{"operation":"document","citation":"CPF 52026003WL","title":"CONTANGO RESCOURCES — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2026-03-19","effective_on":null,"summary":"CLOSED warning letter citing 194.101(a), 195.402(a), 195.64(c)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52026003wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52026003wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52026003wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52026003WL","body":"Warning Letter involving CONTANGO RESCOURCES. PHMSA's enforcement data identifies the cited regulations as 194.101(a),  195.402(a),  195.64(c)(2). The case was opened on 2026-03-19 and is reported as closed as of 2026-03-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52026003WL_Warning Letter_03192026_(25-329418).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52026003WL/52026003WL_Warning%20Letter_03192026_(25-329418).pdf\n\n52026003WL_Warning Letter_03192026_(25-329418)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52026003WL/52026003WL_Warning%20Letter_03192026_(25-329418)_text.pdf\n\n52026003WL_Warning Letter_03192026_(25-329418)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n12300 W. Dakota Ave., Suite 340\nLakewood, CO 80228\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: greg.westfall@contango.com\nMarch 19, 2026\nMr. Greg Westfall\nDirector\nContango Resources\n1717 South Boulder, Suite 900\nTulsa, OK 74119\nCPF 5-2026-003-WL\nDear Mr. Westfall:\nFrom September 22 through September 25, 2025 representatives of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code, (U.S.C.) inspected Contango Resource’s (Contango) Wamsutter Crude System in\nWamsutter, Wyoming.\nAs a result of the inspection, it is alleged that Contango has committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall be\nreviewed at intervals not exceeding 15 months, but at least once each calendar year,\nand appropriate changes made as necessary to ensure that the manual is effective.\nThis manual shall be prepared before initial operations of a pipeline system\ncommence, and appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\n\n\n\nContango failed to have a written manual of procedures for conducting normal operations and\nmaintenance activities and handling abnormal operations and emergencies, as required.\nSpecifically, during the PHMSA inspection, Contango was unable to provide its step-by-step\noperating procedures for any covered task specific to the pipeline system, as defined per\n§ 195.501(b), such as how to close a block valve during normal operations or emergencies.\nPHMSA reviewed Contango’s operations and maintenance manual (O&M) during the PHMSA\ninspection which cross referenced Standard Operating Procedures (SOPs) specific to the\nWamsutter Pipeline System. The O&M also noted that the SOPs manual was located at the\nWamsutter, Wyoming Field Operations Office. However, when asked, Contango was unable to\nprovide the SOPs for review.\nTherefore, Contango failed to prepare and follow a manual of written procedures for normal\noperations, maintenance activities, abnormal operating conditions and emergencies in\naccordance with § 195.402(a).\n2. § 194.101 Operators required to submit plans.\n(a) Except as provided in paragraph (b) of this section, unless OPS grants a request\nfrom a Federal On-Scene Coordinator (FOSC) to require an operator of a pipeline\nin paragraph (b) to submit a response plan, each operator of an onshore pipeline\nfacility shall prepare and submit a response plan to PHMSA as provided in\n§ 194.119. A pipeline which does not meet the criteria for significant and substantial\nharm as defined in § 194.103(c) and is not eligible for an exception under\n§ 194.101(b), can be expected to cause substantial harm. Operators of substantial\nharm pipeline facilities must prepare and submit plans to PHMSA for review.\nContango failed to submit a response plan to PHMSA as provided in § 194.119. Specifically,\nduring inspection, Contango was unable to provide the PHMSA inspector a copy of its response\nplan or any proof a response plan had been prepared and submitted to PHMSA for approval in\naccordance with § 194.119, as required. Further, the exception for not preparing and submitting\na response plan to PHMSA, as described per § 194.101(b), did not apply to the Wamsutter Crude\nSystem because the system consists of approximately 26 miles of 6-inch pipe and 6.1 miles of 8-\ninch pipe.\nTherefore, Contango failed to prepare a response plan that was reviewed and approved by\nPHMSA in accordance with § 194.101(a).\n3. § 195.64 National Registry of Operators.\n(a) …\n(c) Changes. Each operator must notify PHMSA electronically through the\nNational Registry of Operators at https://portal.phmsa.dot.gov, of certain events.\n(1) …\n(2) An operator must notify PHMSA of any following event not later than 60 days\nafter the event occurs:\n2\n\n\n\n(i) A change in the primary entity responsible (i.e., with an assigned OPID) for\nmanaging or administering a safety program required by this part covering\npipeline facilities operated under multiple OPIDs.\n(ii) A change in the name of the operator;\n(iii) A change in the entity (e.g., company, municipality) responsible for operating\nan existing pipeline, pipeline segment, or pipeline facility;\n(iv) The acquisition or divestiture of 50 or more miles of pipeline or pipeline system\nsubject to this part; or\n(v) The acquisition or divestiture of an existing pipeline facility subject to this part.\nContango failed to notify PHMSA of an acquisition of an existing pipeline facility subject to this\npart within 60 days, as required. Specifically, Western Midstream Partners, the prior owners of\nthe Wamsutter Crude System, submitted a divestiture notification to PHMSA on August 13,\n2024 with an effective date of July 31, 2024. However, Contango did not notify PHMSA it had\ntaken responsibility of the system. Rather, PHMSA learned of Contango’s acquisition seven\nmonths later on March 25, 2025 when a PHMSA representative spoke with Contango’s\nDepartment of Transportation compliance point of contact who verified the acquisition.\nTherefore, Contango failed to notify PHMSA of its acquisition of an existing pipeline facility\nsubject to Part 195 no later than 60 days after the event occurred.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a\nrelated series of violations. For violation occurring on or after December 28, 2023 and before\nDecember 30, 2024, the maximum penalty may not exceed $266,015 per violation per day the\nviolation persists, up to a maximum of $2,660,135 for a related series of violations. For violation\noccurring on or after January 6, 2023 and before December 28, 2023, the maximum penalty may\nnot exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627\nfor a related series of violations. For violation occurring on or after March 21, 2022 and before\nJanuary 6, 2023, the maximum penalty may not exceed $239,142 per violation per day the\nviolation persists, up to a maximum of $2,391,142 for a related series of violations. For violation\noccurring on or after May 3, 2021 and before March 21, 2022, the maximum penalty may not\nexceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for\na related series of violations. For violation occurring on or after January 11, 2021 and before\nMay 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation\npersists, up to a maximum of $2,225,034 for a related series of violations. For violation\noccurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not\nexceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for\na related series of violations.\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 items identified in this letter. Failure to do so will result in\nContango being subject to additional enforcement action.\n3\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2026-003-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\nthe redacted information qualifies for confidential treatment under 5 U.S.C. § 552(b).\nSincerely,\nDustin Hubbard\nDirector, Western Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 E. Ballado (25-329418)\nRandy Schrinar, Contango Resources, Pipeline Manager, randy.schrinar@contango.com\n4","truncated":false,"body_characters":9313}