{"operation":"document","citation":"CPF 520181002W","title":"QUESTAR SOUTHERN TRAILS PIPELINE COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-01-31","effective_on":null,"summary":"CLOSED warning letter citing 192.491(c), 192.614(c)(1), 192.614(c)(2)(i), 192.736(b)(1), 192.917(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520181002w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520181002w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520181002w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520181002W","body":"Warning Letter involving QUESTAR SOUTHERN TRAILS PIPELINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 192.491(c),  192.614(c)(1),  192.614(c)(2)(i),  192.736(b)(1),  192.917(b). The case was opened on 2018-01-31 and is reported as closed as of 2018-01-31. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520181002W_Warning Letter_01312018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520181002W/520181002W_Warning%20Letter_01312018.pdf\n\n520181002W_Warning Letter_01312018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520181002W/520181002W_Warning%20Letter_01312018_text.pdf\n\n520181002W_Warning Letter_01312018_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 31, 2018\nMr. Ron Jorgensen\nVice President – Operations and Gas Control\nDominion Energy Questar Pipeline, LLC\nP.O. Box 45360\nSalt Lake City, UT 84145\nCPF 5-2018-1002W\nDear Mr. Jorgensen:\nOn June 5 through 9, 2017 and July 17 through 21, 2017, a representative of the Arizona\nCorporation Commission (ACC), pursuant to Chapter 601 of 49 United States Code,\ninspected your Arizona Dominion Energy Questar Pipeline segments: Line 90 and Line 92.\nRecords review for the 12-inch - Line 92 and the 16-inch- Line 90 facilities occurred in the\nSalt Lake City, Utah offices during June 5 through 9, 2017. Field inspections for these\nfacilities were completed on July 17 through 21, 2017. These Arizona-based Dominion\nEnergy Questars’ pipelines stretch between the New Mexico and California State borders.\nAs a result of the inspection, it is alleged probable violations of the Pipeline Safety\nRegulations, Title 49, Code of Federal Regulations (CFR) have been committed. The items\ninspected and the probable violation(s) are:\n1. § 192.491 Corrosion control records.\n(c) Each operator shall maintain a record of each test, survey, or inspection\nrequired by this subpart in sufficient detail to demonstrate the adequacy of\ncorrosion control measures or that a corrosive condition does not exist. These\nrecords must be retained for at least 5 years, except that records related to\n\n\n\n§192.465(a) and (e) and 192.475(b) must be retained for as long as the pipeline\nremains in service.\nAlthough the requested records were provided for review, they were not completed in a\ncorrect manner and demonstrated insufficient detail to demonstrate the adequacy of corrosion\ncontrol measures. The documentation provided during the inspection of the 2015 annual\nsurvey, lacked both the survey date and personnel identification for whom conducted the\nsurvey; this was shown on page 3 of the survey. The documentation, on page 41, also lacked\nthe personnel identification for whom conducted the survey. For the 2016 annual survey\naudit, page 3 lacked the personnel identification for whom conducted the survey as well.\n2. §192.614 Damage prevention program.\n(c) The damage prevention program required by paragraph (a) of this section\nmust, at a minimum:\n(1) Include the identity, on a current basis, of persons who normally engage in\nexcavation activities in the area in which the pipeline is located.\n(2) Provides for notification of the public in the vicinity of the pipeline and actual\nnotification of the persons identified in paragraph (c)(1) of this section of the\nfollowing as often as needed to make them aware of the damage prevention\nprogram:\n(i) The program's existence and purpose;\nDuring the inspection, documentation was not available to establish that Dominion Energy\nQuestar Pipeline Company provided damage prevention/public awareness information to\nNorthern Pipeline Construction Company– Prescott Valley (NPL-PV). This was\ndemonstrated by “Questar Southern Trails Pipeline 2017 Inspection” mailer list omitting\nNPL-PV as an existing excavator in areas where Dominion‘s pipeline is located; this omission\nresulted in a lack of information concerning Dominion‘s damage prevention program from\nbeing communicated or provided to NPL-PV.\n3. §192.917 How does an operator identify potential threats to pipeline integrity\nand use the threat identification in its integrity program?\n(b) Data gathering and integration. To identify and evaluate the potential threats\nto a covered pipeline segment, an operator must gather and integrate existing\ndata and information on the entire pipeline that could be relevant to the covered\nsegment. In performing this data gathering and integration, an operator must\nfollow the requirements in ASME/ANSI B31.8S, section 4. At a minimum, an\noperator must gather and evaluate the set of data specified in Appendix A to\nASME/ANSI B31.8S, and consider both on the covered segment and similar non-\ncovered segments, past incident history, corrosion control records, continuing\nsurveillance records, patrolling records, maintenance history, internal inspection\nrecords and all other conditions specific to each pipeline.\n2\n\n\n\nDominion provided Patrol/Leak Survey documentation for Segment 13 (page 2), that was\nconducted on April 8, 2015, and it lacked required record header information. This header\ninformation documented the type of patrols done, the right-of-way condition, atmospheric\ncorrosion inspections and other data associated with the patrol survey. Without this relevant\ninformation for the covered segment, the validity of the survey is questionable. Moreover, the\nsurvey record provided to ACC indicated the patrol survey was completed “on foot” by one\nindividual for approximately 70-80 miles of right-of-way in one day. This amount and type\nof patrolling seems unlikely, or even possible, for an individual to complete in the amount of\ntime stated in Dominion‘s records.\n4. §192.736 Compressor stations: Gas detection\n(b) Except when shutdown of the system is necessary for maintenance under\nparagraph (c) of this section, each gas detection and alarm system required by\nthis section must–\n(1) Continuously monitor the compressor building for a concentration of gas in\nair of not more than 25 percent of the lower explosive limit;\nDocumentation provided during the June 5-9, 2017 records inspection demonstrated 1.)\nDominion‘s gas detector testing on June 3, 2014 at the Mohave Valley Station and 2.)\nDecember 8, 2014 at the Cameron Station. These records contained results showing detection\nlevels had exceeded the “25 percent of the lower explosive limit (LEL)”. Documents also\nshowed upon completion of Dominion‘s testing at the above two locations, the higher settings\nwere left at these unacceptable documented levels.\nTo clarify the inspection results mentioned above, the Gas Detectors Inspection Report for\ntesting at the Mohave Valley compressor station, dated June 3, 2014, showed two methane\ndetectors for the engine and fuel gas sensors were discovered and left at 26 percent and 27\npercent of the LEL. In addition, the Gas Detectors Inspection Report documented gas\ndetector testing at the Cameron compressor station, dated December 8, 2014, showed the\nmethane detectors for the compressor, engine and generator sensors were found and left at 26\npercent of the LEL. Additional data at this site revealed Sensor 3 was found at 25 percent of\nLEL and was adjusted and left at 26 percent of the LEL. This means the concentration of gas\nin air would be more than the prescribed 25 percent of the lower explosive limit. This is\nbecause the alarming sensors have been left at excessive detection levels.\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. For violations occurring prior to November 2, 2015, the\nmaximum penalty may not exceed $200,000 per violation per day, with a maximum penalty\nnot to exceed $2,000,000 for a related series of violations. We have reviewed the\ncircumstances and supporting documents involved in this case, and have decided not to\nconduct additional enforcement action or penalty assessment proceedings at this time. We\nadvise you to correct the item(s) identified in this letter. Failure to do so will result in\nDominion Energy Questar Pipeline, LLC being subject to additional enforcement action.\n3\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2018-1002W. 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\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 H.M. Flaherty (#157168)\n4","truncated":false,"body_characters":9059}