{"operation":"document","citation":"CPF 520181007M","title":"DOMINION ENERGY QUESTAR PIPELINE, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-08-17","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(1), 192.605(b)(2), 192.605(b)(8), 192.605(c)(4), 192.614(c)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520181007m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520181007m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520181007m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520181007M","body":"Notice of Amendment involving DOMINION ENERGY QUESTAR PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(1),  192.605(b)(2),  192.605(b)(8),  192.605(c)(4),  192.614(c)(1). The case was opened on 2018-08-17 and is reported as closed as of 2018-10-24. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520181007M_Closure Letter_10242018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520181007M/520181007M_Closure%20Letter_10242018.pdf\n\n520181007M_Closure Letter_10242018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520181007M/520181007M_Closure%20Letter_10242018_text.pdf\n\n520181007M_Notice of Amendment_08172018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520181007M/520181007M_Notice%20of%20Amendment_08172018.pdf\n\n520181007M_Notice of Amendment_08172018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520181007M/520181007M_Notice%20of%20Amendment_08172018_text.pdf\n\n520181007M_Operator Response to Notice_09202018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520181007M/520181007M_Operator%20Response%20to%20Notice_09202018.pdf\n\n520181007M_Closure Letter_10242018_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 24, 2018\nMr. Ron Jorgensen\nVice President, Operations and Gas Control\nDominion Energy Questar Pipeline\n333 South State Street\nP.O. Box 45360\nSalt Lake City, UT 84145-0360\nCPF 5-2018-1007M\nClosure Letter\nDear Mr. Jorgensen:\nOn March 12, 2018, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) and Arizona Corporation Commission, pursuant to Chapter 601 of 49\nUnited States Code, inspected Dominion Energy Questar Pipeline’s (DEQP) procedures for\noperation and maintenance in Salt Lake City, Utah. As a result of the inspection, DEQP was\nissued a Notice of Amendment on August 17, 2018, which proposed amendment of your\nprocedures.\nDEQP submitted its amended procedures on September 20, 2018. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nKim West\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 C. Allen (#157195)\n\n520181007M_Notice of Amendment_08172018_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 17, 2018\nMr. Ron Jorgensen\nVice President, Operations and Gas Control\nDominion Energy Questar Pipeline\n333 South State Street\nP.O. Box 45360\nSalt Lake City, UT 84145-0360\nCPF 5-2018-1007M\nDear Mr. Jorgensen:\nOn March 12, 2018, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) and Arizona Corporation Commission, pursuant to Chapter 601 of\n49 United States Code, inspected Dominion Energy Questar Pipeline’s (DEQP) procedures\nfor operation and maintenance in Salt Lake City, Utah.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nDEQP’s plans or procedures, as described below:\n\n\n\n1. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\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(1) Operating, maintaining, and repairing the pipeline in accordance with each of\nthe requirements of this subpart and subpart M of this part.\nDEQP’s O&M did not have adequate procedures for operating, maintaining, and repairing\nthe pipeline in accordance with §192.736(c).1 Specifically, DEQP did not have\nprocedures for maintaining each gas detection and alarm system required by Section\n192.736 to ensure they were functioning properly. At the time of inspection, DEQP did\nnot have detailed procedures for gas detector and flame detector equipment maintenance\n(including inspection and calibration) to ensure they were functioning properly.\n2. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\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(2) Controlling corrosion in accordance with the operations and maintenance\nrequirements of subpart I of this part.\nDEQP’s O&M did not have adequate procedures for corrosion control in accordance with\n§192.479.2 Although DEQP has procedures for atmospheric corrosion control in Section\n18.1 of SP 7-00-01, that procedure states that \"[e]ach aboveground pipeline or portion of a\npipeline installed after July 31, 1971 that is exposed to the atmosphere will be cleaned and\neither coated or jacketed with a material suitable for the prevention of atmospheric\ncorrosion.” The conditional statement, “installed after July 31, 1971” should be removed\nor otherwise revised to clarify that this regulation applies to each pipeline or portion of\npipeline that is exposed to the atmosphere, unless it falls under the exceptions listed in\nparagraph (c). In addition, the procedures do not give personnel adequate guidance on\nhow to evaluate the condition of no coating or inadequate coating at air-soil interface\nlocations.\n1 49 C.F.R. § 192.736(c) requires that “[e]ach gas detection and alarm system required by this section must be\nmaintained to function properly. The maintenance must include performance tests.”\n2 49 C.F.R. §192.479 Atmospheric corrosion control: General.\n(a) Each operator must clean and coat each pipeline or portion of pipeline that is exposed to the\natmosphere, except pipelines under paragraph (c) of this section.\n(b) Coating material must be suitable for the prevention of atmospheric corrosion.\n(c) Except portions of pipelines in offshore splash zones or soil-to-air interfaces, the operator need not\nprotect from atmospheric corrosion any pipeline for which the operator demonstrates by test,\ninvestigation, or experience appropriate to the environment of the pipeline that corrosion will -\n(1) Only be a light surface oxide; or\n2\n\n\n\n3. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(c) Abnormal operation. For transmission lines, the manual required by\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.\nDEQP’s O&M did not have adequate procedures for abnormal operations with regard to\nperiodically reviewing the response of operator personnel to determine the effectiveness\nof the procedures controlling abnormal operations and taking corrective action where\ndeficiencies are found. Although DEQP has procedures for atmospheric corrosion\ncontrol, Section 7.1.5 of its procedures states DEQP \"shall review\" abnormal event\nprocedures, but does not specify when or how long they have to accomplish review of\nabnormal event procedures. Since the regulation requires periodic review, DEQP’s\nwritten procedures must specify how often these reviews must take place.\n4. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(b) Maintenance and normal operations. The manual required by paragraph\n(a) of this section must include procedures for the following, if applicable, to\nprovide safety during maintenance and operations.\n(8) Periodically reviewing the work done by operator personnel to determine\nthe effectiveness, and adequacy of the procedures used in normal operation\nand maintenance and modifying the procedures when deficiencies are found.\nDEQP’s O&M did not have adequate procedures for periodically reviewing the work done\nby operator personnel to determine the effectiveness, and adequacy of the procedures used\nin normal operation and maintenance and modifying the procedures when deficiencies are\nfound. Although DEQP has procedures for periodic review of operation and maintenance\nprocedures in SP 3-90-01, Annual Review of Procedures Manual and Periodic Review of\nWork Done by Company Personnel: Section 7, Periodic Review of Work Done by\nCompany Personnel, it does not specify when or how long they have to accomplish review\nof their maintenance and normal operating procedures to determine adequacy and\neffectiveness. Although DEQP informed PHMSA that periodic means 3 years, not-to-\nexceed 39 months, during the inspection, their procedures do not reflect this. Since the\nregulation requires periodic review, DEQP’s written procedures must specify how often\nthese reviews must take place.\n5. §192.614 Damage prevention program.\n(a) . . .\n(c) The damage prevention program required by paragraph (a) of this section\nmust, at a minimum:\n(2) Not affect the safe operation of the pipeline before the next scheduled inspection.\n3\n\n\n\n(1) Include the identity, on a current basis, of persons who normally\nengage in excavation activities in the area in which the pipeline is located.\nDEQP’s written program to prevent damage to its pipeline from excavation activities is\ndeficient because it fails to sufficiently identify the persons normally engaged in\nexcavation activities in the area in which the pipeline is located. Although DEQP has\nprocedures for identifying persons who normally engage in excavation activities in\nStandard Practice 5-00-07, Sect 7., it does not currently have a procedure (or ability) to\nidentify excavators from one-call not included on their excavator/contractors list. And the\nprocedure did not specify how reports of Third Party Activity and names of associated\ncontractors or excavators are input back into the mail-outs and communications with\nexcavators along the system.\nIn addition to the alleged inadequacies cited above, PHMSA would also like to recommend\nthat DEQP define the terms “management” and “for cause” in its procedures for anomalies\ndiscovered in non-HCA areas. Specifically, Standard Practices (SP) 5-01-00, Section 6, the\nprocedure for Anomaly Response Scheduling for Non-covered Segments, indicates that “[i]f\nthe anomaly is in a Class 1 Location, non-HCA, and outside any Consequence Areas, the\nresponsible time requirement may be lengthened with management approval (for cause).”\nThis is not an alleged violation.\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\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. §\n190.206). 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 DEQP maintain documentation of the safety improvement\n4\n\n\n\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Kim West, Director, Western Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please\nrefer to CPF 5-2018-1007M and, for each document you submit, please provide a copy in\nelectronic format whenever possible.\nSincerely,\nKim West\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 C. Allen (#157195)\n5","truncated":false,"body_characters":13109}