{"operation":"document","citation":"CPF 320151005W","title":"WTG-HUGOTON, LP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-05-20","effective_on":null,"summary":"CLOSED warning letter citing 192.463(a), 192.706, 192.736(c), 192.805(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320151005w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320151005w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320151005w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320151005W","body":"Warning Letter involving WTG-HUGOTON, LP. PHMSA's enforcement data identifies the cited regulations as 192.463(a),  192.706,  192.736(c),  192.805(b). The case was opened on 2015-05-20 and is reported as closed as of 2015-05-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320151005W_Warning_05202015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320151005W/320151005W_Warning_05202015.pdf\n\n320151005W_Warning_05202015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320151005W/320151005W_Warning_05202015_text.pdf\n\n320151005W_Warning_05202015_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 20, 2015\nMr. J. L. Davis, President\nWTG Hugoton, LP\n211 North Colorado\nMidland, Texas 79701\nCPF 3-2015-1005W\nDear Mr. Davis:\nOn July 22-24 and 29-30, 2014, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected your records and facilities in Hugoton, Kansas.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected\nand the probable violations are:\n1. §192.736 Compressor stations: Gas detection.\n(c) Each gas detection and alarm system required by this section must be\nmaintained to function properly. The maintenance must include performance\ntests.\nThe gas detection systems in the Hugoton Compressor station were not tested to\ndemonstrate performance of the alarm system. The maintenance tests included only an\ninternally automatic electronic self-check diagnostic. Although this showed the devices\nwere functioning properly, the internal test is insufficient to demonstrate detection of gas to\nproduce the alarm.\n\n\n\n2. §192.706 Transmission lines: Leakage surveys.\nLeakage surveys of a transmission line must be conducted at intervals not\nexceeding 15 months, but at least once each calendar year. However, in the\ncase of a transmission line which transports gas in conformity with §192.625\nwithout an odor or odorant, leakage surveys using leak detector equipment\nmust be conducted-\n(a) In Class 3 locations, at intervals not exceeding 7 1/2 months, but at least\ntwice each calendar year; and\n(b) In Class 4 locations, at intervals not exceeding 4 1/2 months, but at least\nfour times each calendar year.\nWTG Hugoton did not conduct leakage surveys of its Class 3 transmission lines twice per\nyear. In 2012 the Class 2 pipe segment south of the town of Sublette, Kansas, running\nparallel to Edelle Avenue was changed from Class 2 to Class 3 location. At the time of the\ninspection the leakage survey frequency had not yet been increased from once annually to\ntwice annually.\n3. §192.463 External corrosion control: Cathodic protection.\n(a) Each cathodic protection system required by this subpart must provide a\nlevel of cathodic protection that complies with one or more of the applicable\ncriteria contained in Appendix D of this part. If none of these criteria is\napplicable, the cathodic protection system must provide a level of cathodic\nprotection at least equal to that provided by compliance with one or more of\nthese criteria.\nWTG Hugoton did not use cathodic protection criteria that complied with Appendix D of\nPart 192. The voltage IR drop between the soil surface and the pipeline were not\nconsidered correctly. Annual monitoring of cathodic protection showed 2014 voltage\nlevels on the Holcomb to Hugoton pipeline that were below (less negative) -850 millivolts\nwith protective current applied; however, WTG Hugoton incorrectly used the 100 mV\nminimum polarization shift alternative criteria. WTG Hugoton used the difference between\nthe energized cathodic protection (CP on) and de-energized (CP “instant off”) as a basis for\ndetermining the 100 mV alternate criteria. Appendix D section III requires the polarization\nshift to be determined by measuring polarization decay only after the “instant off” shift is\naccounted for.\n4. §192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The\nprogram shall include provisions to:\n(b) Ensure through evaluation that individuals performing covered tasks are\nqualified;\n2\n\n\n\nWTG Hugoton’s evaluation of personnel task performance was inadequate to ensure\nqualification for two tasks. PHMSA observed that tasks for Cathodic Protection (CP)\nMonitoring and for Maintenance of Pressure Relief Valve were performed inadequately.\nThe CP Monitoring task evaluation was insufficient because records showed that CP\nvoltage minimum criteria had been applied incorrectly, and CP was inadequate as cited in\nItem 3. The relief valve maintenance task was observed to be performed incorrectly when\nthe task was requested by PHMSA to be demonstrated during the inspection. Personnel\nwere unable to complete the task because they were unfamiliar with the configuration of the\nrelief valves at the Hugoton Compressor station.\nUnder 49 United States Code, §60122, you are subject to a civil penalty not to exceed\n$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the maximum\npenalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a related series of violations. We have reviewed the circumstances\nand supporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to\ncorrect the item(s) identified in this letter. Failure to do so will result in WTG Hugoton, LP\nbeing subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please\nrefer to CPF 3-2015-1005W. 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.\n552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 5 U.S.C. 552(b).\nSincerely,\nAllan C. Beshore\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\ncc: Mr. Richard Hatchett, Vice President\nWTG Hugoton, LP\n211 North Colorado\nMidland, Texas 79701\n3","truncated":false,"body_characters":6654}