{"operation":"document","citation":"CPF 520171006W","title":"QEP MARKETING COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-05-26","effective_on":null,"summary":"CLOSED warning letter citing 192.481(a), 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520171006w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520171006w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520171006w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520171006W","body":"Warning Letter involving QEP MARKETING COMPANY. PHMSA's enforcement data identifies the cited regulations as 192.481(a),  192.605(a). The case was opened on 2017-05-26 and is reported as closed as of 2017-05-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520171006W_Operator Response to Notice_06222017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520171006W/520171006W_Operator%20Response%20to%20Notice_06222017.pdf\n\n520171006W_Warning Letter_05262017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520171006W/520171006W_Warning%20Letter_05262017.pdf\n\n520171006W_Warning Letter_05262017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520171006W/520171006W_Warning%20Letter_05262017_text.pdf\n\n520171006W_Warning Letter_05262017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL – RETURN RECEIPT REQUESTED\nMay 26, 2017\nMr. Matt Thompson\nVice President Energy\nQEP Energy\n1050 17th St, Suite 800\nDenver, CO 80265\nCPF 5-2017-1006W\nDear Mr. Thompson:\nOn August 17 through 21, 2015, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected QEP\nMarketing Company’s (QEP) Clear Creek Gas Storage gas transmission unit located near Evanston,\nWyoming.\nAs a result of the inspection, it is alleged that you have committed probable violations of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations. The item inspected and the probable\nviolations are:\n1. §192.481 Atmospheric corrosion control: Monitoring.\n(a) Each operator must inspect each pipeline or portion of pipeline that is exposed to the\natmosphere for evidence of atmospheric corrosion, as follows:\nIf the pipeline is\nlocated:\nThen the frequency of inspection is:\nOnshore At least once every 3 calendar years, but with\nintervals not exceeding 39 months\nOffshore At least once each calendar year, but with intervals\nnot exceeding 15 months\nQEP’s records existed indicating that an atmospheric corrosion survey was conducted in 2005 and\n2008. There are no records indicating that a survey was conducted in 2011 or 2014. Records do\ndocument an atmospheric corrosion survey conducted in 2015.\n\n\n\n2. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include procedures\nfor handling abnormal operations. This manual must be reviewed and updated by the\noperator at intervals not exceeding 15 months, but at least once each calendar year. This\nmanual must be prepared before operations of a pipeline system commence.\nAppropriate parts of the manual must be kept at locations where operations and\nmaintenance activities are conducted.\nQEP’s records indicated that an annual review of the operator's written procedures manual was\nconducted annually as required by 192.605(a) in the years 2005 through 2009 but no annual review\nwas conducted in 2010 through 2014. The records did indicate that an annual review was conducted\nin August 2015.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $205,638 per\nviolation per day the violation persists up to a maximum of $2,056,380 for a related series of\nviolations. For violation occurring between January 4, 2012 to August 1, 2016, the maximum penalty\nmay not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000 for\na related series of violations. For violations occurring prior to January 4, 2012, the maximum penalty\nmay not exceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for\na related 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 QEP Energy Company being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF\n5-2017-1006W. Be advised that all material you submit in response to this enforcement action is\nsubject to being made publicly available. If you believe that any portion of your responsive material\nqualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must provide 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).\nSincerely,\nKim West\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 B. Brown (#149941)","truncated":false,"body_characters":5027}