# DOMINION ENERGY QUESTAR PIPELINE, LLC — Notice of Amendment

**Citation:** CPF 520181007M  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2018-08-17

CLOSED notice of amendment citing 192.605(b)(1), 192.605(b)(2), 192.605(b)(8), 192.605(c)(4), 192.614(c)(1).

## Document text

Notice of Amendment involving DOMINION ENERGY QUESTAR PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(1),  192.605(b)(2),  192.605(b)(8),  192.605(c)(4),  192.614(c)(1). The case was opened on 2018-08-17 and is reported as closed as of 2018-10-24. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520181007M_Closure Letter_10242018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520181007M/520181007M_Closure%20Letter_10242018.pdf

520181007M_Closure Letter_10242018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520181007M/520181007M_Closure%20Letter_10242018_text.pdf

520181007M_Notice of Amendment_08172018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520181007M/520181007M_Notice%20of%20Amendment_08172018.pdf

520181007M_Notice of Amendment_08172018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520181007M/520181007M_Notice%20of%20Amendment_08172018_text.pdf

520181007M_Operator Response to Notice_09202018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520181007M/520181007M_Operator%20Response%20to%20Notice_09202018.pdf

520181007M_Closure Letter_10242018_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
October 24, 2018
Mr. Ron Jorgensen
Vice President, Operations and Gas Control
Dominion Energy Questar Pipeline
333 South State Street
P.O. Box 45360
Salt Lake City, UT 84145-0360
CPF 5-2018-1007M
Closure Letter
Dear Mr. Jorgensen:
On March 12, 2018, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) and Arizona Corporation Commission, pursuant to Chapter 601 of 49
United States Code, inspected Dominion Energy Questar Pipeline’s (DEQP) procedures for
operation and maintenance in Salt Lake City, Utah. As a result of the inspection, DEQP was
issued a Notice of Amendment on August 17, 2018, which proposed amendment of your
procedures.
DEQP submitted its amended procedures on September 20, 2018. My staff reviewed the amended
procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been
corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely,
Kim West
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 C. Allen (#157195)

520181007M_Notice of Amendment_08172018_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
August 17, 2018
Mr. Ron Jorgensen
Vice President, Operations and Gas Control
Dominion Energy Questar Pipeline
333 South State Street
P.O. Box 45360
Salt Lake City, UT 84145-0360
CPF 5-2018-1007M
Dear Mr. Jorgensen:
On March 12, 2018, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) and Arizona Corporation Commission, pursuant to Chapter 601 of
49 United States Code, inspected Dominion Energy Questar Pipeline’s (DEQP) procedures
for operation and maintenance in Salt Lake City, Utah.
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
DEQP’s plans or procedures, as described below:



1. §192.605 Procedural manual for operations, maintenance, and emergencies.
(a) . . .
(b) Maintenance and normal operations. The manual required by paragraph (a)
of this section must include procedures for the following, if applicable, to provide
safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in accordance with each of
the requirements of this subpart and subpart M of this part.
DEQP’s O&M did not have adequate procedures for operating, maintaining, and repairing
the pipeline in accordance with §192.736(c).1 Specifically, DEQP did not have
procedures for maintaining each gas detection and alarm system required by Section
192.736 to ensure they were functioning properly. At the time of inspection, DEQP did
not have detailed procedures for gas detector and flame detector equipment maintenance
(including inspection and calibration) to ensure they were functioning properly.
2. §192.605 Procedural manual for operations, maintenance, and emergencies.
(a) . . .
(b) Maintenance and normal operations. The manual required by paragraph (a)
of this section must include procedures for the following, if applicable, to provide
safety during maintenance and operations.
(2) Controlling corrosion in accordance with the operations and maintenance
requirements of subpart I of this part.
DEQP’s O&M did not have adequate procedures for corrosion control in accordance with
§192.479.2 Although DEQP has procedures for atmospheric corrosion control in Section
18.1 of SP 7-00-01, that procedure states that "[e]ach aboveground pipeline or portion of a
pipeline installed after July 31, 1971 that is exposed to the atmosphere will be cleaned and
either coated or jacketed with a material suitable for the prevention of atmospheric
corrosion.” The conditional statement, “installed after July 31, 1971” should be removed
or otherwise revised to clarify that this regulation applies to each pipeline or portion of
pipeline that is exposed to the atmosphere, unless it falls under the exceptions listed in
paragraph (c). In addition, the procedures do not give personnel adequate guidance on
how to evaluate the condition of no coating or inadequate coating at air-soil interface
locations.
1 49 C.F.R. § 192.736(c) requires that “[e]ach gas detection and alarm system required by this section must be
maintained to function properly. The maintenance must include performance tests.”
2 49 C.F.R. §192.479 Atmospheric corrosion control: General.
(a) Each operator must clean and coat each pipeline or portion of pipeline that is exposed to the
atmosphere, except pipelines under paragraph (c) of this section.
(b) Coating material must be suitable for the prevention of atmospheric corrosion.
(c) Except portions of pipelines in offshore splash zones or soil-to-air interfaces, the operator need not
protect from atmospheric corrosion any pipeline for which the operator demonstrates by test,
investigation, or experience appropriate to the environment of the pipeline that corrosion will -
(1) Only be a light surface oxide; or
2



3. §192.605 Procedural manual for operations, maintenance, and emergencies.
(a) . . .
(c) Abnormal operation. For transmission lines, the manual required by
paragraph (a) of this section must include procedures for the following to provide
safety when operating design limits have been exceeded:
(4) Periodically reviewing the response of operator personnel to determine the
effectiveness of the procedures controlling abnormal operation and taking
corrective action where deficiencies are found.
DEQP’s O&M did not have adequate procedures for abnormal operations with regard to
periodically reviewing the response of operator personnel to determine the effectiveness
of the procedures controlling abnormal operations and taking corrective action where
deficiencies are found. Although DEQP has procedures for atmospheric corrosion
control, Section 7.1.5 of its procedures states DEQP "shall review" abnormal event
procedures, but does not specify when or how long they have to accomplish review of
abnormal event procedures. Since the regulation requires periodic review, DEQP’s
written procedures must specify how often these reviews must take place.
4. §192.605 Procedural manual for operations, maintenance, and emergencies.
(a) . . .
(b) Maintenance and normal operations. The manual required by paragraph
(a) of this section must include procedures for the following, if applicable, to
provide safety during maintenance and operations.
(8) Periodically reviewing the work done by operator personnel to determine
the effectiveness, and adequacy of the procedures used in normal operation
and maintenance and modifying the procedures when deficiencies are found.
DEQP’s O&M did not have adequate procedures for periodically reviewing the work done
by operator personnel to determine the effectiveness, and adequacy of the procedures used
in normal operation and maintenance and modifying the procedures when deficiencies are
found. Although DEQP has procedures for periodic review of operation and maintenance
procedures in SP 3-90-01, Annual Review of Procedures Manual and Periodic Review of
Work Done by Company Personnel: Section 7, Periodic Review of Work Done by
Company Personnel, it does not specify when or how long they have to accomplish review
of their maintenance and normal operating procedures to determine adequacy and
effectiveness. Although DEQP informed PHMSA that periodic means 3 years, not-to-
exceed 39 months, during the inspection, their procedures do not reflect this. Since the
regulation requires periodic review, DEQP’s written procedures must specify how often
these reviews must take place.
5. §192.614 Damage prevention program.
(a) . . .
(c) The damage prevention program required by paragraph (a) of this section
must, at a minimum:
(2) Not affect the safe operation of the pipeline before the next scheduled inspection.
3



(1) Include the identity, on a current basis, of persons who normally
engage in excavation activities in the area in which the pipeline is located.
DEQP’s written program to prevent damage to its pipeline from excavation activities is
deficient because it fails to sufficiently identify the persons normally engaged in
excavation activities in the area in which the pipeline is located. Although DEQP has
procedures for identifying persons who normally engage in excavation activities in
Standard Practice 5-00-07, Sect 7., it does not currently have a procedure (or ability) to
identify excavators from one-call not included on their excavator/contractors list. And the
procedure did not specify how reports of Third Party Activity and names of associated
contractors or excavators are input back into the mail-outs and communications with
excavators along the system.
In addition to the alleged inadequacies cited above, PHMSA would also like to recommend
that DEQP define the terms “management” and “for cause” in its procedures for anomalies
discovered in non-HCA areas. Specifically, Standard Practices (SP) 5-01-00, Section 6, the
procedure for Anomaly Response Scheduling for Non-covered Segments, indicates that “[i]f
the anomaly is in a Class 1 Location, non-HCA, and outside any Consequence Areas, the
responsible time requirement may be lengthened with management approval (for cause).”
This is not an alleged violation.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed
as part of this Notice is a document entitled Response Options for Pipeline Operators in
Compliance Proceedings. Please refer to this document and note the response options. Be
advised that all material you submit in response to this enforcement action is subject to being
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 the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under §190.211. 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 an Order Directing
Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you
may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. §
190.206). If you are not contesting this Notice, we propose that you submit your amended
procedures to my office within 30 days of receipt of this Notice. This period may be extended
by written request for good cause. Once the inadequacies identified herein have been
addressed in your amended procedures, this enforcement action will be closed.
It is requested (not mandated) that DEQP maintain documentation of the safety improvement
4



costs associated with fulfilling this Notice of Amendment (preparation/revision of plans,
procedures) and submit the total to Kim West, Director, Western Region, Pipeline and
Hazardous Materials Safety Administration. In correspondence concerning this matter, please
refer to CPF 5-2018-1007M and, for each document you submit, please provide a copy in
electronic format whenever possible.
Sincerely,
Kim West
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
cc: PHP-60 Compliance Registry
PHP-500 C. Allen (#157195)
5

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/520181007M>
- Source ID: `phmsa-enforcement`
- SHA-256: `20fff05ac24e3e765cf6ada3d367c96d43b4bdcff5aa1a1627dce64ab3416c5b`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T11:38:27.127Z
- Document slug: `phmsa-enforcement-520181007m`

### Source metadata

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  "pipelineType": "GAS INTERSTATE ONSHORE",
  "caseStatus": "CLOSED",
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    "192.614(c)(1)"
  ],
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```
