{"operation":"document","citation":"CPF 520200004M","title":"FAIRBANKS NATURAL GAS — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-02-28","effective_on":null,"summary":"CLOSED notice of amendment citing 192.1007(a), 192.1007(b), 192.1007(e), 192.1007(g), 192.285(d), 192.605(a), 192.605(b)(1), 192.617.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520200004m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520200004m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520200004m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520200004M","body":"Notice of Amendment involving FAIRBANKS NATURAL GAS. PHMSA's enforcement data identifies the cited regulations as 192.1007(a),  192.1007(b),  192.1007(e),  192.1007(g),  192.285(d),  192.605(a),  192.605(b)(1),  192.617. The case was opened on 2020-02-28 and is reported as closed as of 2020-08-27. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520200004M_Closure Letter_08272020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520200004M/520200004M_Closure%20Letter_08272020.pdf\n\n520200004M_Closure Letter_08272020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520200004M/520200004M_Closure%20Letter_08272020_text.pdf\n\n520200004M_Notice of Amendment_02282020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520200004M/520200004M_Notice%20of%20Amendment_02282020.pdf\n\n520200004M_Notice of Amendment_02282020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520200004M/520200004M_Notice%20of%20Amendment_02282020_text.pdf\n\n520200004M_Operator Response to Notice_05292020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520200004M/520200004M_Operator%20Response%20to%20Notice_05292020.pdf\n\n520200004M_Notice of Amendment_02282020_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 28, 2020\nMr. Daniel Britton\nPresident\nFairbanks Natural Gas, LLC\n3408 International Way\nFairbanks, Alaska 99701\nCPF 5-2020-0004M\nDear Mr. Britton:\nOn May 6 through 10 and June 24 through 27, 2019, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code, inspected Fairbanks Natural Gas’s (FNG) maintenance & operations procedures\nin Fairbanks, Alaska.\nOn the basis of the inspection, PHMSA has identified apparent inadequacies found within\nFNG’s plans or procedures, as described below:\n1. § 192.285 Plastic pipe: Qualifying persons to make joints.\n(a) ….\n(d) Each operator shall establish a method to determine that each person making\njoints in plastic pipelines in the operator's system is qualified in accordance with\nthis section.\nFNG Standard Operating Procedure (SOP) 2220 Plastic Pipe Fusion Precautions, SOP 2222\nSaddle Fusion Procedure, SOP 2221 Butt Fusion Procedure, SOP 2225 Side Tap Procedures\n(Hot Tap Tool) and SOP 2230 Electrofusion Procedure were inadequate because they did not\n\n\n\nestablish a method to determine that each person making joints in plastic pipelines in the\noperator's system is qualified in accordance with the testing required by § 192.285(b). The\nTraining & Qualification sections of the above listed procedures stated operators will be\nqualified to make hot tap or other joints based on on-the-job training, SOP review,\nperformance on-the-job, oral examination, and written examination. A person must be\nqualified based on the joint specimen testing as required by the code.\n2. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual\nof written procedures for conducting operations and maintenance activities and\nfor emergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least once\neach calendar year. This manual must be prepared before operations of a pipeline\nsystem commence. Appropriate parts of the manual must be kept at locations\nwhere operations and maintenance activities are conducted.\n(b) Maintenance and normal operations. The manual required by paragraph (a)\nof this section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in accordance with each of\nthe requirements of this subpart and subpart M of this part.\nFNG’s SOP 2225 Side Tap Procedures (Hot Tap Tool) was inadequate because it did not\nrequire individuals performing hot taps to be qualified as required by § 192.627.\n3. § 192.617 Investigation of failures.\nEach operator shall establish procedures for analyzing accidents and failures,\nincluding the selection of samples of the failed facility or equipment for laboratory\nexamination, where appropriate, for the purpose of determining the causes of the\nfailure and minimizing the possibility of a recurrence.\nFNG’s SOP 1425 Investigation of Accidents and Material Failures was inadequate because\nthey do not require the selection of samples of failed facilities or equipment for laboratory\nexamination, where appropriate, for determining the causes of the failure, as required.\n4. § 192.1007 What are the required elements of an integrity management plan?\nA written integrity management plan must contain procedures for developing and\nimplementing the following elements:\n(a) Knowledge. An operator must demonstrate an understanding of its gas\ndistribution system developed from reasonably available information.\n(1) Identify the characteristics of the pipeline's design and operations and the\nenvironmental factors that are necessary to assess the applicable threats and risks\nto its gas distribution pipeline.\n2\n\n\n\n(2) Consider the information gained from past design, operations, and\nmaintenance.\n(3) Identify additional information needed and provide a plan for gaining that\ninformation over time through normal activities conducted on the pipeline (for\nexample, design, construction, operations or maintenance activities).\n(4) Develop and implement a process by which the IM program will be reviewed\nperiodically and refined and improved as needed.\n(5) Provide for the capture and retention of data on any new pipeline installed.\nThe data must include, at a minimum, the location where the new pipeline is\ninstalled and the material of which it is constructed.\nFNG did not have a written Distribution Integrity Management Plan (DIMP) beyond some\nsections printed out of the Simple, Handy, Risk-based Integrity Management Plan (SHRIMP)\nassessment. The plan did not have an adequate description of data sources, consideration of\nenvironmental risk factors, a risk evaluation model or method, methods of ranking threats, or\nperiodic review and improvement plan.\n5. § 192.1007 What are the required elements of an integrity management plan?\nA written integrity management plan must contain procedures for developing and\nimplementing the following elements:\n(a) ….\n(b) Identify threats. The operator must consider the following categories of threats\nto each gas distribution pipeline: corrosion, natural forces, excavation damage,\nother outside force damage, material or welds, equipment failure, incorrect\noperations, and other concerns that could threaten the integrity of its pipeline. An\noperator must consider reasonably available information to identify existing and\npotential threats. Sources of data may include, but are not limited to, incident and\nleak history, corrosion control records, continuing surveillance records, patrolling\nrecords, maintenance history, and excavation damage experience.\nFNG’s DIMP does not contain an adequate description of the consideration given, if any, to\nenvironmental factors such as flooding, or frost heave as common threats unique to its system\nwhen identifying threats to the distribution system. The threats that were considered did not\ngo beyond those recommended by SHRIMP.\n6. § 192.1007 What are the required elements of an integrity management plan?\nA written integrity management plan must contain procedures for developing and\nimplementing the following elements:\n(a) .…\n(e) Measure performance, monitor results, and evaluate effectiveness. (1) Develop\nand monitor performance measures from an established baseline to evaluate the\neffectiveness of its IM Program. An operator must consider the results of its\nperformance monitoring in periodically re-evaluating the threats and risks. These\nperformance measures must include the following:\n3\n\n\n\n(i) Number of hazardous leaks either eliminated or repaired as required by\n§ 192.703(c) of this subchapter (or total number of leaks if all leaks are repaired\nwhen found), categorized by cause;\n(ii) Number of excavation damages;\n(iii) Number of excavation tickets (receipt of information by the underground\nfacility operator from the notification center);\n(iv) Total number of leaks either eliminated or repaired, categorized by cause;\n(v) Number of hazardous leaks either eliminated or repaired as required by\n§ 192.703(c) (or total number of leaks if all leaks are repaired when found),\ncategorized by material; and\n(vi) Any additional measures the operator determines are needed to evaluate the\neffectiveness of the operator's IM program in controlling each identified threat.\nFNG's DIMP did not have any written procedures discussing how to measure performance,\nmonitor results, and evaluate effectiveness of its integrity management plan.\n7. § 192.1007 What are the required elements of an integrity management plan?\nA written integrity management plan must contain procedures for developing and\nimplementing the following elements:\n(a) .…\n(g) Report results. Report, on an annual basis, the four measures listed in\nparagraphs (e)(1)(i) through (e)(1)(iv) of this section, as part of the annual report\nrequired by § 191.11. An operator also must report the four measures to the state\npipeline safety authority if a state exercises jurisdiction over the operator's\npipeline.\nFNG's DIMP did not have any written procedures discussing the requirements for reporting the\nfour measures listed in § 192.1007(e)(1)(i) through (e)(1)(iv) to PHMSA as part of the annual\nreport required by § 191.11.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must 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).\n4\n\n\n\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged\nin this Notice without further notice to you and to issue an Order Directing Amendment. If\nyour plans or procedures are found inadequate as alleged in this Notice, you may be ordered to\namend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are\nnot contesting this Notice, we propose that you submit your amended procedures to my office\nwithin 30 days of receipt of this Notice. This period may be extended by written request for\ngood cause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested (not mandated) that Fairbanks Natural Gas maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision\nof plans, procedures) and submit the total to Dustin Hubbard, Director, Western, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please\nrefer to CPF 5-2020-0004M and, for each document you submit, please provide a copy in\nelectronic format whenever possible.\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 G. St. Pierre (#162682)\nMark Rockwell, Director of Operations, Fairbanks Natural Gas (via email)\nChris Gillespie, Chief of Engineering, Fairbanks Natural Gas (via email)\n5\n\n520200004M_Closure Letter_08272020_text.pdf\n\nVIA E-MAIL TO MR. DANIEL BRITTON\nAugust 27, 2020\nMr. Daniel Britton\nPresident\nFairbanks Natural Gas, LLC\n3408 International Way\nFairbanks, Alaska 99701\nCPF 5-2020-0004M\nClosure Letter\nDear Mr. Britton:\nOn May 6 through 10 and June 24 through 27, 2019, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected\nFairbanks Natural Gas’s (FNG) procedures in Fairbanks, Alaska. As a result of the inspection, FNG was\nissued a Notice of Amendment (NOA) on February 28, 2020.\nFNG submitted its amended procedures on May 29 and August 19, 2020. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this NOA have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you for your\ncooperation.\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 Gabrielle St. Pierre (#162682, #168355)\nMark Rockwell, Director of Operations, Fairbanks Natural Gas (via email)\nChris Gillespie, Chief of Engineering, Fairbanks Natural Gas (via email)","truncated":false,"body_characters":13687}