{"operation":"document","citation":"CPF 52025012WL","title":"INTERIOR GAS UTILITY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-12-03","effective_on":null,"summary":"CLOSED warning letter citing 192.631(d)(2), 192.631(d)(3), 192.631(j)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52025012wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52025012wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52025012wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52025012WL","body":"Warning Letter involving INTERIOR GAS UTILITY. PHMSA's enforcement data identifies the cited regulations as 192.631(d)(2),  192.631(d)(3),  192.631(j)(2). The case was opened on 2025-12-03 and is reported as closed as of 2025-12-03. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52025012WL_Warning Letter_12032025_(24-298947).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025012WL/52025012WL_Warning%20Letter_12032025_(24-298947).pdf\n\n52025012WL_Warning Letter_12032025_(24-298947)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025012WL/52025012WL_Warning%20Letter_12032025_(24-298947)_text.pdf\n\n52025012WL_Warning Letter_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\nWARNING LETTER\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 5-2025-012-WL\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, procedures, and records in Fairbanks\nand North Pole, Alaska.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. § 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) …\n(2) Educate controllers and supervisors in fatigue mitigation strategies and how off-\nduty activities contribute to fatigue;\n\n\n\n(3) Train controllers and supervisors to recognize the effects of fatigue;\nIGU failed to educate its controllers and supervisors in fatigue mitigation strategies and how off-\nduty activities contribute to fatigue, and to recognize the effects of fatigue, as required by\n§ 192.631(d)(2) and (3).\nSpecifically, during the inspection, PHMSA reviewed IGU’s procedures and training records.\nPHMSA observed that the IGU could not provide records demonstrating that its controllers and\nsupervisors received fatigue training focused on mitigation strategies and how off-duty activities\ncontribute to fatigue, and how to recognize the effects of fatigue during the calendar years of\n2022 and 2023.\nA review of IGU’s Gas Control Plan, Fatigue Mitigation and Scheduling, found that the plan was\nsilent on the frequency in which controller education regarding fatigue mitigation would occur.\nFurther, the plan did not include any criterion for successfully completing the fatigue mitigation\ntraining.\nWhile PHMSA did observe a record dated December 2, 2022 labeled “Training Attendance\nRecord: Subject G&D SOP Review,” PHMSA was unable to determine if fatigue mitigation\ntraining was included as part of this training session. Further, there was nothing included with\nthis record which demonstrated any fatigue training was conducted as part of this training session\nsuch as a training agenda or training materials related to fatigue mitigation.\nPHMSA did observe a memo titled “Training Objective: CRM Fatigue Mitigation” during the\ninspection as evidence of its calendar year 2023 fatigue mitigation training. While the title stated\nit was fatigue training, the memo did not contain any supporting documentation that explained\nwhat was covered in the training such as an agenda or training materials. Further, the 2023\nmemo did not include a sign in sheet or attendance roster of who received the training. Without\nsuch a record, PHMSA could not confirm that IGU’s controllers and supervisors were the IGU\npersonnel who attended the training.\nIGU was required per § 192.631(j)(1) to maintain for review during an inspection records that\ndemonstrate compliance with § 192.631(d). Without such records, PHMSA cannot verify an\noperator complied with the requirements of the pipeline safety regulations.\nTherefore, IGU failed to provide fatigue mitigation to its controllers and supervisors as required\nby § 192.631(d)(2) and (3).\n2\n\n\n\n2. § 192.631 Control room management.\n(a) …\n(j) Compliance and deviations. An operator must maintain for review during\ninspection:\n(1) …\n(2) Documentation to demonstrate that any deviation from the procedures required\nby this section was necessary for the safe operation of a pipeline facility.\nIGU failed to provide documentation to demonstrate that any deviation from the procedures\nrequired by § 192.631 was necessary for the safe operation of a pipeline facility, as required.\nSpecifically, during the inspection, PHMSA reviewed the Hours of Service (HOS) deviations for\ncontrollers who worked shifts on the following dates: July 27, 2023, August 17, 2023, and\nAugust 18, 2023. However, none of the records provided included any justification explaining\nwhy the deviations were necessary for maintaining the safe operation of the pipeline. The\ndeviation records lacked any rationale and were entirely silent on the operational necessity of the\nexceptions.\nTherefore, IGU failed to provide documentation to demonstrate why deviations from procedures\nrequired by § 192.631 was necessary for the safe operation of the pipeline as required by\n§ 192.631(j)(2).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a\nrelated series of violations. For violation occurring on or after December 28, 2023 and before\nDecember 30, 2024, the maximum penalty may not exceed $266,015 per violation per day the\nviolation persists, up to a maximum of $2,660,135 for a related series of violations. For violation\noccurring on or after January 6, 2023 and before December 28, 2023, the maximum penalty may\nnot exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627\nfor a related series of violations. For violation occurring on or after March 21, 2022 and before\nJanuary 6, 2023, the maximum penalty may not exceed $239,142 per violation per day the\nviolation persists, up to a maximum of $2,391,142 for a related series of violations. For violation\noccurring on or after May 3, 2021 and before March 21, 2022, the maximum penalty may not\nexceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for\na related series of violations. For violation occurring on or after January 11, 2021 and before\nMay 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation\npersists, up to a maximum of $2,225,034 for a related series of violations. For violation\noccurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not\nexceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for\na related series of violations.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\n3\n\n\n\ntime. We advise you to correct the items identified in this letter. Failure to do so will result in\nInterior Gas Utility being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2025-012 WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. § 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. § 552(b).\nSincerely,\nDustin Hubbard\nDirector, Western Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 D. Fehling (24-298947)\n4","truncated":false,"body_characters":8463}