# QEP MARKETING COMPANY — Notice of Amendment

- **operation:** document
- **citation:** CPF 520070025M
- **title:** QEP MARKETING COMPANY — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2007-11-16
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 192.905(a), 192.905(c).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520070025m.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520070025m.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520070025m
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520070025M
**body:**

Notice of Amendment involving QEP MARKETING COMPANY. PHMSA's enforcement data identifies the cited regulations as 192.905(a),  192.905(c). The case was opened on 2007-11-16 and is reported as closed as of 2008-03-03. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520070025M_notice of amendment_11162007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520070025M/520070025M_notice%20of%20amendment_11162007.pdf

520070025m_notice of amendment_11162007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520070025M/520070025m_notice%20of%20amendment_11162007_text.pdf

520070025M_operator response to notice_12052007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520070025M/520070025M_operator%20response%20to%20notice_12052007.pdf

520070025m_notice of amendment_11162007_text.pdf

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12300 W Dakota Ave, Suite 110
Lakewood, CO 80228
U. S. Deportment
of Transportation
Pipeline and
Hazardous Materials Safety
Administration
NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT RE UESTED
November 16, 2007
Mr, Perry H. Richards
General Manager
Questar Energy Trading
1050 17'" S
Denver, CO 80265
CPF 5-2007-0025M
Dear Mr. Richards:
On November 6, 2007, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Questar
Energy Trading's {QET) procedures and records for your Integrity Management Program {IMP)
in Evanston, Wyoming.
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
QET plans and procedures, as described below:
1. HCA Identification
$192. 905 How does an operator identify a high consequence area?
(a) GeneraL To determine which segments of an operator's transmission pipeline
system are covered by this subpart, an operator must identify the high consequence
areas. An operator must use method (1) or (2) from the definition in g 192. 903 to
identify a high consequence area. An operator may apply one method to its entire
pipeline system, or an operator may apply one method to individual portions of the
pipeline system. An operator must describe in its integrity management program
which method it is applying to each portion of the operator's pipeline system. The



description must include the potential impact radius when utilized to establish a high
consequence area. (See appendix E. I. for guidance on identifying high consequence
areas. )
(b)(1) Identified sites. An operator must identify an identified site, for purposes of this
subpart, from information the operator has obtained from routine operation and
maintenance activities and from public officials with safety or emergency response or
planning responsibilities who indicate to the operator that they know of locations that
meet the identified site criteria. These public officials could include officials on a local
emergency planning commission or relevant Native American tribal officials.
(2) If a public official with safety or emergency response or planning responsibilities
informs an operator that it does not have the information to identify an identified site,
the operator must use one of the following sources, as appropriate, to identify these
sites.
(i) Visible marking (e. g. ,
a sign); or
(ii) The site is licensed or registered by a Federal, State, or local government agency;
or
(iii) The site is on a list (including a list on an internet web site) or map maintained by
or available from a Federal, State, or local government agency and available to the
general public.
(c) Newly identified areas. When an operator has information that the area around a
pipeline segment not previously identified as a high consequence area could satisfy any
of the definitions in g 192. 903, the operator must complete the evaluation using method
(1) or (2). If the segment is determined to meet the definition as a high consequence
area, it must be incorporated into the operator's baseline assessment plan as a high
consequence area within one year from the date the area is identified.
~ Item 1A: $192. 905(a) and $192. 905(b)(1) &(2)
The QET HCA identification process does not clearly define in sufficient detail who is
responsible for making decisions regarding the determination of HCAs and the
qualifications of that individual as required by ASME B31. 8S Section 12. 2. 4 and (192. 915.
~ Item 1B: $192. 905(c)
The HCA process used by QET does not require the pipeline be surveyed and evaluated for
any other changes on an annual basis to determine if there are any new HCAs along the
pipeline.
Res onse to this Notice
This Notice is provided pursuant to 49 U. S. C. $ 60108(a) and 49 C. F. R. $ 190. 237. 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). 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 a Final Order.
If, after opportunity for a hearing, 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. 237). 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.
In correspondence concerning this matter, please refer to CPF 5-2007-0025M and, for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
QU
Chris Hoidal
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 J. Gilliam (¹120027)
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