{"operation":"document","citation":"CPF 520163004W","title":"FAIRBANKS NATURAL GAS — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-08-26","effective_on":null,"summary":"CLOSED warning letter citing 193.2507, 193.2625(b)(1), 193.2635(d), 193.2637, 193.2639(a), 193.2719(a)(1), 193.2719(a)(2), 193.2907(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520163004w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520163004w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520163004w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520163004W","body":"Warning Letter involving FAIRBANKS NATURAL GAS. PHMSA's enforcement data identifies the cited regulations as 193.2507,  193.2625(b)(1),  193.2635(d),  193.2637,  193.2639(a),  193.2719(a)(1),  193.2719(a)(2),  193.2907(b). The case was opened on 2016-08-26 and is reported as closed as of 2016-08-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520163004W_Operator Response to Notice_09292016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520163004W/520163004W_Operator%20Response%20to%20Notice_09292016.pdf\n\n520163004W_Warning Letter_08262016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520163004W/520163004W_Warning%20Letter_08262016.pdf\n\n520163004W_Warning Letter_08262016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520163004W/520163004W_Warning%20Letter_08262016_text.pdf\n\n520163004W_Warning Letter_08262016_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 26, 2016\nMr. Daniel W. Britton\nPresident/CEO\nFairbanks Natural Gas, LLC\n3408 International Way\nFairbanks, Alaska 99701\nCPF 5-2016-3004W\nDear Mr. Britton:\nOn April 18-20 and June 6-10, 2016, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\ninspected your LNG Facilities in Fairbanks, AK.\nAs a result of the inspection, it appears that Fairbanks Natural Gas, LLC has committed\nprobable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations.\nThe items inspected and the probable violation(s) are:\n1. §193.2507 Monitoring operations.\nEach component in operation or building in which a hazard to persons or\nproperty could exist must be monitored to detect fire or any malfunction or\nflammable fluid that could cause a hazardous condition. Monitoring must be\naccomplished by watching or listening from an attended control center for\nwarning alarms, such as gas, temperature, pressure, vacuum, and flow alarms, or\nby conducting an inspection or test at intervals specified in the operating\nprocedures.\nFNG failed to maintain a Fire Eye (flame detector) with a broken glass sight piece which\nwould affect its ability to operate correctly, could fail to detect fire, and could cause a\nhazardous condition. Inspections in both April 2016 and June 2016 by PHMSA\n\n\n\n\n\n\n\nrepresentatives revealed a Fire Eye (flame detector) with a broken glass sight piece. FNG was\nfirst notified of the Fire Eye (flame detector) deficiency in April 2016.\n2. §193.2907 Protective enclosure construction\n(b) Openings in or under protective enclosures must be secured by grates, doors\nor covers of construction and fastening of sufficient strength such that the\nintegrity of the protective enclosure is not reduced by any opening.\nFNG did not maintain proper cover under gates at both LNG sites. The openings under the\nenclosures (gates) are not otherwise secured by grates, doors, or covers. A person could\neasily breach the security of the enclosure by slipping under the gates resulting in a protective\nenclosure that does not prevent unauthorized access to the facility.\n3. §193.2639 Maintenance records.\n(a) Each operator shall keep a record at each LNG plant of the date and type of\neach maintenance activity performed on each component to meet the\nrequirements of this part. For each LNG facility that is designed and constructed\nafter March 31, 2000 the operator shall also maintain related periodic inspection\nand testing records that NFPA-59A-2001 (incorporated by reference, see\n§193.2013) requires. Maintenance records, whether required by this part or\nNFPA-59A-2001, must be kept for a period of not less than five years.\n§193.2625 Corrosion protection.\n(b) Components whose integrity or reliability could be adversely affected by\ncorrosion must be either?\n(1) Protected from corrosion in accordance with §§193.2627 through 193.2635, as\napplicable;\nFNG provided no repair records that showed repair, protection, or replacement as a result of\ncorrosion inspections that identified deficiencies. No repair records were provided by\noperator that showed repair or protection as a result of the deficiencies identified by a\nDecember 12, 2015 corrosion inspection. FNG’s compliance officer stated that there were no\nother corrosion documents related to inspection, identification of components, or repairs prior\nto or after the December 12, 2015 inspection. Additionally, FNG’s compliance officer\nconfirmed that the corroded infrastructure identified by the December 12, 2015 inspection\nwere not subsequently protected from corrosion. FNG’s compliance officer also stated that\nFNG generally repairs corrosion coating deficiencies themselves, but keep no records of the\nrepairs.\n4. §193.2639 Maintenance records.\n(a) Each operator shall keep a record at each LNG plant of the date and type of\neach maintenance activity performed on each component to meet the\nrequirements of this part. For each LNG facility that is designed and constructed\n\n\n\nafter March 31, 2000 the operator shall also maintain related periodic inspection\nand testing records that NFPA-59A-2001 (incorporated by reference, see\n\n\n\n§193.2013) requires. Maintenance records, whether required by this part or\nNFPA-59A-2001, must be kept for a period of not less than five years.\n§193.2635 Monitoring corrosion control. Corrosion protection provided as\nrequired by this subpart must be periodically monitored to give early recognition\nof ineffective corrosion protection, including the following, as applicable:\n(d) Each component that is protected from atmospheric corrosion must be\ninspected at intervals not exceeding 3 years\nFNG failed to demonstrate that monitoring for atmospheric corrosion was performed once\nevery 3 years. No records provided by FNG demonstrated that monitoring for atmospheric\ncorrosion was performed once every 3 years. FNG made available corrosion inspection\nrecords from December 12, 2015. FNG’s compliance officer stated that there were no other\ncorrosion documents related to inspection prior to or after the December 12, 2015 inspection.\n5. §193.2637 Remedial measures.\nPrompt corrective or remedial action must be taken whenever an operator learns\nby inspection or otherwise that atmospheric, external, or internal corrosion is not\ncontrolled as required by this subpart.\nFNG did not provide records that show that prompt corrective or remedial action was taken\nwhen corrosion control deficiencies were found. A corrosion inspection of FNG’s two LNG\nfacilities was completed on December 12, 2015. Field inspection by PHMSA representatives\nrevealed that tanks and pipelines show some evidence of coating via painting but age could\nnot be determined, although the coating was not recent. No corrosion deficiencies from the\nDecember 12, 2015 inspection were corrected before the time of the PHMSA’s June 2016\ninspection.\n6. §193.2719 Remedial measures.\nTraining: records.\n(a) Each operator shall maintain a system of records which—\n(1) Provide evidence that the training programs required by this subpart have\nbeen implemented; and\n(2) Provide evidence that personnel have undergone and satisfactorily completed\nthe required training programs.\nPHMSA representatives discovered that training records for one FNG supervisor were not\nmaintained with the expected record requirements. No initial training records were provided\nfor the aforementioned supervisor, who started working for FNG in 2012. FNG failed to\nshow that personnel have satisfactorily completed the required initial training. Upon\nexamination of existing training records for covered tasks including first aid, fire, and lock-\nout-tag-out training, FNG displayed records for the aforementioned FNG supervisor for fire\ntraining on 05/27/2014 and 06/01/2016, lock-out-tag-out training on 5/19/2016, and first aid\n\n\n\non 12/08/2014 but no other records were provided. FNG failed to provide records that\npersonnel received refresher training every two years. FNG provided neither records that\n\n\n\nshow that personnel received the mandatory initial training nor evidence that FNG kept such\nrecords of implementation and completion or maintained the records for the required period of\ntime.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the maximum\npenalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a related series of violations. Also, for LNG facilities, an additional\npenalty of not more than $50,000 for each violation may be imposed. 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 item(s) identified in this letter. Failure to do so will result in FNG\nbeing subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2016-3004W and for each document you submit, please provide a copy in\nelectronic format to PHP-WRADMIN@dot.gov whenever possible. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust 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).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 Jennifer Owens\nItem 1: Activity 152965","truncated":false,"body_characters":10034}