# FAIRBANKS NATURAL GAS — Warning Letter

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

Official case documents:

520160023W_Operator Response to Notice_11302016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160023W/520160023W_Operator%20Response%20to%20Notice_11302016.pdf

520160023W_Warning Letter_10142016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160023W/520160023W_Warning%20Letter_10142016.pdf

520160023W_Warning Letter_10142016_tect.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160023W/520160023W_Warning%20Letter_10142016_tect.pdf

520160023W_Warning Letter_10142016_tect.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
October 14, 2016
Mr. Daniel W. Britton
President / CEO
Fairbanks Natural Gas
3408 International Way
Fairbanks, AK 99701
CPF 5-2016-0023W
Dear Mr. Britton:
On April 18 through April 20, 2016, and on June 6 through June 9, 2016, representatives of
the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter
601 of 49 United States Code, inspected your Fairbanks Natural Gas (FNG) Distribution
system located in Fairbanks, Alaska.
As a result of the inspection, it is alleged that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and
the probable violations are:
1) §192.807 Recordkeeping.
Each operator shall maintain records that demonstrate compliance with this
subpart.
(a) Qualification records shall include:
(1) Identification of qualified individual(s);
(2) Identification of the covered tasks the individual is qualified to perform;
(3) Date(s) of current qualification; and
(4) Qualification method(s).



(b) Records supporting an individual’s current qualification shall be maintained
while the individual is performing the covered task. Records of prior
qualification and records of individuals no longer performing covered tasks shall
be retained for a period of five years.
At the time of the inspection, FNG personnel were not able to provide records of personnel
qualifications for joining plastic pipe CFR 192.285 and records of personnel qualification for
inspection of plastic pipe joints CFR 192.287 for year 2013. FNG appears to be in violation
of CFR 192.807(b) which requires records to be kept for 5 years 192.807(b). FNG personnel
were however, able to supply qualification records for individuals qualified in joining plastic
pipe and inspection of plastic pipe joints for years 2014 and 2015.
2) §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.
At the time of the inspection, FNG personnel were not able to supply validation records of
their “risk ranking” process of the FNG integrity management plan. FNG personnel were also
unable to provide implementation records for all elements of the FNG integrity management
plan. Records of validation of the risk ranking process and implementation records of an
integrity management plan are required by CFR 192.1007(f).
3. §192.739 Pressure limiting and regulating stations: Inspection and testing.
(a) Each pressure limiting station, relief device (except rupture discs), and
Pressure regulating station and its equipment must be subjected at intervals not
exceeding 15 months, but at least once each calendar year, to inspections and
tests to determine that it is-
(1) In good mechanical condition;
(2) Adequate from the standpoint of capacity and reliability of operation for the
service in which it is employed;
(3) Except as provided in paragraph (b) of this section, set to control or relieve at
the correct pressure consistent with the pressure limits of §192.201(a); and
(4) Properly installed and protected from dirt, liquids, or other conditions that
might prevent proper operation.
At the time of the inspection, FNG personnel were not able to provide pressure safety valve
records required by CFR 192.739 for year 2013. FNG personnel were able to supply pressure
safety valve records required by CFR 192.739 for 2014 and 2015.



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 violations occurring between January 4, 2012 and 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. 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
Fairbanks Natural Gas 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 5-2016-0023W. 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 R. Guisinger (#152966)

520160023W_Warning Letter_10142016.pdf

of Transportation
U.S. Department
12300 W. Dakota Ave.., Suite 110
Lakewood, CO 80228
Pipeline and Hazardous Materials
Safety Administration
WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
October 14, 2016
Mr. Daniel W. Britton
President / CEO
Fairbanks Natural Gas
3408 International Way
Fairbanks, AK 99701
CPF 5-2016-0023W
Dear Mr. Britton:
On April 18 through April 20, 2016, and on June 6 through June 9, 2016, representatives of
the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter
601 of 49 United States Code, inspected your Fairbanks Natural Gas (FNG) Distribution
system located in Fairbanks, Alaska.
As a result of the inspection, it is alleged that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and
the probable violations are:
1)
§192.807 Recordkeeping.
Each operator shall maintain records that demonstrate compliance with this
subpart.
(a) Qualification records shall include:
(1) Identification of qualified individual(s);
(2) Identification of the covered tasks the individual is qualified to perform;
(3) Date(s) of current qualification; and
(4) Qualification method(s).



(b) Records supporting an individual's current qualification shall be maintained
while the individual is performing the covered task. Records of prior
qualification and records of individuals no longer performing covered tasks shall
be retained for a period of five years.
At the time of the inspection, FNG personnel were not able to provide records of personnel
qualifications for joining plastic pipe CFR 192.285 and records of personnel qualification for
inspection of plastic pipe joints CFR 192.287 for year 2013. ENG appears to be in violation
of CFR 192.807(b) which requires records to be kept for 5 years 192.807(b). FNG personnel
were however, able to supply qualification records for individuals qualified in joining plastic
pipe and inspection of plastic pipe joints for years 2014 and 2015.
§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:
(t) 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.
At the time of the inspection, ENG personnel were not able to supply validation records of
their "risk ranking" process of the FNG integrity management plan. FNG personnel were also
unable to provide implementation records for all elements of the FNG integrity management
plan. Records of validation of the risk ranking process and implementation records of an
integrity management plan are required by CFR 192.1007(f).
§192.739 Pressure limiting and regulating stations: Inspection and testing.
(a) Each pressure limiting station, relief device (except rupture discs), and
Pressure regulating station and its equipment must be subjected at intervals not
exceeding 15 months, but at least once each calendar year, to inspections and
tests to determine that it is-
(1) In good mechanical condition;
(2) Adequate from the standpoint of capacity and reliability of operation for the
service in which it is employed;
(3) Except as provided in paragraph (b) of this section, set to control or relieve at
the correct pressure consistent with the pressure limits of §192.201(a); and
(4) Properly installed and protected from dirt, liquids, or other conditions that
might prevent proper operation.
At the time of the inspection, FNG personnel were not able to provide pressure safety valve
records required by CFR 192.739 for year 2013. ENG personnel were able to supply pressure
safety valve records required by CFR 192.739 for 2014 and 2015.



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 violations occurring between January 4, 2012 and 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. 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
Fairbanks Natural Gas 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 5-2016-0023W. 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),
long with the complete original document you must provide a second copy of the document
vith the portions you believe qualify for confidential treatment redacted and an explanation o
why you believe the redacted information qualifies for confidential treatment under 5 U.S.C.
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
CC:
PHP-60 Compliance Registry
PHP-500 R. Guisinger (#152966)
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