# ENSTAR NATURAL GAS CO — Notice of Amendment

- **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:** Not available
- **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).
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- **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.

Official case documents:

520150005M_Closure Letter_ 11182015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150005M/520150005M_Closure%20Letter_%2011182015_text.pdf

520150005M_Closure Letter_11182015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150005M/520150005M_Closure%20Letter_11182015.pdf

520150005M_notice of amendment_06082015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150005M/520150005M_notice%20of%20amendment_06082015.pdf

520150005M_notice of amendment_06082015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150005M/520150005M_notice%20of%20amendment_06082015_text.pdf

520150005M_Operator Response to Notice_08042015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520150005M/520150005M_Operator%20Response%20to%20Notice_08042015.pdf

520150005M_notice of amendment_06082015_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
June 8, 2015
Mr. Jared Green
President
Enstar Natural Gas Company
P.O. Box 190288
Anchorage, AK 99519-0288
CPF 5-2015-0005M
Dear Mr. Green:
On March 17-21, 2014, April 28-May 2, 2014, and June 2-6, 2014, a representative of the
Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601
of 49 United States Code, inspected Enstar Natural Gas Company’s (Enstar) Standard
Operating Procedures (SOP) in Anchorage, Alaska.
On the basis of the inspection, PHMSA identified the following apparent inadequacies within
Enstar Natural Gas Company’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.
Enstar did not have adequate procedures for the following Maintenance and Operation
activities as required by Subparts L & M, 49 CFR Part 192:



• A process for determining the maximum allowable operating pressure (MAOP) for its
lower pressure distribution system operating at 60 psig or less in accordance with
§192.619.
• A procedure that ensures the checking and servicing of valves used for the safe
operation of a distribution system. Enstar’s SOP 1306 titled “Operating Valve
Maintenance Procedure,” did not specify the types of operating devices that are
permitted for use in operating valves for valve maintenance and inspection activities
per the requirements of §192.747. A valve maintenance record review found
documented use of wrenches, wheels, gear, keys, and cheater bars as operating
devices.
2. §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.
(2) Controlling corrosion in accordance with the operations and maintenance
requirements of Subpart I of this part.
Enstar’s procedures, SOP 1505 titled “Corrosion Control Policy,” were inadequate because
they did not address the following corrosion regulations per the requirements of 49 CFR Part
192, Subpart I:
• §192.452(a) requires that each buried or submerged pipeline that has been converted
to gas service and was installed after July 31, 1971 be protected against external
corrosion unless exempted. Records showed evidence that Enstar converted an 8-inch
gas main line from a jet fuel line on the Joint Base Elmendorf-Richardson in 1995.
While this conversion was done in accordance with 192.452(a), there was no provision
in the O&M manual to address conversions in the future. To that end, Enstar must
ensure future pipelines subject to conversion of service will be protected against
external corrosion in accordance with Subpart I.
• §192.455(a) requires that each buried or submerged pipeline installed after July 31,
1971 be protected against external corrosion, including an external protective coating
and a cathodic protection system installed within 1 year after completion of
construction.
• The procedures also did not adequately describe the process for identifying
interference bonds that are used to monitor cathodic protection system integrity.
2



3. §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.
(3) Making construction records, maps, and operating history available to
appropriate operating personnel.
Enstar’s procedures, SOP 1315 titled “Engineering Records Retention Procedures” did not
adequately address making construction records, maps, and operating history available to the
appropriate operating personnel. Enstar’s current use of a Geographic Information System
(GIS) as a source of pipeline maps must be maintained and updated as appropriate. A
procedure to require that update must be included. The procedures also did not adequately
specify the code requirement of §192.605(b) (3) that operating history, maps, and records be
made available to appropriate operating personnel.
4. §192.615 Emergency plans.
(b) Each operator shall:
(2) Train the appropriate operating personnel to assure that they are
knowledgeable of the emergency procedures and verify that the training is
effective.
Enstar’s procedures, SOP 1105 titled “Enstar Emergency Operating Plan,” did not specify the
methods of emergency preparedness and response training and post-training evaluations. In
addition, the procedures lacked directives to document and act upon the recommendations for
improvement identified in the training evaluations.
5. §192.616 Public awareness.
(a) Except for an operator of a master meter or petroleum gas system covered
under paragraph (j) of this section, each pipeline operator must develop and
implement a written continuing public education program that follows the
guidance provided in the American Petroleum Institute's (API) Recommended
Practice (RP) 1162 (incorporated by reference, see § 192.7).
Enstar’s Public Awareness Program did not adequately address the following per the
requirements of §192.616 and referenced API’s Recommended Practice 1162.
• Program documentation did not show evidence of a written statement of commitment
of management support and allocation of resources and funding as recommended in
API RP 1162 Section 2.7 Program Development Guide and 7.1 Program
Documentation.
• A description of the methods used to identify the individual stakeholders in the four
stakeholder audience groups: (1) affected public, (2) emergency officials, (3) local
3



public officials, and (4) excavators, as well as affected municipalities, school districts,
businesses, and residents. The procedures must clearly identify the process and data
sources used to identify these individual stakeholders for inclusion in outreach efforts.
• The specified frequency of effectiveness evaluations and the stakeholder audiences to
be evaluated. The procedures did not adequately describe the evaluation process and
the methodology used in the effectiveness evaluations.
6. §192.616 Public awareness.
(b) The operator's program must follow the general program recommendations
of API RP 1162 and assess the unique attributes and characteristics of the
operator's pipeline and facilities.
Enstar’s O&M procedures, SOP 1162 “Public Awareness Program,” did not include an
adequate description of each pipeline system's unique attributes and characteristics. SOP 1162
listed several pipeline systems that are included in Enstar’s Public Awareness Program,
including Enstar’s distribution pipelines, Alaska Pipeline Company transmission pipelines,
pipelines owned by others and operated by Enstar or Norstar Pipeline Company, and Cook
Inlet Natural Gas Storage Alaska (CINGSA).
7. §192.805 Qualification program.
Each operator shall have and follow a written qualification program. The
program shall include provisions to:
(h) After December 16, 2004, provide training, as appropriate, to ensure that
individuals performing covered tasks have the necessary knowledge and skills to
perform the tasks in a manner that ensures the safe operation of pipeline
facilities; and
Enstar’s procedures for plastic pipe joints did not adequately address the requirements of
§192.287 “Plastic pipe: Inspection of joints.” Enstar’s SOP 2240 “How to Qualify an
Individual to Make Plastic Pipe Joints” did not specify that no person may carry out the
inspection of joints in plastic pipes unless that person has been qualified by appropriate
training or experience in evaluating the acceptability of plastic pipe joints made under the
applicable joining procedure.
8. §192.1007 What are the required elements of an integrity management plan?
A written integrity management plan must contain procedures for developing
and implementing the following elements:
(b) Identify threats. The operator must consider the following categories of
threats to each gas distribution pipeline: corrosion, natural forces, excavation
damage, other outside force damage, material or welds, equipment failure,
incorrect operations, and other concerns that could threaten the integrity of its
pipeline. An operator must consider reasonably available information to identify
4



existing and potential threats. Sources of data may include, but are not limited to,
incident and leak history, corrosion control records, continuing surveillance
records, patrolling records, maintenance history, and excavation damage
experience.
Enstar’s procedures, SOP 2102 “Distribution Integrity Management Program (DIMP),” did
not consider their association or training from industry trade, training, research and technical
organizations to assist in identifying potential threats. Enstar is associated with or has
employees who received training from the following industry groups: AGA, Western Energy
Institute, PPI, NACE, and Gas Technology Institute.
9. §192.1007 What are the required elements of an integrity management plan?
A written integrity management plan must contain procedures for developing
and implementing the following elements:
(f) Periodic Evaluation and Improvement. An operator must re-evaluate threats
and risks on its entire pipeline and consider the relevance of threats in one
location to other areas. Each operator must determine the appropriate period for
conducting complete program evaluations based on the complexity of its system
and changes in factors affecting the risk of failure. An operator must conduct a
complete program re-evaluation at least every five years. The operator must
consider the results of the performance monitoring in these evaluations.
Enstar’s procedures, SOP 2102 “Distribution Integrity Management Program (DIMP),”
lacked specific directives to monitor completion of issues identified through periodic
evaluation. PHMSA representatives found a lack of documentation to support steps were
taken to address the issues identified, changes were made as needed, the date completed, and
that these changes were communicated to Enstar’s organization as appropriate. SOP 2102
must clearly define each step of the evaluation process.
10. §191.22 National Registry of Pipeline and LNG Operators.
(d) Reporting. An operator must use the OPID issued by PHMSA for all
reporting requirements covered under this subchapter and for submissions to the
National Pipeline Mapping System.
Enstar’s procedures, SOP 1330 titled “Expenditure Request,” did not specify the code
requirement to use OPIDs for all reporting requirements and National Pipeline Mapping
System submissions.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. 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
5



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). 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 a Final Order.
If, after opportunity for a hearing, 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. § 190.237). If you are not contesting this Notice, we propose that
you submit your amended procedures to my office within 60 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.
It is requested (not mandated) that Enstar Natural Gas Company maintain documentation of
the safety improvement costs associated with fulfilling this Notice of Amendment
(preparation/revision of plans, procedures) and submit the total to Chris Hoidal, Director,
Western Region, Pipeline and Hazardous Materials Safety Administration. In correspondence
concerning this matter, please refer to CPF 5-2015-0005M and, for each document you
submit, please provide a copy in electronic format whenever possible to PHP-
WRADMIN@dot.gov.
Sincerely,
Chris Hoidal
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 C. Ishikawa (#145394)
6

520150005M_Closure Letter_11182015.pdf

of Transportation
U.S. Department
Lakewood, CO
12300 W. Dakota Ave., Suite 110
80228
Pipeline and Hazardous Material:
afety Administration
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
November 18, 2015
Mr. Jared Green
President
ENSTAR Natural Gas Company
P.O. Box 190288
Anchorage, AK 99519-0288
CPF 5-2015-0005M
Case Closure
Dear Mr. Green:
On March 17-21, 2014, April 28-May 2, 2014, and June 2-6, 2014, a representative from the
Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49
United States Code, conducted an on-site pipeline safety inspection of ENSTAR Natural Gas
Company's (ENSTAR) Standard Operating Procedures (SOPs) in Anchorage, Alaska. As a result
of the inspection, ENSTAR was issued a Notice of Amendment on June 8, 2015, which proposed
amendment of your procedures.
ENSTAR submitted its amended SOPs on August 10, 2015, in a letter dated August 4, 2015.
PHMSA reviewed the amended procedures and found two items insufficient, as described in a
September 24, 2015 Inadequate Response letter. ESNTAR further modified its SOPs and
submitted them October 26, 2015. PHMSA reviewed the second amendment of the procedures,
and it appears that the inadequacies outlined in the Notice of Amendment and the Inadequate
Response letter, have been corrected.
This letter is to inform you no further action is necessary and this case is now closed.
Sincerely,
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
CC:
PHP-60 Compliance Registry
PHP-500 D. Hassell (#145394)

520150005M_Closure Letter_ 11182015_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
November 18, 2015
Mr. Jared Green
President
ENSTAR Natural Gas Company
P.O. Box 190288
Anchorage, AK 99519-0288
CPF 5-2015-0005M
Case Closure
Dear Mr. Green:
On March 17-21, 2014, April 28-May 2, 2014, and June 2-6, 2014, a representative from the
Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49
United States Code, conducted an on-site pipeline safety inspection of ENSTAR Natural Gas
Company's (ENSTAR) Standard Operating Procedures (SOPs) in Anchorage, Alaska. As a result
of the inspection, ENSTAR was issued a Notice of Amendment on June 8, 2015, which proposed
amendment of your procedures.
ENSTAR submitted its amended SOPs on August 10, 2015, in a letter dated August 4, 2015.
PHMSA reviewed the amended procedures and found two items insufficient, as described in a
September 24, 2015 Inadequate Response letter. ESNTAR further modified its SOPs and
submitted them October 26, 2015. PHMSA reviewed the second amendment of the procedures,
and it appears that the inadequacies outlined in the Notice of Amendment and the Inadequate
Response letter, have been corrected.
This letter is to inform you no further action is necessary and this case is now closed.
Sincerely,
For Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 D. Hassell (#145394)
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