{"operation":"document","citation":"CPF 520171013W","title":"QEP MARKETING COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-12-05","effective_on":null,"summary":"CLOSED warning letter citing 191.29(b), 192.465(a), 192.807(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520171013w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520171013w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520171013w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520171013W","body":"Warning Letter involving QEP MARKETING COMPANY. PHMSA's enforcement data identifies the cited regulations as 191.29(b),  192.465(a),  192.807(b). The case was opened on 2017-12-05 and is reported as closed as of 2017-12-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520171013W_Operator Response to Notice_01172018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520171013W/520171013W_Operator%20Response%20to%20Notice_01172018.pdf\n\n520171013W_Warning Letter_12052017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520171013W/520171013W_Warning%20Letter_12052017.pdf\n\n520171013W_Warning Letter_12052017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520171013W/520171013W_Warning%20Letter_12052017_text.pdf\n\n520171013W_Warning Letter_12052017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 5, 2017\nMr. Charles Stanley\nCEO, QEP Resources\nQEP Marketing Co.\n1050 17th St., Suite 800\nDenver, CO 80265\nCPF 5-2017-1013W\nDear Mr. Stanley:\nOn August 21 through 25, 2017, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\ninspected your Clear Creek Gas Storage facility, northeast of Evanston, Wyoming.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items\ninspected and the probable violations are:\n1. §191.29 National Pipeline Mapping System.\n(b) The information required in paragraph (a) of this section must be submitted\neach year, on or before March 15, representing assets as of December 31 of the\nprevious year. If no changes have occurred since the previous year's submission,\nthe operator must comply with the guidance provided in the NPMS Operator\nStandards manual available at www.npms.phmsa.dot.gov or contact the PHMSA\nGeographic Information Systems Manager at (202) 366-4595.\nDuring the records review of the Clear Creek Gas Storage facility, it was noted that no\nnotifications were sent to the National Pipeline Mapping System (NPMS) to comply with the\nannual requirements, or to document any changes from 2010 through 2016.\n\n\n\n2. §192.465 External corrosion control: Monitoring.\n(a) Each pipeline that is under cathodic protection must be tested at least once\neach calendar year, but with intervals not exceeding 15 months, to determine\nwhether the cathodic protection meets the requirements of §192.463. However, if\ntests at those intervals are impractical for separately protected short sections of\nmains or transmission lines, not in excess of 100 feet (30 meters), or separately\nprotected service lines, these pipelines may be surveyed on a sampling basis. At\nleast 10 percent of these protected structures, distributed over the entire system\nmust be surveyed each calendar year, with a different 10 percent checked each\nsubsequent year, so that the entire system is tested in each 10-year period.\nDuring the records review of your annual Cathodic Protection (CP) surveys, it was noted that\nQEP exceeded the once each calendar year, but not to exceed 15 months interval between\nyour 2015 and 2016 annual surveys.\n3. §192.807 Recordkeeping.\nEach operator shall maintain records that demonstrate compliance with this\nsubpart.\n(b) Records supporting an individual's current qualification shall be maintained\nwhile the individual is performing the covered task. Records of prior\nqualification and records of individuals no longer performing covered tasks shall\nbe retained for a period of five years.\nDuring the records review of your qualification of pipeline personnel, it was noted that one of\nyour Operators did not have a record of qualification on file for performing an OQ task. The\nOQ task performed was for taking and recording rectifier readings from January through\nAugust of 2016, in accordance with §192.465(b).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to\nexceed $209,002 per violation per day the violation persists up to a maximum of $2,090,022\nfor a related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement\naction or penalty assessment proceedings at this time. We advise you to correct the items\nidentified in this letter. Failure to do so will result in QEP Marketing Company being subject\nto additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2017-1013W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\n2\n\n\n\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nKim West\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Coleman (#156207)\n3","truncated":false,"body_characters":5367}