# WTG-HUGOTON, LP — Notice of Amendment

- **operation:** document
- **citation:** CPF 32022029NOA
- **title:** WTG-HUGOTON, LP — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2022-01-24
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 192.605(b)(6).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-32022029noa.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-32022029noa.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-32022029noa
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/32022029NOA
**body:**

Notice of Amendment involving WTG-HUGOTON, LP. PHMSA's enforcement data identifies the cited regulation as 192.605(b)(6). The case was opened on 2022-01-24 and is reported as closed as of 2022-05-11. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

32022029NOA_Closure Letter_05112022_(21-207936).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022029NOA/32022029NOA_Closure%20Letter_05112022_(21-207936).pdf

32022029NOA_Closure Letter_05112022_(21-207936)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022029NOA/32022029NOA_Closure%20Letter_05112022_(21-207936)_text.pdf

32022029NOA_Notice of Amendment_01242022_(21-207936).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022029NOA/32022029NOA_Notice%20of%20Amendment_01242022_(21-207936).pdf

32022029NOA_Notice of Amendment_01242022_(21-207936)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022029NOA/32022029NOA_Notice%20of%20Amendment_01242022_(21-207936)_text.pdf

32022029NOA_Closure Letter_05112022_(21-207936)_text.pdf

VIA ELECTRONIC MAIL TO: rhatchett@westtexasgas.com; rreed@westtexasgas.com
May 11, 2021
Richard Hatchett, President
WTG-HUGOTON, LP
211 North Colorado
Midland, TX 79701
RE: CPF 3-2022-029-NOA
Dear Mr. Hatchett:
From June 29, 2021 to July 1, 2021, 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 WTG-Hugoton, LP’s (WTG) procedures for system operation and maintenance in
Hugoton, Kansas. As a result of the inspection, WTG was issued a Notice of Amendment on January 24,
2022, which proposed amendment of WTG’s procedures.
On September 13, 2021, WTG submitted its amended procedure P-192.605(b)(6). My staff has reviewed
the amended procedure and it appears that the inadequacies outlined in the 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,
Gregory A. Ochs
Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Ray Reed, Director of Pipeline Compliance rreed@westtexasgas.com

32022029NOA_Notice of Amendment_01242022_(21-207936)_text.pdf

NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: rhatchett@westtexasgas.com; rreed@westtexasgas.com
January 24, 2022
Richard Hatchett
President
WTG-Hugoton, LP
211 North Colorado
Midland, TX 79701
CPF 3-2022-029-NOA
Dear Mr. Hatchett:
From June 29, 2021 to July 1, 2021, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected WTG-Hugoton’s
procedures for system operation and maintenance in Hugoton, Kansas.
On the basis of the inspection, PHMSA has identified the apparent inadequacy found within WTG-
Hugoton’s plans or procedures, as described below:
1. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) . . . .
(b) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following, if applicable, to provide safety during
maintenance and operations.
(1) . . . .
(6) Maintaining compressor stations, including provisions for isolating units or sections of
pipe and for purging before returning to service.
WTG-Hugoton’s procedures for maintaining compressor stations were inadequate because they failed to
include provisions to address purging of air from compressors and/or associated piping when returning units



to service. Proper purging is essential to ensure that no hazardous mixture of gas and air remains in the
system. WTG-Hugoton provided an updated procedure P-192.605(b)(6) on September 13, 2021 to address
this item. No further action is required.
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 WTG-Hugoton, LP maintain documentation of the safety improvement
costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and
submit the total to Gregory A. Ochs, Director, Central Region, Pipeline and Hazardous Materials Safety
Administration. In correspondence concerning this matter, please refer to CPF 3-2022-029-NOA and, for
each document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
Gregory A. Ochs
Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Ray Reed, Director of Pipeline Compliance rreed@westtexasgas.com
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
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