO. 7706 2920 1025
October 30, 2017
Mr. Daniel Britton
President
Titan Alaska LNG
3408 International Way
Fairbanks, AK 99701
Revised CPF 5-2017-0014M
Closure Letter
Dear Mr. Britton:
On March 13 through 15, 2017, representatives of the Pipeline and Hazardous Materials
Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,
inspected your Titan Alaska LNG system facilities located in Wasilla, Alaska. As a result of
the inspection, Titan was issued a Notice of Amendment on August 30, 2017 which proposed
amendment of your procedures.
Titan submitted its amended procedures dated October 5, 2107. 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 B. Hubbard
Acting Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 M. Chard (#155026)

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/520170014M>
- Source ID: `phmsa-enforcement`
- SHA-256: `e3bc0a9736be8b1bde255b2bf86c0bf3642ce7b55edccda9004366cb38e7e919`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T11:16:34.863Z
- Document slug: `phmsa-enforcement-520170014m`

### Source metadata

```json
{
  "cpf": "520170014M",
  "operator": "TITAN ALASKA LNG",
  "region": "Western",
  "pipelineType": "GAS INTRASTATE ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "192.605(b)(1)",
    "192.805(a)",
    "192.805(b)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 5,
  "attachments": [
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      "bytes": 73980,
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      "bytes": 76606,
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    {
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      "bytes": 362953,
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    }
  ],
  "extractedAgencyDocumentCount": 2,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "TITAN ALASKA LNG"
}
```
