WEST TEXAS GAS INC — Notice of Amendment

42021023NOA_Notice of Amendment_05252021_(20-179421)_text.pdf, page 1Official PDFNOTICE OF AMENDMENT ELECTRONIC MAIL - RETURN RECEIPT REQUESTED May 25, 2021 Richard D. Hatchett President West Texas Gas, Inc. 211 North Colorado Midland, Texas 79701 CPF 4-2021-023-NOA Dear Mr. Hatchett: From April 20, 2020 through October 4, 2020, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) virtually inspected West Texas Gas, Inc.’s (WTG) operations and maintenance manual. Based on the inspection, PHMSA has identified the apparent inadequacy found within WGT’s Gas Operations and Maintenance Manual as described below: 1. § 192.605 - Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. For transmission lines, the manual must also include procedures for handling abnormal operations. This manual must be reviewed and updated by the operator at intervals not exceeding 15 months, but at least once each calendar year. This manual must be prepared before operations of a pipeline system commence. Appropriate parts of the manual must be kept at locations where operations and maintenance activities are conducted. § 192.707 - Line markers for mains and transmission lines. (a) Buried pipelines. Except as provided in paragraph (b) of this section, a line marker must be placed and maintained as close as practical over each buried main and transmission line: (1) At each crossing of a public road and railroad;#

42021023NOA_Notice of Amendment_05252021_(20-179421)_text.pdf, page 22 WTG failed to include a requirement to install and maintain pipeline markers at crossings of public roads and railroads as required in § 192.707(a) in its written operations and maintenance procedures. WTG’s Gas Operations and Maintenance Manual, P-192.707 (Revised December 2013) procedure does not mention public roads or railroad crossings in the written procedure. On October 26, 2020, WTG provided an amended P-192.707 procedure to include public roads and railroad crossings in its Gas Operations and Maintenance Manual. After review, the amended procedure was found to be adequate. 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. As mentioned above, West Texas Gas, Inc. previously submitted revised procedures to PHMSA that reflect the amendments required by this Notice. These submitted procedures were reviewed and found to be adequate by PHMSA, therefore, no further action or response is required. If no additional response is received within 30 days of receipt of this Notice, this enforcement will be automatically closed. It is requested (not mandated) that West Texas Gas, Inc. maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Mary L. McDaniel, Director, Southwest, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 4-2021- 023-NOA, and for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Mary L. McDaniel, P.E. Director, Southwest Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration#