# ENSTAR NATURAL GAS CO — Warning Letter

- **operation:** document
- **citation:** CPF 520110021W
- **title:** ENSTAR NATURAL GAS CO — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2011-10-25
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.481, 192.723.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520110021w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520110021w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520110021w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520110021W
**body:**

Warning Letter involving ENSTAR NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulations as 192.481,  192.723. The case was opened on 2011-10-25 and is reported as closed as of 2011-10-25. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520110021W_warning letter_10252011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520110021W/520110021W_warning%20letter_10252011.pdf

520110021W_warning letter_10252011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520110021W/520110021W_warning%20letter_10252011_text.pdf

520110021W_warning letter_10252011_text.pdf

WARNING LETTER
VIA UPS GROUND
October 25, 2011
Mr. Dave Bredin
Director of Operations
Enstar Natural Gas Co.
401 East International Airport Rd.
P.O. Box 1902888
Anchorage, AK 99519-0288
CPF 5-2011-0021W
Dear Mr. Bredin:
On September 26-28, 2011, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your
Whittier/Girdwood Pipeline in Anchorage, Alaska.
As a result of the inspection, it appears that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and
the probable violations are:
1. §192.481 Atmospheric corrosion control: Monitoring.
(a) Each operator must inspect each pipeline or portion of pipeline that is
exposed to the atmosphere for evidence of atmospheric corrosion, as follows:
If the pipeline is lo-
cated:
Then the frequency of inspection is:
Onshore …………. At least once every 3 calendar years,
but with intervals not exceeding 39
months
Offshore …………. At least once each calendar year, but
with intervals not exceeding 15
months
(b) During inspections the operator must give particular attention to pipe at
soil-to-air interfaces, under thermal insulation, under disbonded coatings, at



pipe supports, in splash zones, at deck penetrations, and in spans over water.
1) Enstar’s pipeline runs approximately 3 miles through a tunnel just before
Whittier. The pipe in the tunnel is subject to atmospheric corrosion
monitoring.
2) Entsar’s annually ground patrol indicated several locations where the pipeline
Is exposed and is subject to atmospheric corrosion.
2. §192.723 Distribution systems: Leakage surveys.
(a) Each operator of a distribution system shall conduct periodic leakage
surveys in accordance with this section.
(b) The type and scope of the leakage control program must be determined by
the nature of the operations and the local conditions, but it must meet the
following minimum requirements:
(1) A leakage survey with leak detector equipment must be conducted in
business districts, including tests of the atmosphere in gas, electric, telephone,
sewer, and water system manholes, at cracks in pavement and sidewalks, and at
other locations providing an opportunity for finding gas leaks, at intervals not
exceeding 15 months, but at least once each calendar year.
(2) A leakage survey with leak detector equipment must be conducted outside
business districts as frequently as necessary, but at least once every 5 calendar
years at intervals not exceeding 63 months. However, for cathodically
unprotected distribution lines subject to § 192.465(e)
on which electrical surveys for corrosion are impractical, a leakage survey must
be conducted at least once every 3 calendar years at intervals not exceeding 39
months.
The right-of-way between Power Line Pass and Twenty Mile has become overgrown
with vegetation and prevents effective patrolling and leak detection.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
$100,000 for each violation for each day the violation persists up to a maximum of
$1,000,000 for any related series of violations. We have reviewed the circumstances and
supporting documents involved in this case, and have decided not to conduct additional
enforcement action or penalty assessment proceedings at this time. We advise you to correct
the items identified in this letter. Failure to do so will result in Enstar Natural Gas Company
being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer
to CPF 5-2011-0021W. 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
2



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).
Sincerely,
Dennis Hinnah
Deputy Director, Western Region
Pipeline and Hazardous Materials Safety Administration
Cc: PHP-60 Compliance Registry
PHP-500 B. Flanders (#135541)
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