{"operation":"document","citation":"CPF 520055030","title":"QEP FIELD SERVICES COMPANY — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2005-10-25","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.452(b)(1), 195.452(b)(3), 195.452(e)(1), 195.452(f), 195.452(f)(1), 195.452(f)(5), 195.452(f)(8), 195.452(i)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520055030.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520055030.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520055030","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520055030","body":"Notice of Probable Violation involving QEP FIELD SERVICES COMPANY. PHMSA's enforcement data identifies the cited regulations as 195,  195.452(b)(1),  195.452(b)(3),  195.452(e)(1),  195.452(f),  195.452(f)(1),  195.452(f)(5),  195.452(f)(8),  195.452(i)(1),  60132. The case was opened on 2005-10-25 and is reported as closed as of 2008-05-28. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520055030_Final Order and Closure Letter_05282008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520055030/520055030_Final%20Order%20and%20Closure%20Letter_05282008.pdf\n\n520055030_final order and closure letter_05282008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520055030/520055030_final%20order%20and%20closure%20letter_05282008_text.pdf\n\n520055030_final order and closure letter_05282008_text.pdf\n\nU S Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Ave S E\nWashington DC 20590\nMAY 2 8 BOOB\nMr, Perry Richards\nVice President\nQuestar Gas Management Company\nQuestar Corporation\n1050 17'\" Street, Suite 500\nDenver, CO 80120\nRe: CPF No. 5-2005-5030\nDear Mr. Richards:\nEnclosed is the Final Order issued in the above-referenced case. It makes a finding of violation\nand finds that you have completed the actions specified in the Notice that were needed to bring\nquestion into compliance with the pipeline safety regulations, as set forth in the Proposed\nCompliance Order. The Order also makes findings of certain other probable violations for\nwhich you must take appropriate action to address, or be subject to future enforcement action.\nThis case is now closed. Your receipt of this Final Order constitutes service of that document\nunder 49 C. F. R. $ 190. 5.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipehne Safety\nEnclosure\ncc: Mr. Chris Hoidal, P. E.\n, Director, Western Region, PHMSA\nCERTIFIED MAIL — RETURN RECEIPT RE UESTED\n\n\n\nU. S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D. C. 20590\nIn the Matter of\nQuestar Gas Management Company, )\nRespondent.\n)\n)\n)\n)\n)\n)\nCPF No. 5-2005-5030\nFINAL ORDER\nOn July 13 and 14, 2005, pursuant to 49 U. S. C. $ 60117, a representative of the Pipeline and\nHazardous Materials Safety Administration's (PHMSA's) Office of Pipeline Safety conducted an\non-site pipeline safety inspection of the highly volatile liquid (HVL) pipeline facilities and\nrecords of Questar Gas Management Company, a subsidiary of Questar Corporation (Questar or\nRespondent), in Granger, Wyoming. As a result of the inspection, the Director, Western Region,\nPHMSA (Director) issued to Respondent, by letter dated October 25, 2005, a Notice of Probable\nViolation and Proposed Compliance Order (Notice). In accordance with 49 C. F. R. ) 190. 207,\nthe Notice proposed finding that Respondent had committed violations of 49 C. F. R. Part 195 and\nordering Respondent to take certain measures to correct the alleged violations. The Notice also\nproposed finding that Respondent had committed certain other probable violations of 49 C. F. R.\nPart 195 and warning Respondent to take appropriate corrective action to address them or be\nsubject to future enforcement action.\nRespondent responded to the Notice by letter dated January 24, 2006 (Response), Respondent\ndid not contest the allegation of violation in Notice Item 8 nor did it address Notice Item 9, but\nindicated that it planned on making modifications to its Liquid Pipeline Integrity Management\nPlan to address Warning Items 1 through 7. Respondent did not request a hearing and therefore\nhas waived its right to one.\nFINDING OF VIOLATION\nIn its Response, Respondent did not contest the allegation in the Notice as follows:\nItem 8:\n116 STAT. 2985 PUBLIC LAW 107 — 355 — DEC, 17, 2002\nSEC. 15. NATIONAL PIPELINE MAPPING SYSTEM.\n\n\n\n49 U. S. C. $ 60132. National pipeline mapping system.\n(a) INFORMATION TO BE PROVIDED — Not later than 6\nmonths after the date of enactment of this section, the operator of a\npipeline facility (except distribution lines and gathering lines) shall\nprovide to the Secretary of Transportation the following information\nwith respect to the facility:\n(1) Geospatial data appropriate for use in the National\nPipeline Mapping System or data in a format that can be readily\nconverted to geospatial data.\n(2) The name and address of the person with primary\noperational control to be identified as its operator for purposes of this\nchapter.\n(3) A means for a member of the public to contact the operator\nfor additional information about the pipeline facilities it operates.\n(b) UPDATES — A person providing information under sub-\nsection (a) shall provide to the Secretary updates of the information to\nreflect changes in the pipeline facility owned or operated by the person\nand as otherwise required by the Secretary.\nThe Notice alleged that Questar failed to submit the geospatial data required under 49 U. S. C. $\n60132 for its HVL pipelines to the National Pipeline Mapping System by the statutory deadline\nof June 17, 2003. Accordingly, I find that Respondent violated 49 U. S. C. ) 60132 by not\nsubmitting said data by the June 17, 2003 statutory deadline.\nThis finding of violation will be considered a prior offense in any subsequent enforcement action\ntaken against Respondent.\nCOMPLIANCE ORDER\nThe Notice proposed a Compliance Order with respect to Item 8 in the Notice for violation of 49\nU. S. C. $ 60132. Under 49 U. S. C. $ 60118(a), each person who engages in the transportation of\ngas, hazardous liquids, or who owns or operates a pipeline facility is required to comply with the\napplicable safety standards established under Chapter 601. The Director has indicated that\nRespondent has satisfied the requirement identified in the Notice and made a submission to\nNPMS. Accordingly, since compliance has been achieved with respect to said violation, it is\nunnecessary to include compliance terms in this Order.\n\n\n\nWARNING ITEMS\nWith respect to Items 1a-c, 2, 3a-c, 4a-e, Sa-b, 6a-b, 7a-i, and 9, the Notice alleged probable\nviolations of various sections of Part 195 but did not propose a civil penalty or compliance order\nfor these items. Therefore, these are considered to be warning items. The warnings, as more\nfully described in the Notice, were as follows:\n49 C. F. R. g 195. 452 (f)(1):\nNotice Item 1a — Respondent's failure to have a documented process in its\nIntegrity Management Program (IMP) for collecting and using field input to\nincorporate local knowledge in the ongoing upkeep of its \"Segment\nIdentification\" process, as well as for assigning which personnel would be\nresponsible for providing information to the IMP team and how it would be\ncommunicated.\nNotice Item 1b — Respondent's failure to have a Segment Identification process\nadequate to ensure that all \"could affect\" segments were covered in its IMP.\nNotice Item 1c — Respondent's failure to have a process for adding and removing\nassets in its IMP.\n49 C, F. R. g 195. 452(b)(3) (Notice Item 2) - Respondent's failure to properly\ndocument a process for revising its baseline assessment plan.\n49 C. F. R. g 195. 452(f)(8) (Notice Item 3):\nNotice Item 3a — Respondent's failure to delineate the qualifications for its\nintegrity results reviewers.\nNotice Item 3b — Respondent's failure to include the means to ensure that its\nprocess for reviewing integrity assessment results was adequate.\nNotice Item 3c — Respondent's failure to define assessment result distribution and\nreview requirements in its IMP with sufficient detail that qualified individuals\ncould produce consistent results.\n49 C. F. R. g 195. 452(e)(1):\nNotice Item 4a — Respondent's failure to provide a formal risk model or\ndocumentation of the risk analysis that it used in its IMP.\nNotice Item 4b — Respondent's failure to include in its IMP a process for\nanalyzing the risk of pipeline facilities.\nNotice Item 4c — Respondent's failure to have a review process for populating its\nrisk model data fields using available records and input from company subject-\nmatter experts.\n\n\n\nNotice Item 4d — Respondent's failure to have documentation of any changes to\nits risk model and/or risk evaluation process.\nNotice Item 4e — Respondent's failure to perform a \"Quality Control\" check of\nthe input in its risk assessment model database to ensure that it matched the input\nprovided by regional field operations.\n49 C. F. R. g 195. 452(i)(1):\nNotice Item 5a — Respondent's failure to have in its IMP a \"Preventive and\nMitigative\" (PkM) process of determining whether and when additional activities\ncould reduce the probabilities or consequences of a failure in a High Consequence\nArea (HCA).\nNotice Item 5b — Respondent's failure to provide a detailed description of how it\nused specific risk factors to determine the need for improvements in leak\ndetection and when emergency flow restricting devices were needed. In addition,\nRespondent's PAM process failed to identify HCA-specific risk drivers.\n49 C. F. R. g 195. 452(f)(5):\nNotice Item 6a — Respondent's failure to include a timeframe, after completing\nan assessment, in which to determine when the next reassessment needed to be\nperformed.\nNotice Item 6b — Respondent's failure to implement a continual process of\nevaluation and assessment,\n49 C. F. R. g 195. 452(f):\nNotice Item 7a — Respondent's failure to document a process for integrating all\navailable information about the integrity of its entire pipeline and the\nconsequences of failures.\nNotice Item 7b — Respondent's failure to document any training requirements for\nindividuals with key risk analysis responsibilities.\nNotice Item 7c — Respondent's failure to have a process for reviewing and\nupdating assumptions that were being used in risk analysis.\nNotice Item 7d — Respondent's failure to have a process for integrating other\ninformation with assessment results when formulating remediation plans.\nNotice Item 7e — Respondent's failure to contain in its procedures a requirement\nto determine and document the cause of all hydrostatic test failures and the\nappropriate corrective actions to be taken in order to mitigate failure defects of a\nsimilar nature.\n\n\n\nNotice Item 7f — Respondent's failure to have an IMP that included how pressure\nreductions were to be determined for corrosion and non-corrosion related\nanomalies.\nNotice Item 7g — Respondent's failure to implement and document its IMP\nevaluation.\nNotice Item 7h — Respondent's failure to develop a process for communicating\nthe results of performance evaluations within the company.\nNotice Item 7i — Respondent's failure to have an IMP that includes a process by\nwhich data from inspections and tests required by Part 195 are integrated in order\nto establish appropriate hydrostatic testing intervals.\n49 C. F. R. g 195. 452 (b)(1) (Notice Item 9) — Respondent's failure to develop a\nwritten IMP within the statutory deadline.\nRespondent indicated in its Response that it planned to make modifications to its Liquid Pipeline\nIMP to address Notice Items 1 through 7 and their subparts, Having considered such\ninformation, I find, pursuant to 49 C. F, R. $ 190. 205, that probable violations of 49 C. F. R. )\n195. 452 (f)(1) (Notice Item la-c), 49 C. F, R. $ 195. 452(b)(3) (Notice Item 2), 49 C. F. R. $\n195. 452(f)(8) (Notice Item 3a-c), 49 C. F. R. ) 195. 452(e)(1) (Notice Item 4a-e), 49 C. F. R. $\n195. 452(i)(1) (Notice Item 5a-b), 49 C. F. R. ) 195. 452(f)(5) (Notice Item 6a-b), 49 C, F. R. $\n195. 452(f) (Notice Item 7a-i), and 49 C. F, R. $ 195. 452 (b)(1) (Notice Item 9) have occurred and\nRespondent is hereby advised to correct such conditions. In the event that PHMSA finds a\nviolation for any of these items in a subsequent inspection, Respondent may be subject to future\nenforcement action.\nUnder 49 C. F. R. $ 190. 215, Respondent has a right to submit a Petition for Reconsideration of\nthis Final Order. The petition must be received within 20 days of Respondent's receipt of this\nFinal Order and must contain a brief statement of the issue(s). The terms of this Order, including\nany required corrective action, remain in full effect unless the Associate Administrator, upon\nrequest, grants a stay.\nThe terms and conditions of this Final Order shall be effective upon receipt.\nMAY 2 8 2008\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nDate Issued","truncated":false,"body_characters":12471}