# INTERIOR GAS UTILITY — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 52025011NOPV
- **title:** INTERIOR GAS UTILITY — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2025-05-02
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 192.1007(d), 192.285(a)(2), 192.285(b)(2), 192.53(c).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-52025011nopv.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-52025011nopv.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-52025011nopv
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/52025011NOPV
**body:**

Notice of Probable Violation involving INTERIOR GAS UTILITY. PHMSA's enforcement data identifies the cited regulations as 192.1007(d),  192.285(a)(2),  192.285(b)(2),  192.53(c). The case was opened on 2025-05-02 and is reported as closed as of 2025-09-18. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

52025011NOPV_Closure Letter_09182025_(24-305759).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025011NOPV/52025011NOPV_Closure%20Letter_09182025_(24-305759).pdf

52025011NOPV_Closure Letter_09182025_(24-305759)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025011NOPV/52025011NOPV_Closure%20Letter_09182025_(24-305759)_text.pdf

52025011NOPV_Final Order_07232025_(24-305759).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025011NOPV/52025011NOPV_Final%20Order_07232025_(24-305759).pdf

52025011NOPV_Final Order_07232025_(24-305759)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025011NOPV/52025011NOPV_Final%20Order_07232025_(24-305759)_text.pdf

52025011NOPV_Operator Response to Notice_05302025_(24-305759).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025011NOPV/52025011NOPV_Operator%20Response%20to%20Notice_05302025_(24-305759).pdf

52025011NOPV_PCO_05022025_(24-305759).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025011NOPV/52025011NOPV_PCO_05022025_(24-305759).pdf

52025011NOPV_PCO_05022025_(24-305759)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025011NOPV/52025011NOPV_PCO_05022025_(24-305759)_text.pdf

52025011NOPV_Final Order_07232025_(24-305759)_text.pdf

July 23, 2025
VIA ELECTRONIC MAIL TO: esudduth@interiorgas.com
Ms. Elena Sudduth
General Manager
Interior Gas Utility
2525 Phillips Field Road
Fairbanks, AK 99709
Re: CPF No. 5-2025-011-NOPV
Dear Ms. Sudduth:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation and specifies actions that need to be taken to comply with the pipeline safety
regulations. When the terms of the compliance order are completed, as determined by the
Director, Western Region, this enforcement action will be closed. Service of the Final Order by
e-mail is effective upon the date of transmission and acknowledgement of receipt as provided
under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Linda Daugherty
Acting Associate Administrator
for Pipeline Safety
Enclosures (Final Order and NOPV)
cc: Mr. Dustin Hubbard, Director, Western Region, Office of Pipeline Safety
Mr. George Deal, Director of Operations, Interior Gas Utility, sdeal@interiorgas.com



CONFIRMATION OF RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Interior Gas Utility, ) CPF No. 5-2025-011-NOPV
)
)
)
Respondent. )
____________________________________)
FINAL ORDER
On May 2, 2025, pursuant to 49 C.F.R. § 190.207, the Director, Western Region, Office of
Pipeline Safety (OPS), issued a Notice of Probable Violation (Notice) to Interior Gas Utility
(Respondent). The Notice proposed finding that Respondent had violated the pipeline safety
regulations in 49 C.F.R. Part 192. The Notice also proposed certain measures to correct the
violations. Respondent did not contest the allegations of violation or corrective measures.
Based upon a review of all of the evidence, pursuant to § 190.213, I find Respondent violated the
pipeline safety regulations listed below, as more fully described in the enclosed Notice, which is
incorporated by reference:
49 C.F.R. § 192.53(c) (Item 1) ─ Respondent failed to utilize material for pipe
that was qualified in accordance with the applicable requirements of Subpart B.
49 C.F.R. § 192.285(a)(2) (Item 2) ─ Respondent failed to qualify its personnel
to make plastic pipe joints in accordance with § 192.285(a)(2) because it did not
have and/or follow a procedure for making a specimen joint from pipe sections
that examined and tested heat fusion joint specimens using a method acceptable
per § 192.285(b)(2).
49 C.F.R. § 192.1007(d) (Item 3) Respondent failed to determine and implement
an effective leak management plan.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
Compliance Actions
Pursuant to 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the



actions proposed in the enclosed Notice to correct the violations. The Director may grant an
extension of time to comply with any of the required items upon a written request timely
submitted by the Respondent and demonstrating good cause for an extension. Upon completion
of the ordered actions, Respondent may request that the Director close the case. Respondent
previously submitted evidence to show appropriate actions have been taken to correct the
violations. This evidence is currently under review by the Director. Failure to comply with this
Order may result in the assessment of civil penalties under 49 C.F.R. § 190.223 or in referral to
the Attorney General for appropriate relief in a district court of the United States.
The terms and conditions of this order are effective upon service in accordance with 49 C.F.R.
§ 190.5.
___________________________________ _________________________
Linda Daugherty Date Issued
Acting Associate Administrator
for Pipeline Safety



NOTICE OF PROBABLE VIOLATION
and
PROPOSED COMPLIANCE ORDER
VIA ELECTRONIC MAIL TO: esudduth@interiorgas.com
May 2, 2025
Ms. Elena Sudduth
General Manager
Interior Gas Utility
2525 Phillips Field Road
Fairbanks, AK 99709
CPF 5-2025-011-NOPV
Dear Ms. Sudduth:
From August 5 to August 9, 2024, representatives of the Pipeline and Hazardous Materials
Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49
United States Code (U.S.C.), inspected Interior Gas Utility’s (IGU) Fairbanks and North Pole
distribution systems in Fairbanks North Star Borough, Alaska.
As a result of the inspection, it is alleged that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected
and the probable violations are:



1. § 192.53 General.
Materials for pipe and components must be:
(a)…
(c) Qualified in accordance with the applicable requirements of this subpart.
IGU failed to utilize material for pipe that was qualified in accordance with the applicable
requirements of Subpart B. During the inspection, an inspector from PHMSA observed a Teflon
hose connection within the Fairbanks distribution system at IGU’s Storage Site 3. The hose
connected pressure measuring instrumentation to the steel distribution header piping.
Per § 192.59, plastic pipe must be manufactured in accordance with a specification listed in
Appendix B to Part 192.
Subsequent to the field inspection, IGU provided to PHMSA manufacturer documentation for
the observed hose demonstrating it was an Eaton Everflex Hose. This manufacturer
documentation indicated that the hose was made of Teflon (PTFE) and had a braided steel
exterior. However, neither the manufacturer information, nor any other information obtained
provided evidence of the hose being manufactured to a specification listed in Appendix B to Part
192, as required.
Accordingly, IGU was in violation of § 192.53(c) for utilizing a material for pipe that was not
qualified in accordance of Subpart B.
2. § 192.285 Plastic pipe: Qualifying persons to make joints.
(a) No person may make a plastic pipe joint unless that person has been qualified
under the applicable joining procedure by:
(1)…
(2) Making a specimen joint from pipe sections joined according to the procedure
that passes the inspection and test set forth in paragraph (b) of this section.
(b) The specimen joint must be:
(1)…
(2) In the case of a heat fusion, solvent cement, or adhesive joint:
(i) Tested under any one of the test methods listed under § 192.283(a), and for PE
heat fusion joints (except for electrofusion joints) visually inspected in accordance
with ASTM F2620 (incorporated by reference, see § 192.7), or a written procedure
that has been demonstrated to provide an equivalent or superior level of safety,
applicable to the type of joint and material being tested;
(ii) Examined by ultrasonic inspection and found not to contain flaws that would
cause failure; or
(iii) Cut into at least 3 longitudinal straps, each of which is:
(A) Visually examined and found not to contain voids or discontinuities on the cut
surfaces of the joint area; and
(B) Deformed by bending, torque, or impact, and if failure occurs, it must not
initiate in the joint area.



IGU failed to qualify its personnel to make plastic pipe joints in accordance with § 192.285(a)(2)
because it did not have and/or follow a procedure for making a specimen joint from pipe sections
that examined and tested heat fusion joint specimens using a method acceptable per
§ 192.285(b)(2).
Section 192.285(b)(2) allows for various methods to be utilized to test and examine joint
specimens to determine adequate joining when qualifying joiners. During the inspection,
PHMSA inspectors observed pictures of plastic pipe butt fusion joint specimen testing that
showed the test joints were cut axially in half and subsequently quality tested by bending the
axial halves of the specimen. Testing methods not specifically described by § 192.285(b)(2) are
not adequate to qualify joiners unless a written procedure that has been previously demonstrated
to provide an equivalent or superior level of safety, applicable to the type of joint and material
being tested, is utilized. IGU did not provide a written procedure demonstrating equivalent or
superior level of safety for butt fusion joint testing during the inspection.
Accordingly, IGU was in violation of § 192.285(a)(2) for failing to follow a procedure to
examine and test heat fusion joint specimens via an acceptable method when qualifying
personnel to join plastic pipe.
3. § 192.1007 – What are the required elements of an integrity management plan?
A written integrity management plan must contain procedures for developing and
implementing the following elements:
(a) ….
(d) Identify and implement measures to address risks. Determine and implement
measures designed to reduce the risks from failure of its gas distribution pipeline.
These measures must include an effective leak management program (unless all
leaks are repaired when found).
IGU failed to implement an effective leak management plan per § 192.1007(d).
During the inspection, PHMSA inspectors reviewed record of a leak, found at meter #340152,
that was identified and graded as a Class 2 leak, pursuant to IGU’s procedures and leak grading
guidelines, by an IGU technician in May 2024. IGU did not have record of the leak being
monitored and scheduled for repair nor did IGU have record that the repair of the leak had
occurred.
PHMSA inspectors and IGU personnel visited the meter location during the inspection on
August 8, 2024, and IGU personnel tested for a leak via gas meter. Testing indicated a Class 2
leak, per IGU’s procedures and leak grading guidelines, was occurring.
Accordingly, IGU was in violation of § 192.1007(d) for failing to have an effective leak
management program.



Proposed Civil Penalty
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a
related series of violations. For violation occurring on or after December 28, 2023 and before
December 30, 2024, the maximum penalty may not exceed $266,015 per violation per day the
violation persists, up to a maximum of $2,660,135 for a related series of violations. For violation
occurring on or after January 6, 2023 and before December 28, 2023, the maximum penalty may
not exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627
for a related series of violations. For violation occurring on or after March 21, 2022 and before
January 6, 2023, the maximum penalty may not exceed $239,142 per violation per day the
violation persists, up to a maximum of $2,391,412 for a related series of violations. For violation
occurring on or after May 3, 2021 and before March 21, 2022, the maximum penalty may not
exceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for
a related series of violations. For violation occurring on or after January 11, 2021 and before
May 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation
persists, up to a maximum of $2,225,034 for a related series of violations. For violation
occurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not
exceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for
a related series of violations.
We have reviewed the circumstances and supporting documents involved in this case, and have
decided not to propose a civil penalty assessment at this time.
Proposed Compliance Order
With respect to Items 1, 2, and 3 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous
Materials Safety Administration proposes to issue a Compliance Order to Interior Gas Utility.
Please refer to the Proposed Compliance Order, which is enclosed and made a part of this
Notice.
Response to this Notice
Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators
in Enforcement Proceedings. Please refer to this document and note the response options. All
material you submit in response to this enforcement action may be made publicly available. If
you believe that any portion of your responsive material qualifies for confidential treatment
under 5 U.S.C. §552(b), along with the complete original document you must provide a second
copy of the document with the portions you believe qualify for confidential treatment redacted
and an explanation of why you believe the redacted information qualifies for confidential
treatment under 5 U.S.C. § 552(b).
Following your receipt of this Notice, you have 30 days to respond as described in the enclosed
Response Options. If you do not respond within 30 days of receipt of this Notice, this constitutes
a waiver of your right to contest the allegations in this Notice and authorizes the Associate
Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to
you and to issue a Final Order. If you are responding to this Notice, we propose that you submit
your correspondence to my office within 30 days from receipt of this Notice. The Region



Director may extend the period for responding upon a written request timely submitted
demonstrating good cause for an extension.
In your correspondence on this matter, please refer to CPF 5-2025-011-NOPV and, for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
Dustin Hubbard
Director, Western Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Enforcement Proceedings
cc: PHP-60 Compliance Registry
PHP-500 H. Keogh (#24-305759)
Mr. George Deal, Director of Operations, Interior Gas Utility – sdeal@interiorgas.com



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Interior Gas Utility (IGU) a Compliance Order
incorporating the following remedial requirements to ensure the compliance of Interior Gas
Utility with the pipeline safety regulations:
A. B. C. D. In regard to Item 1 of the Notice pertaining to the Teflon hose connection at
Storage Site 3, IGU must replace the Teflon hose with piping acceptable for use
per § 192.53 within 30 days of receipt of the Final Order and submit
documentation this was completed to the Western Region Director.
In regard to Item 2 of the Notice pertaining to the testing of joint specimens for
qualifying joiners, IGU must provide the Western Region Director with either (a)
evidence that the observed method of joint testing has been demonstrated to
provide an equivalent or superior level, or (b) provide the Western Region
Director with a procedure adopted to provide for conformance with
§ 192.285(b)(2) within 90 days of receipt of the Final Order.
In regard to Item 3 of the Notice pertaining to the observed gas leak, IGU must
provide the Western Region Director record of repair of the identified leak and an
updated leak management program that tracks and repairs leaks appropriately,
within 60 days of receipt of the Final Order.
It is requested (not mandated) that Interior Gas Utility maintain documentation of
the safety improvement costs associated with fulfilling this Compliance Order and
submit the total to Dustin Hubbard, Director, Western Region, Pipeline and
Hazardous Materials Safety Administration. It is requested that these costs be
reported in two categories: 1) total cost associated with preparation/revision of
plans, procedures, studies and analyses, and 2) total cost associated with
replacements, additions and other changes to pipeline infrastructure.

52025011NOPV_Closure Letter_09182025_(24-305759)_text.pdf

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
VIA ELECTRONIC MAIL TO: esudduth@interiorgas.com
September 18, 2025
Ms. Elena Sudduth
General Manager
Interior Gas Utility
2025 Phillips Field Road
Fairbanks, AK 99709
12300 W. Dakota Ave., Suite 340
Lakewood, CO 80228
CPF 5-2025-011-NOPV
Closure Letter
Dear Ms. Sudduth:
On July 23, 2025, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued
a Final Order to Interior Gas Utility (IGU) in the above-referenced case. This Order included a
Compliance Order requirement for IGU to take certain corrective actions.
Per the terms of the Final Order, this enforcement action would be closed once IGU addressed
the deficiencies outlined in the Compliance Order. On September 17, 2025, IGU submitted to
PHMSA the remainder of the documentation demonstrating the identified deficiencies had been
remediated.
Accordingly, this case is now closed. Thank you for your cooperation in this matter.
Sincerely,
Dustin Hubbard
Director, Western Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 H. Keogh (#24-305759)
George Deal, Director of Operations, Interior Gas Utility, sdeal@interiorgas.com
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