# STATOIL OIL & GAS LP — Warning Letter

- **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:** Not available
- **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.

Official case documents:

320176010W_Warning Letter_09292017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320176010W/320176010W_Warning%20Letter_09292017.pdf

320176010W_Warning Letter_09292017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320176010W/320176010W_Warning%20Letter_09292017_text.pdf

320176010W_Warning Letter_09292017_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
September 29, 2017
Mr. Frederick Beck, Senior Vice President DPUSA
Statoil & Gas LP
6300 Bridge Point Parkway, Bldg 2, Suite 100
Austin, TX 78730
CPF 3-2017-6010W
Dear Mr. Beck:
On March 22-24 and May 3-5, 2016, representatives of the Pipeline and Hazardous Materials
Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.)
inspected your North Dakota pipeline unit in Williston, North Dakota.
As a result of the inspection, it is alleged that you have committed probable viloations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items
inspected and the probable violation(s) are:
1. §195.104 Variations in pressure.
If, within a pipeline system, two or more components are to be connected at a
place where one will operate at a higher pressure than another, the system must
be designed so that any component operating at the lower pressure will not be
overstressed.
Statoil Oil & Gas LP (Statoil) failed to demonstrate that when two or more
components are connected, the system must be designed so the component operating at
a lower pressure will not be overstressed. When asked to demonstrate that the lowest
rated component was used in the MOP calculation, no documentation was produced.



2. §195.507 Recordkeeping
Each operator shall maintain records that demonstrate compliance with this
subpart.
(a) Qualification records shall include:
(1) Identification of qualified individual(s);
(2) Identification of the covered tasks the individual is qualified to
perform;
(3) Date(s) of current qualification; and
(4) Qualification method(s).
(b) Records supporting an individual's current qualification shall be maintained
while the individual is performing the covered task. Records of prior qualification
and records of individuals no longer performing covered tasks shall be retained
for a period of five years.
Statoil failed to maintain records that demonstrated an individual’s current
qualification while the individual was performing the covered task. The Operator
Qualification Solutions Group (OQSG) generic Abnormal Operating Condition (AOC)
module is in Statoil's list of covered tasks but the corrosion techician’s Operator
Qualification (OQ) records showed he was not qualified. A valve maintenance
contractor performed covered tasks, but had not taken the ISNETWORLD generic
AOC module for Statoil.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to
exceed $209,002 per violation per day the violation persists up to a maximum of $2,090,022
for a related series of violations. We have reviewed the circumstances and supporting
documents involved in this case, and have decided not to conduct additional enforcement
action or penalty assessment proceedings at this time. We advise you to correct the item(s)
identified in this letter. Failure to do so will result in Statoil & Gas, LP being subject to
additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer
to CPF 3-2017-6010W. 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
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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).
Sincerely,
Allan C. Beshore
Director, Central Region, OPS
Pipeline and Hazardous Materials Safety Administration
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