{"operation":"document","citation":"CPF 320176010W","title":"STATOIL OIL & GAS LP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-09-29","effective_on":null,"summary":"CLOSED warning letter citing 195.104, 195.507.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320176010w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320176010w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320176010w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320176010W","body":"Warning Letter involving STATOIL OIL & GAS LP. PHMSA's enforcement data identifies the cited regulations as 195.104,  195.507. The case was opened on 2017-09-29 and is reported as closed as of 2017-09-29. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320176010W_Warning Letter_09292017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320176010W/320176010W_Warning%20Letter_09292017.pdf\n\n320176010W_Warning Letter_09292017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320176010W/320176010W_Warning%20Letter_09292017_text.pdf\n\n320176010W_Warning Letter_09292017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 29, 2017\nMr. Frederick Beck, Senior Vice President DPUSA\nStatoil & Gas LP\n6300 Bridge Point Parkway, Bldg 2, Suite 100\nAustin, TX 78730\nCPF 3-2017-6010W\nDear Mr. Beck:\nOn March 22-24 and May 3-5, 2016, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.)\ninspected your North Dakota pipeline unit in Williston, North Dakota.\nAs a result of the inspection, it is alleged that you have committed probable viloations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items\ninspected and the probable violation(s) are:\n1. §195.104 Variations in pressure.\nIf, within a pipeline system, two or more components are to be connected at a\nplace where one will operate at a higher pressure than another, the system must\nbe designed so that any component operating at the lower pressure will not be\noverstressed.\nStatoil Oil & Gas LP (Statoil) failed to demonstrate that when two or more\ncomponents are connected, the system must be designed so the component operating at\na lower pressure will not be overstressed. When asked to demonstrate that the lowest\nrated component was used in the MOP calculation, no documentation was produced.\n\n\n\n2. §195.507 Recordkeeping\nEach operator shall maintain records that demonstrate compliance with this\nsubpart.\n(a) Qualification records shall include:\n(1) Identification of qualified individual(s);\n(2) Identification of the covered tasks the individual is qualified to\nperform;\n(3) Date(s) of current qualification; and\n(4) Qualification method(s).\n(b) Records supporting an individual's current qualification shall be maintained\nwhile the individual is performing the covered task. Records of prior qualification\nand records of individuals no longer performing covered tasks shall be retained\nfor a period of five years.\nStatoil failed to maintain records that demonstrated an individual’s current\nqualification while the individual was performing the covered task. The Operator\nQualification Solutions Group (OQSG) generic Abnormal Operating Condition (AOC)\nmodule is in Statoil's list of covered tasks but the corrosion techician’s Operator\nQualification (OQ) records showed he was not qualified. A valve maintenance\ncontractor performed covered tasks, but had not taken the ISNETWORLD generic\nAOC module for Statoil.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to\nexceed $209,002 per violation per day the violation persists up to a maximum of $2,090,022\nfor a related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement\naction or penalty assessment proceedings at this time. We advise you to correct the item(s)\nidentified in this letter. Failure to do so will result in Statoil & Gas, LP being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 3-2017-6010W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any portion\nof your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along\n2\n\n\n\nwith the complete original document you must provide a second copy of the document with\nthe portions you believe qualify for confidential treatment redacted and an explanation of why\nyou believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nAllan C. Beshore\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\n3","truncated":false,"body_characters":4439}