# WILLIAMS FIELD SERVICES — Warning Letter

- **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:** Not available
- **summary:** CLOSED warning letter citing 195.402(a).
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- **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.

Official case documents:

120175031W_Warning Letter_10302017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120175031W/120175031W_Warning%20Letter_10302017.pdf

120175031W_Warning Letter_10302017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120175031W/120175031W_Warning%20Letter_10302017_text.pdf

120175031W_Warning Letter_10302017_text.pdf

WARNING LETTER
OVERNIGHT EXPRESS DELIVERY
October 30, 2017
Mr. Mark Cluff
VP Safety & Operational Discipline
Williams Field Services
One Williams Center
Tulsa, OK 74172
CPF 1-2017-5031W
Dear Mr. Cluff:
From March 6 – 10, 2017, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected
Williams Field Services’ (Williams) pipeline facility located in Moundsville, West Virginia.
As a result of the inspection, it is alleged that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected
and the probable violation(s) are:
1. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a
manual of written procedures for conducting normal operations and maintenance
activities and handling abnormal operations and emergencies. This manual shall
be reviewed at intervals not exceeding 15 months, but at least once each calendar
year, and appropriate changes made as necessary to insure that the manual is
effective. This manual shall be prepared before initial operations of a pipeline
system commence, and appropriate parts shall be kept at locations where
operations and maintenance activities are conducted.
Williams failed to conduct an annual review of its emergency response plans and procedures at
intervals not exceeding 15 months, but at least once each calendar year to insure that the manual



CPF 1-2017-5031W
is effective. Specifically, Williams failed to conduct an annual review of its emergency response
plans for the 2014 - 2016 calendar years.
During the inspection, the PHMSA inspector requested annual review records for the 2014 - 2016
calendar years. Williams stated they have no specific documentation related to an annual review
other than the change log on its procedure, Emergency Response and Planning, SIP-ADM-12.01,
Effective 11/17/16. Williams was unable to provide any data or response as to why the annual
review was not conducted.
Therefore, Williams failed to conduct an annual review of its emergency response plans and
procedures during the 2014, 2015 and 2016 calendar years.
2. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a
manual of written procedures for conducting normal operations and maintenance
activities and handling abnormal operations and emergencies. This manual shall
be reviewed at intervals not exceeding 15 months, but at least once each calendar
year, and appropriate changes made as necessary to insure that the manual is
effective. This manual shall be prepared before initial operations of a pipeline
system commence, and appropriate parts shall be kept at locations where
operations and maintenance activities are conducted.
Williams failed to follow its manual of written procedures for conducting normal operations and
maintenance activities. Specifically, Williams failed to follow its Pipeline Integrity procedure for
examining and documenting exposed pipe conditions in accordance with § 195.589(c).
During the inspection, the PHMSA inspector reviewed Williams’ Examining and Documenting
the Condition of an Underground Pipeline or Related Facility When Exposed – Pipeline Integrity,
dated 4/10/13 (Procedure) and 02-OPR-1581 – Maintenance Reports (Records).
The Procedure stated, “Each time a buried Pipeline or related underground Facility is exposed for
any reason (intentionally or unintentionally), it must be thoroughly inspected (end-to-end) and the
conditions documented on the appropriate form(s).” Additionally, the Procedure requires that the
02-OPR-1581 – Maintenance Report must be filled out.
In 4 instances the Records indicated incomplete data on the following sections:
• Leak Data
• Property Damage
• Shallow/Exposed Pipe
• Non-Destructive Testing and Pressure Test Data
• Pipe Installed
• Pipe Retired
• Fabricated Bends
• Pipe Detail
• Approval and Signatures
120175031W_Warning Letter_10302017_text Page 2 of 3



CPF 1-2017-5031W
The PHMSA inspector asked Williams where the applicable information is documented and
Williams was not able to provide a response.
Therefore, Williams failed to follow its Pipeline Integrity Procedure regarding completion of
documentation of exposed pipeline conditions.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$209,002 per violation per day the violation persists up to a maximum of $2,090,022 for a related
series of violations. We have reviewed the circumstances and supporting documents involved in
this case, and have decided not to conduct additional enforcement action or penalty assessment
proceedings at this time. We advise you to correct the item(s) identified in this letter. Failure to do
so will result in Williams being subject to additional enforcement action.
Please be advised that all material you submit in response to this enforcement action is subject to
being made publicly available. If you believe that any portion of your responsive material qualifies
for confidential treatment under 5 U.S.C. 552(b), along with the complete original document you
must provide a second copy of the document with the portions you believe qualify for confidential
treatment redacted and an explanation of why you believe the redacted information qualifies for
confidential treatment under 5 U.S.C. 552(b).
No reply to this letter is required. If you choose to reply, please submit all correspondence in this
matter to Robert Burrough, Acting Director, PHMSA Eastern Region, 820 Bear Tavern Road,
Suite 103, West Trenton, NJ 08628. Please refer to CPF 1- 2017-5031W on each document you
submit, and whenever possible provide a signed PDF copy in electronic format. Smaller files may
be emailed to robert.burrough@dot.gov. Larger files should be sent on a CD accompanied by the
original paper copy to the Eastern Region Office.
Sincerely,
Robert Burrough
Acting Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
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