# SOUTHWEST GAS TRANSMISSION COMPANY A LIMITED PARTNERSHIP — Warning Letter

- **operation:** document
- **citation:** CPF 520181008W
- **title:** SOUTHWEST GAS TRANSMISSION COMPANY A LIMITED PARTNERSHIP — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2018-11-19
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.805(a), 192.805(b).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520181008w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520181008w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520181008w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520181008W
**body:**

Warning Letter involving SOUTHWEST GAS TRANSMISSION COMPANY A LIMITED PARTNERSHIP. PHMSA's enforcement data identifies the cited regulations as 192.805(a),  192.805(b). The case was opened on 2018-11-19 and is reported as closed as of 2018-11-19. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520181008W_Operator Response to Notice_12202018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520181008W/520181008W_Operator%20Response%20to%20Notice_12202018.pdf

520181008W_Warning Letter_11192018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520181008W/520181008W_Warning%20Letter_11192018.pdf

520181008W_Warning Letter_11192018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520181008W/520181008W_Warning%20Letter_11192018_text.pdf

520181008W_Warning Letter_11192018_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
November 19, 2018
Mr. Jeffrey W. Shaw
Vice President of Regulation & Public Affairs
Southwest Gas Corporation
5241 Spring Mountain Road
P.O. Box 98510
Las Vegas, Nevada 89193-8510
CPF 5-2018-1008W
Dear Mr. Shaw:
On April 24 through 28, 2017, a representative of the Arizona Corporation Commission (ACC),
pursuant to Chapter 601 of 49 United States Code, inspected and reviewed records for Southwest
Gas Transmission Company’s (SGTC), an affiliate of Southwest Gas Corporation, pipeline. This
is a 9.5-mile, 20-inch interstate natural gas pipeline in Mohave County, Arizona. The pipeline
starts at a connection to El Paso Gas in Arizona and terminates at the Arizona-Nevada border
where a SGTC intrastate segment begins.
As a result of the inspection, it is alleged the following probable violation of the Pipeline Safety
Regulations, Title 49, Code of Federal Regulations (CFR) has been committed:
1. §192.805 Qualification program.
Each operator shall have and follow a written qualification program. The program
shall include provisions to:
(a) Identify covered tasks;
(b) Ensure through evaluation that individuals performing covered tasks are
qualified;
SGTC’s Operator Qualification (OQ) Program pursuant to its procedures and covered task list,
identified the Control Room Supervisor as being required to have the same covered task
qualifications as the Gas Control Technician. The OQ covered tasks for both the Control Room
Supervisor and the Gas Control Technician included SCADA Monitoring, Starting, Operating,



Shut Down, Alarm Management, Opening & Closing Valves, Abnormal Operating Conditions
and Communication Plan for Manual Operation.
The ACC representative reviewed the OQ records and discovered that the Control Room
Supervisor did not have the proper qualifications according to the procedures and covered task
list. During discussions with Control Room personnel, it was disclosed that the Control Room
Supervisors are not being OQ qualified on the covered tasks listed above. Based on this
information, SGTC was not following its OQ Program.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$209,002 per violation per day the violation persists, up to a maximum of $2,090,022 for a related
series of violations. For violations occurring prior to November 2, 2015, the maximum penalty
may not exceed $200,000 per violation per day, with a maximum penalty not to exceed
$2,000,000 for a related series of violations.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 5-2018-1008W. 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).
Sincerely,
Kim West
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 H.M. Flaherty (#161967)
James Lantto, Southwest Gas Corporation, Administrator/Compliance, Engineering
Service
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