{"operation":"document","citation":"CPF 520080010W","title":"ENSTAR NATURAL GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-04-23","effective_on":null,"summary":"CLOSED warning letter citing 192.905, 192.917, 192.933, 192.933(d), 192.945(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520080010w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520080010w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520080010w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520080010W","body":"Warning Letter involving ENSTAR NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulations as 192.905,  192.917,  192.933,  192.933(d),  192.945(a). The case was opened on 2008-04-23 and is reported as closed as of 2008-04-23. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520080010W_warning letter_04232008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520080010W/520080010W_warning%20letter_04232008.pdf\n\n520080010w_warning letter_04232008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520080010W/520080010w_warning%20letter_04232008_text.pdf\n\n520080010w_warning letter_04232008_text.pdf\n\nU. S Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n12300 W Dakota Ave, Suite 110\nLakewood, CO 80228\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nApril 23, 2008\nMr. John Lau\nDirector, Transmission Operations\nAlaska Pipehne Company\n401 E International Airport Road\nP 0 Box 190288\nAnchorage, AK 99519-0288\nCPF 5-2008-0010W\nDear Mr Lau\nOn May 7-11, 2007, representatives of the Pipehne and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Alaska\nPipehne Company's Integrity Management program m Anchorage, Alaska.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipehne Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are.\ng 192. 903 What definitions apply to this subpart? The following definitions apply to\nthis subpart:\nHigh consequence area means an area established by one of the methods described\nin paragraphs (1) or (2) as follows:\n(2) The area within a potential impact circle containing — (ii) An identified site.\nIdentified site means each of the following areas: (b) A building that is occupied by\ntwenty (20) or more persons on at least five (5) days a week for ten (10) weeks in\nany twelve (12)-month period. (The days and weeks need not be consecutive. )\n\n\n\nExamples include, but are not limited to, religious facilities, office buildings,\ncommunity centers, general stores, 4-H facilities, or roller skating rinks.\n$ 192. 905 How does an operator identify a high consequence area? (a) General. To\ndetermine which segments of an operator's transmission pipeline system are\ncovered by this subpart, an operator must identify the high consequence areas. An\noperator must use method (1) or (2) from the definition in g 192. 903 to identify a\nhigh consequence area. An operator may apply one method to its entire pipeline\nsystem, or an operator may apply one method to individual portions of the pipeline\nsystem. An operator must describe in its integrity management program which\nmethod it is applying to each portion of the operator's pipeline system. The\ndescription must include the potential impact radius when utilized to establish a\nhigh consequence area. (See appendix E. I. for guidance on identifying high\nconsequence areas. )\n(b)(1) Identified sites. An operator must identify an identified site, for purposes of\nthis subpart, from information the operator has obtained from routine operation\nand maintenance activities and from public officials with safety or emergency\nresponse or planning responsibilities who indicate to the operator that they know of\nlocations that meet the identified site criteria. These public officials could include\nofficials on a local emergency planning commission or relevant Native American\ntribal officials.\nAn HCA was added on 11/30/05 to the BAP as a new HCA, however this was identified\nas the Beluga Power Plant which was m existence and should have been identified as an\norigmal HCA by the December 17, 2004 date\niiEvidence i APC Annual HCA Report for 2005\ng 192. 907 What must an operator do to implement this subpart'?\n(a) General. No later than December 17, 2004, an operator of a covered pipeline\nsegment must develop and follow a written integrity management program that\ncontains all the elements described in g 192. 911 and that addresses the risks on each\ncovered transmission pipeline segment.\n(b) Implementation Standards. In carrying out this subpart, an operator must follow\nthe requirements of this subpart and of ASME/ANSI B31. 8S (ibr, see g 192. 7) and\nits appendices, where specified. An operator may follow an equivalent standard or\npractice only when the operator demonstrates the alternative standard or practice\nprovides an equivalent level of safety to the public and property. In the event of a\nconflict between this subpart and ASME/ANSI B31. 8S, the requirements in this\nsubpart control.\n$ Bl. 91'l How t4es an operator i6enti4y potential threats to pipeline integrity and\nuse the threat identification in its integrity program?\n\n\n\n(a) Threat identification. An operator must identify and evaluate all potential\nthreats to each covered pipeline segment. Potential threats that an operator must\nconsider include, but are not limited to, the threats listed in ASME/ANSI B31. 8S\n(ibr, see g 192. 7), section 2, which are grouped under the following four categories:\n(1) Time dependent threats such as internal corrosion, external corrosion, and\nstress corrosion cracking; (2) Static or resident threats, such as fabrication or\nconstruction defects; (3) Time independent threats such as third party damage and\noutside force damage; and (4) Human error.\nAPC has no documented evaluation for mteractmg threats and there are no program\nprocedures to define how an evaluation is to be performed\niiEvidence i APC IMP Plan, Section 4. 10\n3 g 192. 933 What actions must be taken to address integrity issues?\n(a) General requirements An operator must take prompt action to address all\nanomalous conditions that the operator discovers through the integrity assessment.\nIn addressing all conditions, an operator must evaluate all anomalous conditions\nand remediate those that could reduce a pipeline's integrity. An operator must be\nable to demonstrate that the remediation of the condition will ensure that the\ncondition is unlikely to pose a threat to the integrity of the pipeline until the next\nreassessment of the covered segment. If an operator is unable to respond within the\ntime limits for certain conditions specified in this section, the operator must\ntemporarily reduce the operating pressure of the pipeline or take other action that\nensures the safety of the covered segment. If pressure is reduced, an operator must\ndetermine the temporary reduction in operating pressure using ASME/ANSI B31G\n(ibr, see g 192. 7) or AGA Pipeline Research Committee Project PR — 3 — 805\n(\"RSTRENG\", ibr, see g 192. 7) or reduce the operating pressure to a level not\nexceeding 80% of the level at the time the condition was discovered. (See appendix\nA to this part 192 for information on availability of incorporation by reference\ninformation). A reduction in operating pressure cannot exceed 365 days without an\noperator providing a technical justification that the continued pressure restriction\nwill not jeopardize the integrity of the pipeline.\nTwo anomahes were identified m HCAs during ILI of the City Gate pipehne that met the\ncriteria for immediate conditions Pressure reductions were not taken by APC upon\ndiscovery of these two anomahes and repairs were completed approximately one month\nand approximately 5 months after discovery of these conditions, respectively.\n(Evidence l\nExcavation Inspection Forms — East City Gate — 5/16/05 & 9/13/05, and other\nexcavation report data.\n4. g 192, . 907%hat must an operator do to implement this subpart?\n\n\n\n(a) General. No later than December 17, 2004, an operator of a covered pipeline\nsegment must develop and follow a written integrity management program that\ncontains all the elements described in g 192. 911 and that addresses the risks on each\ncovered transmission pipeline segment.\n(b) Implementation Standards. In carrying out this subpart, an operator must follow\nthe requirements of this subpart and of ASMK/ANSI B31. 8S (ibr, see g 192. 7) and\nits appendices, where specified. An operator may follow an equivalent standard or\npractice only when the operator demonstrates the alternative standard or practice\nprovides an equivalent level of safety to the public and property. In the event of a\nconflict between this subpart and ASMK/ANSI B31. 8S, the requirements in this\nsubpart control.\ng 192. 933 What actions must be taken to address integrity issues?\n(d) Special requirements for scheduling remediation. — (1) Immediate repair\nconditions. An operator's evaluation and remediation schedule must follow ASME/\nANSI B31. 8S, section 7 in providing for immediate repair conditions. To maintain\nsafety, an operator must temporarily reduce operating pressure in accordance with\nparagraph (a) of this section or shut down the pipeline until the operator completes\nthe repair of these conditions. An operator must treat the following conditions as\nimmediate repair conditions:\n(i) A calculation of the remaining strength of the pipe shows a predicted failure\npressure less than or equal to 1. 1 times the maximum allowable operating pressure\nat the location of the anomaly. Suitable remaining strength calculation methods\ninclude, ASME/ANSI B31G; RSTRENG; or an alternative equivalent method of\nremaining strength calculation. These documents are incorporated by reference\nand available at the addresses listed in appendix A to part 192.\n(ii) A dent that has any indication of metal loss, cracking or a stress riser.\n(iii) An indication or anomaly that in the judgment of the person designated by the\noperator to evaluate the assessment results requires immediate action.\nThe two immediate repair conditions on the City Gate pipehne noted m 3 above, were\nnot scheduled for repair m accordance with the requirements of ASME B31. 8S-2001,\nSection 7.\n(Evidence i\nExcavation Inspection Forms — East City Gate — 5/16/05 R, 9/13/05, and other\nexcavation report data\ng 192. 907 What must an operator do to implement this subpart?\n(a) General. No later than December 17, 2004, an operator of a covered pipeline\nsegment must develop anh follow a written integrity management yrogram that\n\n\n\ncontains all the elements described in g 192. 911 and that addresses the risks on each\ncovered transmission pipeline segment.\ng 192. 945 What methods must an operator use to measure program effectiveness?\n(a) General. An operator must include in its integrity management program\nmethods to measure, on a semi-annual basis, whether the program is effective in\nassessing and evaluating the integrity of each covered pipeline segment and in\nprotecting the high consequence areas. These measures must include the four\noverall performance measures specified in ASME/ANSI B31. SS (ibr, see $192. 7),\nsection 9. 4, and the specific measures for each identified threat specified in\nASME/ANSI B31. 8S, Appendix A.\nAPC had not collected data as of the inspection on the threat-specific measures listed in\nTable 9 of ASME B31. 8S and has no process to do so.\n(Evidence l APC IMP Plan, Section 10.\nUnder 49 United States Code, $ 60122, you are subject to a civil penalty not to exceed $100, 000\nfor each violation for each day the violation persists up to a maximum of $1, 000, 000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the items identified in this letter.\nFailure to do so will result in Alaska Pipeline Company being subject to additional enforcement\naction.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2008-0010W. 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\nthe redacted information qualifies for confidential treatment under 5 U. S. C. 552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Strawn (4118987)","truncated":false,"body_characters":12495}