# USG WHEATLAND PIPELINE, LLC — Notice of Amendment

**Citation:** CPF 320176005M  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2017-07-27

CLOSED notice of amendment citing 195.234(e), 195.234(f), 195.234(g), 195.402(e)(1), 195.440(c).

## Document text

Notice of Amendment involving USG WHEATLAND PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulations as 195.234(e),  195.234(f),  195.234(g),  195.402(e)(1),  195.440(c). The case was opened on 2017-07-27 and is reported as closed as of 2018-06-26. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320176005M_Closure Letter_06262018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320176005M/320176005M_Closure%20Letter_06262018.pdf

320176005M_Closure Letter_06262018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320176005M/320176005M_Closure%20Letter_06262018_text.pdf

320176005M_Notice of Amendment_07272017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320176005M/320176005M_Notice%20of%20Amendment_07272017.pdf

320176005M_Notice of Amendment_07272017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320176005M/320176005M_Notice%20of%20Amendment_07272017_text.pdf

320176005M_Operator Response to Notice_08172017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320176005M/320176005M_Operator%20Response%20to%20Notice_08172017.pdf

320176005M_Closure Letter_06262018_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
June 26, 2018
Mr. Larry Wall
COO Gas Infrastructure
USG Wheatland Pipeline, LLC
601 Travis Street
Houston, TX 77002
CPF 3-2017-6005M
Dear Mr. Wall:
On May 10-12, 2016, 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 USG Wheatland Pipeline, LLC procedures in Williston, North
Dakota. As a result of the inspection, USG Wheatland Pipeline, LLC was issued a Notice of
Amendment on July27, 2017, which proposed amendment of your procedures.
USG Wheatland Pipeline, LLC submitted its amended procedures on June 5, 2018. My staff
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,
Allan C. Beshore
Director, Central Region, OPS
Pipeline and Hazardous Materials Safety Administration

320176005M_Notice of Amendment_07272017_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
July 27, 2017
Mr. Larry Wall, COO Gas Infrastructure
USG Wheatland Pipeline, LLC
601 Travis Street
Houston, TX 77002
CPF 3-2017-6005M
Dear Mr. Wall:
On May 10-12, 2016, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected USG
Wheatland Pipeline, LLC procedures for operations, maintenance, public awareness and
operator qualifications in Williston, North Dakota.
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
USG Wheatland Pipeline, LLC (Wheatland) plans or procedures, as described below:
1. §195.402 Procedural manual for operations, maintenance, and emergencies.
(e) Emergencies. The manual required by paragraph (a) of this section must
include procedures for the following to provide safety when an emergency
condition occurs;
(1) Receiving, identifying, and classifying notices of events which need
immediate response by the operator or notice to fire, police, or other
appropriate public officials and communicating this information to
appropriate operator personnel for corrective action.



Wheatland’s Emergency Response Procedures (ERP) do not include provisions to classify
events for immediate response. Wheatland must amend its ERP to include procedures for
classifying events which need immediate response.
2. §195.440 Public awareness
(c) The operator must follow the general program recommendations, including
baseline and supplemental requirements of API RP 1162, unless the operator
provides justification in its program or procedural manual as to why compliance
with all or certain provisions of the recommended practice is not practicable and
not necessary for safety.
Wheatland’s public awareness written plan is inadequate because it is missing some of the
baseline messages, especially the public official section which is missing emergency
communications and other messages as required in API RP 1162. The written plan’s
effectiveness evaluation section is also missing the following items:
• Margin of error for surveys
• Sample sizes for surveys
• Pretesting of materials
• Picking bottom line results value
• Methodology for the four required effectiveness measures in RP 1162
Wheatland must amend its public awareness procedures to include all required baseline
messages for all required audiences and also to include all bulleted items above.
3. §195.234 Welds: Nondestructive testing.
(e) All girth welds installed each day in the following locations must be
nondestructively tested over their entire circumference, except that when
nondestructive testing is impracticable for a girth weld, it need not be tested if the
number of girth welds for which testing is impracticable does not exceed 10
percent of the girth welds installed that day:
(1) At any onshore location where a loss of hazardous liquid could
reasonably be expected to pollute any stream, river, lake, reservoir, or
other body of water, and any offshore area;
(2) Within railroad or public road rights-of-way;
(3) At overhead road crossings and within tunnels;
(4) Within the limits of any incorporated subdivision of a State
government; and,
2



(5) Within populated areas, including, but not limited to, residential
subdivisions, shopping centers, schools, designated commercial areas,
industrial facilities, public institutions, and places of public assembly.
(f) When installing used pipe, 100 percent of the old girth welds must be
nondestructively tested.
(g) At pipeline tie-ins, including tie-ins of replacement sections, 100 percent of the
girth welds must be nondestructively tested.
Wheatland’s Operations & Maintenance Manual, Section 5.3.6.10 Nondestructive Testing,
states that the acceptability of welds will be determined according to API 1104, Section 9.
API 1104 Section 9 does not cover the sampling requirement to non-destructively test welds
that is noted in the consideration. Wheatland must amend its O&M manual to include all
required NDT sampling requirements of §195.234.
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 Amendment. 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 Wheatland maintain documentation of the safety
improvement costs associated with fulfilling this Notice of Amendment (preparation/revision
3



of plans, procedures) and submit the total to Allan Beshore, Director, Central Region, Pipeline
and Hazardous Materials Safety Administration. In correspondence concerning this matter,
please refer to CPF 3-2017-6005M and, for each document you submit, please provide a copy
in electronic format whenever possible.
Sincerely,
Allan C. Beshore
Director, Central Region, OPS
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
4

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/320176005M>
- Source ID: `phmsa-enforcement`
- SHA-256: `c05f9b7038c52e8767ef36b27b6a2d96673d5a33557263d49de0a4fd9f53bf47`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-23T10:34:50.602Z
- Document slug: `phmsa-enforcement-320176005m`

### Source metadata

```json
{
  "cpf": "320176005M",
  "operator": "USG WHEATLAND PIPELINE, LLC",
  "region": "Central",
  "pipelineType": "INTRASTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.234(e)",
    "195.234(f)",
    "195.234(g)",
    "195.402(e)(1)",
    "195.440(c)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 5,
  "attachments": [
    {
      "name": "320176005M_Closure Letter_06262018.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/320176005M/320176005M_Closure%20Letter_06262018.pdf",
      "bytes": 168921,
      "category": "agency_document"
    },
    {
      "name": "320176005M_Closure Letter_06262018_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/320176005M/320176005M_Closure%20Letter_06262018_text.pdf",
      "bytes": 73402,
      "category": "agency_document"
    },
    {
      "name": "320176005M_Notice of Amendment_07272017.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/320176005M/320176005M_Notice%20of%20Amendment_07272017.pdf",
      "bytes": 2320029,
      "category": "agency_document"
    },
    {
      "name": "320176005M_Notice of Amendment_07272017_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/320176005M/320176005M_Notice%20of%20Amendment_07272017_text.pdf",
      "bytes": 90529,
      "category": "agency_document"
    },
    {
      "name": "320176005M_Operator Response to Notice_08172017.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/320176005M/320176005M_Operator%20Response%20to%20Notice_08172017.pdf",
      "bytes": 350860,
      "category": "party_submission"
    }
  ],
  "extractedAgencyDocumentCount": 2,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "USG WHEATLAND PIPELINE, LLC"
}
```
