{"operation":"document","citation":"CPF 120175030M","title":"WILLIAMS FIELD SERVICES — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-10-30","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(a), 195.402(c)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120175030m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120175030m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120175030m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120175030M","body":"Notice of Amendment involving WILLIAMS FIELD SERVICES. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.402(c)(3). The case was opened on 2017-10-30 and is reported as closed as of 2018-02-27. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120175030M_Closure Letter_02272018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120175030M/120175030M_Closure%20Letter_02272018.pdf\n\n120175030M_Closure Letter_02272018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120175030M/120175030M_Closure%20Letter_02272018_text.pdf\n\n120175030M_Notice Of Amendment_10302017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120175030M/120175030M_Notice%20Of%20Amendment_10302017.pdf\n\n120175030M_Notice Of Amendment_10302017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120175030M/120175030M_Notice%20Of%20Amendment_10302017_text.pdf\n\n120175030M_Closure Letter_02272018_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nFebruary 27, 2018\nMr. Mark Cluff\nVP Safety & Operational Discipline\nWilliams Field Services\nOne Williams Center\nTulsa, OK 74172\nCPF 1-2017-5030M\nDear Mr. Cluff:\nFrom March 6 – 10, 2017, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Williams\nField Services’ (Williams) procedures for operations and maintenance in Moundsville,\nWest Virginia.\nAs a result of the inspection, Williams was issued a Notice of Amendment (NOA) dated\nOctober 30, 2017. In response to the NOA, Williams requested a 90-day time extension on\nNovember 29, 2017. PHMSA granted the request on November 30, 2017. Williams submitted\nrevised procedures on February 16, 2018. PHMSA reviewed the amended procedures, and it\nappears that the inadequacies outlined in this NOA have been corrected.\nThis letter is to inform you that no further action is necessary, and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n120175030M_Notice Of Amendment_10302017_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nOctober 30, 2017\nMr. Mark Cluff\nVP Safety & Operational Discipline\nWilliams Field Services\nOne Williams Center\nTulsa, OK 74172\nCPF 1-2017-5030M\nDear Mr. Cluff:\nFrom March 6 – 10, 2017, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nWilliams Field Services’ (Williams) procedures for operations and maintenance in\nMoundsville, West Virginia.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nWilliams’ plans or procedures, as described below:\n1. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall be\nreviewed at intervals not exceeding 15 months, but at least once each calendar year,\nand appropriate changes made as necessary to insure that the manual is effective.\nThis manual shall be prepared before initial operations of a pipeline system\ncommence, and appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\nWilliams’ written procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies for each pipeline system were inadequate.\nSpecifically, Williams’ procedures failed to include sufficient guidance for emergency response\nsupervisors to be knowledgeable of emergency response procedures for which they are\n\n\n\nCPF 1-2017-5030M\nresponsible, per the requirements of § 195.403(c).\nSection 195.403(c) states:\n“Each operator shall require and verify that its supervisors maintain a thorough knowledge of that\nportion of the emergency response procedures established under §195.402 for which they are\nresponsible to ensure compliance.”\nDuring the inspection, the PHMSA inspector reviewed Williams’ SIP-ADM-12.01 Emergency\nResponse and Planning – Emergency Management, dated 11/17/16 (Procedure). The Procedure\ndid not include adequate details on the following:\n• Defining Emergency response supervisor role\n• Emergency response supervisor training\n• Emergency response supervisor knowledge verification\n• Training requirements\n• Training documentation\nDuring the inspection, the PHMSA inspector asked Williams where the applicable information\nwas documented and Williams was not able to provide a response.\nTherefore, Williams failed to include guidance in its procedures for emergency response\nsupervisors, per the requirements of § 195.403(c).\n2. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\nWilliams’ procedures for operating, maintaining and repairing the pipeline system in accordance\nwith each of the requirements of this subpart and subpart H of this part are inadequate for\noverpressure safety devices. Specifically, Williams’ procedure failed to provide sufficient\nguidance on how to conduct and document relief valve inspections, per § 195.428(a).\nSection 195.428(a) states in part:\n“…inspect and test each pressure limiting device, relief valve, pressure regulator, or other item of\npressure control equipment to determine that it is functioning properly, is in good mechanical\ncondition, and is adequate from the standpoint of capacity and reliability of operation for the\nservice in which it is used.”\nDuring the inspection, the PHMSA inspector reviewed Williams’ 9.01-ADM-018 Tests and\nInspections of Overpressure Protection and Pressure Limiting Devices - Operations, dated\n10/21/11, (Procedure) and Form WES-57 – Regulator, Overpressure Protection Device and\nControl Valve Inspection (Record), Rev #2, dated 1/1/07.\n120175030M_Notice Of Amendment_10302017_text Page 2 of 4\n\n\n\nCPF 1-2017-5030M\nWilliams’ Procedure did not provide sufficient guidance on conducting and documenting a relief\nvalve inspection.\nWilliams’ Procedure did not include any definitions, requirements or guidance on the related\nRecord for, but not limited to, the following Record fields:\n• Controlled Pressure Found\n• Controlled Pressure Left\n• Reset Pressure Found\n• Reset Pressure Left\n• Required Set Pressure\n• Capacity Mcf/Hr at Set Point\nTherefore, Williams failed to provide sufficient guidance on how to conduct and document relief\nvalve inspections, per the requirements of § 195.428(a).\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. Failure to respond within 30 days of receipt\nof this Notice constitutes a waiver of your right to contest the allegations in this Notice, and\nauthorizes 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 30 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.\nIt is requested (not mandated) that Williams maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Robert Burrough, Acting Director, PHMSA Eastern Region,\n820 Bear Tavern Road, Suite 103, West Trenton, NJ 08628. In correspondence concerning this\nmatter, please refer to CPF 1-2017-5030M and, whenever possible provide a signed PDF copy in\nelectronic format. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should\nbe sent on a CD accompanied by the original paper copy to the Eastern Region Office.\n120175030M_Notice Of Amendment_10302017_text Page 3 of 4\n\n\n\nCPF 1-2017-5030M\nAdditionally, if you choose to respond to this (or any other case), please ensure that any response\nletter pertains solely to one CPF case number.\nSincerely,\nRobert Burrough\nActing Director, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120175030M_Notice Of Amendment_10302017_text Page 4 of 4","truncated":false,"body_characters":9898}