{"operation":"document","citation":"CPF 52025007NOA","title":"INTERIOR GAS UTILITY — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-12-03","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(a), 192.631(a)(1), 192.631(d)(1), 192.631(d)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52025007noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52025007noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52025007noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52025007NOA","body":"Notice of Amendment involving INTERIOR GAS UTILITY. PHMSA's enforcement data identifies the cited regulations as 192.605(a),  192.631(a)(1),  192.631(d)(1),  192.631(d)(4). The case was opened on 2025-12-03 and is reported as closed as of 2026-01-22. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52025007NOA_Closure Letter_01222026_(24-298947).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025007NOA/52025007NOA_Closure%20Letter_01222026_(24-298947).pdf\n\n52025007NOA_Closure Letter_01222026_(24-298947)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025007NOA/52025007NOA_Closure%20Letter_01222026_(24-298947)_text.pdf\n\n52025007NOA_Notice of Amendment_12032025_(24-298947).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025007NOA/52025007NOA_Notice%20of%20Amendment_12032025_(24-298947).pdf\n\n52025007NOA_Notice of Amendment_12032025_(24-298947)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025007NOA/52025007NOA_Notice%20of%20Amendment_12032025_(24-298947)_text.pdf\n\n52025007NOA_Operator Response to Notice_12292025_(24-298947).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025007NOA/52025007NOA_Operator%20Response%20to%20Notice_12292025_(24-298947).pdf\n\n52025007NOA_Notice of Amendment_12032025_(24-298947)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n12300 W. Dakota Ave., Suite 340\nLakewood, CO 80228\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: esudduth@interiorgas.com\nDecember 3, 2025\nMs. Elena Sudduth\nGeneral Manager\nInterior Gas Utility\n2525 Phillips Field\nFairbanks, AK 99709\nCPF 5-2025-007-NOA\nDear Ms. Sudduth:\nFrom July 29 through August 3, 2024, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.)\ninspected Interior Gas Utility’s (IGU) Gas Control Plan and procedures in Fairbanks and North\nPole, Alaska.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nIGU’s plans or procedures. The items inspected and the inadequacies are described below:\n1. §192.631 Control room management.\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline\nfacility through a SCADA system. Each operator must have and follow written\ncontrol room management procedures that implement the requirements of this\nsection, except that for each control room where an operator’s activities are limited\nto either or both of:\n(i) Distribution with less than 250,000 services, or\n\n\n\n(ii) Transmission without a compressor station, the operator must have and follow\nwritten procedures that implement only paragraphs (d) (regarding fatigue), (i)\n(regarding compliance validation), and (j) (regarding compliance and deviations) of\nthis section.\nIGU’s procedures were inadequate to ensure the safe operation of a pipeline facility.\nSpecifically, a review of IGU’s Gas Control Plan (GCP), Revision 03, effective date July 22,\n2024, revealed that the GCP did not include what criteria IGU used to establish what it\nconsidered to be a control room. IGU has three physical sites and several portable laptop\ncomputers capable of accessing its Supervisory Control and Data Acquisition (SCADA) system\nin order to monitor and control parts of its pipeline facility. A review of IGU’s GCP found that\nwhile it identified the three physical locations as primary and backup control rooms, it was silent\nregarding the laptop computers. Further, the plan did not define a control room. As its control\nroom personnel were required to be qualified controllers, without defining what was a control\nroom or identifying through specified criteria whether the laptops capable of accessing its\nSCADA system were considered control rooms pers IGU’s GCP, it is unclear whether IGU\nrequired its personnel to be qualified controllers in order to access and operate the SCADA\nsystem via the laptops.\nAccordingly, PHMSA proposes that IGU must amend its written procedures to establish criteria\ndefining a control room.\n2. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency 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 each\ncalendar 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.\nIGU’s procedures were inadequate to ensure the safe operation of a pipeline facility.\nSpecifically, IGU’s GPC failed to provide a clear process for reviewing the fatigue education\ntraining program, required by its plan.\nDuring the inspection, PHMSA reviewed IGU’s GCP. While reviewing the GPC’s section on\nFatigue Management and Training, PHMSA observed that the section stated, in part that “[t]he\nFatigue Management plan shall be reviewed once per calendar year, not to exceed 15 months.”\nHowever, upon further review, the GCP did not include any details or specifics on how IGU’s\npersonnel would conduct the review. In addition, the GPC was silent regarding who was\nresponsible for conducting the annual review, what metrics IGU’s personnel should use to\ndetermine effectiveness, how IGU’s personnel should address identified deficiencies, and how\nthe review would be documented.\n2\n\n\n\nAccordingly, PHMSA proposes that IGU must amend its written procedures to provide a process\non how to conduct the annual review of its fatigue management and training plan.\n3. § 192.631 Control room management.\n(a) …\n(d) Fatigue mitigation. Each operator must implement the following methods to\nreduce the risk associated with controller fatigue that could inhibit a controller's\nability to carry out the roles and responsibilities the operator has defined:\n(1) Establish shift lengths and schedule rotations that provide controllers off-duty\ntime sufficient to achieve eight hours of continuous sleep;\nIGU’s procedures were inadequate to ensure the safe operation of a pipeline facility.\nSpecifically, a review of IGU’s GCP revealed the plan failed to establish schedule rotations that\nprovided controllers off-duty time sufficient to achieve eight hours of continuous sleep, as\nrequired.\nDuring the inspection, PHMSA reviewed IGU’s GCP and found the Fatigue Mitigation and\nScheduling section did not provide schedule rotations (e.g., DuPont Schedule or modified\nversions) demonstrating that controllers are given sufficient off-duty time to achieve eight hours\nof continuous sleep. While the plan outlined day and night shift times, it lacked detail on how\nshifts rotate or how the scheduling system ensures adequate rest between shifts.\nFurther, PHMSA identified that the Fatigue Mitigation and Scheduling section failed to address\non-call personnel who are qualified controllers. The GCP did not define or identify on-call\ncontrollers who may be called in to operate the control room. These individuals appear to\nmaintain traditional work schedules with other responsibilities outside the control room but who\nare available to fill in when needed. The GCP did not outline shift lengths or shift rotations for\nthese on-call personnel nor did it describe how their hours would be tracked to ensure the ability\nto achieve eight hours of continuous off-duty sleep. On-call controllers are subject to the same\nfatigue mitigation standards as regular controllers including defined shift lengths and schedule\nrotations to ensure fatigue risk is managed.\nAccordingly, PHMSA proposes that IGU must amend its written procedures to establish shift\nlength and schedule rotations that provide controllers off-duty time sufficient to achieve eight\nhours of continuous sleep.\n4. § 192.631 Control room management.\n(a) …\n(d) Fatigue mitigation. Each operator must implement the following methods to\nreduce the risk associated with controller fatigue that could inhibit a controller's\nability to carry out the roles and responsibilities the operator has defined:\n(1) …\n3\n\n\n\n(4) Establish a maximum limit on controller hours-of-service, which may provide\nfor an emergency deviation from the maximum limit if necessary for the safe\noperation of a pipeline facility.\nIGU’s procedures were inadequate to ensure the safe operation of a pipeline facility.\nSpecifically, a review of IGU’s GCP revealed it was unclear regarding the establishment of a\nmaximum limit on controller hours-of-service.\nDuring the inspection, PHMSA reviewed IGU’s GCP. Within the Fatigue Mitigation and\nScheduling section, the plan stated that controller hours of service would be limited to 65 hours\nin a sliding seven day period and that all work performed for the operator, regardless of what\nfunctions the controller performed would be counted as part of the 65 hours. PHMSA observed\nthat the plan also required that a controller was not to work for more than 14 consecutive hours\nduring normal operating conditions in a 24 hour sliding period. However, the plan also stated\nthat “[i]n the event a controller is required to exceed the consecutive hourly limitation or exceed\n16 hours in a single shift, a Deviation Form shall be filled out and approved by the Director of\nOperations or their designee.”\nThis language was unclear if all deviations, including the exceeding of 65 hours in any 7 day\nsliding day period needed to be recorded on a Deviation Form, or if it was only referencing the\nrequirement to not exceed 14 consecutive hours in a 24 hour sliding period. In addition, the\nlanguage of the Gas Control Plan was unclear if 14 or 16 hours was the correct maximum\nconsecutive hours of service in a 24 hour sliding period.\nAccordingly, PHMSA proposes that IGU must amend its written procedures to provide clarity on\nmaximum hours of service and how deviations of these hours would be documented.\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\nEnforcement 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\n4\n\n\n\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\n30 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.\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 5-2025-007-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 D. Fehling (24-303396 & 24-298947)\nJeremiah Flint, Operations Supervisor, Interior Gas Utility, jflint@interiorgas.com\nGeorge Deal, Director of Operations, Interior Gas Utility, sdeal@interiorgas.com\n5\n\n52025007NOA_Closure Letter_01222026_(24-298947)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nVIA ELECTRONIC MAIL – esudduth@interiorgas.com\n12300 W. Dakota Ave., Suite 340\nLakewood, CO 80228\nJanuary 22, 2026\nMs. Elena Sudduth\nGeneral Manager\nInterior Gas Utility\n2525 Phillips Field\nFairbanks, AK 99709\nCPF 5-2025-007-NOA\nClosure Letter\nDear Ms. Sudduth:\nFrom July 29 through August 3, 2024 a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of Interior Gas Utility’s (IGU) Gas Control Plan\nand procedures in Fairbanks and North Pole, Alaska. As a result of the inspection, IGU was\nissued a Notice of Amendment on December 3, 2025, which proposed amendment of your\nprocedures.\nIGU submitted its amended procedures on December 29, 2025. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nFor Dustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\n\n\n\ncc: PHP-60 Compliance Registry\nPHP-500 D. Fehling (24-298947)\nJeremiah Flint, IGU Operations Supervisor, jflint@interiorgas.com\nGeorge Deal, IGU Director of Operations, sdeal@interiorgas.com","truncated":false,"body_characters":14485}