{"operation":"document","citation":"CPF 120171008M","title":"WILLIAMS FIELD SERVICES — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-03-23","effective_on":null,"summary":"CLOSED notice of amendment citing 195.202.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171008m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171008m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171008m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120171008M","body":"Notice of Amendment involving WILLIAMS FIELD SERVICES. PHMSA's enforcement data identifies the cited regulation as 195.202. The case was opened on 2017-03-23 and is reported as closed as of 2017-08-23. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120171008M_Closure Letter_08232017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171008M/120171008M_Closure%20Letter_08232017.pdf\n\n120171008M_Closure letter_08232017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171008M/120171008M_Closure%20letter_08232017_text.pdf\n\n120171008M_Notice of Amendment_03232017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171008M/120171008M_Notice%20of%20Amendment_03232017.pdf\n\n120171008M_Notice of Amendment_03232017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171008M/120171008M_Notice%20of%20Amendment_03232017_text.pdf\n\n120171008M_Operator Response to Notice_04212017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171008M/120171008M_Operator%20Response%20to%20Notice_04212017.pdf\n\n120171008M_Closure letter_08232017_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nAugust 23, 2017\nMark Cluff\nVice President, Safety & Operational Discipline\nWilliams Field Services Company, LLC\nOne Williams Center\nTulsa, OK 74172\nCPF 1-2017-1008M\nDear Mr. Cluff:\nFrom December 15 to 18, 2015; a representative from the Pipeline and Hazardous Materials Safety\nAdministration, Office of Pipeline Safety, pursuant to Chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of Williams Field Services Company, LLC’s\n(Williams) written specifications and records for the construction of an interstate ethane pipeline\nsystem, known as the Ohio Valley Midstream, in Pittsburgh, Pennsylvania. As a result of the\ninspection, Williams was issued a Notice of Amendment (NOA) on March 23, 2017, which\nproposed amendments to its written specifications.\nWilliams submitted its amended written specifications on July 26, 2017. My staff reviewed the\namended written specifications, and it appears that the inadequacies outlined in the NOA have\nbeen corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nActing Director, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n120171008M_Notice of Amendment_03232017_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nMarch 23, 2017\nMark Cluff\nVice President, Safety & Operational Discipline\nWilliams Field Services Company, LLC\nOne Williams Center\nTulsa, OK 74172\nCPF 1-2017-1008M\nDear Mr. Cluff:\nFrom December 15 to 18, 2015, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nWilliams Field Services Company, LLC’s (Williams) written specification and records for the\nconstruction of an interstate ethane pipeline system (Ohio Valley Midstream (OVM)) in\nPittsburgh, Pennsylvania.\nBased on the inspection, PHMSA has identified the apparent inadequacies found within Williams’s\nwritten specifications and standards, as described below:\n1. §195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive written\nspecifications or standards that are consistent with the requirements of this part.\nWilliams’s written specification, Onshore Carbon Steel Pipeline Design, DG-4851, Effective\nDate: 5/21/2003 did not have adequate instructions to ensure each closure installed in a pipeline\nsystem will comply with the ASME Boiler and Pressure Vessel Code, section VII, Pressure Vessel\nDivision I, 2007 edition, July 2007 as prescribed in §195.124.\nDuring this inspection, a PHMSA representative requested to review Williams’s written\nspecifications or standards that require closures to comply with the ASME Boiler and Pressure\nVessel Code (BPVC), Section VIII, Pressure Vessels, Division 1. Subsequently, Williams\nprovided its Onshore Carbon Steel Pipeline Design, DG-4851, Section 2.2, which states that\n\n\n\nCPF 1-2017-1008M\n“pipelines shall be designed and fabricated to comply with the latest revision of all applicable\nfederal, state and local codes, standards and regulations, except as modified to be more stringent\nby WES’s.” Section 2.2 also states that the “[c]odes and standards shall include but are not limited\nto:” and then listed certain industry codes and standards. The PHMSA representative noted that\nthe aforementioned did not reference ASME BPVC, Section VIII, Pressure Vessels, Division 1.\nAt the exit interview, the PHMSA representative discussed with Williams that the Onshore Carbon\nSteel Pipeline Design, DG-4851, Section 2.2 did not mention ASME BPVC, Section VIII, Pressure\nVessels, Division 1 in accordance with§195.124.\nOn December 22, 2015, the PHMSA representative sent a follow-up e-mail to Williams regarding\nthe request to review its process that ensures closures met the terms in ASME Boiler and Pressure\nVessel Code (BPVC), Section VIII, Pressure Vessels, Division 1. Williams responded on\nJanuary 8, 2016 stating:\n“[T]he design for the project specified that the pipeline would be\nconstructed in accordance with 49 CFR 195 and as well as ASME B31.4.\nIncluded in that standard is section 404.7 stating that that the ASME\nBoiler and Pressure Vessel Code, Section VIII is to be followed for\nclosures. Enclosed is the standard drawing and closure documentation\nstating that the closures comply with ASME BPVC Section VIII Div 1.\nEnclosed is a copy of the Closure Drawing and Design Calculations\ndemonstrating its compliance.”\nPursuant to §195.124, ASME BPVC, Section VIII, Division 1, 2007 edition, July 1, 2007 is the\nedition incorporated by reference, as seen in §195.3. ASME/ANSI B31.4-2009 Pipeline\nTransportation Systems for Liquid Hydrocarbon and Other (ASME/ANSI B31.4-2009), under the\nChapter II, 404.7 does reference ASME BPVC, Section VIII, Division 1 requirements on closures.1\nHowever, Appendix I of ASME B31.4-2009, which list the specific editions of standards\nincorporated in that Code, refers to ASME BPVC, 1998 Ed. and 1999 Addenda. This edition is\nnot an approved standard which is incorporated by reference for §195.124.\nIn addition, Williams’s closure drawing and design calculation records refers to ASME Section\nVIII Division 1 2010 Edition, Addenda 2011.\nClearly, the reference to ASME B31.4 and Part 195 in Onshore Carbon Steel Pipeline Design,\nDG-4851 did not ensure compliance with §195.124.\nThus, Williams’s written specification, Onshore Carbon Steel Pipeline Design, DG-4851, did not\ninclude adequate instructions to ensure that each closures installed in a pipeline system must\ncomply with the ASME Boiler and Pressure Vessel Code, section VII, Pressure Vessel Division I,\n2007 edition, July 2007 as prescribed in §195.124.\n2. §195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive written\nspecifications or standards that are consistent with the requirements of this part.\n1 As seen in §195.3, ASME B31.4-2006 Pipeline Transportation Systems for Liquid Hydrocarbon and Other Liquid\nis an approved incorporated by reference for §§195.110(a) and 185.452(h).\n120171008M_Notice of Amendment_03232017_text Page 2 of 5\n\n\n\nCPF 1-2017-1008M\nWilliams’s written specifications and standards were inadequate because it did not include clear,\ndetailed instructions for pipeline location in accordance with §195.210.\nDuring this inspection, a PHMSA representative requested to review written specifications or\nstandards for pipeline location in accordance with §195.210. Subsequently, Williams provided its\nEngineering Standard, Document No.: CZ-9019, Form Revision A, Effective Date 10/15/01,\nDocument titled: New Construction Hazardous Liquids Checklist. Williams indicated that the New\nConstruction Hazardous Liquids Checklist is a pre-filled checklist that shows an “X” under a\nparty’s responsibility and performance for a specific code sections in 49 C.F.R. Part 195. The\nPHMSA representative noticed the checklist had a blank space next to the “Project Name,”\n“Project Number,” “Approved by,” and “Prepared By.” The New Construction Hazardous Liquids\nChecklist was incomplete. Moreover, Williams was unable to provide a written specification or\nstandard that referenced this document. During the exit interview, Williams informed the PHMSA\nrepresentative that the Project Managers for the construction of the OVM confirmed that the\nSystem Integrity Program did not mention the New Construction Hazardous Liquids Checklist.\nConsequently, the PHMSA representative discussed with Williams the lack of written\nspecification or standard that referenced the New Construction Hazardous Liquids Checklist.\nOn December 22, 2015, the PHMSA representative sent a follow-up e-mail to Williams regarding\nthe request to review a written specification or standard that referenced the New Construction\nHazardous Liquids Checklist. The PHMSA representative requested the current, official copy of\nWilliams Field Services construction specification or standard, which describes pipeline location\nin accordance with §195.210. In addition, the PHMSA representative requested a completed copy\nof the New Construction Hazardous Liquids Checklist for the construction of the OVM.\nWilliams responded on January 8, 2016 stating, “CZ-9019 was not filled out for this project. There\nis no specific requirement in Williams standards stating this document must be filled out. The copy\nreceived in the audit is the current official copy. This form is not mentioned on any other procedure\nstandard or specification. Document CZ-9019 provides the specification.”\nFirst, the New Construction Hazardous Liquids Checklist did not include information about\nplacing the pipeline “as far as practicable” from areas as prescribed in §195.210. On page 4 of New\nConstruction Hazardous Liquids Checklist, it states “§195.210 Pipeline R.O.W. to maintain a\nminimum distance of 50 feet from: Private dwellings, Industrial buildings, Places of public\nassembly. Unless the pipe is provided with an additional 12” of cover in additional to the described\nminimum ground cover stated in this document under 195.248.” The New Construction Hazardous\nLiquids Checklist only states the minimum distance allowed.\nSecond, the New Construction Hazardous Liquids Checklist was incomplete. The New\nConstruction Hazardous Liquids Checklist did not contain information about the construction of\nthe OVM next to the appropriate fields therein.\nLast, William presented the New Construction Hazardous Liquids Checklist to the PHMSA\nrepresentative as a stand-alone document. Williams did not produce a written specification or\nstandard with instructions to use the New Construction Hazardous Liquids Checklist.\n120171008M_Notice of Amendment_03232017_text Page 3 of 5\n\n\n\nCPF 1-2017-1008M\nTherefore, Williams’s written specification and standard were inadequate since there was no\ninstructions on which document to use or how it should be filled out for ensuring compliance\nwith §195.210.\n3. §195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive written\nspecifications or standards that are consistent with the requirements of this part.\nWilliams’s written specification, Onshore Carbon Steel Pipeline Installation, ES-4852, Effective\nDate: 9/30/2015 included a provision that was unclear and inconsistent with §195.248. Pursuant\nto §195.248, the depth of cover for crossing of inland bodies of water with a width of at least\n100 feet (30 millimeters) from high water mark to high water mark must be 48 inches for normal\nexcavation.\nDuring this inspection, a PHMSA representative requested to review written specification or\nstandards for pipeline installed with a depth of cover in accordance with §195.248. Subsequently,\nWilliams provided Onshore Carbon Steel Pipeline Installation, ES-4852, Section 7.8 which states\nin part, “[w]hen no cover is specified, the following shall be the minimum: Water Crossing,\nincluding Marshes 42 Inches of Cover, Water Crossing 60 Inches of Cover.” PHMSA\nrepresentative noted that there were two “Water Crossing” locations with different inches of cover.\nTherefore, the Onshore Carbon Steel Pipeline Installation, ES-4852, Section 7.8 did not define a\n“Water Crossing” so that it is clear which requirement meets §195.248.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 90 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\n120171008M_Notice of Amendment_03232017_text Page 4 of 5\n\n\n\nCPF 1-2017-1008M\nIt is requested (not mandated) that Williams Field Services maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Robert Burrough, Acting Director, PHMSA Eastern\nRegion, 820 Bear Tavern Road, Suite 103, West Trenton, NJ 08628. In correspondence concerning\nthis matter, please refer to CPF 1-2017-1008M and, for each document you submit, please provide\na copy in electronic format whenever possible.\nSincerely,\nRobert Burrough\nActing Director, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120171008M_Notice of Amendment_03232017_text Page 5 of 5","truncated":false,"body_characters":15184}