{"operation":"document","citation":"CPF 420111013W","title":"WEST TEXAS GAS INC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2011-10-24","effective_on":null,"summary":"CLOSED warning letter citing 192.807(a)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420111013w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420111013w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420111013w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420111013W","body":"Warning Letter involving WEST TEXAS GAS INC. PHMSA's enforcement data identifies the cited regulation as 192.807(a)(2). The case was opened on 2011-10-24 and is reported as closed as of 2011-10-24. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420111013W_Warning Letter_10242011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420111013W/420111013W_Warning%20Letter_10242011.pdf\n\n420111013W_Warning Letter_10242011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420111013W/420111013W_Warning%20Letter_10242011_text.pdf\n\n420111013W_Warning Letter_10242011_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 24, 2011\nMr. Richard Hatchett\nV. P. of Operations\nWest Texas Gas, Inc.\nWestern Gas Interstate Co.\nWTG-Hugoton, LP\n211 North Colorado\nMidland, TX 79701-4607\nCPF 4-2011-1013W\nDear Mr. Hatchett:\nOn April 25-28, 2011, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your\nWest Texas Gas, Inc., Western Gas Interstate Co and WTG-Hugoton, LP (WTG) Operator\nQualification Program in Amarillo, TX.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the\nprobable violation is:\n1. §192.807 Recordkeeping.\nEach operator shall maintain records that demonstrate compliance with this\nsubpart.\n(a) Qualification records shall include:\n(2) Identification of the covered tasks the individual is qualified to perform;\nWTG uses EnergyWorldNet for database storage and maintenance of OQ records and keeps\nvarious worksheets in-house to track and accumulate information pertinent to the OQ program,\nbut these resources are not well-linked or integrated so that everyone within the company has\nconsistent information and access to the information. Due to these inconsistencies and the fact\n\n\n\nthat both sources are not synced together, it is difficult to track an individual’s qualification for a\nspecific covered task.\nIn review of the employee qualifications from the Dalhart and Guymon Districts, it was\ndiscovered that numerous individuals were no longer qualified in core covered tasks. When\nPHMSA inspectors inquired into the reasoning behind the 'not qualified' status, WTG stated the\nindividual or individuals no longer performs the tasks in question. WTG fails to meet the\nrequirements of the code.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of $1,000,000\nfor any related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement action\nor penalty assessment proceedings at this time. We advise you to correct the item(s) identified\nin this letter. Failure to do so will result in WTG being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2011-1013W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials\nSafety Administration\n2","truncated":false,"body_characters":3849}