{"operation":"document","citation":"CPF 520085017W","title":"QEP FIELD SERVICES COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-06-19","effective_on":null,"summary":"CLOSED warning letter citing 195.452(f)(3), 195.452(f)(8), 195.452(i)(1), 195.452(i)(4), 195.452(k).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085017w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085017w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085017w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520085017W","body":"Warning Letter involving QEP FIELD SERVICES COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.452(f)(3),  195.452(f)(8),  195.452(i)(1),  195.452(i)(4),  195.452(k). The case was opened on 2008-06-19 and is reported as closed as of 2008-06-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520085017W_warning letter_06192008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085017W/520085017W_warning%20letter_06192008.pdf\n\n520085017W_warning letter_06192008.pdf\n\nU.S. Department\nof Transportation Pipeline and\nHazardous Materials Safety\nAdministration\n12300 W. Dakota Ave., Suite 110\nLakewood, CO 80228\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 19,2008\nMr. Perry Richards\nGeneral Manager\nQuestar Gas Management\n1050 1 7 ~ ~ Street, Suite 500\nDenver, CO 80265\nDear Mr. Richards:\nOn April 23,2008, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Questar\nGas Management's (QGM) Integrity Management Program near Lyman, Wyoming.\n. As a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n1. 5195.452 Pipeline integrity management in high consequence areas.\nf) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\n\n\n\n2. 3. integrity management program:\n(8) A process for review of integrity assessment results and information analysis by\na person qualified to evaluate the results and information (see paragraph (h)(2) of\nthis section).\nQGM personnel were not knowledgeable about the requirements of 49 CFR, Part 195\nSubpart E. Our inspector did not believe QGM staff were hlly qualified to conduct,\nreview, and evaluate this type of assessment.\n8195.452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\nintegrity management program:\n(3) An analysis that integrates all available information about the integrity of the\nentire pipeline and the consequences of a failure (see paragraph (g) of this section);\nQGM did not adequately perform their risk analysis after conducting a baseline\nassessment in 2005 for one of their propane pipelines. In addition, field input was not\nadequately incorporated in their annual risk analysis.\n8195.452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\nintegrity management program:\n(6) Identification of preventive and mitigative measures to protect the high\nconsequence area (see paragraph (i) of this section);\n(i) What preventive and mitigative measures must an operator take to protect the\nhigh consequence area?\n(1) General requirements. An operator must take measures to prevent and\nmitigate the consequences of a pipeline failure that could affect a high consequence\narea. These measures include conducting a risk analysis of the pipeline segment to\nidentify additional actions to enhance public safety or environmental protection.\nSuch actions may include, but are not limited to, implementing damage prevention\nbest practices, better monitoring of cathodic protection where corrosion is a\nconcern, establishing shorter inspection intervals, installing EFRDs on the pipeline\n\n\n\n4. 5. segment, modifying the systems that monitor pressure and detect leaks, providing\nadditional training to personnel on response procedures, conducting drills with\nlocal emergency responders and adopting other management controls.\nQGM did not adequately document their efforts to identify and evaluate additional\npreventive and mitigative measures (P&MM) that could further enhance safety.\ng195.452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\nintegrity management program:\n(6) Identification of preventive and mitigative measures to protect the high\nconsequence area (see paragraph (i) of this section);\n(i) What preventive and mitigative measures must an operator take to protect the\nhigh consequence area?\n(4) Emergency Flow Restricting Devices (EFRD). If an operator determines that an\nEFRD is needed on a pipeline segment to protect a high consequence area in the\nevent of a hazardous liquid pipeline release, an operator must install the EFRD. In\nmaking this determination, an operator must, at least, consider the following\nfactors-the swiftness of leak detection and pipeline shutdown capabilities, the type\nof commodity carried, the rate of potential leakage, the volume that can be\nreleased, topography or pipeline profile, the potential for ignition, proximity to\npower sources, location of nearest response personnel, specific terrain between the\npipeline segment and the high consequence area, and benefits expected by reducing\nthe spill size.\nQGM did not produce any documentation that indicated an in-depth evaluation was\nconducted regarding the need for EFRD's.\ng195.452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\nintegrity management program:\n(7) Methods to measure the program's effectiveness (see paragraph (k) of this\nsection);\n\n\n\n(k) What methods to measure program effectiveness must be used? An operator's\nprogram must include methods to measure whether the program is effective in\nassessing and evaluating the integrity of each pipeline segment and in protecting\nthe high consequence areas. See Appendix C of this part for guidance on methods\nthat can be used to evaluate a program's effectiveness.\nQGM did not have an adequate set of performance measures to address the effectiveness\nof their IMP for each particular pipeline segment.\nUnder 49 United States Code, $60 122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violation persists up to a maximum of $1,000,000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the items identified in this letter.\nFailure to do so will result in Questar Gas Management being subject to additional enforcement\naction.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2008-5017W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 H. Nguyen (#I21 193)","truncated":false,"body_characters":9275}