{"operation":"document","citation":"CPF 520150005M","title":"ENSTAR NATURAL GAS CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-06-08","effective_on":null,"summary":"CLOSED notice of amendment citing 191.22(d), 192.1007(b), 192.1007(f), 192.605(b)(1), 192.605(b)(2), 192.605(b)(3), 192.615(b)(2), 192.616(a), 192.616(b), 192.805(h).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520150005m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520150005m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520150005m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520150005M","body":"Notice of Amendment involving ENSTAR NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulations as 191.22(d),  192.1007(b),  192.1007(f),  192.605(b)(1),  192.605(b)(2),  192.605(b)(3),  192.615(b)(2),  192.616(a),  192.616(b),  192.805(h). The case was opened on 2015-06-08 and is reported as closed as of 2015-11-18. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520150005M_Closure Letter_ 11182015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150005M/520150005M_Closure%20Letter_%2011182015_text.pdf\n\n520150005M_Closure Letter_11182015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150005M/520150005M_Closure%20Letter_11182015.pdf\n\n520150005M_notice of amendment_06082015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150005M/520150005M_notice%20of%20amendment_06082015.pdf\n\n520150005M_notice of amendment_06082015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150005M/520150005M_notice%20of%20amendment_06082015_text.pdf\n\n520150005M_Operator Response to Notice_08042015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150005M/520150005M_Operator%20Response%20to%20Notice_08042015.pdf\n\n520150005M_notice of amendment_06082015_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 8, 2015\nMr. Jared Green\nPresident\nEnstar Natural Gas Company\nP.O. Box 190288\nAnchorage, AK 99519-0288\nCPF 5-2015-0005M\nDear Mr. Green:\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 Enstar Natural Gas Company’s (Enstar) Standard\nOperating Procedures (SOP) in Anchorage, Alaska.\nOn the basis of the inspection, PHMSA identified the following apparent inadequacies within\nEnstar Natural Gas Company’s plans or procedures, as described below:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies\n(b) Maintenance and normal operations. The manual required by paragraph (a)\nof this section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in accordance with each\nof the requirements of this subpart and Subpart M of this part.\nEnstar did not have adequate procedures for the following Maintenance and Operation\nactivities as required by Subparts L & M, 49 CFR Part 192:\n\n\n\n• A process for determining the maximum allowable operating pressure (MAOP) for its\nlower pressure distribution system operating at 60 psig or less in accordance with\n§192.619.\n• A procedure that ensures the checking and servicing of valves used for the safe\noperation of a distribution system. Enstar’s SOP 1306 titled “Operating Valve\nMaintenance Procedure,” did not specify the types of operating devices that are\npermitted for use in operating valves for valve maintenance and inspection activities\nper the requirements of §192.747. A valve maintenance record review found\ndocumented use of wrenches, wheels, gear, keys, and cheater bars as operating\ndevices.\n2. §192.605 Procedural manual for operations, maintenance, and emergencies\n(b) Maintenance and normal operations. The manual required by paragraph (a)\nof this section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(2) Controlling corrosion in accordance with the operations and maintenance\nrequirements of Subpart I of this part.\nEnstar’s procedures, SOP 1505 titled “Corrosion Control Policy,” were inadequate because\nthey did not address the following corrosion regulations per the requirements of 49 CFR Part\n192, Subpart I:\n• §192.452(a) requires that each buried or submerged pipeline that has been converted\nto gas service and was installed after July 31, 1971 be protected against external\ncorrosion unless exempted. Records showed evidence that Enstar converted an 8-inch\ngas main line from a jet fuel line on the Joint Base Elmendorf-Richardson in 1995.\nWhile this conversion was done in accordance with 192.452(a), there was no provision\nin the O&M manual to address conversions in the future. To that end, Enstar must\nensure future pipelines subject to conversion of service will be protected against\nexternal corrosion in accordance with Subpart I.\n• §192.455(a) requires that each buried or submerged pipeline installed after July 31,\n1971 be protected against external corrosion, including an external protective coating\nand a cathodic protection system installed within 1 year after completion of\nconstruction.\n• The procedures also did not adequately describe the process for identifying\ninterference bonds that are used to monitor cathodic protection system integrity.\n2\n\n\n\n3. §192.605 Procedural manual for operations, maintenance, and emergencies\n(b) Maintenance and normal operations. The manual required by paragraph (a)\nof this section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(3) Making construction records, maps, and operating history available to\nappropriate operating personnel.\nEnstar’s procedures, SOP 1315 titled “Engineering Records Retention Procedures” did not\nadequately address making construction records, maps, and operating history available to the\nappropriate operating personnel. Enstar’s current use of a Geographic Information System\n(GIS) as a source of pipeline maps must be maintained and updated as appropriate. A\nprocedure to require that update must be included. The procedures also did not adequately\nspecify the code requirement of §192.605(b) (3) that operating history, maps, and records be\nmade available to appropriate operating personnel.\n4. §192.615 Emergency plans.\n(b) Each operator shall:\n(2) Train the appropriate operating personnel to assure that they are\nknowledgeable of the emergency procedures and verify that the training is\neffective.\nEnstar’s procedures, SOP 1105 titled “Enstar Emergency Operating Plan,” did not specify the\nmethods of emergency preparedness and response training and post-training evaluations. In\naddition, the procedures lacked directives to document and act upon the recommendations for\nimprovement identified in the training evaluations.\n5. §192.616 Public awareness.\n(a) Except for an operator of a master meter or petroleum gas system covered\nunder paragraph (j) of this section, each pipeline operator must develop and\nimplement a written continuing public education program that follows the\nguidance provided in the American Petroleum Institute's (API) Recommended\nPractice (RP) 1162 (incorporated by reference, see § 192.7).\nEnstar’s Public Awareness Program did not adequately address the following per the\nrequirements of §192.616 and referenced API’s Recommended Practice 1162.\n• Program documentation did not show evidence of a written statement of commitment\nof management support and allocation of resources and funding as recommended in\nAPI RP 1162 Section 2.7 Program Development Guide and 7.1 Program\nDocumentation.\n• A description of the methods used to identify the individual stakeholders in the four\nstakeholder audience groups: (1) affected public, (2) emergency officials, (3) local\n3\n\n\n\npublic officials, and (4) excavators, as well as affected municipalities, school districts,\nbusinesses, and residents. The procedures must clearly identify the process and data\nsources used to identify these individual stakeholders for inclusion in outreach efforts.\n• The specified frequency of effectiveness evaluations and the stakeholder audiences to\nbe evaluated. The procedures did not adequately describe the evaluation process and\nthe methodology used in the effectiveness evaluations.\n6. §192.616 Public awareness.\n(b) The operator's program must follow the general program recommendations\nof API RP 1162 and assess the unique attributes and characteristics of the\noperator's pipeline and facilities.\nEnstar’s O&M procedures, SOP 1162 “Public Awareness Program,” did not include an\nadequate description of each pipeline system's unique attributes and characteristics. SOP 1162\nlisted several pipeline systems that are included in Enstar’s Public Awareness Program,\nincluding Enstar’s distribution pipelines, Alaska Pipeline Company transmission pipelines,\npipelines owned by others and operated by Enstar or Norstar Pipeline Company, and Cook\nInlet Natural Gas Storage Alaska (CINGSA).\n7. §192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The\nprogram shall include provisions to:\n(h) After December 16, 2004, provide training, as appropriate, to ensure that\nindividuals performing covered tasks have the necessary knowledge and skills to\nperform the tasks in a manner that ensures the safe operation of pipeline\nfacilities; and\nEnstar’s procedures for plastic pipe joints did not adequately address the requirements of\n§192.287 “Plastic pipe: Inspection of joints.” Enstar’s SOP 2240 “How to Qualify an\nIndividual to Make Plastic Pipe Joints” did not specify that no person may carry out the\ninspection of joints in plastic pipes unless that person has been qualified by appropriate\ntraining or experience in evaluating the acceptability of plastic pipe joints made under the\napplicable joining procedure.\n8. §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\n4\n\n\n\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’s procedures, SOP 2102 “Distribution Integrity Management Program (DIMP),” did\nnot consider their association or training from industry trade, training, research and technical\norganizations to assist in identifying potential threats. Enstar is associated with or has\nemployees who received training from the following industry groups: AGA, Western Energy\nInstitute, PPI, NACE, and Gas Technology Institute.\n9. §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(f) Periodic Evaluation and Improvement. An operator must re-evaluate threats\nand risks on its entire pipeline and consider the relevance of threats in one\nlocation to other areas. Each operator must determine the appropriate period for\nconducting complete program evaluations based on the complexity of its system\nand changes in factors affecting the risk of failure. An operator must conduct a\ncomplete program re-evaluation at least every five years. The operator must\nconsider the results of the performance monitoring in these evaluations.\nEnstar’s procedures, SOP 2102 “Distribution Integrity Management Program (DIMP),”\nlacked specific directives to monitor completion of issues identified through periodic\nevaluation. PHMSA representatives found a lack of documentation to support steps were\ntaken to address the issues identified, changes were made as needed, the date completed, and\nthat these changes were communicated to Enstar’s organization as appropriate. SOP 2102\nmust clearly define each step of the evaluation process.\n10. §191.22 National Registry of Pipeline and LNG Operators.\n(d) Reporting. An operator must use the OPID issued by PHMSA for all\nreporting requirements covered under this subchapter and for submissions to the\nNational Pipeline Mapping System.\nEnstar’s procedures, SOP 1330 titled “Expenditure Request,” did not specify the code\nrequirement to use OPIDs for all reporting requirements and National Pipeline Mapping\nSystem submissions.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\n5\n\n\n\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond\nwithin 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the\nallegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to\nfind facts as alleged in this Notice without further notice to you and to issue a Final Order.\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the\ninadequacies (49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that\nyou submit your amended procedures to my office within 60 days of receipt of this Notice.\nThis period may be extended by written request for good cause. Once the inadequacies\nidentified herein have been addressed in your amended procedures, this enforcement action\nwill be closed.\nIt is requested (not mandated) that Enstar Natural Gas Company maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Chris Hoidal, Director,\nWestern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 5-2015-0005M and, for each document you\nsubmit, please provide a copy in electronic format whenever possible to PHP-\nWRADMIN@dot.gov.\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 C. Ishikawa (#145394)\n6\n\n520150005M_Closure Letter_11182015.pdf\n\nof Transportation\nU.S. Department\nLakewood, CO\n12300 W. Dakota Ave., Suite 110\n80228\nPipeline and Hazardous Material:\nafety Administration\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 18, 2015\nMr. Jared Green\nPresident\nENSTAR Natural Gas Company\nP.O. Box 190288\nAnchorage, AK 99519-0288\nCPF 5-2015-0005M\nCase Closure\nDear Mr. Green:\nOn March 17-21, 2014, April 28-May 2, 2014, and June 2-6, 2014, a representative from the\nPipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49\nUnited States Code, conducted an on-site pipeline safety inspection of ENSTAR Natural Gas\nCompany's (ENSTAR) Standard Operating Procedures (SOPs) in Anchorage, Alaska. As a result\nof the inspection, ENSTAR was issued a Notice of Amendment on June 8, 2015, which proposed\namendment of your procedures.\nENSTAR submitted its amended SOPs on August 10, 2015, in a letter dated August 4, 2015.\nPHMSA reviewed the amended procedures and found two items insufficient, as described in a\nSeptember 24, 2015 Inadequate Response letter. ESNTAR further modified its SOPs and\nsubmitted them October 26, 2015. PHMSA reviewed the second amendment of the procedures,\nand it appears that the inadequacies outlined in the Notice of Amendment and the Inadequate\nResponse letter, have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed.\nSincerely,\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nCC:\nPHP-60 Compliance Registry\nPHP-500 D. Hassell (#145394)\n\n520150005M_Closure Letter_ 11182015_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 18, 2015\nMr. Jared Green\nPresident\nENSTAR Natural Gas Company\nP.O. Box 190288\nAnchorage, AK 99519-0288\nCPF 5-2015-0005M\nCase Closure\nDear Mr. Green:\nOn March 17-21, 2014, April 28-May 2, 2014, and June 2-6, 2014, a representative from the\nPipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49\nUnited States Code, conducted an on-site pipeline safety inspection of ENSTAR Natural Gas\nCompany's (ENSTAR) Standard Operating Procedures (SOPs) in Anchorage, Alaska. As a result\nof the inspection, ENSTAR was issued a Notice of Amendment on June 8, 2015, which proposed\namendment of your procedures.\nENSTAR submitted its amended SOPs on August 10, 2015, in a letter dated August 4, 2015.\nPHMSA reviewed the amended procedures and found two items insufficient, as described in a\nSeptember 24, 2015 Inadequate Response letter. ESNTAR further modified its SOPs and\nsubmitted them October 26, 2015. PHMSA reviewed the second amendment of the procedures,\nand it appears that the inadequacies outlined in the Notice of Amendment and the Inadequate\nResponse letter, have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed.\nSincerely,\nFor Chris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 D. Hassell (#145394)","truncated":false,"body_characters":17823}