# ENERGY WEST DEVELOPMENT, INC. — Notice of Amendment

**Citation:** CPF 520070026M  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2007-12-10

CLOSED notice of amendment citing 192.905(a).

## Document text

Notice of Amendment involving ENERGY WEST DEVELOPMENT, INC.. PHMSA's enforcement data identifies the cited regulation as 192.905(a). The case was opened on 2007-12-10 and is reported as closed as of 2008-03-03. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520070026M_notice of amendment_12102007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520070026M/520070026M_notice%20of%20amendment_12102007.pdf

520070026m_notice of amendment_12102007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520070026M/520070026m_notice%20of%20amendment_12102007_text.pdf

520070026M_Operator Response_01282008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520070026M/520070026M_Operator%20Response_01282008.pdf

520070026m_notice of amendment_12102007_text.pdf

BEN'I 'N! l oMP|. IANcE REGls+T
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U. S. Department
of Transportation
Pipeline and
Hazardous Materials Safety
Administration
12300 W Dakota Ave, Suite 110
I akewood, CO 80228
NOTICE OF AMKNDMKNT
CERTIFIED MAIL - RETURN RECEIPT RE UESTED
December 10, 2007
Mr. Steve Miller
Assistant Vice President
Energy West Development
2320 Mountain View Drive
Cody, WY 82414
CPF 5-2007-0026M
Dear Mr. Miller;
On May 29, 2007, a representative of the Pipehne and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Energy
West Development (EWD) procedures for integrity management in Cody, Wyoming.
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
EWD's plans or procedures, as described below:
$192. 911 What are the elements of an integrity management program?
An operator's initial integrity management program begins with a framework (see
g 192. 907) and evolves into a more detailed and comprehensive integrity
management program, as information is gained and incorporated into the
program. An operator must make continual improvements to its program. The
initial program framework and subsequent program must, at minimum, contain
the following elements. (When indicated, refer to ASME/ANSI B31. 8S
(incorporated by reference, see g 192. 7) for more detailed information on the listed
element. )



(a) An identification of all high consequence areas, in accordance with g 192. 905.
The following procedures were inadequate for identification of high consequence areas.
~ Item 1. A: $192. 905(a)
Section 1 of Energy West Development's (EWD) integrity management program (IMP)
refers to $192. 5 for definitions of Class 3 and 4 areas. These definitions must direct the
reader to other company manuals that determine class locations, or the IMP procedure
itself must fully describe how a Class 3 and Class 4 area are identified.
~ Item 1. B: $192. 905(a)
Section 1 of EWD's IMP which describes the process for determining if a potential
impact circle contains an identified site, refers to Appendix E of Part 192 for drawings
depicting the method. EWD's procedure cannot reference Part 192 for descriptions of
methods to be used for determining high consequence areas (HCAs).
~ Item 1. C: $192. 905(a)
Under Section 1, Identification of HCAs the First Step, paragraph 3, EWD refers to 49
CFR 192 and not their IMP for definitions of HCA determination methods.
~ Item 1. D: $192. 905(a)
Under Section 1, Identification of HCAs the First Step, paragraph 4, EWD refers to%9
CFR 192 and not their IMP for definitions of identified sites.
Res onse to this Notice
This Notice is provided pursuant to 49 U. S. C. $ 60108(a) and 49 C. F. R. $ 190. 237. 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). 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 a Final Order.



If, after opportunity for a hearing, 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. 237). 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.
In correspondence concerning this matter, please refer to CPF 5-2007-0026M and, for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
C ' oidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 G Davis ¹ 118733
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/520070026M>
- Source ID: `phmsa-enforcement`
- SHA-256: `54867e4037f723061deb6a1e77a1c2b737dc337e4b2fb72ab0d5843ed73f12c5`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T23:20:55.330Z
- Document slug: `phmsa-enforcement-520070026m`

### Source metadata

```json
{
  "cpf": "520070026M",
  "operator": "ENERGY WEST DEVELOPMENT, INC.",
  "region": "Western",
  "pipelineType": "GAS INTRASTATE ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "192.905(a)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 3,
  "attachments": [
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    {
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      "bytes": 25371,
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  ],
  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "ENERGY WEST DEVELOPMENT, INC."
}
```
