{"operation":"document","citation":"CPF 52020001WL","title":"ENSTAR NATURAL GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-10-09","effective_on":null,"summary":"CLOSED warning letter citing 192.481(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52020001wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52020001wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52020001wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52020001WL","body":"Warning Letter involving ENSTAR NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulation as 192.481(a). The case was opened on 2020-10-09 and is reported as closed as of 2020-10-09. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52020001WL_Warning Letter_10092020_(20-179456).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52020001WL/52020001WL_Warning%20Letter_10092020_(20-179456).pdf\n\n52020001WL_Warning Letter_10092020_(20-179456)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52020001WL/52020001WL_Warning%20Letter_10092020_(20-179456)_text.pdf\n\n52020001WL_Warning Letter_10092020_(20-179456)_text.pdf\n\nWARNING LETTER\nVIA E-MAIL TO MR. JOHN SIMS\nOctober 9, 2020\nMr. John Sims\nPresident\nENSTAR Natural Gas Company\nP.O. Box 190288\nAnchorage, AK 99519-0288\nCPF 5-2020-001-WL\nDear Mr. Sims:\nFrom February 3 through 6, March 2 through 4 and June 29 through July 2, 2020, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.), inspected your natural gas distribution system.\nAs a result of the inspection, it is alleged that you have committed probable violations of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected and the probable\nviolations are:\n1. § 192.481 - Atmospheric corrosion control: Monitoring.\n(a) Each operator must inspect each pipeline or portion of pipeline that is exposed to the\natmosphere for evidence of atmospheric corrosion, as follows:\nIf the pipeline is located: Then the frequency of inspection is:\nOnshore… At least once every 3 calendar years, but with intervals not\nexceeding 39 months\nOffshore… At least once each calendar year, but with intervals not\nexceeding 15 months\nRecords showed that atmospheric corrosion was not completed within the three-year time period required\nby § 192.481 for some areas of aboveground piping in Grid 1740.\n\n\n\nENSTAR Natural Gas Company (ENSTAR) conducted biennial atmospheric corrosion inspections.\nEvery four years these were conducted in conjunction with leak surveys. The Daily Leak Survey Report\ndated August 2, 2017 did not have any indications under the atmospheric corrosion inspection section for\nthe five locations surveyed on the record in Grid 1740. Atmospheric corrosion inspections for those\nlocations were conducted in 2015 and 2019, four years apart. Therefore, ENSTAR did not conduct\natmospheric corrosion inspections in the required three-year interval.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related series\nof violations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the\nmaximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to exceed\n$2,132,679. For violation occurring on or after November 2, 2015 and before November 27, 2018, the\nmaximum penalty may not exceed $209,002 per violation per day, with a maximum penalty not to exceed\n$2,090,022. For violations occurring prior to November 2, 2015, the maximum penalty may not exceed\n$200,000 per violation per day, with a maximum penalty not to exceed $2,000,000 for a related series of\nviolations. We have reviewed the circumstances and supporting documents involved in this case, and\nhave decided not to conduct additional enforcement action or penalty assessment proceedings at this time.\nWe advise you to correct the items identified in this letter. Failure to do so will result in ENSTAR being\nsubject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 5-\n2020-001-WL. Be advised that all material you submit in response to this enforcement action is subject\nto being made publicly available. 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 must\nprovide a second copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 G. St. Pierre (#20-179456)\nMr. Rusty Allen, Compliance / Integrity Engineer (via email)\nMr. Steve Cooper, Director of Operations (via email)","truncated":false,"body_characters":4670}