{"operation":"document","citation":"CPF 520160023W","title":"FAIRBANKS NATURAL GAS — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-10-14","effective_on":null,"summary":"CLOSED warning letter citing 192.1007(f), 192.739(a), 192.807(a), 192.807(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520160023w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520160023w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520160023w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520160023W","body":"Warning Letter involving FAIRBANKS NATURAL GAS. PHMSA's enforcement data identifies the cited regulations as 192.1007(f),  192.739(a),  192.807(a),  192.807(b). The case was opened on 2016-10-14 and is reported as closed as of 2016-10-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520160023W_Operator Response to Notice_11302016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160023W/520160023W_Operator%20Response%20to%20Notice_11302016.pdf\n\n520160023W_Warning Letter_10142016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160023W/520160023W_Warning%20Letter_10142016.pdf\n\n520160023W_Warning Letter_10142016_tect.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160023W/520160023W_Warning%20Letter_10142016_tect.pdf\n\n520160023W_Warning Letter_10142016_tect.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 14, 2016\nMr. Daniel W. Britton\nPresident / CEO\nFairbanks Natural Gas\n3408 International Way\nFairbanks, AK 99701\nCPF 5-2016-0023W\nDear Mr. Britton:\nOn April 18 through April 20, 2016, and on June 6 through June 9, 2016, representatives of\nthe Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter\n601 of 49 United States Code, inspected your Fairbanks Natural Gas (FNG) Distribution\nsystem located in Fairbanks, Alaska.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violations are:\n1) §192.807 Recordkeeping.\nEach operator shall maintain records that demonstrate compliance with this\nsubpart.\n(a) Qualification records shall include:\n(1) Identification of qualified individual(s);\n(2) Identification of the covered tasks the individual is qualified to perform;\n(3) Date(s) of current qualification; and\n(4) Qualification method(s).\n\n\n\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.\nAt the time of the inspection, FNG personnel were not able to provide records of personnel\nqualifications for joining plastic pipe CFR 192.285 and records of personnel qualification for\ninspection of plastic pipe joints CFR 192.287 for year 2013. FNG appears to be in violation\nof CFR 192.807(b) which requires records to be kept for 5 years 192.807(b). FNG personnel\nwere however, able to supply qualification records for individuals qualified in joining plastic\npipe and inspection of plastic pipe joints for years 2014 and 2015.\n2) §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.\nAt the time of the inspection, FNG personnel were not able to supply validation records of\ntheir “risk ranking” process of the FNG integrity management plan. FNG personnel were also\nunable to provide implementation records for all elements of the FNG integrity management\nplan. Records of validation of the risk ranking process and implementation records of an\nintegrity management plan are required by CFR 192.1007(f).\n3. §192.739 Pressure limiting and regulating stations: Inspection and testing.\n(a) Each pressure limiting station, relief device (except rupture discs), and\nPressure regulating station and its equipment must be subjected at intervals not\nexceeding 15 months, but at least once each calendar year, to inspections and\ntests to determine that it is-\n(1) In good mechanical condition;\n(2) Adequate from the standpoint of capacity and reliability of operation for the\nservice in which it is employed;\n(3) Except as provided in paragraph (b) of this section, set to control or relieve at\nthe correct pressure consistent with the pressure limits of §192.201(a); and\n(4) Properly installed and protected from dirt, liquids, or other conditions that\nmight prevent proper operation.\nAt the time of the inspection, FNG personnel were not able to provide pressure safety valve\nrecords required by CFR 192.739 for year 2013. FNG personnel were able to supply pressure\nsafety valve records required by CFR 192.739 for 2014 and 2015.\n\n\n\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$205,638 per violation per day the violation persists up to a maximum of $2,056,380 for a\nrelated series of violations. For violations occurring between January 4, 2012 and August 1,\n2016, the maximum penalty may not exceed $200,000 per violation per day, with a maximum\npenalty not to exceed $2,000,000 for a related series of violations. We have reviewed the\ncircumstances and supporting documents involved in this case, and have decided not to\nconduct additional enforcement action or penalty assessment proceedings at this time. We\nadvise you to correct the items identified in this letter. Failure to do so will result in\nFairbanks Natural Gas being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2016-0023W. 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 R. Guisinger (#152966)\n\n520160023W_Warning Letter_10142016.pdf\n\nof Transportation\nU.S. Department\n12300 W. Dakota Ave.., Suite 110\nLakewood, CO 80228\nPipeline and Hazardous Materials\nSafety Administration\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 14, 2016\nMr. Daniel W. Britton\nPresident / CEO\nFairbanks Natural Gas\n3408 International Way\nFairbanks, AK 99701\nCPF 5-2016-0023W\nDear Mr. Britton:\nOn April 18 through April 20, 2016, and on June 6 through June 9, 2016, representatives of\nthe Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter\n601 of 49 United States Code, inspected your Fairbanks Natural Gas (FNG) Distribution\nsystem located in Fairbanks, Alaska.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violations are:\n1)\n§192.807 Recordkeeping.\nEach operator shall maintain records that demonstrate compliance with this\nsubpart.\n(a) Qualification records shall include:\n(1) Identification of qualified individual(s);\n(2) Identification of the covered tasks the individual is qualified to perform;\n(3) Date(s) of current qualification; and\n(4) Qualification method(s).\n\n\n\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.\nAt the time of the inspection, FNG personnel were not able to provide records of personnel\nqualifications for joining plastic pipe CFR 192.285 and records of personnel qualification for\ninspection of plastic pipe joints CFR 192.287 for year 2013. ENG appears to be in violation\nof CFR 192.807(b) which requires records to be kept for 5 years 192.807(b). FNG personnel\nwere however, able to supply qualification records for individuals qualified in joining plastic\npipe and inspection of plastic pipe joints for years 2014 and 2015.\n§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(t) 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.\nAt the time of the inspection, ENG personnel were not able to supply validation records of\ntheir \"risk ranking\" process of the FNG integrity management plan. FNG personnel were also\nunable to provide implementation records for all elements of the FNG integrity management\nplan. Records of validation of the risk ranking process and implementation records of an\nintegrity management plan are required by CFR 192.1007(f).\n§192.739 Pressure limiting and regulating stations: Inspection and testing.\n(a) Each pressure limiting station, relief device (except rupture discs), and\nPressure regulating station and its equipment must be subjected at intervals not\nexceeding 15 months, but at least once each calendar year, to inspections and\ntests to determine that it is-\n(1) In good mechanical condition;\n(2) Adequate from the standpoint of capacity and reliability of operation for the\nservice in which it is employed;\n(3) Except as provided in paragraph (b) of this section, set to control or relieve at\nthe correct pressure consistent with the pressure limits of §192.201(a); and\n(4) Properly installed and protected from dirt, liquids, or other conditions that\nmight prevent proper operation.\nAt the time of the inspection, FNG personnel were not able to provide pressure safety valve\nrecords required by CFR 192.739 for year 2013. ENG personnel were able to supply pressure\nsafety valve records required by CFR 192.739 for 2014 and 2015.\n\n\n\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$205,638 per violation per day the violation persists up to a maximum of $2,056,380 for a\nrelated series of violations. For violations occurring between January 4, 2012 and August 1,\n2016, the maximum penalty may not exceed $200,000 per violation per day, with a maximum\npenalty not to exceed $2,000,000 for a related series of violations. We have reviewed the\ncircumstances and supporting documents involved in this case, and have decided not to\nconduct additional enforcement action or penalty assessment proceedings at this time. We\nadvise you to correct the items identified in this letter. Failure to do so will result in\nFairbanks Natural Gas being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2016-0023W. 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),\nlong with the complete original document you must provide a second copy of the document\nvith the portions you believe qualify for confidential treatment redacted and an explanation o\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nCC:\nPHP-60 Compliance Registry\nPHP-500 R. Guisinger (#152966)","truncated":false,"body_characters":12356}