# WILLIAMS FIELD SERVICES — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 120165010
- **title:** WILLIAMS FIELD SERVICES — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2016-10-31
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.64(c)(1)(ii).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120165010
**body:**

Notice of Probable Violation involving WILLIAMS FIELD SERVICES. PHMSA's enforcement data identifies the cited regulation as 195.64(c)(1)(ii). The case was opened on 2016-10-31 and is reported as closed as of 2017-06-27. Proposed civil penalty: $22,400. Assessed civil penalty: $22,400. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120165010_Final Order_06272017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120165010/120165010_Final%20Order_06272017.pdf

120165010_Final Order_06272017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120165010/120165010_Final%20Order_06272017_text.pdf

120165010_NOPV PCP_10312016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120165010/120165010_NOPV%20PCP_10312016.pdf

120165010_NOPV PCP_10312016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120165010/120165010_NOPV%20PCP_10312016_text.pdf

120165010_Final Order_06272017_text.pdf

June 27, 2017
Mr. Alan Armstrong
President and Chief Executive Officer
Williams Partners, LP
One Williams Center
Tulsa, Oklahoma 74172
Re: CPF No. 1-2016-5010
Dear Mr. Armstrong:
Enclosed please find the Final Order issued in the above-referenced case. It makes a finding of
violation and assesses a civil penalty of $22,400. This is to acknowledge receipt of payment of
the full penalty amount, by wire transfer, dated November 15, 2016. This enforcement action is
now closed. Service of the Final Order is deemed effective 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: Director, Eastern Region, Office of Pipeline Safety, PHMSA
Ms. Stephanie Timmermeyer, Vice President of Safety and Regulatory Compliance,
Williams Field Services Company, LLC, 525 Central Park Drive, Oklahoma City,
Oklahoma 73105
CERTIFIED MAIL - RETURN 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 Company, LLC, )
an operating company of Williams Partners, LP, )
Respondent. )
________________________________________________)
) CPF No. 1-2016-5010
FINAL ORDER
On May 8, 2014, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), reviewed the March
24, 2014 Operator Registry Notification G-20140324-4502 from Williams Field Services
Company, LLC (Williams or Respondent), submitted online through the National Registry of
Pipeline and LNG Operators website. Williams is an operating company of Williams Partners,
LP, and operates approximately 1,153 miles of hazardous liquid pipeline throughout Colorado,
Kansas, Pennsylvania, West Virginia and Wyoming.1
As a result of the review, the Director, Eastern Region, OPS (Director), issued to Respondent, by
letter dated October 31, 2016, a Notice of Probable Violation and Proposed Civil Penalty
(Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Williams
had violated 49 C.F.R. § 195.64, and proposed assessing a civil penalty of $22,400 for the
alleged violation.
Williams did not respond to the Notice but paid the proposed civil penalty of $22,400. In
accordance with 49 C.F.R. § 190.208(a)(1), such payment authorizes the Associate
Administrator to make a finding of violation and to issue this Final Order.
FINDING OF VIOLATION
Williams did not contest the allegation 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. § 195.64(c)(1)(ii), which states:
1 Pipeline Safety Violation Report (Violation Report), (Oct. 31, 2016) (on file with PHMSA), at 1.



CPF No. 1-2016-5010
Page 2
§ 195.64 National Registry of Pipeline and LNG Operators.
(a) ….
(c) Changes. Each operator must notify PHMSA electronically through
the National Registry of Pipeline and LNG Operators at
http://opsweb.phmsa.dot.gov, of certain events.
(1) An operator must notify PHMSA of any of the following events not
later than 60 days before the event occurs:
(i) ….
(ii) Construction of 10 or more miles of a new or replacement
hazardous liquid pipeline.
The Notice alleged that Respondent violated 49 C.F.R. § 195.64(c)(1)(ii) by failing to notify
PHMSA of the construction of 10 or more miles of new hazardous liquid pipeline at least 60
days before the event occurred. Specifically, the Notice alleged that Williams failed to notify
PHMSA of a construction project that consisted of 50 miles of new hazardous liquid pipeline
until after construction of the project began. On May 8, 2014, a PHMSA inspector reviewed a
construction notification submitted by Williams, dated March 24, 2014. Williams submitted the
“Type G” (construction of 10 miles or more of line pipe) notification through the online National
Registry of Pipeline and LNG Operators website. Williams’ construction notification reported
field construction for approximately 50 miles of new hazardous liquid, interstate pipeline. The
notification indicated the new pipeline would start at the Oak Grove Extraction Plant in
Moundsville, West Virginia, and end at a meter and regulator site in Houston, Pennsylvania.
The Notice also alleged that Williams personnel confirmed that construction of the new
hazardous liquid line began on June 13, 2013, over nine months before the construction
notification was submitted to PHMSA. 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. § 195.64(c)(1)(ii) by failing to notify PHMSA of the construction of 10 or more miles
of new hazardous liquid pipeline at least 60 days before the event occurred.
This finding of violation will be considered a prior offense 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.2 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; and any effect
that the penalty may have on its ability to continue doing business; and the good faith of
2 These amounts are adjusted annually for inflation. See, e.g., Pipeline Safety: Inflation Adjustment of Maximum
Civil Penalties, 82 Fed. Reg. 19325 (April 27, 2017).



CPF No. 1-2016-5010
Page 3
Respondent in attempting to comply with the pipeline safety regulations. 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 $22,400 for the violations cited above.
Item 1: The Notice proposed a civil penalty of $22,400 for Respondent’s violation of 49 C.F.R.
§ 195.64(c)(1)(ii), for failing to notify PHMSA of the construction of 10 or more miles of new
hazardous liquid pipeline at least 60 days before the event occurred. Williams neither contested
the allegation nor presented any evidence or argument justifying elimination of the proposed
penalty. Accordingly, having reviewed the record and considered the assessment criteria, I
assess Respondent a civil penalty of $22,400 for violation of 49 C.F.R. § 195.64. Payment for
this Item was received on November 15, 2016.
In summary, having reviewed the record and considered the assessment criteria for the Item cited
above, I assess the respondent a total civil penalty of $22,400.
The terms and conditions of this Final Order are effective upon service in accordance with 49
C.F.R. § 190.5.
June 27, 2017
___________________________________ __________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety
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