# WILLIAMS FIELD SERVICES — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 120175032
- **title:** WILLIAMS FIELD SERVICES — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2017-11-09
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.402(a).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120175032
**body:**

Notice of Probable Violation involving WILLIAMS FIELD SERVICES. PHMSA's enforcement data identifies the cited regulation as 195.402(a). The case was opened on 2017-11-09 and is reported as closed as of 2018-07-24. 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:

120175032_Final Order_07242018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120175032/120175032_Final%20Order_07242018.pdf

120175032_Final Order_07242018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120175032/120175032_Final%20Order_07242018_text.pdf

120175032_NOPV PCP_11092017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120175032/120175032_NOPV%20PCP_11092017.pdf

120175032_NOPV PCP_11092017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120175032/120175032_NOPV%20PCP_11092017_text.pdf

120175032_Operator Response To Notice_12082017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120175032/120175032_Operator%20Response%20To%20Notice_12082017.pdf

120175032_Final Order_07242018_text.pdf

July 24, 2018
Mr. Alan S. Armstrong
President and Chief Executive Officer
Williams Companies, Inc.
One Williams Center
Tulsa, OK 74172
Re: CPF No. 1-2017-5032
Dear Mr. Armstrong:
Enclosed please find the Final Order issued in the above-referenced case to your subsidiary,
Williams Field Services Company, LLC. 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 December 8, 2017. This enforcement action is now closed. Service of the
Final Order by certified mail is effective upon the date of mailing 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: Mr. Robert Burrough, Director, Eastern Region, Office of Pipeline Safety, PHMSA
Mr. Mark Cluff, VP Safety & Operational Discipline, Williams Field Services Company,
LLC, Mark.Cluff@williams.com
Mr. Clint Ratke, Manager – Pipeline Safety, Williams Field Services Company, LLC,
Clint.Ratke@williams.com
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, )
a subsidiary of Williams Companies, Inc., )
Respondent. )
__________________________________________)
) CPF No. 1-2017-5032
FINAL ORDER
From March 6 through 10, 2017, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline
and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),
conducted an on-site pipeline safety inspection of the facilities and records of Williams Field
Services Company, LLC, a subsidiary of Williams Companies, Inc. (Williams or Respondent), in
Moundsville, West Virginia. Williams owns and operates interstate liquid pipelines throughout
the states of Pennsylvania, West Virginia, Colorado, Kansas, and Wyoming. The facility
inspected is a 50-mile pipeline initiating at the Oak Grove processing plant in Marshall County,
West Virginia, and running to the MarkWest Houston processing plant in Washington County,
Pennsylvania.
As a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Respondent,
by letter dated November 9, 2017, 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. § 195.402, and proposed assessing a civil penalty of $22,400 for the
alleged violation.
Williams responded to the Notice by letter dated December 8, 2017 (Response). The company
did not contest the allegation of violation and paid the proposed civil penalty of $22,400 by wire
transfer dated December 8, 2017. 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
without further proceedings.
FINDING OF VIOLATION
In its Response Williams did not contest the allegation in the Notice that it violated 49 C.F.R.
Part 195, as follows:



CPF No. 1-2017-5032
Page 2
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a), which states:
§ 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.
The Notice alleged that Williams violated 49 C.F.R. § 195.402(a) by failing to follow for each
pipeline system a manual of written procedures for conducting normal operations and
maintenance activities and handling abnormal operations and emergencies. Specifically, the
Notice alleged that Williams failed to follow its abnormal operating conditions (AOCs)
procedure for completion of AOC reports.
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. § 195.402(a) by failing to follow for
each pipeline system a manual of written procedures for conducting normal operations and
maintenance activities and handling abnormal operations and emergencies, specifically its
manual for AOCs.
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.1
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 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
1 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. 1-2017-5032
Page 3
require. The Notice proposed a total civil penalty of $22,400 for the violation cited above.
Item 1: The Notice proposed a civil penalty of $22,400 for Respondent’s violation of 49 C.F.R.
§ 195.402(a), for failing to follow for each pipeline system a manual of written procedures for
conducting normal operations and maintenance activities and handling abnormal operations and
emergencies, specifically, its manual for AOCs. Williams neither contested the allegation nor
presented any evidence or argument justifying a reduction in, or elimination of, the proposed
penalty. The violation was an activities violation discovered by PHMSA. Although pipeline
safety was minimally affected, Williams failed to take appropriate action to comply with a
requirement that was clearly applicable, and provided no explanation or justification for the
violation.
Accordingly, having reviewed the record and considered the assessment criteria for Item 1, I
assess Respondent a total civil penalty of $22,400, which has already been paid by Respondent
by wire transfer dated December 8, 2017.
The terms and conditions of this Final Order are effective upon service in accordance with
49 C.F.R. § 190.5.
July 24, 2018
___________________________________ __________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety
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