# WILLIAMS FIELD SERVICES - GULF COAST COMPANY, LP — Notice of Probable Violation

**Citation:** CPF 42022039NOPV  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2022-06-17

CLOSED notice of probable violation citing 195.452(g)(1)(xxi), 195.579(b)(3).

## Document text

Notice of Probable Violation involving WILLIAMS FIELD SERVICES - GULF COAST COMPANY, LP. PHMSA's enforcement data identifies the cited regulations as 195.452(g)(1)(xxi),  195.579(b)(3). The case was opened on 2022-06-17 and is reported as closed as of 2024-03-22. Proposed civil penalty: $116,600. Assessed civil penalty: $116,600. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

42022039NOPV_Closure Letter_03222024_(21-203269).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022039NOPV/42022039NOPV_Closure%20Letter_03222024_(21-203269).pdf

42022039NOPV_Closure Letter_03222024_(21-203269)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022039NOPV/42022039NOPV_Closure%20Letter_03222024_(21-203269)_text.pdf

42022039NOPV_Final Order_12142023_(21-203269).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022039NOPV/42022039NOPV_Final%20Order_12142023_(21-203269).pdf

42022039NOPV_Final Order_12142023_(21-203269)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022039NOPV/42022039NOPV_Final%20Order_12142023_(21-203269)_text.pdf

42022039NOPV_Operator Response and Request_07152022_(21-203269).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022039NOPV/42022039NOPV_Operator%20Response%20and%20Request_07152022_(21-203269).pdf

42022039NOPV_Operator Withdrawal of RfH_01122023_(21-203269).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022039NOPV/42022039NOPV_Operator%20Withdrawal%20of%20RfH_01122023_(21-203269).pdf

42022039NOPV_PCP PCO_06172022_(21-203269).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022039NOPV/42022039NOPV_PCP%20PCO_06172022_(21-203269).pdf

42022039NOPV_PCP PCO_06172022_(21-203269)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022039NOPV/42022039NOPV_PCP%20PCO_06172022_(21-203269)_text.pdf

42022039NOPV_PHC Hearing Scheduled_11042022_(21-203269).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022039NOPV/42022039NOPV_PHC%20Hearing%20Scheduled_11042022_(21-203269).pdf

42022039NOPV_PHC Hearing Scheduled_11042022_(21-203269)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022039NOPV/42022039NOPV_PHC%20Hearing%20Scheduled_11042022_(21-203269)_text.pdf

42022039NOPV_PHC Hearing Scheduled_11042022_(21-203269)_text.pdf

November 4, 2022
VIA ELECTRONIC MAIL TO: john.bell@williams.com and bryan.lethcoe@dot.gov
Mr. John Bell
Manager of Pipeline Safety – Transmission and Gulf of Mexico
Williams Field Services – Gulf Coast Company, LP
One Williams Center
P.O. Box 645
Tulsa, Oklahoma 74172
Mr. Bryan Lethcoe
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
8701 South Gessner Road, Suite 630
Houston, Texas 77074
Re: Notice of Hearing, Williams Field Services – Gulf Coast Company, LP
CPF No. 4-2022-039-NOPV
Dear Mr. Bell and Mr. Lethcoe:
In accordance with 49 C.F.R. § 190.211, an informal hearing will be held regarding the Notice of
Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order issued by the Pipeline
and Hazardous Materials Safety Administration in the above-referenced case. The hearing will take
place on February 1, 2023, beginning at 8:30 a.m. Central Time.
The hearing will take place at the PHMSA Southwest Region office, 8701 South Gessner Road,
Suite 630, Houston, TX 77074. Upon arrival at the building, attendees will be required to present
photo identification to security personnel. A contact phone number for the day of the hearing is
(713) 272-2859.
At least 10 calendar days prior to the hearing (or by January 23, 2023), both parties must submit and
exchange any additional written materials they intend to present at the hearing and the name and
email address of each attendee. This information should be provided electronically. Materials not
submitted by this date may be excluded.



If you have any questions, please do not hesitate to contact me.
Sincerely,
Larry White
Presiding Official
cc: Mr. Mark Cluff, Vice President Safety and Operational Discipline, Williams Field
Services – Gulf Coast Company, LP, mark.cluff@williams.com
Ms. Erin Sullenger, Senior Attorney Environmental, Health & Safety, Williams Field
Services – Gulf Coast Company, LP, erin.pottersullenger@williams.com
Mr. Ian Curry, Esq., Counsel, Southwest Region, Office of Pipeline Safety, PHMSA,
ian.curry@dot.gov

42022039NOPV_Final Order_12142023_(21-203269)_text.pdf

December 14, 2023
VIA ELECTRONIC MAIL TO: Amy.Shank@williams.com
Amy Shank
Vice President, Safety & Operational Discipline
Williams Field Services – Gulf Coast Company, LP
One Williams Center, P.O. Box 645
Tulsa, Oklahoma 74172
Re: CPF No. 4-2022-039-NOPV
Dear Ms. Shank:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation, assesses a civil penalty of $116,600, and specifies actions that need to be taken by
Williams to comply with the pipeline safety regulations. The penalty payment terms are set forth
in the Final Order. When the civil penalty has been paid and the terms of the compliance order
completed, as determined by the Director, Southwest 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 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Bryan Lethcoe, Director, Southwest Region, Office of Pipeline Safety, PHMSA
Mr. John Bell, Manager of Pipeline Safety – Transmission & Gulf of Mexico,
Williams, John.Bell@williams.com
Mr. Clint Pernack, Director of Pipeline Safety & Asset Integrity, Williams,
Clint.Pernack@williams.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 )
Williams Field Services – Gulf Coast Company, LP, ) CPF No. 4-2022-039-NOPV
)
)
)
Respondent. )
______________________________________________)
FINAL ORDER
From May 18, 2021, through September 2, 2021, pursuant to 49 U.S.C. § 60117,
representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA),
Office of Pipeline Safety (OPS), conducted an on-site pipeline safety inspection of the
facilities and records of Williams Field Services – Gulf Coast Company, LP (Williams or
Respondent) in Bay City, Texas and Mobile, Alabama. The facility that was the subject of the
inspection is a 401-mile crude oil offshore gathering pipeline. The parent company, The
Williams Companies, responded on Respondent’s behalf.
As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to
Respondent, by letter dated June 17, 2022, a Notice of Probable Violation, Proposed Civil
Penalty, and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207,
the Notice proposed finding that Williams had violated 49 C.F.R. §§ 195.452(g) and
195.579(b) and proposed assessing a total civil penalty of $116,600 for the alleged violations.
The Notice also proposed ordering Respondent to take certain measures to correct the alleged
violations.
Williams responded to the Notice by letter dated July 15, 2022 (Response). Williams
contested Item 1 and did not contest Item 2 of the two allegations of violation and requested a
consultation and settlement meeting with PHMSA regarding: the contested Item, the
obligations in the Proposed Compliance Order (PCO), and the proposed civil penalty for both
Items 1 and 2. Williams’ Response also reserved the right to request a hearing regarding the
items in the NOPV should Williams not be satisfied with the outcome of the consultation and
settlement meeting. By letter dated January 12, 2023 (Second Response), Respondent
withdrew its request for a hearing and its opposition to Item 1 and thereby authorized the entry
of this Final Order without further notice.



FINDINGS OF VIOLATION
In its Second Response, Williams did not contest the allegations in the Notice that it violated
49 C.F.R. Part 195, as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.452(g), which states:
§ 195.452 Pipeline integrity management in high consequence areas.
(a) …
(g) What is an information analysis? In periodically evaluating the
integrity of each pipeline segment (see paragraph (j) of this section), an
operator must analyze all available information about the integrity of its
entire pipeline and the consequences of a possible failure along the
pipeline. Operators must continue to comply with the data integration
elements specified in § 195.452(g) that were in effect on October 1, 2018,
until October 1, 2022. Operators must begin to integrate all the data
elements specified in this section starting October 1, 2020, with all
attributes integrated by October 1, 2022. This analysis must:
(1) Integrate information and attributes about the pipeline that
include, but are not limited to:
(i) …
(xxi) Other pertinent information derived from operations and
maintenance activities and any additional tests, inspections, surveys,
patrols, or monitoring required under this part.
The Notice alleged that Respondent violated 49 C.F.R. § 195.452(g)(1)(xxi) by failing to
analyze all available information when conducting its information analysis when it did not
include proper information derived from operations and maintenance activities including tests,
inspections, surveys, patrols, or monitoring requirements. Specifically, the Notice alleged that
Williams did not conduct internal corrosion coupon inspections in calendar years 2017, 2018,
2019, 2020, and 2021, and Williams used invalid internal corrosion rates in its information
analysis for those years. The Notice further alleged that these inaccurate inputs resulted in
flawed outputs from its Pipeline Risk Model.
Respondent withdrew its opposition to this allegation of violation in its Second Response.
Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49
C.F.R. § 195.452(g)(1)(xxi) by using invalid corrosion rates in its information analysis, such
that it failed to effectively integrate information and attributes about the pipeline including
tests, inspections, surveys, patrols, or monitoring.
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.579(b), which states in
relevant part:
§ 195.579 What must I do to mitigate internal corrosion?
(a) …
(b) Inhibitors. If you use corrosion inhibitors to mitigate
internal corrosion, you must—
(1) …



(3) Examine the coupons or other monitoring equipment at least
twice each calendar year, but with intervals not exceeding 7 ½
months.
The Notice alleged that Respondent violated 49 C.F.R. § 195.579(b)(3) by failing to examine
coupons at least twice each calendar year for seven inspection intervals from 2017 through
2021. Specifically, the Notice alleged that Williams’ failure to monitor coupons prevented
Williams from properly integrating information about the pipeline in order to effectively
monitor of the use or effectiveness of corrosion inhibitors for the purpose of mitigating
internal corrosion.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of
all of the evidence, I find that Respondent violated 49 C.F.R. § 195.579(b)(3) by failing to
examine coupons as required to evaluate the effectiveness of corrosion inhibitors.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to
exceed $200,000 per violation for each day of the violation, up to a maximum of $2,000,000
for any related series of violations.1
In determining the amount of a civil penalty under 49 U.S.C. § 60122 and 49 C.F.R.
§ 190.225, I must consider the following criteria: the nature, circumstances, and gravity of the
violation, including adverse impact on the environment; the degree of Respondent’s
culpability; the history of Respondent’s prior offenses; any effect that the penalty may have on
its ability to continue doing business; the good faith of Respondent in attempting to comply
with the pipeline safety regulations; and self-disclosure or actions to correct a violation prior to
discovery by PHMSA. In addition, I may consider the economic benefit gained from the
violation without any reduction because of subsequent damages, and such other matters as
justice may require. The Notice proposed a total civil penalty of $116,600 for the violations
cited above.
Item 1: The Notice proposed a civil penalty of $55,200 for Respondent’s violation of 49
C.F.R. § 195.452(g)(1)(xxi), for failing to effectively integrate information and attributes
about the pipeline including tests, inspections, surveys, patrols, or monitoring by using invalid
corrosion rates in its information analysis.
In its Second Response, Williams requests that PHMSA reduce the civil penalties associated
with Item 1, arguing that the proposed civil penalty did not accurately reflect the statutory and
regulatory penalty assessment criteria required by 49 U.S.C. § 60122(b) and 49 C.F.R. §
190.225. Williams specifically argues that PHMSA erred in considering the following criteria
1 These amounts are adjusted annually for inflation. See 49 C.F.R. § 190.223 for adjusted amounts.



that are relevant to the calculation of the proposed civil penalty in the Notice.
First, Respondent argues it should have received a credit based on the “good faith” factor.
Williams contends that despite the omission of corrosion coupon data, its risk model’s use of
in-line inspection (ILI) data demonstrates a good faith effort to comply with both the
regulation and Williams’ procedures. Williams further argues that that ILI data provides
quantitative data, whereas corrosion coupon data is more qualitative. Williams argues that
PHMSA should have awarded it with a “-10” for this factor. I find a credit based on Williams’
actions in this case is not warranted. Section 195.452(g)(1)(xxi) specifically requires the
consideration of multiple factors and data points in each information analysis, including
“pertinent data derived from operations and maintenance activities and any additional tests,
inspections, surveys, patrols, or monitoring required under this part.” Williams was correct to
consider ILI data, but it was also required to collect and utilize corrosion coupon data, which is
pertinent data. Given that the plain language of the regulation conveys the importance of
multiple data sources, Williams’ reliance on ILI data to exclusion of the other data does not
demonstrate a good faith effort to comply with the letter of the regulation.
Next, Williams argues that in calculating the proposed civil penalty pursuant to the “other
matters as justice may require” factor, PHMSA failed to provide Williams with credit to reflect
that its failure to collect and input corrosion coupon data into its information analysis did not
impact the safety of the pipeline. Williams argues that its use of the ILI data in its risk
assessment still resulted in Williams identifying the segment as susceptible to internal
corrosion, which resulted in Williams taking various actions to manage the threat of internal
corrosion. I find a credit based on the “other matters as justice may require” is not warranted
here because Williams’ procedures did not exceed the regulatory requirements, so William’s
noncompliance was with the regulations and not a procedure that exceeded the standards set in
the regulations.
Lastly, with regard to the “gravity” factor, Williams disagrees with PHMSA’s enhancement
that was based on the violation occurring in a high consequence area (HCA). Williams does
not dispute that the violation occurred in an HCA but argues that the gravity factor should be
reduced because the violation only minimally affected pipeline safety. I disagree. The fact
that the violation occurred in an HCA is determinative, so no reduction is warranted.
Accordingly, having reviewed the record and considered the assessment criteria, I assess
Respondent a civil penalty of $55,200 for violation of 49 C.F.R. § 195.452(g)(1)(xxi).
Item 2: The Notice proposed a civil penalty of $61,400 for Respondent’s violation of 49
C.F.R. § 195.479(b)(3), for failing to examine internal corrosion coupons at least twice each
calendar year, but with intervals not exceeding 7 ½ months, in accordance with its procedure
and § 195.579(b)(3). Williams provides an accounting of the actions it has taken since the
discovery of the missed inspections and its disclosure to PHMSA. In light of the actions it
describes, Williams requests that PHMSA reduce the proposed civil penalty for Item 2 in
accordance with the following criteria that are relevant to the calculation of the proposed civil
penalty in the Notice.
First, with regard to the “circumstances” factor and the 25 percent mitigation that PHMSA



awarded in the calculation of the proposed civil penalty based on Williams’ self-report,
Williams points out that in a separate PHMSA enforcement case involving a natural gas
pipeline, PHMSA applied a 50 percent mitigation factor following Williams’ disclosure of its
failure to collect corrosion coupon data. Williams asserts that PHMSA should have applied
the 50 percent mitigation in this case, given the similarity in the violations. However, the
circumstances of the present case are distinguishable from the case involving the natural gas
pipeline. The natural gas pipeline did not pose an environmental risk to the offshore area, and,
unlike the current case, that pipeline was not located in an HCA. Additionally, in this case,
Williams’ failure to collect coupon data resulted in the use of a flawed risk model. In
determining mitigation values, PHMSA considers the totality of the circumstances and the risk
level, which is unique in each case. Here, I do not find any error in PHMSA’s provision of a
25 percent mitigation factor for Williams self-reporting violations that had been occurred over
the course of five years.
Next, with regard to the “culpability” factor, Williams argues that PHMSA did not account for
the fact that Williams identified the violation to PHMSA and that “it was taking and had
completed proactive steps to address the deficiencies prior to issuance of the NOPV.”
However, PHMSA does not provide credit for corrective actions taken after PHMSA learned
of the violation. For this reason, a reduction based on the “culpability” factor is not warranted.
Lastly, Williams argues that PHMSA erroneously enhanced the civil penalty by a factor of
“20.40” based on the “gravity” component of the civil penalty calculation. To support its
argument, Williams again argues that the missed inspections did not affect the risk to pipeline
safety because Williams had identified the pipeline as affected by internal corrosion due to the
use of ILI data. However, the “20.40” here represents the additional points for multiple
instances of violation, as reflected in the Violation Report. Accordingly, no reduction based
on the “gravity” factor is warranted.
For the above reasons, Williams has failed to demonstrate that PHMSA’s calculation of the
civil penalty proposed in the Notice was incorrect or inappropriate. Accordingly, having
reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty
of $61,400 for violation of 49 C.F.R. § 195.479(b)(3).
In summary, having reviewed the record and considered the assessment criteria for each of the
Items cited above, I assess Respondent a total civil penalty of $116,600.
Payment of the civil penalty must be made within 20 days after receipt of this Final Order.
Federal regulations (49 C.F.R. § 89.21(b)(3)) require such payment to be made by wire
transfer through the Federal Reserve Communications System (Fedwire), to the account of the
U.S. Treasury. Detailed instructions are contained in the enclosure. Questions concerning
wire transfers should be directed to: Financial Operations Division (AMK-325), Federal
Aviation Administration, Mike Monroney Aeronautical Center, 6500 S MacArthur Blvd,
Oklahoma City, Oklahoma 79169. The Financial Operations Division telephone number is
(405) 954-8845.
Failure to pay the civil penalty will result in accrual of interest at the current annual rate in
accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to those



same authorities, a late penalty charge of six percent (6%) per annum will be charged if
payment is not made within 110 days of service. Furthermore, failure to pay the civil penalty
may result in referral of the matter to the Attorney General for appropriate action in a district
court of the United States.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Items 1 and 2 in the Notice for
violations of 49 C.F.R. §§ 195.452(g)(1)(xxi) and 195.579(b)(3). Under 49 U.S.C. § 60118(a),
each person who engages in the transportation of hazardous liquids or who owns or operates a
pipeline facility is required to comply with the applicable safety standards established under
chapter 601.
With regard to the violation of § 195.452(g) (Item 1), Respondent did not contest the PCO.
With regard to the violation of § 195.479(b) (Item 2), Respondent argues the compliance terms
should be modified. Williams states that during discussions with PHMSA representatives,
PHMSA agreed that the root cause analysis performed by DNV prior to the issuance of the
Notice satisfies the PCO requirement that Williams submit the findings from a root cause
failure analysis performed by an independent technical expert regarding the company’s failure
to complete the inspections. PHMSA agrees that the submitted root cause analysis fulfills the
requirement. Thus, the first requirement of PCO Item 2 has been completed.
The PCO also stated that Williams must conduct the required internal corrosion inspections
within 30 days of receipt of the Final Order. Williams argues that the offshore locations of
these coupons requires arranging for the coupons’ pull and transportation. Thus, Williams
requests that PHMSA permit it to comply with the compliance order by pulling coupons
during their next scheduled inspection in 2023. The next regularly scheduled coupon pulls
were set to occur in March, April, and May of 2023. Given that these dates have passed, the
coupon inspections should have already occurred. If Williams needs additional time to
complete the compliance order after issuance of the Final Order, the Director may extend the
deadline by written request for good cause.
For the above reasons, the Compliance Order is modified as set forth below.
Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is
ordered to take the following actions to ensure compliance with the pipeline safety regulations
applicable to its operations:
1. With respect to the violation of § 195.452(g) (Item 1), Respondent must
conduct a review of internal corrosion coupon inputs and update with the
information analysis with the current input. If the current input is not available,
Williams must default to the most conservative value. Williams must submit an
updated information analysis, reflecting this review, to PHMSA for review within
90 days of receipt of the Final Order
2. With respect to the violation of § 195.479(b) (Item 2), Respondent must



conduct the required internal corrosion inspections within 90 days of receipt of the
Final Order.
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.
PHMSA requests that Respondent maintain documentation of the safety improvement costs
associated with fulfilling this Compliance Order and submit the total to the Director. 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.
Failure to comply with this Order may result in the administrative assessment of civil penalties
not to exceed $200,000, as adjusted for inflation (see 49 C.F.R. § 190.223), for each violation
for each day the violation continues or in referral to the Attorney General for appropriate relief
in a district court of the United States.
Under 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this
Final Order to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New
Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the
Office of Chief Counsel, PHMSA, at the same address. The written petition must be received
no later than 20 days after receipt of the Final Order by Respondent. Any petition submitted
must contain a statement of the issue(s) and meet all other requirements of 49 C.F.R.
§ 190.243. The filing of a petition automatically stays the payment of any civil penalty
assessed. The other terms of the order, including corrective action, remain in effect unless the
Associate Administrator, upon request, grants a stay.
The terms and conditions of this Final Order are effective upon service in accordance with 49
C.F.R. § 190.5.
December 14, 2023
___________________________________ __________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety

42022039NOPV_Operator Withdrawal of RfH_01122023_(21-203269).pdf

One Williams Center
P.O. Box 645
Tulsa, OK 74172
January 12, 2023
Bryan Lethcoe
Director, Southwest Region
8701 S. Gessner, Suite 630
Houston, TX 77074
Re: Williams Field Services – Gulf Coast Company, L.P., Notice of Probable Violation, CPF
No.4-2022-039-NOPV Appeal
Mr. Lethcoe,
On behalf of Williams Field Services – Gulf Coast Company, L.P. (Williams or the
Company), this letter is to withdraw the Company’s Request for Hearing previously submitted to
the Pipeline and Hazardous Materials Safety Administration (PHMSA or the Agency) on July 15,
2022 in CPF No. 4-2022-039. Williams appreciates PHMSA’s willingness to engage on these
issues and shares the Agency’s commitment to pipeline safety. In the spirit of cooperation and
without admission, the Company is electing not to contest the two (2) alleged violations issued
in the Notice of Probable Violation (NOPV) associated with the above-referenced matter. As
detailed below, the Company submits supplemental information in support of a request for
reduction in the proposed civil penalty pursuant to 49 C.F.R. § 190.208(a)(2) and a modification
of the associated Proposed Compliance Order (PCO) requirements associated
The NOPV was issued on June 17,2022. The NOPV asserted two (2) alleged violations
of the federal pipeline safety regulations: a violation of § 195.452 related to integrity
management in high consequence areas (HCAs) (Item 1) and a violation of § 192.579 related to
internal corrosion (Item 2). In conjunction with the proposed allegations, PHMSA proposed a
total civil penalty of $116,660 and two (2) associated proposed compliance order (PCO) items.
The allegations arise out of a voluntarily self-disclosure made by the Company on May
18, 2021 and supplemented that self-disclosure on August 11, 2021 with additional information.
Upon discovering the corrosion coupon inspection deficiencies, the Company voluntarily
initiated a root cause analysis to identify the cause(s) of the deficiencies and ways to improve its
procedures and processes. Williams shared the results of this root cause analysis (RCA) with
PHMSA on October 29, 2021 and met with PHMSA representatives from the Southwest Region
to discuss the findings. After discussing the RCA’s findings and in coordination with PHMSA
representatives, Williams engaged a third-party consultant, DNV GL USA, Inc., to conduct a
second root cause analysis and to share those results with PHMSA. The third-party root cause
analysis was shared with PHMSA on May 11, 2022. Notably, Williams’ and DNV’s root cause
analyses arrived at very similar conclusions and made similar recommendations for corrective



action. Williams was in the process of implementing process and procedural improvements
when PHMSA issued the NOPV on June 17, 2022.
Pursuant to 49 C.F.R. § 190.208(a)(4), Williams responded to the NOPV on July 15, 2022
and contested NOPV Item 1 and the associated proposed civil penalty and PCO requirement.
Williams asserted that the allegation was based on a misunderstanding of its procedures and that
the Company appropriately includes required data within its Pipeline Risk Model and monitors for
the threat of internal corrosion across its system. As it relates to NOPV Item 2, Williams elected
not to contest the allegation, but requested a modification of the PCO requirement and a reduction
in the associated civil penalty. To resolve the contested item and requests for modifications, the
Company requested an informal settlement meeting with PHMSA. To preserve its rights, the
Company also requested a hearing.
On August 11, 2022 and August 19, 2022 Williams and PHMSA representatives from the
Southwest Region met to discuss the contested item and requests for modification. In the spirit
of cooperation, Williams is now withdrawing its request for hearing and submits this response to
provide additional factual clarifications about the Company’s self-disclosure of the missed internal
corrosion coupon inspections and its work to address the underlying issue. Williams respectfully
requests that the Agency reduce the civil penalties associated with the alleged violations to more
accurately reflect the statutory and regulatory penalty assessment criteria required by 49 U.S.C.
§ 60122(b) and 49 C.F.R. § 190.225 and modify the proposed compliance order requirements as
provided below.
PHMSA Allegation:
1. §195.452 Pipeline integrity management in high consequence areas.
a. …
g. What is an information analysis? In periodically evaluating the integrity of
each pipeline segment (see paragraph (j) of this section), an operator must
analyze all available information about the integrity of its entire pipeline
and the consequences of a possible failure along the pipeline. Operators
must continue to comply with the data integration elements specified in
195.452(g) that were in effect on October 1, 2018, until October 1, 2022.
Operators must begin to integrate all the data elements specified in this
section starting October 1, 2020, with all attributes integrated by October 1,
2022. This analysis must:
i. Integrate information and attributes about the pipeline that include,
but are not limited to:
1. …
2. Other pertinent information derived from operations and
maintenance activities and any additional tests, inspections,
surveys, patrols, or monitoring required under this part.
Williams failed to analyze all available information about the integrity of its
pipeline during its information analysis in accordance with § 195.452(g)(1)(xxi).
Specifically, Williams used invalid internal corrosion rates in its information



analysis because it failed to conduct the required internal corrosion inspections
or use a conservative internal corrosion rate.
Williams transports corrosive hazardous liquid in its Gulf of Mexico offshore gathering
pipelines. It uses internal corrosion coupons to monitor the internal corrosion rates
within those pipelines, and these rates are used as pipeline attributes in the Williams’
Pipeline Risk Model that analyzes all available information about the integrity of the
entire pipeline. This process is detailed in Williams’ Pipeline Risk Assessment Program,
5.1 Input Data (Revision 4, Effective Date: 4/1/2021) and Risk Algorithm Document,
3.20 MAX_COUPON_MPY as well as 7.1.2.2.1.3 Worst Coupon MPY (Revision 1.2).
In calendar years 2017, 2018, 2019, 2020, and 2021, Williams missed seven required
internal corrosion coupon inspections. Due to these missing internal corrosion coupon
inspections, Williams relied on inaccurate internal corrosion rates for the pipeline
attributes in its Pipeline Risk Model, and instead should have used a more conservative
rate. These inaccurate inputs resulted in flawed outputs from its Pipeline Risk Model.
Proposed Compliance Order Requirement: Williams must conduct a review of
internal corrosion inputs and update with the current input. If the current input is
not available, Williams must default to the most conservative value. Williams must
submit an updated information analysis reflecting this review, to PHMSA for
review within 90 days of receipt of the Final Order.
Proposed Civil Penalty: $55,200
Williams Appeal:
This allegation relates to whether the Company relied on inaccurate internal corrosion rates in
its Pipeline Risk Model. As indicated in its prior response, Williams believes this allegation is
based on a misunderstanding of its procedures and the Company’s application of its risk model.
Further, Williams believes its risk model exhibits a good faith effort to comply with 49 C.F.R. §
195.452, particularly when viewed as a component of a broader, sophisticated internal corrosion
program.
At the outset, Williams’ procedures and process allow the Company to use either (1) the actual
tool results from an in-line inspection (ILI) tool or (2) modeled defects based on coupon
corrosion rates in its Pipeline Risk Model. Williams’ current approach when no ILI data is
available is to infer the pipeline’s condition based on indirect measurements like coupon
corrosion rates and sampling results. In this case, ILI results were available for the relevant
segments and that data was used in the Company’s risk model for purposes of identifying and
assessing whether the pipeline is susceptible to internal corrosion. The Company elects to use
ILI data, if available, because it provides quantitative evidence of the asset’s conditions as
compared to coupon corrosion rate information, which only qualitatively predicts the condition of
the asset. Using the ILI data as provided by its procedures, the Company’s risk model indicated
that the segment is susceptible to the threat of internal corrosion, but it calculated a low risk
value for the threat.
Having identified the segment as a segment susceptible to the threat of internal corrosion,
Williams utilizes multiple methodologies to actively monitor the threat of internal corrosion and



the segment undergoes scheduled risk assessment reevaluations. The Company monitors for
the threat of internal corrosion using MFL ILI technology, which was used to assess the
segment in 2018 and will also be used on the next scheduled assessment in 2023. After each
integrity assessment, Williams completes a Post Assessment form that summarizes the
assessment findings, risk results and provides support for the reassessment interval. Further, to
prevent and mitigate the threat of internal corrosion, this segment is included within the
Company’s robust internal corrosion program. Subject matter experts coordinate the program
with Operations, which includes pigging, corrosion inhibitor injection and monitoring, and
continuous, real-time monitoring of BS&W values. BS&W refers to basic sediment and water
content. To best manage internal corrosion, Williams institutes real-time surveillance of the
crude’s BS&W% content, which in large enough volume, could support an internal corrosion
mechanism. Management of internal corrosion is always in place with injection of a designed
corrosion inhibitor specific for the pipelines purpose and crude’s 1% BS&W specification
regardless of the level of BS&W%. If BS&W content exceeds the pipeline specification of 1%,
alarms signal Operations and SMEs where enhanced mitigation efforts can be employed,
including increased inhibitor injections or immediate pigging. Through the combination of these
activities, the threat of internal corrosion is dramatically reduced, as evidenced by the low
severity and risk result calculated from the ILI-called anomalies.
As a part of the PCO in Item A, PHMSA is requesting that Williams conduct a review of the
internal corrosion coupon inputs and update them with the current input. After updating the
inputs Williams would then be required to submit an updated information analysis to PHMSA
within 90 days of receipt of the Final Order. Williams is committed to the safe operation of its
pipeline facilities and in compliance with all applicable health, safety, and environmental laws
and regulations and works to continuously improve its processes and procedures in furtherance
of this goal. Consistent with its commitment Williams has identified improvements to strengthen
its risk model to better account for corrosion coupon data as action items for 2023. Fully
updating the risk model to be more comprehensive will take some time. Work is underway to
update the risk model that would drive this updated analysis, but Williams needs more than 90
days to provide the resulting analysis to PHMSA. Williams anticipates being able to complete
PHMSA’s request by July 2023. The risk model already captured that this pipeline was
susceptible to internal corrosion. Due to the fact that the pipeline was already flagged as
susceptible to internal corrosion and is currently subject to corrosion control monitoring and
mitigative strategies, Williams believes the additional time requested does not jeopardize public
safety.
In light of the foregoing, Williams requests that PHMSA reduce the civil penalty associated with
Item 1 to more accurately reflect the statutory and regulatory penalty assessment criteria and the
Company’s efforts to monitor and manage the threat of internal corrosion on its system.
Specifically, Williams requests that PHMSA reduce the proposed civil penalty based on the
following factors:
• Good Faith – PHMSA failed to provide Williams with any credit for the Company’s
good faith belief that it was acting in compliance with 49 C.F.R. § 195.452(g)(i)(2) and
its procedural requirements by using ILI information in its risk assessment rather than
modeled data based on coupon corrosion rates. As indicated above, the ILI data
provides more quantitative information about the pipeline asset as compared to the
more qualitative information provided by the coupon corrosion rate data. Moreover,



the Company used its risk model to determine that the segment is susceptible to the
threat of internal corrosion and has actively worked to monitor and mitigate that risk
as required by the federal pipeline safety regulations. In light of the Company’s good
faith efforts to comply with this requirement, Williams should be credited with a “-10”
for this factor.
• Other Matters as Justice May Require – PHMSA has also failed to provide Williams
with any credit to reflect that the alleged violation did not impact the safety of the
pipeline. As indicated, Williams uses quantitative data gathered from ILI tools to
assess the risk of internal corrosion on its system. Using that data, the Company
identified that the pipeline segment is susceptible to internal corrosion and actively
manages that threat. As such, any alleged failure to include coupon corrosion rate
data did not impact the system or the Company’s efforts to monitor its system for
internal corrosion. Williams should be credited with a “-10” for this factor.
• Gravity – Relatedly, PHMSA found that the penalty associated with NOPV Item 1
should be enhanced by a factor of “17” because the violation occurred in an HCA.
Although the violation does relate to an HCA, the Company requests that PHMSA
reduce the gravity factor to “1” to reflect that the alleged violation did not impact the
safe operation the pipeline. The Company monitors the pipeline for internal corrosion
and, as such, pipeline safety was minimally affected by the Company’s decision to use
ILI data rather than coupon corrosion rate data.
PHMSA Allegation:
2. 195.579 What must I do to mitigate internal corrosion?
a. …
b. Inhibitors. If you use corrosion inhibitors to mitigate internal corrosion, you
must –
i. …
iii. Examine the coupons or other monitoring equipment at least twice
each calendar year, but with intervals not exceeding 7 ½ months.
Williams failed to examine internal corrosion coupons at least twice each calendar year,
but with intervals not exceeding 7 ½ months in accordance with § 195.579(b)(3).
Specifically, Williams missed seven internal corrosion coupon inspections from 2017
through 2021.
Section 10.1 of its Corrosion Control for Hazardous Liquid Pipelines (Revision 3,
Effective Date 7/22/2021) manual states that “[i]f a pipeline transports any hazardous
liquid that could corrode the pipeline, investigate the corrosive effect of the hazardous
liquid on the pipeline and take adequate steps to mitigate internal corrosion.” Because
Williams transports corrosive hazardous liquid, it injects corrosion inhibitors and uses
internal corrosion coupons to monitor the effectiveness of the inhibitors.
In addition, Section 10.1 of its Corrosion Control for Hazardous Liquid Pipelines
(Revision 3, Effective Date 7/22/2021) manual states that Williams must “[c]heck



coupons or other monitoring equipment at least twice each calendar year, not to exceed
7 ½ months.” The results of these semiannual coupon inspections are recorded on form
F-227 Corrosion Coupon Report.
In calendar years 2017, 2018, 2019, 2020, and 2021, seven required internal corrosion
coupon inspections intervals were missed or exceeded the 7 ½ months required interval.
Therefore, Williams failed to examine internal corrosion coupons at least twice each
calendar year, but with intervals not exceeding 7 ½ months in accordance with its
procedure and § 195.579(b)(3).
Proposed Compliance Order Requirement: Williams must submit the findings
from a root cause failure analysis performed by an independent technical expert
regarding the company’s failure to complete the inspections to PHMSA for review
within 90 days of receipt of the Final Order. In addition, Williams must conduct the
required internal corrosion inspections within 30 days of receipt of the Final
Order.
Proposed Civil Penalty: $61,400
Williams Response:
Williams does not contest this allegation. As summarized above, Williams submitted a voluntary
self-disclosure to PHMSA on May 18, 2021. This initial disclosure identified missed coupon
inspections in anticipation of an upcoming inspection with PHMSA for these assets. However,
after submitting the initial disclosure, Williams continued its comprehensive review to determine
whether similar gaps existed for other offshore assets. After completing this review, Williams
supplemented its disclosure on August 11, 2021, identifying other instances where Williams had
missed the coupon pulls that were not within the scope of the PHMSA inspection. This
comprehensive voluntary disclosure highlights Williams commitment to continuously improve its
processes and procedures and sharing identified gaps with PHMSA.
After providing a supplemental self-disclosure, Williams conducted an internal root cause
analysis, which was shared with PHMSA on October 29, 2021. After discussing the findings of
Williams analysis and in coordination with PHMSA representatives, Williams engaged a third-
party consultant, DNV GL USA, Inc. (DNV) to conduct an investigation and perform an
independent root cause analysis. The completed DNV analysis was shared with PHMSA on
May 11, 2022 and a meeting was held with the Southwest Region Director, Mary McDaniel, and
Transportation Specialist, Thomas Warner, to discuss the findings on June 6, 2022. The
Williams and DNV RCA’s had very similar findings and recommendations regarding gaps in
management processes.
Williams has already implemented several of the recommendations from these reports, including
improved monitoring of contracted vendors and filling the management gaps identified in the root
cause analysis by implementing a work-task tracking system that maintains deadlines and
reminders for each coupon.



Below is a detailed description of the actions taken and changes that have been made as a
result of the recommendations.
1. Remediation of the deficient management process for tracking coupon pulls:
a. Williams instituted a Maximo work management system for all corrosion
coupons. This included the creation of a Preventive Maintenance (PM) task
within Maximo to track due dates and completion of both the coupon pull and
receiving data back from the lab.
b. The Maximo work order process was incorporated into the Williams Corrosion
Control Operating Requirements for both 49 CFR Part 192 and Part 195 assets.
c. Williams instituted a Chain of Custody process for the life cycle of the corrosion
coupon- from pull request to the receipt of the compliance data. This Chain of
Custody process was incorporated into the Williams Corrosion Control Operating
Requirements for both 49 CFR Part 192 and Part 195 assets.
d. Creation of a comprehensive flow chart documenting role and responsibilities for
the pulling of coupons.
2. Vendor accountability:
a. Met with management of the vendor who performs many of Williams’ coupon
pulls to address the gaps identified. Vendor submitted letters of commitment that
demonstrate their plan and commitment to:
i. Immediately implement the Chain of Custody process across the Williams
business.
ii. Process all corrosion coupons within 3 weeks.
b. Williams Supply Chain is sending out vendor letters enterprise wide addressing
our contractual requirements regarding the corrosion coupon pulls and data
analysis.
i. The Chain of Custody process is to be used on all Williams corrosion
coupons.
ii. Corrosion coupon processing time will not exceed 3 weeks.
iii. Failure to comply with the above (i or ii) could serve as cause for
termination of the contract.
3. Williams internal checks and communication:
a. Instituting quarterly reviews by division with representatives from Operations,
Tech Services, Asset Integrity, and SMEs. A talking point is to be documented
that addresses corrosion coupon records.
i. Evaluate whether the Chain of Custody process is being adhered to and
properly cataloged.
ii. Identification of any potential non-compliant records and if so, initiate
appropriate tracking mechanism and remedial actions.
b. Williams will incorporate an Administrative Management of Change (AMOC) to
ensure all stakeholders are notified and properly trained in any change to the
internal corrosion coupon monitoring program. This AMOC process will be written
into the Williams Operating Requirements.
In light of the foregoing and consistent with the Company’s self-disclosure of the underlying
allegation, Williams is requesting that PHMSA modify the proposed civil penalty to more
accurately reflect the Company’s voluntary self-disclosure of the underlying violation and the
Company’s proactive efforts to address the issue prior to issuance of the NOPV. Specifically, the



Company requests that the Agency reduce the associated civil penalty based on the following
factors:
• Circumstances – In its self-disclosure, along with the coupon locations on its
hazardous liquids lines, Williams also identified corrosion coupon inspection
deficiencies at certain locations on offshore gas lines, which were at issue in the NOPV
issued in CPF No. 4-2022-038. The mitigation factor applied in CPF 4-2022-038 was
50%, while the mitigation factor for NOPV Item 2 in action this is only 25%. PHMSA
has not provided any basis to support the discrepancy and Williams requests that
PHMSA reduce the civil penalty associated with NOPV Item 2 consistent with the
mitigation applied in CPF No. 4-2022-038.
• Culpability – In its calculation of the proposed civil penalty, PHMSA failed to properly
account for the fact that the Company identified the underlying violation and was taking
and had completed proactive steps to address the deficiencies prior to issuance of the
NOPV. Given the Company’s extensive efforts to address this issue, this factor should
be reduced from a “2” to a “-12.”
• Gravity – In the civil penalty worksheet, PHMSA enhanced the civil penalty associated
with this item by a factor of “20.40.” It is not clear why PHMSA selected this factor to
enhance the proposed civil penalty, but Williams requests that PHMSA use its
enforcement discretion to reduce this factor given that the missed inspections did not
have an impact on the Company’s assessment of the relevant segments. As
discussed in relation to NOPV Item 1, the Company was using other data to assess
the threat of internal corrosion on its system and continues to actively monitor,
manage, and mitigate that threat on its system. As a result, the failure to conduct the
internal corrosion coupon inspections did not impact the safety of the pipeline. As
such, Williams requests that PHMSA reduce or remove the “20.40” enhancement for
this factor.
Finally, the PCO associated with Item 2 of the NOPV contains two requirements. The first
requirement directs the Company provide the results of a third-party root cause analysis to the
Agency within 90 days of receipt of the Final Order. Prior to PHMSA issuing this NOPV,
Williams engaged DNV to perform an independent root cause analysis and shared those results
with PHMSA. After discussions between Williams and PHMSA representatives, Williams
understands that the DNV root cause analysis satisfies this PCO requirement. Williams
requests the Final Order reflect it has satisfied this requirement of the PCO.
As to the additional requirement in the PCO to complete the coupon pulls within 30 days of
receipt of the Final Order, Williams requests a modification to this requirement. Due to the
offshore locations of these coupons and difficulty arranging for their pull and transportation,
Williams requests that PHMSA permit it to comply with the PCO by pulling coupons during their
next scheduled inspection in 2023. The next regularly scheduled coupon pulls will occur in
March, April, and May of 2023.



* * * * *
Williams appreciates PHMSA’s continued engagement in this matter. These issues arise out of
a voluntary self-disclosure and the Company is electing not to further contest the underlying
allegations. As detailed above, Williams respectfully requests that the Agency consider this
additional explanation which supports a reduction of the proposed civil penalties to more
appropriately reflect the Company’s self-disclosure of the underlying issue and its proactive work
to improve its processes and procedures. Additionally, Williams requests that PHMSA modify the
PCO requirements considering the work the Company has done prior to and since issuance of
the NOPV.
Please let me know if you have any questions.
Respectfully,
John Bell
Manager of Pipeline Safety – Transmission & Gulf of Mexico
John.Bell@williams.com
Cc: Amy Shank – Williams, Director of Pipeline Safety & Asset Integrity
Mark Cluff – Williams, Vice President Safety & Operational Discipline

42022039NOPV_Closure Letter_03222024_(21-203269)_text.pdf

VIA ELECTRONIC MAIL TO: amy.shank@williams.com
March 22, 2024
Amy Shank
Vice President, Safety & Operational Discipline
Williams Field Services – Gulf Coast Company, LP
One Williams Center
P.O. Box 645
Tulsa, Oklahoma 74172
CPF 4-2022-039-NOPV
Dear Ms. Shank:
From May 18, 2021, through September 2, 2021, a representative from the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,
conducted an on-site pipeline safety inspection of Williams Field Services – Gulf Coast Company, LP
(Williams) hazardous liquid pipeline in the Gulf of Mexico. As a result of the inspection, Williams
was issued a Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order
on June 17, 2022. The Final Order, issued December 14, 2023, assessed a $116,600 civil penalty and
specified actions that needed to be taken to comply with the pipeline safety regulations.
Williams submitted payment on January 11, 2024 and on March 13, 2024 completed submitting
documentation to satisfy the Compliance Order. My staff reviewed the required documentation, and it
appears that all requirements of the Compliance Order have been satisfied.
This letter is to inform you that no further action is necessary, and this case is now closed. Thank you
for your cooperation.
Sincerely,
Bryan Lethcoe
Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Mr. John Bell, Manager of Pipeline Safety – Transmission & Gulf of Mexico,
John.Bell@williams.com
Mr. Clint Pernack, Director of Pipeline Safety & Asset Integrity,
Clint.Pernack@williams.com

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/42022039NOPV>
- Source ID: `phmsa-enforcement`
- SHA-256: `444627cbae5e82b8ac498871248194d71f983610a56d319e2408c89d335cd8af`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T22:04:46.717Z
- Document slug: `phmsa-enforcement-42022039nopv`

### Source metadata

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