{"operation":"document","citation":"CPF 420121008","title":"WEST TEXAS GAS INC — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-05-16","effective_on":null,"summary":"CLOSED notice of probable violation citing 192.616(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420121008.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420121008.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420121008","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420121008","body":"Notice of Probable Violation involving WEST TEXAS GAS INC. PHMSA's enforcement data identifies the cited regulation as 192.616(c). The case was opened on 2012-05-16 and is reported as closed as of 2014-05-20. Proposed civil penalty: $53,000. Assessed civil penalty: $53,000. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420121008_Closure_05202014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420121008/420121008_Closure_05202014.pdf\n\n420121008_Closure_05202014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420121008/420121008_Closure_05202014_text.pdf\n\n420121008_Final Order_06172013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420121008/420121008_Final%20Order_06172013.pdf\n\n420121008_Final Order_06172013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420121008/420121008_Final%20Order_06172013_text.pdf\n\n420121008_NOPV PCP PCO_05162012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420121008/420121008_NOPV%20PCP%20PCO_05162012.pdf\n\n420121008_NOPV PCP PCO_05162012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420121008/420121008_NOPV%20PCP%20PCO_05162012_text.pdf\n\n420121008_Operator Response to Notice_06142012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420121008/420121008_Operator%20Response%20to%20Notice_06142012.pdf\n\n420121008_Closure_05202014_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 20, 2014\nMr. Richard Hatchett\nVice President of Operations\nWest Texas Gas, Inc.\n211 North Colorado\nMidland TX 70701-4607\nCPF 4-2012-1008\nDear Mr. Hatchett:\nOn July 6-7, 2011, a representative of the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the West Texas Gas, Inc.\n(WTG) Public Awareness Program at the WTG offices in Plainview, Texas.\nA Notice of Probable Violation and Proposed Compliance Order was issued to WTG on May 16, 2012.\nWTG responded by letter dated June 14, 2012. A Final Order for this case was issued on May 17,\n2013.\nWTG submitted a copy of amended procedures on June 27, 2013. My staff reviewed the information\nprovided, and it appears that the inadequacies outlined in this Notice of Probable Violation and\nProposed Compliance Order have been corrected.\nThis letter is to inform you that no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nR. M. Seeley\nDirector, Southwest region\nPipeline and Hazardous Materials Safety Administration\n\n420121008_Final Order_06172013_text.pdf\n\nJUNE 17, 2013\nMr. J.L. Davis\nPresident\nWest Texas Gas, Inc.\n211 N. Colorado\nMidland, TX 79701\nRe: CPF No. 4-2012-1008\nDear Mr. Davis:\nEnclosed please find the Final Order issued in the above-referenced case. It makes findings\nof violation, assesses a civil penalty of $53,000, and specifies actions that need to be taken by\nWest Texas Gas, Inc. to comply with the pipeline safety regulations. The penalty payment\nterms are set forth in the Final Order. When the civil penalty has been paid and the terms of\nthe compliance order completed, as determined by the Director, Southwest Region, this\nenforcement action will be closed. Service of the Final Order by certified mail is deemed\neffective upon the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. Richard Hatchett, Vice President of Operations, West Texas Gas, Inc.\n211 N. Colorado, Midland, TX 79701\nMr. R.M. Seeley, Director, Southwest Region, OPS\nMr. Alan Mayberry, Deputy Associate Administrator for Field Operations, OPS\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\n)\nIn the Matter of )\n)\nWest Texas Gas, Inc. , ) CPF No. 4-2012-1008\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nFrom July 6 and 7, 2011, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),\nconducted on-site pipeline safety inspections of the Public Awareness Program (PAP) of West\nTexas Gas, Inc. (WTG or Respondent) in Plainview, Texas. Respondent owns and operates\napproximately 7,200 miles of pipeline, including natural gas distribution, natural gas\ntransmission, gathering, and hazardous liquids transmission pipelines within the states of Kansas,\nLouisiana, New Mexico, Oklahoma, and Texas.\n1\nAs a result of the inspection, the Director, Southwest Region, OPS (Director), issued to\nRespondent, by letter dated May 16, 2012, a Notice of Probable Violation, Proposed Civil\nPenalty, and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the\nNotice proposed finding that WTG committed three violations of 49 C.F.R. §192.616(c) and\nproposed assessing a civil penalty of $53,000 for the alleged violations. The Notice also\nproposed ordering Respondent to take certain measures to correct the alleged violation.\nWTG responded to the Notice by letter dated June 14, 2012 (Response). The company did not\ncontest the allegations of violation but provided information concerning the corrective actions it\nhad taken. Respondent did not request a hearing and therefore has waived its right to one.\nFINDINGS OF VIOLATION\nIn its Response, WTG did not contest the allegation in the Notice that it violated\n49 C.F.R. Part 192, as follows:\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.616(c), which states:\n1 See http://www.westtexasgas.com/?page_id=12 (last accessed February 20, 2013)\n\n\n\n2\n§ 192.616 Public awareness.\n(a) Except for an operator of a master meter or petroleum gas system\ncovered under paragraph (j) of this section, each pipeline operator must\ndevelop and implement a written continuing public education program that\nfollows the guidance provided in the American Petroleum Institute’s (API)\nRecommended Practice (RP) 1162 (incorporated by reference,\nsee § 192.7)\n(b) …\n(c) The operator must follow the general program recommendations,\nincluding baseline and supplemental requirements of API RP 1162, unless\nthe operator provides justification in its program or procedural manual as\nto why compliance with all or certain provisions of the recommended\npractice is not practicable and not necessary for safety.\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.616(c) by failing to develop and\nimplement a written public education program that followed the general program\nrecommendations, including baseline and supplemental requirements, provided in American\nPetroleum Institute’s (API) Recommended Practice (RP) 1162. Specifically, the Notice alleged\nWTG’s Public Awareness Program (PAP) had been developed by copying API RP 1162 and\nrevising the text to substitute the phrase “WTG/WGI” for “the operator”, adding the phrase\n“WTG/WGI” throughout the text of its PAP, and deleting all language not specifically related to\nnatural gas transmission operators.2 PHMSA’s audit also revealed that WTG’s PAP did not take\ninto account the unique attributes of Respondent’s pipeline system. Each pipeline is unique and\nhas its own specific attributes such as its geographical location, design, operating environment,\nthe commodity being transported, and other factors. Operators are required to develop and\nimplement a public education program that takes into consideration the unique attributes of the\noperator’s pipeline system.\nRespondent did not contest this allegation of violation. Accordingly, based upon a review of all\nof the evidence, I find that Respondent violated 49 C.F.R. § 192.616(c) by failing to develop and\nimplement a written public education program that followed the guidance provided in API RP\n1162.\nItem 2: The Notice alleged that Respondent violated 49 C.F.R. § 192.616(c), which states:\n§ 192.616 Public awareness.\n(a) …\n(c) The operator must follow the general program recommendations,\nincluding baseline and supplemental requirements of API RP 1162, unless\nthe operator provides justification in its program or procedural manual as\nto why compliance with all or certain provisions of the recommended\npractice is not practicable and not necessary for safety.\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.616(c) by failing to follow and\nimplement a public education program meeting the general program recommendations set forth\n2 Pipeline Safety Violation Report (Violation Report) (May 16, 2012) (on file with PHMSA), Exhibit A.\n\n\n\n3\nin API RP 1162, including baseline and supplemental requirements. Specifically, the Notice\nalleged that WTG failed to conduct an annual audit to determine whether its PAP had been\ndeveloped and implemented in accordance with WTG’s PAP, Section 8.3, and Table 8-1 of API\nRP 1162.3\nIn its Response, WTG contended that it had conducted an audit to determine whether its PAP\nhad been developed and implemented in accordance with the regulatory requirements.\nHowever, the company did not provide any documentation to support its claim that an audit had\nbeen performed. Accordingly, based upon a review of all of the evidence, I find that Respondent\nviolated 49 C.F.R. § 192.616(c) by failing to conduct an annual audit to determine whether its\nPAP had been developed to follow general program recommendations set forth in API RP 1162\nand the company’s procedures.\nItem 3: The Notice alleged that Respondent violated 49 C.F.R. § 192.616(c), which states:\n§ 192.616 Public awareness.\n(a) …\n(c) The operator must follow the general program recommendations,\nincluding baseline and supplemental requirements of API RP 1162, unless\nthe operator provides justification in its program or procedural manual as\nto why compliance with all or certain provisions of the recommended\npractice is not practicable and not necessary for safety.\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.616(c) by failing to follow and\nimplement a public education program meeting the program recommendations of API RP 1162,\nincluding baseline and supplemental requirements and its company’s procedures. Specifically,\nthe Notice alleged that WTG did not evaluate the effectiveness of its PAP every four years, in\naccordance with WTG PAP, Section 8.4.2. and Table 8-1 of API RP 1162.4 Respondent did not\ncontest this allegation of violation. Accordingly, based upon a review of all of the evidence, I\nfind that Respondent violated 49 C.F.R. § 192.616(c) by failing to evaluate the effectiveness of\nits PAP in accordance with company procedures and the general program recommendations set\nforth in API RP 1162.\nThese findings of violation will be considered prior offenses in any subsequent enforcement\naction taken against Respondent.\n3 WTG’s PAP, Section 8.3 reads: “WGT/WGI shall complete an annual audit or review of whether the program has\nbeen developed and implemented according to the guidelines in API RP 1162. The purpose of the audit is to answer\nthe following two questions: (1) Has the Public Awareness Program been developed and written to address the\nobjectives, elements and baseline schedule as described [in] Section 2 and the remainder of this API RP 1162? and\n(2) Has the Public Awareness Program been implemented and documented according to the written program?” See\nViolation Report, Exhibit A.\n4 WTG’s PAP, Section 8.4.2 reads: “Once validated in this initial manner, a program effectiveness survey is only\nrequired about every four years. However, when the operator introduces major design changes in its Public\nAwareness Program a survey to validate the new approaches may be warranted”\n. In addition, Table -8.1 of API RP\n1162 recommends an effectiveness evaluation no more than four years apart. Id.\n\n\n\n4\nASSESSMENT OF PENALTY\nUnder 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed\n$100,000 per violation for each day of the violation, up to a maximum of $1,000,000 for any\nrelated series of violations. In determining the amount of a civil penalty under 49 U.S.C.\n§ 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature,\ncircumstances, and gravity of the violation, including adverse impact on the environment; the\ndegree of Respondent’s culpability; the history of Respondent’s prior offenses; the Respondent’s\nability to pay the penalty and any effect that the penalty may have on its ability to continue doing\nbusiness; and the good faith of Respondent in attempting to comply with the pipeline safety\nregulations. In addition, I may consider the economic benefit gained from the violation without\nany reduction because of subsequent damages, and such other matters as justice may require.\nThe Notice proposed a total civil penalty of $53,000 for the violations cited above.\nItem 2: The Notice proposed a civil penalty of $26,800 for Respondent’s violation of\n49 C.F.R. § 192.616(c), for failing to conduct an annual audit to determine whether its PAP had\nbeen developed and implemented in accordance with WTG’s PAP, Section 8.3, and Table 8-1\nand guidance in API RP 1162. WTG did not present any evidence or argument justifying a\nreduction in or elimination of the proposed penalty. WTG is fully culpable for the violation.\nRespondent was cognizant of the requirement to follow the program recommendations of API\nRP 1162, and the company’s requirements to conduct an annual audit of its PAP. Furthermore,\nRespondent’s prior enforcement history was taken into account. The operator had fourteen\nviolations in the five years that preceded the issuance of the Notice.5 Accordingly, having\nreviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of\n$26,800, for violation of 49 C.F.R. § 192.616(c).\nItem 3: The Notice proposed a civil penalty of $26,200 for Respondent’s violation of 49 C.F.R.\n§ 192.616(c), for failing to evaluate the effectiveness of its PAP every four years, in accordance\nwith company procedures and the general program recommendations set forth in API RP 1162.\nWTG neither contested the allegation nor presented any evidence or argument justifying a\nreduction in or elimination of the proposed penalty. WTG is fully culpable for the violation.\nRespondent was cognizant of the requirement to follow API RP 1162 and to evaluate the\neffectiveness of its PAP every four years. Furthermore, Respondent’s prior enforcement history\nwas taken into account.6 The operator had fourteen violations in the five years that preceded the\nissuance of the Notice. Accordingly, having reviewed the record and considered the assessment\ncriteria, I assess Respondent a civil penalty of $26,200 for violation of 49 C.F.R. § 192.616(c).\nIn summary, having reviewed the record and considered the assessment criteria for each of the\nItems cited above, I assess Respondent a total civil penalty of $53,000.\nPayment of the civil penalty must be made within 20 days of service. Federal regulations\n(49 C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer through the Federal\nReserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed\n5 Violation Report at 21.\n6 Id.\n\n\n\n5\ninstructions are contained in the enclosure. Questions concerning wire transfers should be\ndirected to: Financial Operations Division (AMZ-341), Federal Aviation Administration, Mike\nMonroney Aeronautical Center, P.O. Box 269039, Oklahoma City, Oklahoma 73125. The\nFinancial Operations Division telephone number is (405) 954-8893.\nCOMPLIANCE ORDER\nThe Notice proposed a Compliance Order with respect to Item 1 in the Notice for violation of\n49 C.F.R. § 192.616(c). Under 49 U.S.C. § 60118(a), each person who engages in the\ntransportation of gas or who owns or operates a pipeline facility is required to comply with the\napplicable safety standards established under chapter 601. Pursuant to the authority of\n49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following\nactions to ensure compliance with the pipeline safety regulations applicable to its operations:\n1. With respect to the violation of § 192.616(c) (Item 1), Respondent must revise its\nPublic Awareness Program to reflect the unique characteristics of WTG’s pipeline\nsystem.\n2. West Texas must submit a copy of the entire revised West Texas Gas Public\nAwareness Program to the Director, Southwest Region, PHMSA within 180 days of\nreceipt of the Final Order.\n3. It is requested, but not required, that Respondent maintain documentation of the\nsafety improvement costs associated with fulfilling this Compliance Order and submit\nthe total to R.M. Seeley, Director, Southwest Region, Pipeline and Hazardous\nMaterials Safety Administration. It is requested that these costs be reported in two\ncategories: 1) total cost associated with preparation/revision of plans, procedures,\nstudies and analyses, and 2) total cost associated with replacements, additions and\nother changes to pipeline infrastructure.\nThe Director may grant an extension of time to comply with any of the required items upon a\nwritten request timely submitted by the Respondent and demonstrating good cause for an\nextension.\nFailure to comply with this Order may result in the administrative assessment of civil penalties\nnot to exceed $100,000 for each violation for each day the violation continues or in referral to the\nAttorney General for appropriate relief in a district court of the United States.\nThe terms and conditions of this Final Order are effective upon service in accordance with\n49 C.F.R. § 190.5.\n___________________________________ __________________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n420121008_NOPV PCP PCO_05162012_text.pdf\n\nNOTICE OF PROBABLE VIOLATION\nPROPOSED CIVIL PENALTY\nand\nPROPOSED COMPLIANCE ORDER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 16, 2012\nRichard Hatchett\nVice President of Operations\nWest Texas Gas, Inc.\n211 North Colorado\nMidland TX 70701-4607\nCPF 4-2012-1008\nDear Mr. Hatchett:\nOn July 6 and 7, 2011, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code was onsite and\ninspected the West Texas Gas, Inc. (WTG) Public Awareness Program (PAP) at the WTG\noffices in Plainview, Texas.\nAs a result of the inspection, it appears that WTG has committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violation(s) are:\n1. §192.616 Public Awareness\n(c) The operator must follow the general program recommendations, including\nbaseline and supplemental requirements of API RP 1162, unless the operator\nprovides justification in its program or procedural manual as to why conditions with\nall or certain provisions of the recommended practice is not practicable and not\nnecessary for safety.\n\n\n\nWTG did not prepare their PAP in accordance with the regulations. Specifically WTG did not include\ntheir unique attributes and characteristics in their PAP. API RP 1162 section 1.3.2 Baseline Public\nAwareness Program states:\n“Refers to general program recommendations, set forth in Recommended Practice 1162, The\nbaseline recommendations do not take into consideration the unique attributes and\ncharacteristics of individual pipeline operators’ pipeline and facilities. Supplemental or\nenhanced program components are described in the RP to provide guidelines to the operator\nfor enhancing its Public Awareness Programs. This is described more fully in Sections 2 and\n6.”\nThe WTG PAP consists mainly of language from parts of API RP 1162 applicable to natural gas\ntransmission systems. In creating its PAP, it appears that WTG started with API RP 1162, substituted\n“WTG/WGI” for “the operator,” added “WTG/WGI” in a number of locations, deleted all language not\nspecifically related to natural gas transmission operators, deleted Figure 2-1 and made only very minor\nadditional editorial changes. As a result, the WTG PAP does not appear to take into consideration any of\nthe unique attributes and characteristics of the WTG system. Based on the on-site inspection, it appears\nthat WTG had little interest in actively participating in the implementation of its PAP. This is consistent\nwith the simplistic approach taken in the creation of the WTG PAP.\n2. §192.616 Public Awareness\n(c) The operator must follow the general program recommendations, including\nbaseline and supplemental requirements of API RP 1162, unless the operator\nprovides justification in its program or procedural manual as to why conditions with\nall or certain provisions of the recommended practice is not practicable and not\nnecessary for safety.\nWTG failed to conduct annual audits or reviews of whether the (PAP) program has been developed and\nimplemented according to the guidelines contained in API RP 1162. Specifically section 8.3 of WTG’s\nPAP states:\n“WGT/WGI shall complete an annual audit or review of whether the program has been developed and\nimplemented according to the guidelines in API RP 1162. The purpose of the audit is to answer the\nfollowing two questions:\n• Has the Public Awareness Program been developed and written to address the objectives,\nelements and baseline schedule as described Section 2 and the remainder of this API RP 1162?\n• Has the Public Awareness Program been implemented and documented according to the written\nprogram?”\nBoth section 8.3 and Table 8-1 of the WTG PAP require an annual audit or review of whether the (PAP)\nprogram has been developed and implemented according to the guidelines contained in API RP 1162.\nBoth the WTG PAP and API RP 1162 cite Appendix E to API RP 1162 for a sample set of questions that\nwill aid the program administrator and district managers in auditing the program implementation process.\nDuring the inspection, WTG asserted that annual reviews had been conducted and researched meeting\nnotes and other records but produced nothing that could be reasonably considered an annual audit or\nreview. Upon further questioning by the inspector, WTG appeared unfamiliar with the sample set of2\n\n\n\nquestions contained in Appendix E to API RP 1162 and ultimately admitted that annual audits or reviews\nhad not been conducted.\n3. 49 CFR §192.616(c)\nThe operator must follow the general program recommendations, including baseline and\nsupplemental requirements of API RP 1162, unless the operator provides justification in its\nprogram or procedural manual as to why conditions with all or certain provisions of the\nrecommended practice is not practicable and not necessary for safety.\nWTG failed to conduct an evaluation of the effectiveness of the PAP implementation every four years.\nSpecifically WTG’s PAP section 8.4.2 states:\n“… Once validated in this initial manner, a program effectiveness survey is only required\nabout every four years. However, when the operator introduces major design changes in its\nPublic Awareness Program a survey to validate the new approaches may be warranted.”\nTable 8.1 adds the recommended frequency is “No more than four years apart”. During the inspection,\nWTG admitted that they had never conducted a four-year effectiveness evaluation.\nProposed Civil Penalties\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violation persists up to a maximum of $1,000,000 for any\nrelated series of violations. The Compliance Officer has reviewed the circumstances and\nsupporting documentation involved in the above probable violations and has recommended that\nyou be preliminarily assessed a civil penalty of $53,000 as follows:\nItem number PENALTY\n2. $26,800\n3. $26,200\nProposed Compliance Order\nWith respect to these items, pursuant to 49 United States Code § 60118, the Pipeline and\nHazardous Materials Safety Administration proposes to issue a Compliance Order to West Texas\nGas, Inc. Please refer to the Proposed Compliance Order, which is enclosed and made a part of\nthis Notice.\nResponse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators\nin Compliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this3\n\n\n\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue a Final Order.\nIn your correspondence on this matter, please refer to CPF 4-2012-1008 and for each document\nyou submit, please provide a copy in electronic format whenever possible.\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Compliance Proceedings\n4\n\n\n\nPROPOSED COMPLIANCE ORDER\nPursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) proposes to issue to West Texas Gas, Inc. a Compliance Order\nincorporating the following remedial requirements to ensure the compliance of West Texas Gas,\nInc. with the pipeline safety regulations:\n1. In regard to Item Number 1 of the Notice pertaining to the failure not take into\nconsideration the unique attributes and characteristics of WTG’s’ pipeline and\nfacilities, WTG must revise its PAP to reflect the unique characteristics of the\nWTG system and submit a copy of the entire revised WTG PAP to the PHMSA\nSouthwest Region within 180 days of the Final Order.\n2. It is requested (not mandated) that WTG maintain documentation of the safety\nimprovement costs associated with fulfilling this Compliance Order and submit\nthe total to R. M. Seeley, Director, Southwest Region, Pipeline and Hazardous\nMaterials Safety Administration. It is requested that these costs be reported in\ntwo categories: 1) total cost associated with preparation/revision of plans,\nprocedures, studies and analyses, and 2) total cost associated with replacements,\nadditions and other changes to pipeline infrastructure.\n5","truncated":false,"body_characters":26832}