{"operation":"document","citation":"CPF 520085019","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":"2008-06-19","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.452(b)(3), 195.452(c)(1)(i)(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085019.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085019.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085019","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520085019","body":"Notice of Probable Violation involving QEP FIELD SERVICES COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.452(b)(3),  195.452(c)(1)(i)(b). The case was opened on 2008-06-19 and is reported as closed as of 2010-03-04. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520085019_FinalOrder_03042010 _text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085019/520085019_FinalOrder_03042010%20_text.pdf\n\n520085019_FinalOrder_03042010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085019/520085019_FinalOrder_03042010.pdf\n\n520085019_NOPV PCO letter_06192008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085019/520085019_NOPV%20PCO%20letter_06192008.pdf\n\n520085019_operator response_02092009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085019/520085019_operator%20response_02092009.pdf\n\n520085019_operator response_07162008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085019/520085019_operator%20response_07162008.pdf\n\n520085019_NOPV PCO letter_06192008.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n12300 W. Dakota Ave., Suite 110\nLakewood, CO 80228\nNOTICE OF PROBABLE VIOLATION\nand\nPROPOSED COMPLIANCE ORDER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 19,2008\nMr. Perry Richards\nGeneral Manager\nQuestar Gas Management\n1050 1 7th street, Suite 500\nDenver, CO 80265\nCPF 5-2008-5019\nDear Mr. Richards:\nOn April 23,2008, a representative of the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your Integrity\nManagement Program (IMP) near Lyman, Wyoming.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the\nprobable violation is:\n1. 5195.452 Pipeline integrity management in high consequence areas.\n(b) What program and practices must operators use to manage pipeline integrity?\nEach operator of a pipeline covered by this section must:\n(3) Include in the program a plan to carry out baseline assessments of line pipe as\nrequired by paragraph (c) of this section.\n(c) What must be in the baseline assessment plan? (1) An operator must include each\nof the following elements in its written baseline assessment plan:\n\n\n\n(i) The methods selected to assess the integrity of the line pipe. An operator must\nassess the integrity of the line pipe by any of the following methods. The methods an\noperator selects to assess low frequency electric resistance welded pipe or lap welded\npipe susceptible to longitudinal seam failure must be capable of assessing seam\nintegrity and of detecting corrosion and deformation anomalies.\n(A) Internal inspection tool or tools capable of detecting corrosion and deformation\nanomalies including dents, gouges and grooves;\n(B) Pressure test conducted in accordance with subpart E of this part;\n(C) External corrosion direct assessment in accordance with 5195.588; or\n(D) Other technology that the operator demonstrates can provide an equivalent\nunderstanding of the condition of the line pipe. An operator choosing this option must\nnotify the Office of Pipeline Safety (OPS) 90 days before conducting the assessment,\nby sending a notice to the address or facsimile number specified in paragraph (m) of\nthis section.;\n(ii) A schedule for completing the integrity assessment;\n(iii) An explanation of the assessment methods selected and evaluation of risk factors\nconsidered in establishing the assessment schedule.\n(2) An operator must document, prior to implementing any changes to the plan, any\nmodification to the plan, and reasons for the modification.\nQuestar Gas Management (QGM) completed a pressure test of their propane line as a\nbaseline assessment in July of 2005. The pressure record provided to our inspector\nindicated that the test was not conducted in accordance with 49 CFR Part 195, Subpart E.\nThe test pressure was only maintained for four hours on a pipeline that could not be\nvisually inspected. Buried lines must be tested for at least eight hours. In addition,\nnitrogen was inappropriately used as the test medium.\nProposed Compliance Order\nPursuant to 49 United States Code § 60 1 18, the Pipeline and Hazardous Materials Safety\nAdministration proposes to issue a Compliance Order to Questar Gas Management. Please refer\nto the Proposed Compliance Order that is enclosed and made a part of this Notice.\nResponse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you must\nprovide a second copy of the document with the portions you believe qualify for confidential\ntreatment redacted and an explanation of why you believe the redacted information qualifies for\nconfidential treatment under 5 U.S.C. 552(b). If you do not respond within 30 days of receipt of\nthis Notice, this constitutes a waiver of your right to contest the allegations in this Notice and\nauthorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue a Final Order.\n\n\n\nIn your correspondence on this matter, please refer to CPF 5-2008-5019 and for each document\nyou submit, please provide a copy in electronic format whenever possible.\nSincerely,\nChri\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Compliance Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 H. Nguyen (#I21 193)\n\n\n\nPROPOSED COMPLIANCE ORDER\nPursuant to 49 United States Code $ 601 18, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) proposes to issue to Questar Gas Management a Compliance Order\nincorporating the following remedial requirements to ensure the compliance of Questar Gas\nManagement with the pipeline safety regulations:\n1. 2. 3. In regard to Item Number 1 of the Notice pertaining to your pipeline systems, Questar\nGas Management must conduct a pressure test in accordance with Part 195 Subpart E.\nWithin 60 days of issuance of the Final Order, Questar Gas Management must\ncomplete the above items, and submit the required documentation and procedures\nto the Director, Western Region, Pipeline and Hazardous Materials Safety\nAdministration, 12300 West Dakota Avenue, Suite 110, Lakewood, Colorado\n80228.\nQuestar Gas Management shall maintain documentation of the safety improvement\ncosts associated with fulfilling this Compliance Order and submit the total to Chris\nHoidal, Director, Western Region, Pipeline and Hazardous Materials Safety\nAdministration. Costs shall be reported in two categories: 1) total cost associated with\npreparationlrevision of plans, procedures, studies and analyses, and 2) total cost\nassociated with replacements, additions and other changes to pipeline infrastructure.\n\n520085019_FinalOrder_03042010 _text.pdf\n\nMAR 4 2010\nMr. Charles B. Stanley\nPresident and Chief Executive Officer\nQuestar Gas Management Company\n1050 17th Street, Suite 500\nDenver, CO 80265\nRe: CPF No. 5-2008-5019\nDear Mr. Stanley:\nEnclosed please find the Final Order issued in the above-referenced case. It makes a finding of\nviolation and finds that Questar Gas Management Company has completed the actions specified\nin the Notice to comply with the pipeline safety regulations. Therefore, this case is now closed.\nService of the Final Order by certified mail is deemed effective upon the date of mailing, or as\notherwise provided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. Chris Hoidal, Director, Western Region, OPS\nMr. Perry Richards, Vice President of Operations, Questar Gas Management Company\nCERTIFIED MAIL – RETURN RECEIPT REQUESTED [7009 1410 0000 2472 5088]\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n______________________________\nIn the Matter of )\nQuestar Gas Management ) CPF No. 5-2008-5019\nCompany, )\n)\n)\n)\nRespondent. )\n______________________________)\nFINAL ORDER\nOn April 23, 2008, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),\nconducted an on-site pipeline safety inspection of the facilities and records of Questar Gas\nManagement Company (Questar or Respondent) near Lyman, Wyoming, including the Emigrant\nTrail Pipeline System, an 8.9-mile-long pipeline constructed in 1984, and the Black Forks\nPipeline System, a pair of 2.85-mile-long pipelines constructed in 1995.\nAs a result of the inspection, the Director, Western Region, OPS (Director), issued to\nRespondent, by letter dated June 19, 2008, a Notice of Probable Violation and Proposed\nCompliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed\nfinding that Questar had violated 49 C.F.R. § 195.452(b)(3) and (c)(1)(i)(B) and proposed\nordering the company to take certain measures to correct the alleged violation.\nQuestar responded to the Notice by letters dated July 16, 2008, and February 9, 2009\n(collectively, Response). Respondent did not contest the allegations of violation but provided\ninformation concerning the corrective actions it had taken. Questar did not request a hearing and\ntherefore has waived its right to one.\nFINDING OF VIOLATION\nIn its Response, Questar did not contest the allegation in the Notice that it violated 49 C.F.R. Part\n195, as follows:\n\n\n\n2\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.452(b)(3) and (c)(1)(i)(B),\nwhich state, in relevant part:\n§ 195.452 Pipeline integrity management in high consequence areas.\n(a) . . . .\n(b) What program and practices must operators use to manage\npipeline integrity? Each operator of a pipeline covered by this section\nmust:\n(1) . . . .\n(3) Include in the program a plan to carry out baseline assessments of\nline pipe as required by paragraph (c) of this section.\n(4) . . . .\n(c) What must be in the baseline assessment plan?\n(1) An operator must include each of the following elements in its\nwritten baseline assessment plan:\n(i) The methods selected to assess the integrity of the line pipe. An\noperator must assess the integrity of the line pipe by any of the following\nmethods. . . .\n(B) Pressure test conducted in accordance with subpart E of this part;\nIn particular, the Notice alleged that Questar violated 49 C.F.R. § 195.452(b)(3) and (c)(1)(i)(B)\nby failing to perform an 8-hour pressure test of its buried propane pipeline as part of the\ncompany’s baseline assessment. Instead, the Notice alleged that Respondent had only performed\na 4-hour pressure test, an inadequate length of time for a pipeline that cannot be visually\nreview of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.452(b)(3) and\ninspected.1 Questar did not contest this allegation of violation.2 Accordingly, based upon a\n(c)(1)(i)(B) by failing to perform an 8-hour pressure test of its buried propane line as part of the\ncompany’s baseline assessment.\n1 49 C.F.R. § 195.304.\n2 The Notice also alleged that Respondent erred in using nitrogen as the test medium. However, in its Response,\nQuestar provided the Director with documentation confirming that the maximum operating pressure of the line in\nquestion is less than 20 percent of the specified minimum yield strength of the line pipe, thereby permitting the use\nof nitrogen as a test medium. See 49 C.F.R. §§ 195.2 (defining low-stress pipeline), 195.306(d) (permitting use of\ninert gases as a test medium for low-stress pipelines).\n\n\n\n3\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 1 in the Notice for violations of 49\nC.F.R. § 195.452(b)(3) and (c)(1)(i)(B). Under 49 U.S.C. § 60118(a), each person who engages\nin the transportation of hazardous liquids or who owns or operates a pipeline facility is required\nto comply with the applicable safety standards established under chapter 601. The Director has\nindicated that Respondent has taken the following actions specified in the proposed compliance\norder:\nOn November 6, 2008, Questar performed an 8-hour pressure test of its\npropane and butane lines. The Director has reviewed the documentation\nfrom those tests and determined that each was conducted in compliance\nwith the requirements of Part 195.\nAccordingly, I find that compliance has been achieved with respect to this violation. Therefore,\nthe compliance terms proposed in the Notice are not included in this Order.\nThe terms and conditions of this Final Order are effective upon receipt of service.\n___________________________________ __________________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n520085019_FinalOrder_03042010.pdf\n\nU.S. Department of Transportation\n1200 New Jersey Ave, S.E.\nPipeline and Hazardous Materials\nWashington, D.C. 20590\nSafety Administration\nMAR 4 2010\nMr. Charles B. Stanley\nPresident and Chief Executive Officer\nQuestar Gas Management Company\n1050 17\" Street, Suite 500\nDenver, CO 80265\nRe: CPF No. 5-2008-5019\nDear Mr. Stanley:\nEnclosed please find the Final Order issued in the above-referenced case. It makes a finding of\nviolation and finds that Questar Gas Management Company has completed the actions specified\nin the Notice to comply with the pipeline safety regulations. Therefore, this case is now closed.\nService of the Final Order by certified mail is deemed effective upon the date of mailing, or as\notherwise provided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nMark Mate,\nfor:\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\nMr. Chris Hoidal, Director, Western Region, OPS\nMr. Perry Richards, Vice President of Operations, Questar Gas Management Company\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED [7009 1410 0000 2472 5088]\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\n)\n)\nQuestar Gas Management\nCPF No. 5-2008-5019\nCompany,\n)\nRespondent.\nFINAL ORDER\nOn April 23, 2008, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),\nconducted an on-site pipeline safety inspection of the facilities and records of Questar Gas\nManagement Company (Questar or Respondent) near Lyman, Wyoming, including the Emigrant\nTrail Pipeline System, an 8.9-mile-long pipeline constructed in 1984, and the Black Forks\nPipeline System, a pair of 2.85-mile-long pipelines constructed in 1995.\nAs a result of the inspection, the Director, Western Region, OPS (Director), issued to\nRespondent, by letter dated June 19, 2008, a Notice of Probable Violation and Proposed\nCompliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed\nfinding that Questar had violated 49 C.F.R. § 195.452(b)(3) and (c)(1)(i)(B) and proposed\nordering the company to take certain measures to correct the alleged violation.\nQuestar responded to the Notice by letters dated July 16, 2008, and February 9, 2009\n(collectively, Response). Respondent did not contest the allegations of violation but provided\ninformation concerning the corrective actions it had taken. Questar did not request a hearing and\nFINDING OF VIOLATION\nIn its Response, Questar did not contest the allegation in the Notice that it violated 49 C.F.R. Part\n195, as follows:\n\n\n\n2\nItem I: The Notice alleged that Respondent violated 49 C.F.R. § 195.452(b)(3) and (c)(1)(i)(B),\nwhich state, in relevant part:\n§ 195.452 Pipeline integrity management in high consequence areas.\n(a) ....\n(b) What program and practices must operators use to manage\npipeline integrity? Each operator of a pipeline covered by this section\nmust:\n(1)....\n(3) Include in the program a plan to carry out baseline assessments of\nline pipe as required by paragraph (c) of this section.\n(4)....\n(c) What must be in the baseline assessment plan?\n(1) An operator must include each of the following elements in its\nwritten baseline assessment plan:\n(i) The methods selected to assess the integrity of the line pipe. An\noperator must assess the integrity of the line pipe by any of the following\nmethods....\n(B) Pressure test conducted in accordance with subpart E of this part;\nIn particular, the Notice alleged that Questar violated 49 C.F.R. § 195.452(b)(3) and (c)(1)(i)(B)\ny failing to perform an 8-hour pressure test of its buried propane pipeline as part of the\nompany's baseline assessment. Instead, the Notice alleged that Respondent had only performer\ninspected.' Questar did not contest this allegation of violation? Accordingly, based upon a\na 4-hour pressure test, an inadequate length of time for a pipeline that cannot be visually\nreview of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.452(b)(3) and\n(c)(1)(i)(B) by failing to perform an 8-hour pressure test of its buried propane line as part of the\ncompany's baseline assessment.\n' 49 C.F.R. § 195.304.\n2 The Notice also alleged that Respondent erred in using nitrogen as the test medium. However, in its Response,\nQuestar provided the Director with documentation confirming that the maximum operating pressure of the line in\nof nitrogen as a test medium. See 49 C.F.R. §§ 195.2 (defining low-stress pipeline), 195.306(d) (permitting use of\nquestion is less than 20 percent of the specified minimum yield strength of the line pipe, thereby permitting the use\ninert gases as a test medium for low-stress pipelines).\n\n\n\n3\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 1 in the Notice for violations of 49\nC.F.R. § 195.452(b)(3) and (c)(1)(i)(B). Under 49 U.S.C. § 60118(a), each person who engages\nin the transportation of hazardous liquids or who owns or operates a pipeline facility is required\nto comply with the applicable safety standards established under chapter 601. The Director has\nindicated that Respondent has taken the following actions specified in the proposed compliance\norder:\nOn November 6, 2008, Questar performed an 8-hour pressure test of its\npropane and butane lines. The Director has reviewed the documentation\nfrom those tests and determined that each was conducted in compliance\nwith the requirements of Part 195.\nAccordingly, I find that compliance has been achieved with respect to this violation. Therefore,\nthe compliance terms proposed in the Notice are not included in this Order.\nThe terms and conditions of this Final Order are effective upon receipt of service.\nMaut Wann\nMAR 4 2010\nfor Jettrey D. Wiese\nDate Issued\nAssociate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":19508}