{"operation":"document","citation":"CPF 520150004W","title":"ENSTAR NATURAL GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-05-20","effective_on":null,"summary":"CLOSED warning letter citing 192.1007(b), 192.453, 192.479(a), 192.616(c), 192.807(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520150004w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520150004w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520150004w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520150004W","body":"Warning Letter involving ENSTAR NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulations as 192.1007(b),  192.453,  192.479(a),  192.616(c),  192.807(b). The case was opened on 2015-05-20 and is reported as closed as of 2015-05-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520150004W_warning letter_05202015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150004W/520150004W_warning%20letter_05202015.pdf\n\n520150004W_warning letter_05202015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150004W/520150004W_warning%20letter_05202015_text.pdf\n\n520150004W_warning letter_05202015_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 20, 2015\nMs. Colleen Starring\nPresident\nEnstar Natural Gas Company\nP.O. Box 190288\nAnchorage, AK 99519-0288\nCPF 5-2015-0004W\nDear Ms. Starring:\nOn March 17-21, 2014, April 28-May 2, 2014, and June 2-6, 2014, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601\nof 49 United States Code, inspected your natural gas distribution system in Anchorage,\nAlaska.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violation(s) are:\n1. §192.453 General.\nThe corrosion control procedures required by §192.605(b)(2), including those for\nthe design, installation, operation, and maintenance of cathodic protection\nsystems, must be carried out by, or under the direction of, a person qualified in\npipeline corrosion control methods.\nEnstar Natural Gas Company (Enstar) did not document the qualified individuals who\nperformed periodic rectifier inspections and obtained readings. PHMSA representatives\ndiscovered Corrosion Test Site Record forms, which were used to document rectifier\ninspections and readings for Enstar’s cathodic protection system in the field that did not\nindicate the individual qualified person who performed the task. Names and/or signatures\nwere missing from the forms on each date a particular rectifier location was inspected.\n\n\n\nPHMSA representatives were unable to verify if a qualified individual performed the covered\ntask on each date of inspection. Enstar Operator Qualification Plan includes rectifier\ninspection and readings as covered task number ASME-0101 “Inspect Rectifier and Obtain\nReadings.”\n2. §192.479 Atmospheric corrosion control – General\n(a) Each operator must clean and coat each pipeline or portion of pipeline that is\nexposed to the atmosphere, except pipelines under paragraph (c) of this section.\nEnstar did not demonstrate that atmospheric corrosion repairs were completed as a result of\ntheir periodic regulator station inspections. PHMSA representatives discovered Regulator\nStation Maintenance Records for stations numbered A136 “Ft. Richardson Laundry” and\nA140 “5th and Davis Hwy” that indicated “needs paint” on the date of inspection, April 24,\n2013. At the time of inspection, no documentation was provided to demonstrate that the\n“needs paint” indication was addressed and the date of completion.\n3. §192.616 Public awareness.\n(c) The operator must follow the general program recommendations, including\nbaseline and supplemental requirements of API RP 1162, unless the operator\nprovides justification in its program or procedural manual as to why compliance\nwith all or certain provisions of the recommended practice is not practicable and\nnot necessary for safety.\nEnstar did not follow its procedures and did not adequately demonstrate that they are in\ncontact with all emergency officials annually. Enstar’s Standard Operating Procedures (SOP)\n1162, titled “Public Awareness Program,” described a direct mailing process to send letters to\nemergency officials every year by First Class US Mail. At the time of the inspection, PHMSA\nrepresentatives discovered only one letter that was mailed to emergency officials, dated\nOctober 3, 2007.\nEnstar did not adequately document audit results, findings, and/or improvements needed as a\nresult of its annual public awareness program audit for 2012 and 2013. Enstar did not\nadequately document that it had addressed the action items indicated on audit records and\ncompleted implementation of changes to the program.\nEnstar did not follow API RP 1162 and did not complete effectiveness evaluations for all\nstakeholder audience groups in their Public Awareness Program (PAP). PHMSA\nrepresentatives discovered that Enstar performed an effectiveness evaluation for only one\nstakeholder audience group, the general public. Documentation was not provided for\neffectiveness evaluations covering emergency officials, local public officials, and excavators.\n\n\n\nEnstar did not document its effectiveness evaluation results, findings, and/or improvements\nafter completion of its 2009 and 2011 evaluations for the general public. Enstar did not\ndemonstrate that it reviewed the general public’s assessment results to determine PAP\neffectiveness and implemented any changes if needed.\n4. §192. 807 Recordkeeping.\nEach operator shall maintain records that demonstrate compliance with this\nsubpart.\n(b) Records supporting an individual’s current qualification shall be maintained\nwhile the individual is performing the covered task. Records of prior\nqualification and records of individuals no longer performing covered tasks shall\nbe retained for a period of five years.\nPHMSA representatives discovered Operator Qualification (OQ) training records for two\nEnstar supervisors that were not up-to-date with the expected qualification needs. These two\nindividuals were not re-qualified for covered task SOP 1150 titled “Damage Response\nProcedures” within the required 3 year re-qualification period. Both individuals last took the\nrequired written test for this covered task in 2009. Enstar must complete re-qualification for\nthese individuals or ensure that they do not perform any part of the covered task unless under\nthe direct supervision of a qualified individual.\n5. §192. 1007 What are the required elements of an integrity management plan?\nA written integrity management plan must contain procedures for developing\nand implementing the following elements:\n(b) Identify threats. The operator must consider the following categories of\nthreats to each gas distribution pipeline: corrosion, natural forces, excavation\ndamage, other outside force damage, material or welds, equipment failure,\nincorrect operations, and other concerns that could threaten the integrity of its\npipeline. An operator must consider reasonably available information to identify\nexisting and potential threats. Sources of data may include, but are not limited to,\nincident and leak history, corrosion control records, continuing surveillance\nrecords, patrolling records, maintenance history, and excavation damage\nexperience.\nEnstar did not adequately demonstrate that its Distribution Integrity Management Program\n(DIMP) addressed risks specific to its higher pressure distribution main lines. PHMSA\nrepresentatives discovered higher pressure distribution main lines were included in the DIMP\nin addition to its lower pressure distribution system.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\n\n\n\nrelated series of violations. For violations occurring prior to January 4, 2012, the maximum\npenalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct\nthe item(s) identified in this letter. Failure to do so will result in Enstar Natural Gas Company\nbeing subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2015-0004W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 C. Ishikawa (#145394)","truncated":false,"body_characters":8867}