# WILLIAMS FIELD SERVICES — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 120185008
- **title:** WILLIAMS FIELD SERVICES — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2018-01-18
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.402(a), 195.402(c)(3), 199.105(b), 199.225(a)(1).
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-120185008
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120185008
**body:**

Notice of Probable Violation involving WILLIAMS FIELD SERVICES. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.402(c)(3),  199.105(b),  199.225(a)(1). The case was opened on 2018-01-18 and is reported as closed as of 2018-12-28. Proposed civil penalty: $192,900. Assessed civil penalty: $171,300. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120185008_Final Order_12102018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120185008/120185008_Final%20Order_12102018.pdf

120185008_Final Order_12102018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120185008/120185008_Final%20Order_12102018_text.pdf

120185008_NOPV PCP_01182018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120185008/120185008_NOPV%20PCP_01182018.pdf

120185008_NOPV PCP_01182018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120185008/120185008_NOPV%20PCP_01182018_text.pdf

120185008_Operator Response to Notice and Request for Hearing (Item 1)_03092018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120185008/120185008_Operator%20Response%20to%20Notice%20and%20Request%20for%20Hearing%20(Item%201)_03092018.pdf

120185008_Operator Response-Request for Hearing and Preliminary Statement Of Issues_03092018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120185008/120185008_Operator%20Response-Request%20for%20Hearing%20and%20Preliminary%20Statement%20Of%20Issues_03092018.pdf

120185008_Final Order_12102018_text.pdf

December 10, 2018
Mr. Alan S. Armstrong
President and Chief Executive Officer
The Williams Companies, Inc.
One Williams Center
Tulsa, OK 74172
Re: CPF No. 1-2018-5008
Dear Mr. Armstrong:
Enclosed please find the Final Order issued in the above-referenced case to your subsidiary,
Williams Field Services Company, LLC. It withdraws one of the allegations of violation, makes
other findings of violation and assesses a reduced civil penalty of $171,300. The penalty
payment terms are set forth in the Final Order. This enforcement action closes automatically
upon receipt of payment. 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
Ms. Amy Shank, Director – Pipeline Safety & Asset Integrity, Williams Field Services
Company, LLC, One Williams Center, 43-4 ATTN: Amy Shank, Tulsa, OK 74172
Mr. Keith J. Coyle, Counsel for Williams, Babst Calland, 505 9th Street N.W., Suite 700
Washington, D.C. 20004
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, ) CPF No. 1-2018-5008
a subsidiary of The Williams Companies, Inc., )
)
)
)
Respondent. )
__________________________________________)
FINAL ORDER
On February 17, 2015, 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 investigation of an accident involving the pipeline system operated by Williams
Field Services Company, LLC (Williams or Respondent), that occurred on February 11, 2015, at
the Williams Field Services Houston M&R facility located at 933 Western Avenue in Houston,
Pennsylvania (Accident). The Williams Companies, Inc., the parent company of Williams, owns
and operates interstate gas pipeline and gathering operations spanning the United States.1
The investigation arose out of an over-pressurization event at the Houston M&R facility and the
release of approximately 51 barrels of ethane. As a result of the investigation, the Director,
Eastern Region, OPS (Director), issued to Respondent, by letter dated January 18, 2018, 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. §§ 199.105(b),
199.225(a)(1), and 195.402(c)(3), and proposed assessing a civil penalty of $192,900 for the
alleged violations.
After requesting and receiving an extension of time to respond, Williams responded to the Notice
by letter dated March 9, 2018 (Response). Williams contested one of the allegations, submitted
additional information to demonstrate compliance, and requested a hearing on that single item.
By letter dated April 13, 2018, Respondent withdrew its request for a hearing after consultation
with the Director regarding the information demonstrating compliance, thereby authorizing the
entry of this Final Order without further notice.
1 The Williams Companies, Inc. website, available at https://investor.williams.com/williams-partners-lp (last
accessed October 18, 2018).



CPF No. 1-2018-5008
Page 2
FINDINGS OF VIOLATION
The Notice alleged that Respondent violated 49 C.F.R. Parts 195 and 199, as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 199.105(b), which at the time
of the Accident stated:
§ 199.105 Drug tests required.
Each operator shall conduct the following drug tests for the presence of
a prohibited drug:
(a) . . .
(b) Post-accident testing. As soon as possible but no later than 32 hours
after an accident, an operator shall drug test each employee whose
performance either contributed to the accident or cannot be completely
discounted as a contributing factor to the accident. An operator may decide
not to test under this paragraph but such a decision must be based on the
best information available immediately after the accident that the
employee’s performance could not have contributed to the accident or that,
because of the time between that performance and the accident, it is not
likely that a drug test would reveal whether the performance was affected
by drug use.2
The Notice alleged that Respondent violated 49 C.F.R. § 199.105(b) by failing to drug test each
employee whose performance either contributed to an accident or could not be completely
discounted as a contributing factor to the accident, as soon as possible but no later than 32 hours
after the accident. Specifically, the Notice alleged that Williams drug-tested its Senior Pipeline
Controller 36 hours after the Accident, four hours beyond the regulatory deadline.
In its Response, Williams contested this allegation of violation, noting that its pipeline controller
received a post-accident drug test within 20 hours of the incident, well within the 32-hour
regulatory deadline, and providing additional documentation. After reviewing the documents
provided in Williams’ response, the Director recommended withdrawal of the allegation of
violation.
Accordingly, after considering all of the evidence, I hereby order the allegation that Williams
violated 49 C.F.R. § 199.105(b) be withdrawn.
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 199.225(a)(1), which at the
time of the Accident stated:
§ 199.225 Alcohol tests required.
Each operator shall conduct the following types of alcohol tests for the
presence of alcohol:
(a) Post-accident. (1) As soon as practicable following an accident,
each operator shall test each surviving covered employee for alcohol if that
2 Section 199.105(b) was subsequently amended on January 23, 2017 (see 82 Fed. Reg. 8001).



CPF No. 1-2018-5008
Page 3
employee's performance of a covered function either contributed to the
accident or cannot be completely discounted as a contributing factor to the
accident. The decision not to administer a test under this section shall be
based on the operator’s determination, using the best available information
at the time of the determination, that the covered employee's performance
could not have contributed to the accident.3
The Notice alleged that Respondent violated 49 C.F.R. § 199.225(a)(1) by failing to test, as soon
as practicable following an accident, each surviving covered employee for alcohol if that
employee’s performance of a covered function either contributed to the accident or could not be
completely discounted as a contributing factor to the accident. Specifically, the Notice alleged
that Williams failed to test the Senior Pipeline Controller who was performing a covered
function during the Accident, for alcohol.
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. § 199.225(a)(1) by failing to test a
covered employee for alcohol as soon as practicable following an accident when that employee’s
performance of a covered function either contributed to the accident or could not be completely
discounted as a contributing factor to the accident.
Item 3: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(c)(3), 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 . . . .
(c) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following to
provide safety during maintenance and normal operations: . . .
(3) Operating, maintaining, and repairing the pipeline system in
accordance with each of the requirements of this subpart and subpart H of
this part.
The Notice alleged that Respondent violated 49 C.F.R. § 195.402(c)(3) by failing to follow its
own manual of written procedures for operating, maintaining, and repairing the pipeline system
in accordance with the requirements for pipeline repairs set forth in § 195.422. Specifically, the
Notice alleged that Williams failed to follow its own System Integrity Plan, Procedure 5.05-
ADM-025 for Lockout/Tagout and the control of hazardous energy sources when it replaced a
faulty solenoid valve on valve MOV17 at the Houston M&R facility, resulting in an over-
pressurization at the station.
Respondent did not contest this allegation of violation.4 Accordingly, based upon a review of all
3 Section 199.225(a)(1) was amended on January 23, 2017 (see 82 Fed. Reg. 8001).
4In its Response, Williams noted that it had provided additional employee training regarding Lockout/Tagout
procedures, replaced its previous procedure with Procedure 02.10.70.26 – Midstream Lockout Tagout (Control of



CPF No. 1-2018-5008
Page 4
of the evidence, I find that Respondent violated 49 C.F.R. § 195.402(c)(3) by failing to follow its
manual of written procedures for repairing the pipeline in accordance with the requirements set
forth in § 195.422.
These findings of violation will be considered prior offenses 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.5
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
require. The Notice proposed a total civil penalty of $192,900 for the violations cited above.
Item 1: The Notice proposed a civil penalty of $21,600 for Respondent’s violation of 49 C.F.R.
§ 199.105(b), for failing to conduct post-accident drug tests on each employee whose
performance either contributed to the accident or could not be completely discounted as a
contributing factor to the accident, as soon as practicable but no later than 32 hours after the
accident. For the reasons stated above, Item 1 is withdrawn in its entirety. Accordingly, the
proposed penalty for Item 1 in the amount of $21,600 is not assessed.
Item 2: The Notice proposed a civil penalty of $21,600 for Respondent’s violation of 49 C.F.R.
§ 199.225(a)(1) by failing to test, as soon as practicable following the Accident, each surviving
covered employee for alcohol if that employee’s performance of a covered function either
contributed to the Accident or cannot be completely discounted as a contributing factor to the
Accident. Williams neither contested the allegation nor presented any evidence or argument
justifying a reduction in or elimination of the proposed penalty. Although pipeline safety was
minimally affected by this violation, Williams failed to comply with a requirement that was
clearly applicable. Accordingly, having reviewed the record and considered the assessment
criteria, I assess Respondent a civil penalty of $21,600 for violation of 49 C.F.R.
§ 199.225(a)(1).
Item 3: The Notice proposed a civil penalty of $149,700 for Respondent’s violation of 49
Hazardous Energy Sources) and conducted training on the new procedure, and had installed a physical lockout switch
at the Houston Meter site for local control only.
5 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. 1-2018-5008
Page 5
C.F.R. § 195.402(c)(3), for failing to follow its own manual of written procedures for operating,
maintaining, and repairing the pipeline system in accordance with the pipeline repair
requirements set forth in § 195.422. Williams neither contested the allegation nor presented any
evidence or argument justifying a reduction in or elimination of the proposed penalty. I would
note that this particular violation was a casual factor to the Accident and Williams failed to
comply with a regulatory requirement that was clearly applicable. Accordingly, having reviewed
the record and considered the assessment criteria, I assess Respondent a civil penalty of
$149,700 for violation of 49 C.F.R. § 195.402(c)(3).
In summary, having reviewed the record and considered the assessment criteria for each of the
Items cited above, I assess Respondent a total civil penalty of $171,300.
Payment of the civil penalty must be made within 20 days of service. Federal regulations (49
C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer through the Federal
Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed
instructions are contained in the enclosure. Questions concerning wire transfers should be
directed to: Financial Operations Division (AMK-325), Federal Aviation Administration, Mike
Monroney Aeronautical Center, 6500 S MacArthur Blvd, Oklahoma City, Oklahoma 79169.
The Financial Operations Division telephone number is (405) 954-8845.
Failure to pay the $171,300 civil penalty will result in accrual of interest at the current annual
rate in accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to
those same authorities, a late penalty charge of six percent (6%) per annum will be charged if
payment is not made within 110 days of service. Furthermore, failure to pay the civil penalty
may result in referral of the matter to the Attorney General for appropriate action in a district
court of the United States.
Under 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this Final
Order to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey
Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of
Chief Counsel, PHMSA, at the same address, no later than 20 days after receipt of service of the
Final Order by Respondent. Any petition submitted must contain a brief statement of the issue(s)
and meet all other requirements of 49 C.F.R. § 190.243. The filing of a petition automatically
stays the payment of any civil penalty assessed. The other terms of the order, including any
corrective action, remain in effect unless the Associate Administrator, upon request, grants a
stay. If Respondent submits payment of the civil penalty, the Final Order becomes the final
administrative decision and the right to petition for reconsideration is waived.
The terms and conditions of this Final Order are effective upon service in accordance with 49
C.F.R. § 190.5.
December 10, 2018
___________________________________ __________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety
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