{"operation":"document","citation":"CPF 120175031W","title":"WILLIAMS FIELD SERVICES — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-10-30","effective_on":null,"summary":"CLOSED warning letter citing 195.402(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120175031w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120175031w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120175031w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120175031W","body":"Warning Letter involving WILLIAMS FIELD SERVICES. PHMSA's enforcement data identifies the cited regulation as 195.402(a). The case was opened on 2017-10-30 and is reported as closed as of 2017-10-30. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120175031W_Warning Letter_10302017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120175031W/120175031W_Warning%20Letter_10302017.pdf\n\n120175031W_Warning Letter_10302017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120175031W/120175031W_Warning%20Letter_10302017_text.pdf\n\n120175031W_Warning Letter_10302017_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nOctober 30, 2017\nMr. Mark Cluff\nVP Safety & Operational Discipline\nWilliams Field Services\nOne Williams Center\nTulsa, OK 74172\nCPF 1-2017-5031W\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) pipeline facility located in Moundsville, West Virginia.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violation(s) are:\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\nbe reviewed at intervals not exceeding 15 months, but at least once each calendar\nyear, and appropriate changes made as necessary to insure that the manual is\neffective. This manual shall be prepared before initial operations of a pipeline\nsystem commence, and appropriate parts shall be kept at locations where\noperations and maintenance activities are conducted.\nWilliams failed to conduct an annual review of its emergency response plans and procedures at\nintervals not exceeding 15 months, but at least once each calendar year to insure that the manual\n\n\n\nCPF 1-2017-5031W\nis effective. Specifically, Williams failed to conduct an annual review of its emergency response\nplans for the 2014 - 2016 calendar years.\nDuring the inspection, the PHMSA inspector requested annual review records for the 2014 - 2016\ncalendar years. Williams stated they have no specific documentation related to an annual review\nother than the change log on its procedure, Emergency Response and Planning, SIP-ADM-12.01,\nEffective 11/17/16. Williams was unable to provide any data or response as to why the annual\nreview was not conducted.\nTherefore, Williams failed to conduct an annual review of its emergency response plans and\nprocedures during the 2014, 2015 and 2016 calendar years.\n2. §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\nbe reviewed at intervals not exceeding 15 months, but at least once each calendar\nyear, and appropriate changes made as necessary to insure that the manual is\neffective. This manual shall be prepared before initial operations of a pipeline\nsystem commence, and appropriate parts shall be kept at locations where\noperations and maintenance activities are conducted.\nWilliams failed to follow its manual of written procedures for conducting normal operations and\nmaintenance activities. Specifically, Williams failed to follow its Pipeline Integrity procedure for\nexamining and documenting exposed pipe conditions in accordance with § 195.589(c).\nDuring the inspection, the PHMSA inspector reviewed Williams’ Examining and Documenting\nthe Condition of an Underground Pipeline or Related Facility When Exposed – Pipeline Integrity,\ndated 4/10/13 (Procedure) and 02-OPR-1581 – Maintenance Reports (Records).\nThe Procedure stated, “Each time a buried Pipeline or related underground Facility is exposed for\nany reason (intentionally or unintentionally), it must be thoroughly inspected (end-to-end) and the\nconditions documented on the appropriate form(s).” Additionally, the Procedure requires that the\n02-OPR-1581 – Maintenance Report must be filled out.\nIn 4 instances the Records indicated incomplete data on the following sections:\n• Leak Data\n• Property Damage\n• Shallow/Exposed Pipe\n• Non-Destructive Testing and Pressure Test Data\n• Pipe Installed\n• Pipe Retired\n• Fabricated Bends\n• Pipe Detail\n• Approval and Signatures\n120175031W_Warning Letter_10302017_text Page 2 of 3\n\n\n\nCPF 1-2017-5031W\nThe PHMSA inspector asked Williams where the applicable information is documented and\nWilliams was not able to provide a response.\nTherefore, Williams failed to follow its Pipeline Integrity Procedure regarding completion of\ndocumentation of exposed pipeline conditions.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$209,002 per violation per day the violation persists up to a maximum of $2,090,022 for a related\nseries of violations. We have reviewed the circumstances and supporting documents involved in\nthis case, and have decided not to conduct additional enforcement action or penalty assessment\nproceedings at this time. We advise you to correct the item(s) identified in this letter. Failure to do\nso will result in Williams being subject to additional enforcement action.\nPlease be advised that all material you submit in response to this enforcement action is subject to\nbeing made publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for confidential\ntreatment redacted and an explanation of why you believe the redacted information qualifies for\nconfidential treatment under 5 U.S.C. 552(b).\nNo reply to this letter is required. If you choose to reply, please submit all correspondence in this\nmatter to Robert Burrough, Acting Director, PHMSA Eastern Region, 820 Bear Tavern Road,\nSuite 103, West Trenton, NJ 08628. Please refer to CPF 1- 2017-5031W on each document you\nsubmit, and whenever possible provide a signed PDF copy in electronic format. Smaller files may\nbe emailed to robert.burrough@dot.gov. Larger files should be sent on a CD accompanied by the\noriginal paper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nActing Director, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120175031W_Warning Letter_10302017_text Page 3 of 3","truncated":false,"body_characters":6898}