QEP MARKETING COMPANY — Notice of Amendment

party submissionOfficial PDF520171008M_Operator Response to Notice_06222017.pdf#

520171008M_Closure Letter_09152017_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED September 15, 2017 Mr. Matt Thompson Vice President Energy QEP Energy 1050 17th St., Suite 800 Denver, CO 80265 CPF 5-2017-1008M Closure Letter Dear Mr. Thompson: On August 17 through 21, 2015, a representative from the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site pipeline safety inspection of the QEP Marketing Company’s (QEP) Clear Creek Gas Storage gas transmission unit located near Evanston, Wyoming. As a result of the inspection, QEP was issued a Notice of Amendment on May 26, 2017, which proposed amendment of your procedures. QEP submitted its amended procedures on June 22, 2017. PHMSA reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Huy Nguyen Acting Director, Western Region Pipeline and Hazardous Materials Safety Administration cc: PHP-60 Compliance Registry PHP-500 B. Brown#

520171008M_Notice of Amendment_05262017_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED May 26, 2017 Mr. Matt Thompson Vice President Energy QEP Energy 1050 17th St, Suite 800 Denver, CO 80265 CPF 5-2017-1008M Dear Mr. Thompson: On August 17 through 21, 2015, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected QEP Marketing Company’s (QEP) Clear Creek Gas Storage gas transmission unit located near Evanston, Wyoming. On the basis of the inspection, PHMSA has identified the apparent inadequacies found within QEP’s plans or procedures, as described below: 1. §192.605 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. For transmission lines, the manual must also include procedures for handling abnormal operations. This manual must be reviewed and updated by the operator at intervals not exceeding 15 months, but at least once each calendar year. This manual must be prepared before operations of a pipeline system commence. Appropriate parts of the manual must be kept at locations where operations and maintenance activities are conducted. (e) Surveillance, emergency response, and accident investigation. The procedures required by §§ 192.613(a), 192.615, and 192.617 must be included in the manual#

520171008M_Notice of Amendment_05262017_text.pdf, page 2required by paragraph (a) of this section. QEP’s Emergency Plan was in a separate book from the O & M Manual and the O & M Manual did not reference the Emergency Plan. Also, the operator's Emergency Plan does not address an annual review of the plan. In accordance with 192.602(e) with the emergency response (emergency plan) part of the O & M Manual that is required in 192.605(a) and thus part of the annual O&M Manual review. Standard 192.605(a), has an annual review requirement, also includes emergency response (emergency plan) in its requirements. Without referencing the Emergency Plan in the O&M Manual there is no Annual Review requirement for the Emergency Plan. QEP’s O&M Manual needs to incorporate the Emergency Plan by reference or add the annual review requirement to the Emergency Plan. 2. §192.605 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. For transmission lines, the manual must also include procedures for handling abnormal operations. This manual must be reviewed and updated by the operator at intervals not exceeding 15 months, but at least once each calendar year. This manual must be prepared before operations of a pipeline system commence. Appropriate parts of the manual must be kept at locations where operations and maintenance activities are conducted. (e) Surveillance, emergency response, and accident investigation. The procedures required by §§ 192.613(a), 192.615, and 192.617 must be included in the manual required by paragraph (a) of this section. §192.615 Emergency Plan. (a) Each operator shall establish written procedures to minimize the hazard resulting from a gas pipeline emergency. At a minimum, the procedures must provide for the following: (6) Emergency shutdown and pressure reduction in any section of the operator's pipeline system necessary to minimize hazards to life or property. QEP’s Emergency Plan did not include procedures for the emergency shutdown or pressure reduction in any section of pipeline system as would be necessary to minimize hazards to life or property. The operator's Emergency Plan needs to be amended to include this procedure. 3. §192.605 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. For transmission lines, the manual must also include procedures for handling abnormal operations. This manual must be reviewed and updated by the operator at intervals not exceeding 15 months, but at least once each calendar year. This manual must be prepared before operations of a pipeline system commence. Appropriate parts of the manual must be kept at locations where operations and maintenance activities are conducted. (c) Abnormal operation. For transmission lines, the manual required by 2#

520171008M_Notice of Amendment_05262017_text.pdf, page 3paragraph (a) of this section must include procedures for the following to provide safety when operating design limits have been exceeded: (4) Periodically reviewing the response of operator personnel to determine the effectiveness of the procedures controlling abnormal operation and taking corrective action where deficiencies are found. QEP’s O&M Manual does not have a procedure requiring a periodic review of operator personnel to determine the effectiveness of the procedures controlling abnormal operation and taking corrective action where deficiencies are found. This review. 4. §192.605 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. For transmission lines, the manual must also include procedures for handling abnormal operations. This manual must be reviewed and updated by the operator at intervals not exceeding 15 months, but at least once each calendar year. This manual must be prepared before operations of a pipeline system commence. Appropriate parts of the manual must be kept at locations where operations and maintenance activities are conducted. (b) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following, if applicable, to provide safety during maintenance and operations. (8) Periodically reviewing the work done by operator personnel to determine the effectiveness, and adequacy of the procedures used in normal operation and maintenance and modifying the procedures when deficiencies are found. QEP’s O&M Manual does not have a procedure requiring a periodic review of operator personnel to determine the effectiveness of the procedures controlling normal operation and taking corrective action where deficiencies are found. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings. Please refer to this document and note the response options. Be advised that all material you submit in response to this enforcement action is subject to being made publicly available. If you believe that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original document you must provide a second copy of the document with the portions you believe qualify for confidential treatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue an Order Directing 3#

520171008M_Notice of Amendment_05262017_text.pdf, page 4Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. §190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that QEP Energy maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Kim West, Acting Director, Western Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 5-2017-1008M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Kim West Acting Director, Western Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings cc: PHP-60 Compliance Registry PHP-500 B. Brown (#149941) 4#