{"operation":"document","citation":"CPF 520121017W","title":"QEP MARKETING COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-08-15","effective_on":null,"summary":"CLOSED warning letter citing 192.616(i).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520121017w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520121017w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520121017w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520121017W","body":"Warning Letter involving QEP MARKETING COMPANY. PHMSA's enforcement data identifies the cited regulation as 192.616(i). The case was opened on 2012-08-15 and is reported as closed as of 2012-08-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520121017W_warning letter_08152012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520121017W/520121017W_warning%20letter_08152012.pdf\n\n520121017W_warning letter_08152012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520121017W/520121017W_warning%20letter_08152012_text.pdf\n\n520121017W_warning letter_08152012_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL [7010 2780 0001 0586 2946] - RETURN RECEIPT REQUESTED\nAugust 15, 2012\nMr. Kevin Peretti\nVice President\nQEP Field Services Company\n1955 Blairtown Road\nRock Springs, WY 82902\nCPF 5-2012-1017W\nDear Mr. Peretti:\nOn June 26, 2012, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\nPublic Awareness Program at your office in Rock Springs, Wyoming. As a result of the\ninspection, it appears that you have committed a probable violation of the Pipeline Safety\nRegulations, Title 49, Code of Federal Regulations. The items inspected and the probable\nviolation is:\n1. §192.616 Public Awareness\n(i) The operator's program documentation and evaluation results must be\navailable for periodic review by appropriate regulatory agencies.\nQEP Field Services did not have program documentation for 2009, 2010, or 2011. Per\n49 CFR §192.616(c), the operator must follow the general program recommendations,\nincluding baseline and supplemental requirements of API RP 1162, unless the operator\nprovides justification in its program or procedural manual as to why compliance with all\n\n\n\nor certain provisions of the recommended practice is not practicable and not necessary\nfor safety.\nAPI RP 1162, Section 8.3 recommend guidance states, “Has the operator performed an\naudit or review of its program implementation annually since it was developed? If not,\ndid the operator provide justification in its program or procedural manual?” QEP\nField Services Company did not have documentation of annual audits from 2009, 2010,\nand 2011. QEP Field Services Company only had documentation for 2008 and for 2012.\nUnder 49 United States Code, § 60122, 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 item(s) identified in this letter.\nFailure to do so will result in Vintage Production California LLC being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2012-1017W. 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).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 T. Finch (#139518)\n2","truncated":false,"body_characters":3768}