{"operation":"document","citation":"CPF 52022016NOA","title":"INTERIOR GAS UTILITY — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-11-03","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(1), 192.605(b)(2), 192.605(b)(3), 192.605(b)(4), 192.614(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52022016noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52022016noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52022016noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52022016NOA","body":"Notice of Amendment involving INTERIOR GAS UTILITY. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(1),  192.605(b)(2),  192.605(b)(3),  192.605(b)(4),  192.614(a). The case was opened on 2022-11-03 and is reported as closed as of 2023-01-31. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52022016NOA_Closure Letter_01312023_(21-217219).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022016NOA/52022016NOA_Closure%20Letter_01312023_(21-217219).pdf\n\n52022016NOA_Closure Letter_01312023_(21-217219)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022016NOA/52022016NOA_Closure%20Letter_01312023_(21-217219)_text.pdf\n\n52022016NOA_Notice of Amendment_11032022_(21-217219).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022016NOA/52022016NOA_Notice%20of%20Amendment_11032022_(21-217219).pdf\n\n52022016NOA_Notice of Amendment_11032022_(21-217219)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022016NOA/52022016NOA_Notice%20of%20Amendment_11032022_(21-217219)_text.pdf\n\n52022016NOA_Operator Response to Notice_12012022_(21-217219).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022016NOA/52022016NOA_Operator%20Response%20to%20Notice_12012022_(21-217219).pdf\n\n52022016NOA_Notice of Amendment_11032022_(21-217219)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA E-MAIL TO MR. DANIEL BRITTON\nNovember 3, 2022\nMr. Daniel Britton\nGeneral Manager\nInterior Gas Utility\n2525 Phillips Field Road\nFairbanks, AK 99709\nCPF 5-2022-016-NOA\nDear Mr. Britton:\nFrom August 2 through 6, 2021, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Interior\nGas Utility’s (IGU) procedures for Maintenance & Operations, Emergency Operations,\nReporting, Design & Construction and Distribution Integrity Management in Fairbanks, Alaska.\nOn the basis of the inspection, PHMSA has identified apparent inadequacies found within IGU’s\nplans or procedures, as described below:\n1. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis 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.\n\n\n\nIGU Standard Operating Procedures (SOP) were inadequate because they did not include\nprocesses to operate, maintain and repair the pipeline as required by § 192.605. The following\ninadequacies were discovered:\n1. SOP S1-7125 Relief, ESD, Regulator and Control Systems Maintenance stated under\nPressure Safety Relief Valve Test Procedure section 2 that, “[d]istribution header\npressure relief valve will be tested annually to have enough capacity, be operable and\npressure to not exceed MAOP of 60 psi.\" The procedure listed under number three\ndirected testing the relief valve on a testing bench, disconnected from the system. The\nprocedure failed to require testing the capacity of the Pressure Safety Relief Valve in-\nplace or by review and calculations as required by § 192.743(a).\n2. The SOPs for Sites 3 and 4 (SOP S3-7125 LNG Site #3 Relief, ESD, Regulator and\nControl System Maintenance and SOP S4-7125 Relief, ESD, Regulator and Control\nSystem Maintenance) required annual testing of the distribution header pressure relief\nvalve. The SOPs were inadequate because Sites 3 and 4 did not have pressure relief\nvalves at the distribution headers. It is notable that the procedures requiring the\ndistribution header pressure relief valve to “be tested annually to have enough capacity,\nbe operable and pressure to not exceed MAOP of 60 psi” was identical to the SOP for\nSite 1, though Site 1 had a Pressure Safety Relief Valve and Sites 3 and 4 did not.\n3. SOP S3-7125 LNG Site #3 Relief, ESD, Regulator and Control System Maintenance\nstated on page 3 as follows: \"Regulators that must be inspected and tested are: a.\nDistribution/Meter Run regulator.\" Site 3 has four regulators connected to the distribution\nheader: PCV 400a, PCV 400b, PCV 401a, and PCV 401b. The procedure did not specify\nthat each of these regulators must be included in the inspection.\n4. The procedures did not require equipment used in joining plastic pipe to be maintained in\naccordance with the manufacturer's recommended practices or with written procedures\nthat had been proven by test and experience to produce acceptable joints, as required by §\n192.756.\n5. The procedures did not state MAOP limits as described in § 192.619. SOP D-2115\nMaximum Allowable Operating Pressure did not require that the MAOP be the lowest of\nthe Design Pressure determined by the HDPE material characteristics and division of 1.5\nof the test pressure. The procedures also failed to state that the amount of allowable\nbuild-up is limited to 10% above MAOP.\nIGU must amend its procedures to (1) require testing the capacity of the Pressure Safety Relief\nValve in-place or by review and calculations as required by § 192.743(a); (2) appropriately\naccount for differing equipment in site specific documents; (3) specify that all regulators must be\nincluded in the inspection; (4) require equipment used in joining plastic pipe to be maintained in\naccordance with the manufacturer's recommended practices or with written procedures that had\nbeen proven by test and experience to produce acceptable joints as required by § 192.756; (5)\ninclude requirements for telemetering readings; and (6) require that the MAOP be the lowest of\nthe Design Pressure determined by the HDPE material characteristics and division of 1.5 of the\ntest pressure, and state that the amount of allowable build-up is limited to 10% above MAOP.\n2. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n\n\n\n(a) . . .\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(1) . . .\n(2) Controlling corrosion in accordance with the operations and maintenance\nrequirements of subpart I of this part.\nIGU SOPs were inadequate to meet the requirements of § 192.605 (b)(2). S1-7205 Corrosion\nControl, S3-7205 LNG Site #3 Corrosion Control, and S4-7205 Corrosion Control included\nprocedures to inspect distribution headers at the LNG storage Sites 1, 3, and 4, respectively.\nHowever, IGU did not have a procedure that outlined atmospheric corrosion inspections of\naboveground distribution piping outside of the LNG storage sites, such as at customer meter\nsets. Nor did the operator have a tracking process that ensured each meter set was inspected at\nthe required intervals. IGU must amend its procedures to include a procedure outlining\natmospheric corrosion inspections of aboveground distribution piping outside of the LNG\nstorage sites, as well as a tracking process to ensure that each meter set is inspected at required\nintervals.\n3. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide safety\nduring maintenance and operations.\n(1) . . .\n(3) Making construction records, maps, and operating history available to\nappropriate operating personnel.\nIGU SOPs failed to meet the requirements of § 192.605 (b)(3). IGU's procedures did not include\na requirement to make construction records, maps, and operating history available to appropriate\noperating personnel. IGU must amend its SOPs to include a procedure for making construction\nrecords, maps, and operating history available to appropriate operating personnel.\n4. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) . . . .\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(1) . . . .\n(4) Gathering of data needed for reporting incidents under Part 191 of this chapter\nin a timely and effective manner.\nIGU SOPs were inadequate to meet the requirements of § 192.605(b)(4) and § 191.9(a). SOP G-\n1005 Reporting did not require preparation and filing of an incident report as soon as practicable,\n\n\n\nbut no later than 30 days after discovery of a reportable incident for their distribution system.\nIGU must amend its procedures to comply with the requirements of § 191.9(a).\n5. § 192.614 Damage prevention program.\n(a) Except as provided in paragraphs (d) and (e) of this section, each operator of a\nburied pipeline must carry out, in accordance with this section, a written program\nto prevent damage to that pipeline from excavation activities. For the purposes of\nthis section, the term “excavation activities” includes excavation, blasting, boring,\ntunneling, backfilling, the removal of aboveground structures by either explosive or\nmechanical means, and other earthmoving operations.\nIGU SOPs were inadequate to meet the requirements of § 192.614. Specifically, SOP D-1405\nLine Locating Policy and Procedures did not include detail describing how the Excavator\nMailing List, which is required by § 192.614(c)(1), is compiled. Further, there was no clause in\nthe procedure requiring IGU to conduct an inspection of its system if personnel suspected that\nexcavation activities had damaged a line, which is required by § 192.614(c)(6). IGU must\namend its procedures to describe how the Excavator Mailing List is compiled and require IGU to\nconduct an inspection of its system if damage to a line is suspected.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 5 U.S.C. 552(b).\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 in\nthis Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not\ncontesting this Notice, we propose that you submit your amended procedures to my office within\n90 days of receipt of this Notice. This period may be extended by written request for good\ncause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\n\n\n\nIt is requested (not mandated) that Interior Gas Utility maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Dustin Hubbard, Director, Western Region, Pipeline\nand Hazardous Materials Safety Administration. In correspondence concerning this matter,\nplease refer to CPF 5-2022-016-NOA and, for each document you submit, please provide a copy\nin electronic format whenever possible.\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 G. St. Pierre (#21-217219)\nMark Rockwell, Interior Gas Utility (via email)\nBrendan Kern, Engineer, Interior Gas Utility (via email)\n\n52022016NOA_Closure Letter_01312023_(21-217219)_text.pdf\n\nVIA E-MAIL TO MR. DANIEL BRITTON\nJanuary 31, 2023\nMr. Daniel Britton\nGeneral Manager\nInterior Gas Utility\n2525 Phillips Field Road\nFairbanks, AK 99709\nCPF 5-2022-016-NOA\nClosure Letter\nDear Mr. Britton:\nFrom August 2 through 6, 2021, representatives from the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site\npipeline safety inspection of Interior Gas Utility’s (IGU) procedures in Fairbanks, Alaska. As a result of\nthe inspection, IGU was issued a Notice of Amendment on November 3, 2022, which proposed\namendment of your procedures.\nIGU submitted its amended procedures on December 1, 2022 and subsequent information on January 16,\n2023. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this\nNotice of Amendment 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 G. St. Pierre (#21-217219)\nMark Rockwell, Interior Gas Utility (via email)\nBrendan Kern, Interior Gas Utility (via email)","truncated":false,"body_characters":13817}