# WESTGAS INTERSTATE, INC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 52025026NOPV
- **title:** WESTGAS INTERSTATE, INC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2025-07-29
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 192.739(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-52025026nopv.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-52025026nopv.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-52025026nopv
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/52025026NOPV
**body:**

Notice of Probable Violation involving WESTGAS INTERSTATE, INC. PHMSA's enforcement data identifies the cited regulation as 192.739(a). The case was opened on 2025-07-29 and is reported as closed as of 2026-05-01. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

52025026NOPV_Closure Letter_05012026_(24-297246).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025026NOPV/52025026NOPV_Closure%20Letter_05012026_(24-297246).pdf

52025026NOPV_Closure Letter_05012026_(24-297246)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025026NOPV/52025026NOPV_Closure%20Letter_05012026_(24-297246)_text.pdf

52025026NOPV_Final Order_10142025_(24-297246).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025026NOPV/52025026NOPV_Final%20Order_10142025_(24-297246).pdf

52025026NOPV_Final Order_10142025_(24-297246)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025026NOPV/52025026NOPV_Final%20Order_10142025_(24-297246)_text.pdf

52025026NOPV_Operator Response to Notice_09192025_(24-297246).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025026NOPV/52025026NOPV_Operator%20Response%20to%20Notice_09192025_(24-297246).pdf

52025026NOPV_PCO_07292025_(24-297246).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025026NOPV/52025026NOPV_PCO_07292025_(24-297246).pdf

52025026NOPV_PCO_07292025_(24-297246)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025026NOPV/52025026NOPV_PCO_07292025_(24-297246)_text.pdf

52025026NOPV_Closure Letter_05012026_(24-297246)_text.pdf

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety Administration
12300 West Dakota Avenue, Suite 340
Lakewood, Colorado 80228
VIA ELECTRONIC MAIL TO: Lauren.Gilliland@xcelenergy.com
May 1, 2026
Lauren Gilliland
Senior Vice President, Gas
WestGas InterState, Inc.
1800 Larimer St.
Denver, CO 80202
CPF 5-2025-026-NOPV
Closure Letter
Dear Ms. Gilliland:
On October 14, 2025, the Pipeline and Hazardous Materials Safety Administration (PHMSA)
issued to WestGas InterState, Inc. a Final Order. This Order included a Compliance Order.
Based on our review of the documentation you provided, it has been determined that you have
complied with the terms of this Order.
Accordingly, this case is now closed, and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
Dustin Hubbard
Director, Western Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 L. Salvador (24-297246)
Nathan Gonzales, Principal Engineer, nathan.a.gonzales@xcelenergy.com

52025026NOPV_Final Order_10142025_(24-297246)_text.pdf

October 14, 2025
VIA ELECTRONIC MAIL TO: Lauren.Gilliland@xcelenergy.com
Lauren Gilliland
Vice President, Gas
WestGas InterState, Inc.
1800 Larimer St.
Denver, CO 80202
Re: CPF No. 5-2025-026-NOPV
Dear Ms. Gilliland:
Enclosed please find the Final Order issued in the above-referenced case. It makes a finding of
violation and specifies actions that need to be taken to comply with the pipeline safety
regulations. When the terms of the compliance order are completed, as determined by the
Director, Western Region, this enforcement action will be closed. Service of the Final Order by
e-mail is effective upon the date of transmission and acknowledgement of receipt as provided
under 49 CFR § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Linda Daugherty
Acting Associate Administrator
for Pipeline Safety
Enclosures (Final Order and NOPV)
cc: Dustin Hubbard, Director, Western Region, Office of Pipeline Safety
Nathan Gonzales, Principal Engineer, Gas Standards, Xcel Energy,
Nathan.A.Gonzales@xcelenergy.com
CONFIRMATION OF RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
)
In the Matter of )
)
WestGas InterState, Inc., )
a subsidiary of Xcel Energy ) CPF No. 5-2025-026-NOPV
)
Respondent. )
____________________________________)
FINAL ORDER
On July 29, 2025, pursuant to 49 CFR § 190.207, the Director, Western Region, Office of
Pipeline Safety (OPS), issued a Notice of Probable Violation (Notice) to WestGas InterState, Inc.
(Respondent). The Notice proposed finding that Respondent had violated the pipeline safety
regulations in 49 CFR Part 192. The Notice also proposed certain measures to correct the
violations. Respondent did not contest the allegations of violation or corrective measures.
Based upon a review of all of the evidence, pursuant to § 190.213, I find Respondent violated the
pipeline safety regulations listed below, as more fully described in the enclosed Notice, which is
incorporated by reference:
49 CFR § 192.739(a) (Item 1) ─ Respondent failed to inspect and test its pressure
limiting devices to determine if they were in good mechanical condition, adequate
from the standpoint of capacity and reliability of operation for the service in
which it is employed, and properly installed and protected.
This finding of violation will be considered a prior offense in any subsequent enforcement action
taken against Respondent.
Compliance Actions
Pursuant to 49 U.S.C. § 60118(b) and 49 CFR § 190.217, Respondent is ordered to take the
actions proposed in the enclosed Notice to correct the violation. The Director may grant an
extension of time to comply with any of the required items upon a written request timely
submitted by the Respondent and demonstrating good cause for an extension. Upon completion
of the ordered actions, Respondent may request that the Director close the case. Failure to
comply with this Order may result in the assessment of civil penalties under 49 CFR § 190.223



or in referral to the Attorney General for appropriate relief in a district court of the United States.
The terms and conditions of this order are effective upon service in accordance with 49 CFR
§ 190.5.
___________________________________ _________________________
Linda Daugherty Date Issued
Acting Associate Administrator
for Pipeline Safety



NOTICE OF PROBABLE VIOLATION
and
PROPOSED COMPLIANCE ORDER
VIA ELECTRONIC MAIL TO: Lauren.Gilliland@xcelenergy.com
July 29, 2025
Ms. Lauren Gilliland
VP Gas Operations
Westgas Interstate, Inc.
1800 Larimer St.
Denver, CO 80202
CPF 5-2025-026-NOPV
Dear Ms. Gilliland:
From October 28, 2024 to October 31, 2024, representatives of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter
601 of 49 United States Code (U.S.C.) inspected Westgas Interstate, Inc.’s (Westgas) natural gas
system in northern Colorado and southern Wyoming.
As a result of the inspection, it is alleged that Westgas has committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected
and the probable violations are:
1. § 192.739 Pressure limiting and regulating stations: Inspection and testing.
(a) Each pressure limiting station, relief device (except rupture discs), and pressure
regulating station and its equipment must be subjected at intervals not exceeding 15
months, but at least once each calendar year, to inspections and tests to determine
that it is--
(1) In good mechanical condition;



(2) Adequate from the standpoint of capacity and reliability of operation for the
service in which it is employed;
(3) Except as provided in paragraph (b) of this section, set to control or relieve at
the correct pressure consistent with the pressure limits of § 192.201(a); and
(4) Properly installed and protected from dirt, liquids, or other conditions that
might prevent proper operation.
Westgas failed to inspect and test its pressure limiting devices at least once a calendar year, at
intervals not to exceed 15 months, to determine if they are in good mechanical condition,
adequate from the standpoint of capacity and reliability of operation for the service in which they
are employed, set to control or relieve at the correct pressure consistent with the pressure limits
of § 192.201(a), and properly installed and protected from dirt, liquids, or other conditions that
might prevent proper operation as required. Specifically, during inspection, Westgas could not
establish through documentation that it had inspected the pressure limiting slam-shut valves at
the Chalk Bluff station for the calendar years of 2020, 2021, 2022, 2023 and 2024.
Section 192.739(a) requires operators to inspect each pressure limiting station, relief device, and
pressure regulating station and its equipment each calendar year at intervals not exceeding 15
months. However, during the inspection Westgas could not provide to the PHMSA inspectors
any records such as inspection reports, test results, or other documentation to demonstrate that
the required inspections and tests had been conducted during the calendar years of 2020, 2021,
2022, 2023, and 2024.
In addition, during the inspection, the PHMSA inspectors asked the Westgas personnel to
conduct a test of the slam-shut valves at the Chalk Bluff station. It was noted that the Westgas
system’s MAOP is 1000 psig with the slam-shut valves set to close at 950 psig. During the field
test, the valves were found to not be in reliable working condition as one valve failed to close
and the other closed at 1040 psig.
Therefore, Westgas failed to inspect and test its pressure limiting devices to determine if they
were in good mechanical condition, of adequate capacity, and in reliable operating condition, as
required by § 192.739(a).
Proposed Civil Penalty
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a
related series of violations. For violation occurring on or after December 28, 2023 and before
December 30, 2024, the maximum penalty may not exceed $266,015 per violation per day the
violation persists, up to a maximum of $2,660,135 for a related series of violations. For violation
occurring on or after January 6, 2023 and before December 28, 2023, the maximum penalty may
not exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627
for a related series of violations. For violation occurring on or after March 21, 2022 and before
January 6, 2023, the maximum penalty may not exceed $239,142 per violation per day the
violation persists, up to a maximum of $2,391,412 for a related series of violations. For violation
occurring on or after May 3, 2021 and before March 21, 2022, the maximum penalty may not



exceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for
a related series of violations. For violation occurring on or after January 11, 2021 and before
May 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation
persists, up to a maximum of $2,225,034 for a related series of violations. For violation
occurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not
exceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for
a related series of violations.
We have reviewed the circumstances and supporting documents involved in this case and have
decided not to propose a civil penalty assessment at this time.
Proposed Compliance Order
With respect to Item 1 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials
Safety Administration proposes to issue a Compliance Order to Westgas. Please refer to the
Proposed Compliance Order, which is enclosed and made a part of this Notice.
Response to this Notice
Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators
in Enforcement Proceedings. Please refer to this document and note the response options. All
material you submit in response to this enforcement action may be 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 your receipt of this Notice, you have 30 days to respond as described in the enclosed
Response Options. If you do not respond within 30 days of receipt of this Notice, this constitutes
a waiver of your right to contest the allegations in this Notice and authorizes the Associate
Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to
you and to issue a Final Order. If you are responding to this Notice, we propose that you submit
your correspondence to my office within 30 days from receipt of this Notice. The Region
Director may extend the period for responding upon a written request timely submitted
demonstrating good cause for an extension.
In your correspondence on this matter, please refer to CPF 5-2025-026-NOPV and, for each
document you submit, please provide a copy in electronic format whenever possible.



Sincerely,
Dustin Hubbard
Director, Western Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 L. Salvador (#24-297246)
Mr. Nathan Gonzales, Senior Engineer - Nathan.A.Gonzales@xcelenergy.com
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Enforcement Proceedings



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Westgas Interstate, Inc. (Westgas) a Compliance
Order incorporating the following remedial requirements to ensure the compliance of Westgas
with the pipeline safety regulations:
A. B. In regard to Item 1 of the Notice pertaining to the annual inspection of each
pressure limiting station, relief device, and pressure regulating station and its
equipment, Westgas must inspect and test, and repair if necessary, the two slam-
shut valves intended to protect against accidental over pressuring at the Chalk
Bluff station to determine that they are in good mechanical condition, adequate
from the standpoint of capacity and reliability of operation for the service in
which they are employed, set to control at the correct pressure consistent with the
pressure limits of § 192.201(a), and properly installed and protected from dirt,
liquids, or other conditions that might prevent proper operation, and send
documentation of the completed inspection and testing, including any required
repairs, to the Director, Western Region within 60 days of receipt of the Final
Order.
It is requested (not mandated) that Westgas maintain documentation of the safety
improvement costs associated with fulfilling this Compliance Order and submit
the total to Dustin Hubbard, Director, Western Region, Pipeline and Hazardous
Materials Safety Administration. It is requested that these costs be reported in
two categories: 1) total cost associated with preparation/revision of plans,
procedures, studies and analyses, and 2) total cost associated with replacements,
additions and other changes to pipeline infrastructure.
- **truncated:** false
- **body characters:** 15541
