{"operation":"document","citation":"CPF 42021021WL","title":"WESTERN GAS INTERSTATE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-08-06","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021021wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021021wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021021wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42021021WL","body":"Warning Letter involving WESTERN GAS INTERSTATE CO. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2021-08-06 and is reported as closed as of 2021-08-06. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42021021WL_Warning Letter_08062021_(20-172066).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021021WL/42021021WL_Warning%20Letter_08062021_(20-172066).pdf\n\n42021021WL_Warning Letter_08062021_(20-172066)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021021WL/42021021WL_Warning%20Letter_08062021_(20-172066)_text.pdf\n\n42021021WL_Warning Letter_08062021_(20-172066)_text.pdf\n\nWARNING LETTER\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nAugust 6, 2021\nRichard Hatchett\nPresident\nWestern Gas Interstate Company\n211 North Colorado\nMidland, Texas 79701\nCPF 4-2021-021-WL\nDear Mr. Hatchett:\nFrom August 31, 2020 through October 6, 2020, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) virtually inspected Western Gas Interstate Company’s (WGI) procedures and records.\nBased on the inspection, it is alleged that WGI has committed a probable violation of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and the\nprobable violation is:\n1. § 192.605 - Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include procedures\nfor handling abnormal operations. This manual must be reviewed and updated by the\noperator at intervals not exceeding 15 months, but at least once each calendar year.\nThis manual must be prepared before operations of a pipeline system commence.\nAppropriate parts of the manual must be kept at locations where operations and\nmaintenance activities are conducted.\nWGI failed to follow its written Gas Operations and Maintenance Manual (Revised May 2020)\nfor documenting Cathodic Protection Surveys, Rectifier Inspections, Odorant Concentration\nTests, and Abandonment of Facilities.\n\n\n\nPHMSA reviewed WGI’s Cathodic Protection Annual Survey Report and discovered that no\ncathodic protection readings were recorded for the B-100 Hinchey Test Station in the calendar\nyear 2019. WGI explained that the B-100 Hinchey Test Station had no readings due to a damaged\nor defective test lead repaired on October 1, 2020. WGI failed to follow its Gas Operations and\nMaintenance Manual, Remedial Action to Correct Deficiencies, P-192.465(d) (Revised: May\n2012) procedure, which requires “Upon the discovery of a cathodic deficiency that cannot be\ncorrected onsite, immediately contact the District / Division Manager” and “Remedial action will\nbe started and documented using F-192.465(d).” WGI could not provide this documentation at\nthe time of the inspection.\nSecond, WGI failed to follow its Gas Operations and Maintenance Manual, P-192.465(b),\nInspect/Test/Repair Rectifier (Revised: May 2019) procedures using the appropriate forms to\ndocument and record rectifier readings. WGI recorded its inspections from calendar years 2015\nthrough 2020 in a spreadsheet rather than the correct form, WTG-1200 Rectifier Inspection, as\nstated in its O&M procedure P-192.465(b).\nThird, WGI failed to follow its Gas Operations and Maintenance Manual, P-\n192.625, Odorization of Gas (Revised: May 2016) procedure using the appropriate forms to\ndocument and record odorant usage and concentration reports for the Beaver District. PHMSA\ninspectors found that WGI’s Odorant concentration test results were not documented correctly\nutilizing WTG Form F-1303, as stated in its O&M procedure P-192.625. In addition, WGI did\nnot maintain Odorant usage test reports for accuracy and completeness on WTG Form F-1301 for\ncalendar years 2019 and 2020.\nFourth, WGI failed to maintain records of abandonment or deactivation of pipelines and facilities\nas required by § 192.709(c). WGI indicated that the abandonment of the pipeline segments was\nperformed but failed to follow its Gas Operations and Maintenance Manual, P-192.727,\nAbandonment or Inactivation of Facilities procedure by using Form F-192.727. The following\nrecords were not provided for the abandonment of segments:\n 2016 WGI East Line, Texhoma, Texas & Oklahoma Re-route abandoned approximately\n1.95 miles of 6” steel pipeline;\n 2016 WGI East Line, Tyrone, Oklahoma HWY 54 Road Expansion abandoned\napproximately 2.4 miles of 4-inch steel pipeline; and\n 2019 WGI West Line, Stratford, Texas Re-route abandoned approximately 0.85 miles of\n6-inch and 2.13 miles of 4-inch steel pipelines.\nIn each of the above-referenced instances, WGI failed to follow its Gas Operations and\nMaintenance Manual procedures to document work performed.\nSubsequent to the inspection, PHMSA requested that WGI submit evidence to reflect the\ninformation was transferred to the appropriate forms. WGI provided documentation related to\ncathodic protection, rectifier readings, and odorization in the correct format; however, the\nrequested abandonment records were not provided.\n2\n\n\n\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, Western Gas Interstate Company is subject to a\ncivil penalty not to exceed $225,134 per violation per day the violation persists, up to a maximum\nof $2,251,334 for a related series of violations. For violations occurring on or after January 11,\n2021, and before May 3, 2021, the maximum penalty may not exceed $222,504 per violation per\nday the violation persists, up to a maximum of $2,225,034 for a related series of violations. For\nviolation occurring on or after July 31, 2019, and before January 11, 2021, the maximum penalty\nmay not exceed $218,647 per violation per day the violation persists, up to a maximum of\n$2,186,465 for a related series of violations. For violations occurring on or after November 27,\n2018, and before July 31, 2019, the maximum penalty may not exceed $213,268 per violation per\nday, with a maximum penalty not to exceed $2,132,679. For violations occurring on or after\nNovember 2, 2015, and before November 27, 2018, the maximum penalty may not exceed\n$209,002 per violation per day, with a maximum penalty not to exceed $2,090,022.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the item identified in this letter. Failure to do so will result in\nWestern Gas Interstate Company 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 4-2021-021-WL. 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 the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nCc: Ray Reed, Director of Pipeline Compliance Management\n3","truncated":false,"body_characters":7625}