{"operation":"document","citation":"CPF 520171008M","title":"QEP MARKETING COMPANY — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-05-26","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(a), 192.605(b)(8), 192.605(e), 192.615(a)(6).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520171008m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520171008m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520171008m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520171008M","body":"Notice of Amendment involving QEP MARKETING COMPANY. PHMSA's enforcement data identifies the cited regulations as 192.605(a),  192.605(b)(8),  192.605(e),  192.615(a)(6). The case was opened on 2017-05-26 and is reported as closed as of 2017-09-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520171008M_Closure Letter_09152017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520171008M/520171008M_Closure%20Letter_09152017.pdf\n\n520171008M_Closure Letter_09152017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520171008M/520171008M_Closure%20Letter_09152017_text.pdf\n\n520171008M_Notice of Amendment_05262017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520171008M/520171008M_Notice%20of%20Amendment_05262017.pdf\n\n520171008M_Notice of Amendment_05262017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520171008M/520171008M_Notice%20of%20Amendment_05262017_text.pdf\n\n520171008M_Operator Response to Notice_06222017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520171008M/520171008M_Operator%20Response%20to%20Notice_06222017.pdf\n\n520171008M_Closure Letter_09152017_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 15, 2017\nMr. Matt Thompson\nVice President Energy\nQEP Energy\n1050 17th St., Suite 800\nDenver, CO 80265\nCPF 5-2017-1008M\nClosure Letter\nDear Mr. Thompson:\nOn August 17 through 21, 2015, a representative from the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of the QEP Marketing Company’s (QEP)\nClear Creek Gas Storage gas transmission unit located near Evanston, Wyoming. As a result\nof the inspection, QEP was issued a Notice of Amendment on May 26, 2017, which proposed\namendment of your procedures.\nQEP submitted its amended procedures on June 22, 2017. PHMSA reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have\nbeen corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nHuy Nguyen\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 B. Brown\n\n520171008M_Notice of Amendment_05262017_text.pdf\n\nNOTICE OF AMENDMENT\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 5-2017-1008M\nDear Mr. Thompson:\nOn August 17 through 21, 2015, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\ninspected QEP Marketing Company’s (QEP) Clear Creek Gas Storage gas transmission unit\nlocated near Evanston, Wyoming.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nQEP’s plans or procedures, as described below:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual\nof written procedures for conducting operations and maintenance activities and\nfor emergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed\nand updated by the operator at intervals not exceeding 15 months, but at least\nonce each calendar year. This manual must be prepared before operations of a\npipeline system commence. Appropriate parts of the manual must be kept at\nlocations where operations and maintenance activities are conducted.\n(e) Surveillance, emergency response, and accident investigation. The procedures\nrequired by §§ 192.613(a), 192.615, and 192.617 must be included in the manual\n\n\n\nrequired by paragraph (a) of this section.\nQEP’s Emergency Plan was in a separate book from the O & M Manual and the O & M\nManual did not reference the Emergency Plan. Also, the operator's Emergency Plan does not\naddress an annual review of the plan. In accordance with 192.602(e) with the emergency\nresponse (emergency plan) part of the O & M Manual that is required in 192.605(a) and thus\npart of the annual O&M Manual review. Standard 192.605(a), has an annual review\nrequirement, also includes emergency response (emergency plan) in its requirements.\nWithout referencing the Emergency Plan in the O&M Manual there is no Annual Review\nrequirement for the Emergency Plan. QEP’s O&M Manual needs to incorporate the\nEmergency Plan by reference or add the annual review requirement to the Emergency Plan.\n2. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual\nof written procedures for conducting operations and maintenance activities and\nfor emergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed\nand updated by the operator at intervals not exceeding 15 months, but at least\nonce each calendar year. This manual must be prepared before operations of a\npipeline system commence. Appropriate parts of the manual must be kept at\nlocations where operations and maintenance activities are conducted.\n(e) Surveillance, emergency response, and accident investigation. The procedures\nrequired by §§ 192.613(a), 192.615, and 192.617 must be included in the manual\nrequired by paragraph (a) of this section.\n§192.615 Emergency Plan.\n(a) Each operator shall establish written procedures to minimize the hazard\nresulting from a gas pipeline emergency. At a minimum, the procedures must\nprovide for the following:\n(6) Emergency shutdown and pressure reduction in any section of the operator's\npipeline system necessary to minimize hazards to life or property.\nQEP’s Emergency Plan did not include procedures for the emergency shutdown or pressure\nreduction in any section of pipeline system as would be necessary to minimize hazards to life\nor property. The operator's Emergency Plan needs to be amended to include this procedure.\n3. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual\nof written procedures for conducting operations and maintenance activities and\nfor emergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed\nand updated by the operator at intervals not exceeding 15 months, but at least\nonce each calendar year. This manual must be prepared before operations of a\npipeline system commence. Appropriate parts of the manual must be kept at\nlocations where operations and maintenance activities are conducted.\n(c) Abnormal operation. For transmission lines, the manual required by\n2\n\n\n\nparagraph (a) of this section must include procedures for the following to provide\nsafety when operating design limits have been exceeded:\n(4) Periodically reviewing the response of operator personnel to determine the\neffectiveness of the procedures controlling abnormal operation and taking\ncorrective action where deficiencies are found.\nQEP’s O&M Manual does not have a procedure requiring a periodic review of operator\npersonnel to determine the effectiveness of the procedures controlling abnormal operation\nand taking corrective action where deficiencies are found. This review.\n4. §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\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least once\neach calendar year. This manual must be prepared before operations of a pipeline\nsystem commence. Appropriate parts of the manual must be kept at locations\nwhere operations and maintenance activities are conducted.\n(b) Maintenance and normal operations. The manual required by paragraph (a)\nof this section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(8) Periodically reviewing the work done by operator personnel to determine the\neffectiveness, and adequacy of the procedures used in normal operation and\nmaintenance and modifying the procedures when deficiencies are found.\nQEP’s O&M Manual does not have a procedure requiring a periodic review of operator\npersonnel to determine the effectiveness of the procedures controlling normal operation and\ntaking corrective action where deficiencies are found.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed\nas 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\nfor 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\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in\nthis Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as\nalleged in this Notice without further notice to you and to issue an Order Directing\n3\n\n\n\nAmendment. If your plans or procedures are found inadequate as alleged in this Notice, you\nmay be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R.\n§190.206). If you are not contesting this Notice, we propose that you submit your amended\nprocedures to my office within 30 days of receipt of this Notice. This period may be extended\nby written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that QEP Energy maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision\nof plans, procedures) and submit the total to Kim West, Acting Director, Western Region,\nPipeline and Hazardous Materials Safety Administration. In correspondence concerning this\nmatter, please refer to CPF 5-2017-1008M and, for each document you submit, please\nprovide a copy in electronic format whenever possible.\nSincerely,\nKim West\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 B. Brown (#149941)\n4","truncated":false,"body_characters":11408}