West Texas Gas Distribution Pipeline IMP 2012 6-22-12

West Texas Gas
Gas Distribution Pipeline Integrity Management

Program

June 22, 2012

Revision 1

2
WEST TEXAS GAS
GAS DISTRIBUTION PIPELINE INTEGRITY MANAGEMENT PROGRAM
TABLE OF CONTENTS

1 - SECTION 1 - REVISION LOG ................................................................................................................... 4
2 - SECTION 2 - INTRODUCTION .................................................................................................................. 5
2.1. The Federal Integrity Management Rule ..................................................................................... 5
2.2. Pipelines Operated by West Texas Gas ...................................................................................... 5
2.3. Terms as Used In the IMP ........................................................................................................... 5
3 - SECTION 3 - WEST TEXAS GAS DISTRIBUTION PIPELINE INTEGRITY MANAGEMENT PROGRAM................... 6
3.1. Overview of West Texas Gas Program ....................................................................................... 6
4 - SECTION 4 - KNOWLEDGE ..................................................................................................................... 7
4.1. Regulation ................................................................................................................................... 7
4.2. System Knowledge ...................................................................................................................... 7
4.3. Updates ....................................................................................................................................... 7
4.4. DOT Annual Report ..................................................................................................................... 8
4.5. Annual Review............................................................................................................................. 8
5 - SECTION 5 - THREAT IDENTIFICATION PLAN ............................................................................................ 9
5.1. Regulation ................................................................................................................................... 9
5.2. Threat Factors ............................................................................................................................. 9
5.3. Threat Factor Information ............................................................................................................ 9
5.4. Threat Identification by System ................................................................................................... 9
6 - SECTION 6 - RISK ANALYSIS PROCESS AND RISK FACTORS ................................................................... 10
6.1. Regulation ................................................................................................................................. 10
6.2. Process ..................................................................................................................................... 10
6.3. Risk Determination .................................................................................................................... 12
6.4. Regions ..................................................................................................................................... 12
6.5. Validation of Results .................................................................................................................. 12
6.6. Pipeline Threats with Associated Threat Factors....................................................................... 13
6.7. Consequence Factors ............................................................................................................... 16
7 - SECTION 7 - ADDITIONAL AND ACCELERATED ACTIONS ......................................................................... 17
7.1. Regulation ................................................................................................................................. 17
7.2. Process for the Identification and Evaluation of New Measures for Line Pipe ........................... 17
7.3. Leak Management Program ...................................................................................................... 20
7.4. West Texas Gas Distribution Pipelines Located in Texas ......................................................... 20
7.5. Mechanical Fitting Failure Regulation ........................................................................................ 21
8 - SECTION 8 - PERFORMANCE PLAN....................................................................................................... 22
8.1. Regulation ................................................................................................................................. 22
8.2. Introduction ................................................................................................................................ 22
8.3. System Specific ......................................................................................................................... 22
9 - SECTION 9 - PERIODIC EVALUATION AND IMPROVEMENT ....................................................................... 23
9.1. Regulation ................................................................................................................................. 23
9.2. Audits ........................................................................................................................................ 23
3
9.3. Improvements ............................................................................................................................ 23
9.4. Metrics Review .......................................................................................................................... 24
9.5. Communication of Results ......................................................................................................... 24
10 - SECTION 10 - RESULTS REPORTING .................................................................................................. 25
10.1. Regulation ............................................................................................................................... 25
10.2. Review Process for Plan Effectiveness ................................................................................... 25
10.3. Performance Measures Submittal to PHMSA and appropriate State Regulatory Agency ....... 25
11 - SECTION 11 - COMMUNICATIONS PLAN .............................................................................................. 26
11.1. External Communications ........................................................................................................ 26
11.2. Safety Concerns ...................................................................................................................... 26
11.3. Internal Communications ......................................................................................................... 26
11.4. External Communications ........................................................................................................ 26
12 - APPENDIX A - PIPELINE INFORMATION................................................................................................ 27
13 - APPENDIX B - SUMMARY AND RISK ANALYSES .................................................................................... 28
14 - APPENDIX C - INFORMATION GATHERING FORM ................................................................................. 29
15 - APPENDIX D - PERFORMANCE METRIC INFORMATION GATHERING FORM .............................................. 30
16 - APPENDIX E - EVALUATION OF A/A ACTIONS ...................................................................................... 35
17 - APPENDIX F - STEEL SERVICE LINE REPLACEMENT ............................................................................ 41
18 - APPENDIX G - MAINLINE STEEL REPLACEMENT .................................................................................. 43

4
WEST TEXAS GAS
GAS DISTRIBUTION PIPELINE INTEGRITY MANAGEMENT PROGRAM

1 - Section 1 - Revision Log
REVISION
NUMBER
REVISION
DATE
REVISION SUMMARY
0 July 14, 2011 New Gas Distribution Pipeline Integrity Management Program
1 June 22, 2012 Minor revisions to 4.3 Updates, 6.2.1.1 Records Retention, 9.4 Metrics Review
and Appendix E Evaluation of A/A Actions
5
2 - Section 2 - Introduction
2.1. The Federal Integrity Management Rule
The Department of Transportation/Pipeline and Hazardous Materials Safety Administration
(DOT/PHMSA) issued a new Subpart P to 192 titled Gas Distribution Pipeline Integrity Management
(DIMP) on December 4, 2009. The latest amended version of Subpart P was issued on February 1, 2011.
The Rule specifies regulations for identifying threats, evaluating risk, implementing measures to address
risk, measure performance, monitor results, and evaluate effectiveness.
Operators are required to develop and implement a gas distribution integrity management plan no later
than August 2, 2011.
2.2. Pipelines Operated by West Texas Gas
West Texas Gas (WTG) operates approximately 485 gas distribution systems in Texas and Oklahoma
totaling over 5000 miles. The systems consist of steel and plastic (ABS, PVC, and PE) and range in size
from less than 2 to 22.
2.3. Terms as Used In the IMP
Terms as used in West Texas Gas Integrity Management Program, e.g. Hazardous Leak, are as defined
or described in 192, the Texas Administrative Code, and the West Texas Gas Operations and
Maintenance Manual.
The Integrity Management Department consists of the Director of Integrity Management and the Pipeline
Integrity Specialist.
6
3 - Section 3 - West Texas Gas Distribution Pipeline Integrity Management Program
3.1. Overview of West Texas Gas Program
WTG is preparing its Program based on the requirements described in Subpart P. As such, it contains the
following sections:
Distribution
Integrity
Management
Program Elements

Periodic Evaluation
and Improvement
Section 9
Results Reporting
Section 10
Communications
Plan
Section 10
Knowledge
Section 4
Threat Identification
Plan
Section 5
Additional and
Accelerated Actions
Section 7
Performance Plan
Section 8
Risk Analysis
Process and Risk
Factors
Section 6
Task
Knowledge

Task
Additional or
Accelerated Actions

Task
Administration

Appendix A
Pipeline
Information
Appendix B
Summary and Risk
Analyses
Appendix D
Performance Metric
Information
Gathering Form
Appendix E
Evaluation of A/A
Actions
Appendix C
Information
Gathering Form
Revision Log
Section 1
Appendix F
Steel Service Line
Replacement
Appendix G
Mainline Steel
Replacement

7
4 - Section 4 - Knowledge
4.1. Regulation
49 CFR 192.1007(a)
(a) Knowledge. An operator must demonstrate an understanding of its gas distribution system
developed from reasonably available information.
1) Identify the characteristics of the pipeline's design and operations and the environmental
factors that are necessary to assess the applicable threats and risks to its gas distribution
pipeline.
2) Consider the information gained from past design, operations, and maintenance.
3) Identify additional information needed and provide a plan for gaining that information over
time through normal activities conducted on the pipeline (for example, design, construction,
operations or maintenance activities).
4) Develop and implement a process by which the IM program will be reviewed periodically and
refined and improved as needed.
5) Provide for the capture and retention of data on any new pipeline installed. The data must
include, at a minimum, the location where the new pipeline is installed and the material of
which it is constructed.
4.2. System Knowledge
Knowledge of a distribution system can be defined as information, such as the materials and type of
construction, the operating conditions of the pipe or facility, and other relevant factors within the
surroundings in which the system operates. This knowledge of the system will help identify the threats to
the system and establish which systems or segments should be subject to a risk evaluation.
4.2.1. Data Gathering
In order to develop an accurate risk assessment of each system, WTG collects data from the following
types of sources:
1. Paper records.
2. Electronic records.
3. Interviews with field personnel.
4. Field observations and research.
Data from the above sources are compiled into a master spreadsheet which serves as the reference for
risk assessment and segment performance assessments.
4.2.2. Missing Data
Where paper or electronic records are not available, WTG shall make use of Subject Matter Experts
(SMEs) or reasonable and carefully considered deductions. These deductions will become part of the
system knowledge until better information may be obtained through design, construction, operations or
maintenance activities.
4.3. Updates
During the course of operating or maintaining a distribution system, additional information will become
available, including pipe and risk factor data. Field personnel should be trained to recognize potentially
useful pipe or risk data during their daily activities. This data shall be reported to the Integrity
Management Department for inclusion in the plan and related risk assessments. The minimum
information that should be recorded each time a segment is serviced or repaired is as follows:
8
1. Location.
2. Pipe type.
3. Pipe size.
Data discovered in the field may become part of a leak report or other maintenance work order. In this
case, notification shall be made to the Integrity Management Department of the additional system
knowledge. Field personnel should carefully complete the necessary forms and documentation for the
work being performed. Updates to system knowledge may be made from the collected data.
Each time a pipeline is exposed, WTG Form 1100 should be filled out to document the condition of the
pipe. A check box is included in this form to verify if the DIMP data currently being used is correct. If the
DIMP data is incorrect, the form will be sent to the Integrity Management Department with the corrected
data in order to update the DIMP risk model and associated databases.
Each time a new pipe line is installed, the Project Report Form WTG-1400 will be filled out to document
pipe material, size, manufacturer, year manufactured, grade, material designation code, pipe category,
wall thickness and test pressure. WTG-1400 along with shape files showing the exact location will be
submitted to the Integrity Management Department for processing and installation into GIS mapping.
4.4. DOT Annual Report
PHMSA Form 7100.1-1, Gas Distribution System Annual Report, contains the basis of WTGs system
knowledge. Form 7100.1-1 is also a source of historical system information. Before data from the annual
report is used as system knowledge, it must be verified as current and accurate by the Integrity
Management Department.
PHMSA Form 7100.1-1 may also be used as a source of information for past design, operations and
maintenance decisions. The Integrity Management Department shall review historical filings for trends
relating to segment risk and incorporate this information into the body of system knowledge.
4.5. Annual Review
At least once per calendar year, at intervals not to exceed 15 months, the Integrity Management
Department shall review this program for consistency with 49 CFR 192 Subpart P and for necessary
updates to system and threat information. The program review shall be documented and retained
according to 49 CFR 192.1011. The annual program review shall include interviews with field personnel
and other SMEs to verify the completeness of data derived from operations and maintenance reports.
Section 10.2 further details the requirements of this report.
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5 - Section 5 - Threat Identification Plan
5.1. Regulation
49 CFR 192.1007(b)
(b) Identify threats. The operator must consider the following categories of threats to each gas
distribution pipeline: corrosion, natural forces, excavation damage, other outside force damage,
material or welds, equipment failure, incorrect operations, and other concerns that could threaten
the integrity of its pipeline. An operator must consider reasonably available information to identify
existing and potential threats. Sources of data may include, but are not limited to, incident and
leak history, corrosion control records, continuing surveillance records, patrolling records,
maintenance history, and excavation damage experience.
5.2. Threat Factors
Threat factors used in the Risk Analysis are listed in Section 6.6.
5.3. Threat Factor Information
The specific threat factor information used in the Threat Identification process is located in Appendix A.
The Integrity Management Department reviews and updates this information annually per Section 6.2.5.
If sufficient information is unavailable or is considered unreliable by the Integrity Management Department
for a particular threat factor, the Integrity Management Department with assistance from the SME of that
specific discipline will either identify that particular threat factor as unknown which scores at the highest
possible value or make a conservative, but realistic, estimate for that information element. The Integrity
Management Department will document the use of all estimated information elements in the Risk Analysis
for that particular segment.
For potential for frost action and corrosive properties of soil data, WTG utilizes information published on
the USDAs National Resources Conservation Services website.
Earthquake faults and acceleration data is obtained from the USGS.
5.4. Threat Identification by System
5.4.1. Process
The Integrity Management Department uses the process contained in Section 6 and the risk model
contained in Appendix B to determine the risk score for each system and the associated Threat Severity
Index.
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6 - Section 6 - Risk Analysis Process and Risk Factors
6.1. Regulation
49 CFR 192.1007(c)
(c) Evaluate and rank risk. An operator must evaluate the risks associated with its distribution
pipeline. In this evaluation, the operator must determine the relative importance of each threat
and estimate and rank the risks posed to its pipeline. This evaluation must consider each
applicable current and potential threat, the likelihood of failure associated with each threat, and
the potential consequences of such a failure. An operator may subdi vide its pipeline into regions
with similar characteristics (e.g., contiguous areas within a distribution pipeline consisting of
mains, services and other appurtenances; areas with common materials or environmental
factors), and for which similar actions likely would be effective in reducing risk.
6.2. Process
This Section describes the use of the relative risk model to evaluate the relative risk posed by each
System, in order to determine the highest priority pipeline segments for use in the Additional and
Accelerated Actions evaluation. Risk is defined as the: Likelihood of Failure times the Consequences of
Failure.
6.2.1. Information Sources
The Integrity Management Department utilized sources such as leak history, corrosion records,
continuing surveillance records, patrolling records, maintenance history, excavation damage experience,
and SME knowledge for initial gathering of threat and consequence related information. The current
information is found in Appendix A and is updated annually per Section 6.2.5.
6.2.1.1. Records Retention
All WTG records that pertain to DIMP will be maintained as required by 192 and the West Texas Gas
O&M Manual. In addition, all DIMP related records must be maintained for at least ten years even if 192
or the West Texas Gas O&M Manual requires less. This will include any superseded revision to this plan.
The Integrity Management Department will be contacted prior to the purging process of all DIMP related
records.
6.2.2. Threats
Probability of Failure is a function of the Threats to a pipelines integrity. Threats to a pipelines integrity
are listed in eight categories. WTG may add additional threat categories in the Other category if
conditions warrant such an addition.
1. Corrosion.
2. Natural forces.
3. Excavation Damage.
4. Other outside force damage.
5. Material of weld failure.
6. Equipment failure.
7. Incorrect operation.
8. Other.
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6.2.3. Threat Severity Index
Each Threat category has numerous factors with which to evaluate the particular pipeline/segments
threat level. The factors are evaluated using a scoring system
1
and the ratings are then summed for each
category to arrive at a raw Threat number. This raw number is normalized by dividing the sum of the
threat scores by the maximum possible threat scores. This number is called the Threat Severity Index.
The Threat Severity Index is established based on guidance found in Criteria and Risk Assessment
sections of ASME B31.8S-2010 Appendix A.
6.2.4. Significant Threats
If the Threat Severity Index is > 67%, that particular threat is deemed to be a Significant Threat and A/A
actions will be considered for that segment.
The Threat Severity Index (TSI) is calculated with the following formula.
TSI = [total risk score points from risk model minus number of risk factors]/[4*number of risk factors]
This methodology is explained as follows.
1. Each threat factor can be scored with a range from a minimum value of 1 to a maximum value of
5. Consequently, there is a scoring range of 4 for each threat factor.
2. Each threat factor is scored appropriately and the individual threat factor scores are summed to
determine the total threat score.
3. Similarly for each threat, e.g. corrosion, the maximum number of points that can possibly be
scored is 4 (range from 1 to 5) times the number of threat factors.
4. For example, if there are fourteen threats in a threat category and total points scored for that
threat is 52, the TSI is 68% by the following calculation; [52-14]/[4*14].
6.2.5. Threat Weighting
The threat sum score is then divided by the number of criteria in each Threat category. This normalized
number is then multiplied by a rating factor for that particular Threat. This yields a series of weighted
Threat category numbers that are summed to determine the Likelihood of Failure for a particular System.
Systems with multiple pipe material types, sizes, or other factors are ranked by their individual Segments
and then averaged to get a System total.
The SME Team meets annually to update the risk analysis using sources of information listed in Section
6.2.1 and establish the weighting factors for the risk model. The SME Team includes the Integrity
Management Department, field personnel, and other SMEs as needed. The SME Team uses historical
failure records, operating experience and available design information to define the relative risk hierarchy
and weighting factors.
The following table shows the threat weighting results for 2011.
2011 THREAT WEIGHTING
THREAT
THREAT WEIGHTING FOR STEEL
SYSTEMS
THREAT WEIGHTING FOR NON-
METALLIC SYSTEMS
Corrosion 20% 0%
___________________________
1
1 being the least threatening condition and 5 being the most threatening condition.
12
2011 THREAT WEIGHTING
THREAT
THREAT WEIGHTING FOR STEEL
SYSTEMS
THREAT WEIGHTING FOR NON-
METALLIC SYSTEMS
Natural Forces 10% 15%
Excavation Damage 25% 30%
Other Outside Forces 20% 25%
Material or Weld 10% 15%
Equipment 6% 6%
Incorrect Operations 6% 6%
Other 3% 3%

6.2.6. Consequence of Failure
Consequence of Failure is a function of the severity of a release. In this case, ten factors found in the
Consequences section of the Risk Analysis are evaluated to determine the consequence of a release
from any West Texas Gas distribution segment.
6.3. Risk Determination
The Risk for each Covered Segment is determined by multiplying the Likelihood of Failure by the
Consequences of Failure. These numbers for each segment are found in Appendix B.
6.4. Regions
Regions can be defined as a method of subdividing pipeline Systems into areas with similar
characteristics (e.g., contiguous areas within a distribution pipeline consisting of mains, services, and
other appurtenances; areas with common material or environmental factors), and for which similar A/A
actions likely would be effective in reducing risk. The WTG risk results can be subdivided in a multitude of
ways. First, risk is looked at on a System basis. This can be narrowed down to an individual Segment risk
within each System to further identify what is driving the risk. Each System can also be narrowed down by
material type, size, or other similar characteristic to further define the region if needed.
6.5. Validation of Results
The information used to fill out each individual threat factor is obtained from electronic records, paper
records, SMEs, or a combination of these as described in Section 4.2.1 and Section 4.2.2. The
information source for each threat factor is identified in the risk model. Upon completion of a new Risk
Analysis, the results shall be validated by a person or persons qualified to validate the results. The
validation process will focus mainly on information from SMEs. Information from paper and electronic
sources are checked for accuracy and completeness before being input into the risk model. The
individuals validating the results must have the following minimum qualifications.
1. Minimum two years engineering, operating or maintenance experience with WTG.
2. Minimum five years experience in pipeline engineering, operating or maintenance.
3. Thorough knowledge of 192 with particular emphasis on Subpart P.
13
4. Detailed knowledge of the WTG DIMP Program.
5. Thorough knowledge of the principles of risk management.
6. Detailed knowledge of the WTG risk model and ability to interpret results produced by the model.
7. Ability to communicate results shown by the risk model to other WTG personnel including
management.
6.6. Pipeline Threats with Associated Threat Factors
CORROSION
Coating
Liquids on the system
Number of Mainline CP readings not within spec
Percentage of Grade 1 Corrosion Leaks
Corrosion A/A Actions
NATURAL FORCES
River or Stream Crossing
Frost Heave Susceptibility
Earthquake Fault Zone
Soil Type
Percentage of Grade 1 Natural Force Leaks
Natural Force A/A Actions
EXCAVATION DAMAGE
One Call Activity
Number of 1
st
Party Damage that did not result in a leak
Number of 2
nd
14
Number of 3
rd
Number of 1
st
Party Damage that resulted in a leak
Number of 2
nd
Number of 3
rd
Mapping Quality
Percentage of non-metallic system with tracer wire
Percentage of Grade 1 Excavation Damage Leaks
Excavation Damage A/A Actions
OTHER OUTSIDE FORCES
Number of shallow sections excluding identified patrol points
Percentage of Grade 1 Other Outside Force Leaks
Other Outside Force A/A Actions
MATERIAL OR WELD FAILURE
Pipe material
Pipe size for main lines
Decade Installed
Manufacturing defects
Mechanical damage failures
Percentage of Grade 1 Material or Weld Leaks
15
Material or Weld A/A Actions
EQUIPMENT MALFUNCTION
PCV Failures
PRV Failures
Odorant Failures
Percentage of Grade 1 Equipment Malfunction Leaks
Equipment Malfunction A/A Actions
INCORRECT OPERATION
Incorrect operations or inadequate procedure failures
Percentage of Grade 1 Incorrect Operation Leaks
Incorrect Operation A/A Actions
OTHER
Other Failures
Line loss percentage for previous 12 months
Percentage of Grade 1 Other Leaks
Other A/A Actions

16
6.7. Consequence Factors
CONSEQUENCES
Business District
Residential Area
Number of Irrigation Services
Number of City Commercial and Public Authority Services
Number of Rural Commercial and Public Authority Services
Number of Rural Domestic Services
Number of City (Municipal) Services
Significant Services Affected (facilities that would be difficult to evacuate, e.g. hospital, day care, etc.)
Home or Business Dwellings Intended for Human Occupancy
Operating Pressure

17
7 - Section 7 - Additional and Accelerated Actions
7.1. Regulation
49 CFR 192.1007(d)
(d) Identify and implement measures to address risks. Determine and implement measures designed
to reduce the risks from failure of its gas distribution pipeline. These measures must include an
effective leak management program (unless all leaks are repaired when found).
7.2. Process for the Identification and Evaluation of New Measures for Line Pipe
The Integrity Management Department will evaluate each System within twelve months of completing a
risk evaluation for the possible implementation of Additional and Accelerated (A/A) actions.
The Integrity Management Department will use the form in Appendix E to facilitate the evaluation of new
A/A actions.
The Integrity Management Department will review the individual Threat and Consequence scores for
each System. Within each System, the Integrity Management Department will identify each threat factor
having the maximum score of five and each System having an individual Threat Severity Index
2
score
67%.
The Integrity Management Department will then review those Systems for possible application of A/A
actions in order to reduce the individual threat factor scores and the Threat Severity Index score.
The Integrity Management Department will develop a specific A/A action plan for the system/segment that
requires A/A actions. This plan will include A/A actions, implementation dates, responsibilities, expected
outcome, measurement and management approval. Management approval will consist of VP, Operations
Manager, District Manager and Integrity Management Department.
The following table provides examples of A/A action to be considered. WTG may implement one or more
of these examples in order to address the threats to each System. The examples given are not intended
to rule out any other reasonable action that WTG may select to reduce the risk of a System.
THREATS
EXAMPLES OF POSSIBLE A/A ACTIONS
PRIMARY SUBCATEGORY
CORROSION
External corrosion
Bare steel pipe (CP)
Bare steel pipe (No CP)
Wrapped steel pipe (CP)
Wrapped steel pipe (No CP)
CI pipe (Graphitization)
Increase frequency of leak surveys.
Replace, insert or rehab.
Provide hot spot protection (e.g., install
anodes at anodic locations).
Correct cathodic protection
deficiencies.
Internal corrosion
Install drips.
Install pipe liner.
Install moisture removal or control
equipment.
Evaluate gas supply inputs and take
corrective action with supplier.
___________________________
2
See Sections 6.2.3. and 6.2.4.
18
THREATS
PRIMARY SUBCATEGORY
Atmospheric corrosion
Coat (paint) the exposed piping.
Increase survey frequency.
Replace or rehab.
Relocate.
NATURAL
FORCES
Outside force/weather:
(e.g., earth movement,
lightning, heavy
rains/floods, temperature
extremes, high winds)
Steel pipe
Plastic pipe
Cast iron pipe
Relocate pipe from high risk locations.
Replace pipe in high risk locations.
Install slip or expansion joints for earth
movement.
Install strain gages on pipe.
Install automatic shut-offs.
Expand the use of excess flow valves.
Conduct leak survey after significant
earthquake or other event.
EXCAVATION
DAMAGE
Third-party damage
Operator damage
Conduct enhanced awareness
education.
Request regulatory intervention.
Inspect targeted excavation and
backfill activities.
Inspect for facility support.
Improve accuracy of line locating.
Participate in pre-construction
meetings with project engineers and
contractors in high-risk areas.
Use warning tape.
Improve system map accuracy and
availability.
Recruit support of public safety officials
(e.g., fire department).
Install additional line markers.
OTHER OUTSIDE
FORCE DAMAGE
Fire/explosion (primary
Provide first responder training.
Install curb valves.
Improve response capability.
Vehicular
Expand policy on when and how to
install protection.
Increase frequency of
patrols/inspections of high-risk
facilities.
Evaluate the need to relocate hard-to-
protect facilities.
Leakage (previous damage)
Inspect exposed pipe prior to backfill.
19
THREATS
PRIMARY SUBCATEGORY
Vandalism
Install or improve fences/enclosures.
Increased surveillance.
Relocate hard-to-protect or critical
facilities.
Blasting
Perform leak survey after blasting.
Relocate away from frequent blast
areas (e.g., mines).
Replace with more ductile pipe
material.
MATERIAL OR
WELD FAILURE
Manufacturing defects
Construction/workmanship
defects
Mechanical damage:
o Steel pipe
o Plastic pipe
o Pipe components
Replace or repair.
Increase frequency of inspection and
monitoring.
Investigate if a type of joint or
equipment is being used in
inappropriate situations or locations.
Improve installation procedure.
Trend equipment failure.
EQUIPMENT
MALFUNCTION
Malfunction of system equipment
Replace or repair.
Increase frequency of inspection and
monitoring.
Investigate if a type of joint or
equipment is being used in
inappropriate situations or locations.
Improve installation procedure.
Trend equipment failure.
INCORRECT
OPERATION
Inadequate procedures
Inadequate safety practices
Failure to follow procedures
Improve procedures.
Improve training.
Evaluate locations where inadequate
practices may have been used.
Perform internal audits or inspections.
OTHER
Increase frequency of leakage survey.
Increase odorant level.
Increase frequency of odorant testing.
Improve choices of odorant testing
locations.

The Integrity Management Department will identify the benefit of implementing additional actions and
make a decision for implementing A/A actions. The Integrity Management Department will utilize
reasonable technical and financial judgment in evaluating recommended actions for implementation.
If approved, the Integrity Management Department will be responsible for implementing the approved
actions within the time frame specified for the approved actions.
20
7.3. Leak Management Program
WTG has implemented an electronic Leak Tracking System (LTS) which stores all leak data. The LTS is
used as a scheduler for upcoming leak surveys, repairs to non-hazard leaks, and re-probes for any open
leaks. The LTS also houses the data used to trend all leaks within WTG.
7.4. West Texas Gas Distribution Pipelines Located in Texas
7.4.1. Service Line Removal or Replacement (TAC 8.209)
WTG owns and operates 424 distribution systems within the state of Texas. These 424 systems have a
total of 269 TRRC system identification numbers. The following is WTGs risk-based program to meet
TAC rule 8.209 for Distribution Facilities Replacement.
TAC rule 8.209 requires each operator to determine what the greatest risk to public safety is for each
system. The process that WTG uses to determine this risk is determined by calculating the number of
leaks for steel service lines and comparing this to the number of leaks on main lines for an equal period of
time. This information will determine if the systems greatest risk is either steel service lines or main lines.
The data used for this comparison is made using the number of leaks reported by WTG on the PS95
filings. The initial determination was made using data from 2009 and 2010. Going forward three years of
data will be used. The following procedure will be followed after the above mentioned determination is
made. The initial scheduling for replacement of any facilities will begin on January 1, 2012.
7.4.1.1. Systems that fall into the Steel Service Lines category:
Each system will have an annualized steel service line leak rate calculated using the following formula:
1. Number of below grade leaks repaired on steel service lines (excluding third party damage leaks
and leaks on steel service lines that have been removed or replaced by this regulation) divided by
the number of steel service lines reported to PHMSA on form F 7100.1-1. Beginning in 2012 three
years (3) of data will be used for this calculation, however for initial implementation only two (2)
years of data is being considered.
Based on the results of the leak rate calculation, the following schedule will be used for replacement:
1. Any system with an annualized steel service line leak rate of 7.5% or greater will be considered
Priority 1 and removed or replaced by June 30, 2013.
2. Any system with an annualized steel service line leak rate greater than 5% but less than 7.5% will
be considered Priority 2 and no less than 10% of the original inventory in service at the beginning
of the year must be removed from service or replaced.
3. Any system with an annualized steel service line leak rate of less than 5% will be considered
Priority 3 and removal or replacement is not required; however upon discovery of any new service
line leak, the service line must be removed or replaced rather than repaired.
The results of the initial data have determined that 12 WTG systems have steel service lines as the
greatest risk to public safety. These systems can be found in Appendix F.
7.4.1.2. Systems that fall into the Main Lines Steel category:
Each system will be prioritized using WTGs DIMP risk model. This risk model takes into consideration
pipe location, proximity to buildings and other structures, the type and use of the buildings, concentration
of the public, composition and nature of the system, age of the pipe, pipe material, type of pipeline facility,
operating pressure, leak history records, prior leak grade repairs, corrosion history, environmental
conditions, and additional factors.
Any system with a total risk score in the DIMP risk model of greater than 4.99 will have at least 5% of the
total system length replaced and/or removed on an annual basis, with the following exception:
1. Poly Pipe segments.
21
2. Coated steel segments with document history of effective corrosion protection (exposed pipe
reports & pipe to soil readings).
3. Pipeline segments greater than 500 foot from a building intended for human occupancy or a well -
defined outside public gathering area.
For each system/segment that meets this DIMP risk score greater than 4.99, the Integrity Management
Department will develop a system specific written plan for replacement and/or removal. Specific written
plans will not be developed for systems that require less than 100 foot of replacement and/or removal.
Required replacement and/or removal footage will be completed under normal routine maintenance
activities. The system specific written plans will be included on the annual report submitted to the TRRC
on or prior to March 15th of each year.
If greater than 5% of a systems mainline footage is replaced and/or removed in a calendar year, this
excess footage will be credited to the following years replacement schedule.
Any system with a total risk score in the DIMP risk model of less than 5.0 will not be included in the
mandatory replacement program.
The results of the initial data have determined that 412 WTG systems have main lines as the greatest risk
to public safety. Of the 412 systems, 30 systems have a DIMP risk score greater than 4.99. These
systems can be found in Appendix G.
7.4.1.3. Reporting Requirements:
On or prior to March 15th of each year, WTG will develop and submit to the TRRC an annual report which
will include the following:
1. A list of steel service lines or other distribution facilities (by system ID number) replaced during
the prior calendar year.
2. Revisions to WTGs risk-based replacement program.
3. Proposed specific work plan (by system ID) for the current year.
7.5. Mechanical Fitting Failure Regulation
49 CFR 192.1009 What must an operator report when a mechanical fitting fails?
(a) Except as provided in paragraph (b) of this section, each operator of a distribution pipeline system
must submit a report on each mechanical fitting failure, excluding any failure that results only in a
nonhazardous leak, on a Department of Transportation Form PHMSA F7100.12. The report(s)
must be submitted in accordance with 191.12.
(b) The mechanical fitting failure reporting requirements in paragraph (a) of this section do not apply
to the following:
(1) Master meter operators;
(2) Small LPG operator as defined in 192.1001; or
(3) LNG facilities.
7.5.1. Mechanical Fitting Failure Process
WTG is tracking all mechanical fitting failures on a distribution system. The Leak Tracking System (LTS)
will flag any mechanical fitting failure and notify the Integrity Management Department. The Integrity
Management Department will contact the district and gather required data to submit Department of
Transportation Form PHMSA F-7100.1-2.
22

8 - Section 8 - Performance Plan
8.1. Regulation
49 CFR 192.1007(e)
(e) Measure performance, monitor results, and evaluate effectiveness.
(1) Develop and monitor performance measures from an established baseline to evaluate the
effectiveness of its IM program. An operator must consider the results of its performance
monitoring in periodically re-evaluating the threats and risks. These performance measures must
include the following:
(i) Number of hazardous leaks either eliminated or repaired as required by 192.703(c) of this
subchapter (or total number of leaks if all leaks are repaired when found), categorized by cause;
(ii) Number of excavation damages;
(iii) Number of excavation tickets (receipt of information by the underground facility operator from
the notification center);
(iv) Total number of leaks either eliminated or repaired, categorized by cause;
(v) Number of hazardous leaks either eliminated or repaired as required by 192.703(c) (or total
number of leaks if all leaks are repaired when found), categorized by material; and
(vi) Any additional measures the operator determines are needed to evaluate the effectiveness of
the operator's IM program in controlling each identified threat.
8.2. Introduction
The Integrity Management Department utilizes this Performance Plan to determine if the West Texas Gas
Distribution program is effective in assessing and evaluating the integrity of distribution systems. The
Performance Plan includes internal evaluation of the Programs performance, internal and external audits,
and reporting of performance results.
8.3. System Specific
The Integrity Management Department will annually, by January 31 for the previous years data, collect
the following performance metrics data for each System as listed below. The form used to document this
information can be found in Appendix D or may utilize an alternative form to document this information.

PERFORMANCE MEASURE EXPECTED PERFORMANCE
Number of hazardous leaks either eliminated or repaired
as required by 192.703(c), categorized by cause

Number of excavation damages
Number of excavation tickets
Total number of leaks either eliminated or repaired,
categorized by cause

Number of hazardous leaks either eliminated or repaired
as required by 192.703(c), categorized by material

WTG specific measures

23
9 - Section 9 - Periodic Evaluation and Improvement
9.1. Regulation
49 CFR 192.1007(f)
(f) Periodic Evaluation and Improvement. An operator must re-evaluate threats and risks on its
entire pipeline and consider the relevance of threats in one location to other areas. Each operator
must determine the appropriate period for conducting complete program evaluations based on
the complexity of its system and changes in factors affecting the risk of failure. An operator must
conduct a complete program re-evaluation at least every five years. The operator must consider
the results of the performance monitoring in these evaluations.
9.2. Audits
The Integrity Management Department should determine if an audit is warranted after the annual review
of the Annual Integrity Management Report found in Section 10.2. Events that would indicate the need
for an audit include the following.
1. Failure to meet expected performance for System Specific performance measures as identified in
Section 8.3.
2. Notice from PHMSA or a state regulatory agency of a pending formal inspection.
The audit may include consideration of the entire Program or only specified sections as determined by the
Integrity Management Department.
The Integrity Management Department may choose to schedule an audit at other times if circumstances
warrant.
After determining that an audit is necessary, the Integrity Management Department should determine if an
internal or an external audit shall be performed.
9.2.1. Internal Audits
The Internal Audit team shall be composed of personnel both with and without direct responsibility for any
distribution integrity management work. This team is constituted by the Integrity Management Department
and reports directly to that position. The audit team will forward its audit results to the Integrity
Management Department within thirty days of completing the audit.
The Integrity Management Department will determine which issues are to be addressed in the audit.
9.2.2. External Audits
When appropriate, the Integrity Management Department will commission an external audit team to
review the overall functioning of the West Texas Gas Distribution Integrity Management Program. The
audit team will forward its audit results to the Integrity Management Department within thirty days of
completing its audit work.
The Integrity Management Department will determine which issues are to be addressed in the audit.
9.2.3. Audit Results
The Vice President of Operations will review audit results for information and for consideration of
implementation.
9.3. Improvements
The Integrity Management Department will be primarily responsible for recommending improvement to
the Program after an annual review of the Performance Plan results.
24
Improvements may also be proposed by any West Texas employee. These improvements may be the
result of exceptional performance achieved at a particular time for one or more metrics or unsatisfactory
performance on a similar scale. The improvements will be documented in the Annual Integrity
Management Report that is described in Section 10.2.
9.4. Metrics Review
The Integrity Management Department will annually review and update, if necessary, the currently
effective system specific metrics based on regulatory changes to current metrics or for other reasons
deemed appropriate.
Within 90 days of a significant revision to this plan, the Integrity Management Department will forward a
revised copy to PHMSA and appropriate state agencies.
9.5. Communication of Results
The Director of Integrity Management will distribute performance results and audit results in accordance
with Section 11.3.
25
10 - Section 10 - Results Reporting
10.1. Regulation
49 CFR 192.1007(e)
(g) Report results. Report, on an annual basis, the four measures listed in paragraphs (e)(1)(i)
through (e)(1)(iv) of this section, as part of the annual report required by 191.11. An operator
also must report the four measures to the state pipeline safety authority if a state exercises
jurisdiction over the operator's pipeline.
10.2. Review Process for Plan Effectiveness
The Integrity Management Department will prepare an Annual Integrity Management Report by April 30
th

each year beginning with year 2012 that includes the following:
1. Overall assessment of the Programs effectiveness.
2. List of A/A actions completed and results obtained.
3. Process improvements identified and implemented.
4. Performance against the previous years Program Performance Parameters and any identified
trends.
5. Any other Distribution Integrity Management Activities carried out in the previous year.
6. Determination if an audit is required in the forthcoming twelve months.
7. Identification of any Distribution Integrity Management work scheduled in the previous year but
not completed.
8. A Recovery Plan for work scheduled but not completed.
9. A review of the overall contents within the DIMP to ensure compliance with 192 Subpart P.
10. An Integrity Management Department and SME review of the current pipeline data used in the
risk assessment to ensure that the most up-to-date information is being used.
The Annual Integrity Management Report will be reviewed and approved by the Vice President of
Operations.
10.3. Performance Measures Submittal to PHMSA and appropriate State Regulatory Agency
The Integrity Management Department will submit a West Texas Gas Performance Report including the
four measures listed in 192.1007(e)(1)(i) through 192.1007(e)(1)(iv) to PHMSA and the appropriate
state regulatory agency as part of the Annual Report required by 191.11. The Annual Report is required
to be submitted by March 15 for the proceeding calendar year. The annual report requirement does not
apply to a master meter system or to a petroleum gas system that serves fewer than 100 customers from
a single source
26
11 - Section 11 - Communications Plan
11.1. External Communications
11.1.1. Public Awareness Program
WTG will cover external communications for the general public, local officials and emergency responders
through the West Texas Public Awareness Program.
11.2. Safety Concerns
11.2.1. DOT/PHMSA
The Integrity Management Department will continually monitor the DOT/PHMSA website for rule changes,
advisory bulletins, new information and recommended practices. An electronic log sheet will be kept to
detail and describe all visits to the PHMSA website. Any changes or notices that would affect the DIMP
will be documented on the log sheet.
11.3. Internal Communications
Internal communications are made per the following table.
DOCUMENT ORIGINATOR
DOCUMENT
RECIPIENT
ACTION REQUIRED
Annual DIMP Update
Integrity Management
Department
Vice President of Gas
Pipeline Operations,
Pipeline Operations and
Maintenance
Review and approval by
Pipeline Operations
Annual Distribution Integrity
Management Report
Department
Department
Review, approval and
distribution within WTG
Annual Risk Analysis Update
Department
Pipeline Operations
Include in DIMP update
including consideration of
A/A actions
External and Internal Audit
Findings
Department via Audit Team
Pipeline Operations
Update DIMP as
appropriate
Abnormal Operating Condition
Report
Field Operations
Department
Update DIMP as
appropriate
Completed Projects Form Field Operations
Department
Update DIMP as
appropriate
Leak Tracking Form Field Operations
Department
Update DIMP as
appropriate
Leak Survey Form Field Operations
Department
Update DIMP as
appropriate

11.4. External Communications
The Integrity Management Department will communicate any significant changes within the WTG DIMP to
PHMSA and the appropriate state authority in a timely manner as soon as these updates are made.
27

12 - Appendix A - Pipeline Information
The Pipeline Information spreadsheet is too large to fit into a Word
table. The most current version of the

Pipeline Information spreadsheet can be found on the WTG internal employee website under the Integrity
Management Department section.
28

13 - Appendix B - Summary and Risk Analyses
The Risk Analysis spreadsheet is too large to fit into a Word
table. The most current version of the Risk

Analysis spreadsheet can be found on the WTG internal employee website under the Integrity
Management Department section.

29
14 - Appendix C - Information Gathering Form
The Pipeline Information Gathering spreadsheet is too large to fit into a Word
table. The most current

version of the Pipeline Information Gathering spreadsheet can be found on the WTG internal employee
website under the Integrity Management Department section.

30
15 - Appendix D - Performance Metric Information Gathering Form

31
West Texas Gas
Information from January 1, _____ to December 31, _____
Date: ___________________________________________________________
Distribution Gas Pipeline Performance Information
Gas Pipeline/Segment Name: ______________________________________
PERFORMANCE METRIC SPECIFIC METRIC
METRIC RESULT
ACHIEVED
COMMENTS
Corrosion
Number of hazardous
leaks either eliminated or
repaired as required by
192.703(c), categorized
by cause

Corrosion
Total number of leaks
either eliminated or
repaired, categorized by
cause

Corrosion
Number of hazardous
by material

Corrosion WTG specific measures
Natural Forces
Number of hazardous
by cause

Natural Forces
cause

Natural Forces
Number of hazardous
by material

Natural Forces WTG specific measures
Excavation Damage
Number of hazardous
by cause

32
METRIC RESULT
ACHIEVED
COMMENTS
Excavation Damage
Number of excavation
damages

Excavation Damage
Number of excavation
tickets

Excavation Damage
cause

Excavation Damage
Number of hazardous
by material

Excavation Damage WTG specific measures
Other Outside Force
Damage
Number of hazardous
by cause

Other Outside Force
Damage
cause

Other Outside Force
Damage
Number of hazardous
by material

Other Outside Force
Damage
Material, Weld or Joint
Failure
Number of hazardous
by cause

Failure
cause

33
METRIC RESULT
ACHIEVED
COMMENTS
Failure
Number of hazardous
by material

Failure
Equipment Failure
Number of hazardous
by cause

Equipment Failure
cause

Equipment Failure
Number of hazardous
by material

Equipment Failure WTG specific measures
Incorrect Operation
Number of hazardous
by cause

Incorrect Operation
cause

Incorrect Operation
Number of hazardous
by material

Incorrect Operation WTG specific measures
Other
Number of hazardous
by cause

34
METRIC RESULT
ACHIEVED
COMMENTS
Other
cause

Other
Number of hazardous
by material

Other WTG specific measures

Comments:

Prepared by: _________________________ Date: _____________________________

35

16 - Appendix E - Evaluation of A/A Actions

36
West Texas Gas
A/A Actions
Date: ____________________

INSTRUCTIONS:
1. The Integrity Management Department completes Part 1 Segment Identification on the form.
2. The Integrity Management Department reviews the individual Threat scores and the individual
Consequence of Failure scores for each segment from the latest risk analysis and completes Part
2: Threat and Consequence Hazard Identification.
3. The Integrity Management Department completes the Part 3: Possible A/A Actions section of the
form.
4. The Integrity Management Department completes the Part 4: Evaluation of Possible A/A Actions
section of the form by performing an evaluation of each possible measure which includes, at a
minimum, pros/cons, cost/benefit, technical analysis, and all assumptions.
5. The Integrity Management Department determines if the identified action is to be implement and
checks the appropriate box in Part 4.
6. The Integrity Management Department retains this form for the service life of the pipeline.

Part 1: System Identification:

System Name: _________________________________________________________
Pipeline System Identification: _____________________________________________
Calendar Year: _________________________________________________________
State: __________________________________________________________________
Systems DIMP Risk Score: _________________________________________________
TAC 8.209 Category: ______________________________________________________
Service Line Priority: ______________________________________________________

37
Part 2: Threat and Consequence Hazard Identification:

Pipeline Segment Threat Scores:
Threat Factors with Risk Analysis Score of 5 or Threat categories with TSI > 67%:
T 1. _____________________________________________________________________
T 2. _____________________________________________________________________
T 3. _____________________________________________________________________
T 4. _____________________________________________________________________
T 5. _____________________________________________________________________
Threat Factors with Possible A/A Actions:
T 1. _____________________________________________________________________
T 2. _____________________________________________________________________
T 3. _____________________________________________________________________
T 4. _____________________________________________________________________
T 5. _____________________________________________________________________

Pipeline Segment Consequence Scores:
Consequence Factors with Risk analysis Score of 5:
C 1. ____________________________________________________________________
C 2. ____________________________________________________________________
C 3. ____________________________________________________________________
C 4. ____________________________________________________________________
C 5. ____________________________________________________________________

38

Part 3: Possible A/A Actions: (reference 192.1007(d)):

List all of the possible A/A Actions that could lower the individual threat or consequence factor risk.
T 1. _____________________________________________________________________
T 2. _____________________________________________________________________
T 3. _____________________________________________________________________
T 4. _____________________________________________________________________
T 5. _____________________________________________________________________

39
Part 4: Evaluation of A/A Actions:
Add additional sections if necessary.

1. A/A Action from Part 3:
Threat to be addressed: ____________________________________________________
Specific Action to be implemented: ___________________________________________

Analysis of Action (pros/cons, cost/benefit, technical analysis, all assumptions, and give details of outside
technical review if appropriate):
1. _________________________________________________________________
2. _________________________________________________________________
3. _________________________________________________________________
Implement Identified Measure: Yes No
Location Affected: _______________________________________________________
Time Frame for Completion: _______________________________________________
Specific Responsibilities for Implementation: ____________________________________
________________________________________________________________________

Specific Action to be implemented: ____________________________________________
1. _________________________________________________________________
2. _________________________________________________________________
3. _________________________________________________________________
Implement Identified Action: Yes No
___________________________________________________________________________

40
Specific Action to be implemented: ____________________________________________
1. _________________________________________________________________
2. _________________________________________________________________
3. _________________________________________________________________
Implement Identified Action: Yes No
________________________________________________________________________

Prepared by: ___________________________________________________________

Date: _________________________________________________________________

Approved by: District Manager: _____________________________________________
Date: ______________________________________________________

Operations Manager: __________________________________________
Date: ______________________________________________________

Vice President: ______________________________________________
Date: ______________________________________________________

41

17 - Appendix F - Steel Service Line Replacement

42
WTG DIMP Risk Scores TAC 8.209 Service Line
SYSTEM NAME SYSTEM TRC ID #
RISK
SCORE
# OF STEEL
SERVICE LINE
LEAKS IN 2009 AND
2010
# OF SYSTEM
STEEL SERVICE
LINES
ANNUALIZED STEEL
SERVICE LINE LEAK
RATE
PRIORITY
Miami 110356 6.578 2 216 0.005 3
JUNCTION 211162 6.528 2 511 0.002 3
Devine 710231 6.220 2 2 0.500 1
Christoval 211087 5.654 2 95 0.011 3
Higgins 110240 5.271 3 240 0.006 3
BALMORHEA 210022 4.654 1 0 0.000
Leak was on a
steel riser,
service line is
poly
Waka 110597 4.290 4 31 0.065 2
Morton System
95
110675 3.876 1 4 0.125 1
Groom Mainline 110455 3.657 1 24 0.021 3
Lelia Lake Rural 110819 2.989 1 0 0.000
Leak was on a
steel riser,
service line is
poly
Poor Boy 110002 2.685 1 8 0.063 2
Regan Lateral 960478 2.496 1 5 0.100 1

43

18 - Appendix G - Mainline Steel Replacement

44

WTG DIMP Risk Scores TAC 8.209 (Scores > 4.99)
DISTRICT SYSTEM NAME TRC ID #
RISK
SCORE
THREAT
SCORE
CONSEQUENCE
SCORE
TOTAL SYSTEM
LENGTH (FEET)
SYSTEM
LENGTH
LESS POLY
& COATED
STEEL
SYSTEM
LENGTH LESS
POLY & COATED
STEEL X 5%
Amarillo Claude Residential 110108 8.915 1.748 5.100 126959 79341 3967
Pearsall Somerset 411170 8.912 1.564 5.700 370775 253757 12688
Kermit Kermit 210347 8.770 1.512 5.800 351054 176913 8846
Canadian Canadian 110085 8.695 1.705 5.100 119679 114869 5743
Junction SONORA 211140 7.563 1.483 5.100 176641 114468 5723
Shamrock Wheeler 110616 7.470 1.437 5.200 117650 27250 1363
Farwell Farwell 110182 7.420 1.400 5.300 73863 62084 3104
Amarillo Groom 110213 7.280 1.427 5.100 55578 39072 1954
Pearsall Natalia 411372 7.196 1.384 5.200 151789 146299 7315
Canadian Follett 110185 7.086 1.363 5.200 53204 46179 2309
Stratford Dumas 110161 7.000 1.429 4.900 39600 19800 990
Shamrock Shamrock 110516 6.908 1.354 5.100 189211 0 0
Stratford Stratford 110545 6.867 1.461 4.700 66665 64434 3222
Junction MENARD 211161 6.626 1.380 4.800 110168 60203 3010
Canadian Darrouzett 110144 6.616 1.408 4.700 39793 34993 1750
Junction Eden 211094 6.404 1.455 4.400 83450 12160 608
Dalhart Texline 110575 6.313 1.315 4.800 19825 1214 61
Shamrock Briscoe 110063 6.194 1.347 4.600 14251 614 31
Junction Paint Rock 211122 6.163 1.340 4.600 22000 1525 76
Pearsall Jungman 411373 6.042 1.343 4.500 59922 34789 1739
Shamrock New Mobeetie 110362 6.034 1.284 4.700 21439 479 24

45
WTG DIMP Risk Scores TAC 8.209 (Scores > 4.99)
DISTRICT SYSTEM NAME TRC ID #
RISK
SCORE
THREAT
SCORE
CONSEQUENCE
SCORE
TOTAL SYSTEM
LENGTH (FEET)
SYSTEM
LENGTH
LESS POLY
& COATED
STEEL
SYSTEM
LENGTH LESS
POLY & COATED
STEEL X 5%
Shamrock Wheeler Mainline 110617 5.998 1.304 4.600 188139 59604 2980
Pearsall LaPryor 710495 5.778 1.481 3.900 55956 13599 680
Shamrock Old Mobeetie 110363 5.670 1.319 4.300 32400 22307 1115
Shamrock Allison 110016 5.652 1.285 4.400 8704 1564 78
Pearsall East Central 411375 5.612 1.369 4.100 34320 31152 1558
Ft.
Stockton
IMPERIAL 210327 5.467 1.367 4.000 83424 57024 2851
Stratford Etter 110176 5.344 1.406 3.800 20095 8710 436
Dalhart NORTEX 110392 5.203 1.334 3.900 658705 0 0
Amarillo Goodnight 110209 5.015 1.433 3.500 88980 79426 3971

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