# ENSTAR NATURAL GAS CO — Warning Letter

- **operation:** document
- **citation:** CPF 520160022W
- **title:** ENSTAR NATURAL GAS CO — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2016-10-06
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.467(c), 192.631(e)(5).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520160022w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520160022w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520160022w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520160022W
**body:**

Warning Letter involving ENSTAR NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulations as 192.467(c),  192.631(e)(5). The case was opened on 2016-10-06 and is reported as closed as of 2016-10-06. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520160022W_Warning Letter_10062016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160022W/520160022W_Warning%20Letter_10062016.pdf

520160022W_Warning Letter_10062016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160022W/520160022W_Warning%20Letter_10062016_text.pdf

520160022W_Warning Letter_10062016_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
October 6, 2016
Mr. Jared Green
President
ENSTAR Natural Gas Company
P.O. Box 190288
Anchorage, AK 99519-0288
CPF 5-2016-0022W
Dear Mr. Green:
On April 18 through 29 and May 13 through 17, 2016, representatives 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) Operation and Maintenance
procedures in Anchorage, Alaska and distribution pipelines on the Kenai Peninsula, Matanuska,
Susitna valleys, Girdwood, and Whittier, Alaska.
As a result of the inspection, it is alleged that that ENSTAR has committed probable violations of
the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and
the probable violations are:
1. §192.467 External corrosion control: Electrical isolation.
(c) Except for unprotected copper inserted in ferrous pipe, each pipeline must be
electrically isolated from metallic casings that are a part of the underground system.
However, if isolation is not achieved because it is impractical, other measures must
be taken to minimize corrosion of the pipeline inside the casing.
Records of pipe-to-soil corrosion control measurements (potential) for the years 2014 and 2015
showed two casings that were not electrically isolated on the main pipeline. The test stations for
the casings were located at Mile Post (MP .4- Door #1 Whittier Tunnel MP) and at (MP 4.95) on
the Whittier eight (8)-inch pipeline. The measurements of potential for the main pipeline and the
casing were nearly identical



at these test stations. These similar potentials indicate the two structures are not isolated. The
pipeline and casing must either be isolated from each other or additional measures to prevent
corrosion of the main carrier pipeline must be taken.
2. §192.631 Control room management.
…(e) Alarm management. Each operator using a SCADA system must have a written
alarm management plan to provide for effective controller response to alarms. An
operator's plan must include provisions to:
…(5) Monitor the content and volume of general activity being directed to and
required of each controller at least once each calendar year, but at intervals not to
exceed 15 months, that will assure controllers have sufficient time to analyze and
react to incoming alarms;
ENSTAR has not assured that controllers have sufficient time to analyze and react to incoming
alarms. ENSTAR has provided a monthly alarm review which indicates the maximum volume
and content of alarms being directed to each controller, but has not demonstrated that their
controllers have sufficient time to analyze that volume.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $205,638
per violation per day the violation persists up to a maximum of $2,056,380 for a related series of
violations. For violation occurring between January 4, 2012 to August 1, 2016, the maximum
penalty may not exceed $200,000 per violation per day, with a maximum penalty not to exceed
$2,000,000 for a related series of violations. For violations occurring prior to January 4, 2012, the
maximum penalty may not exceed $100,000 per violation per day, with a maximum penalty not to
exceed $1,000,000 for a 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 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 5-2016-0022W. 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 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,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 J. Gano (#152025, #152026, #152027)
- **truncated:** false
- **body characters:** 5185
