NORTHWEST PIPELINE LLC — Warning Letter

12021064WL_Warning Letter_11032021_(20-179974)_text.pdf, page 1Official PDFWARNING LETTER VIA ELECTRONIC MAIL TO: alan.armstrong@williams.com November 3, 2021 Mr. Alan Armstrong President/CEO Northwest Pipeline LLC 2800 Post Oak Blvd Houston, TX 77056 CPF 1-2021-064-WL Dear Mr. Armstrong: From May 11 to May 14, 2020, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected Northwest Pipeline LLC’s (NWPL) control room management program and Salt Lake City control room. As a result of the inspection/investigation, it is alleged that you have committed a probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and the probable violation is: 1. § 192.631 Control room management. (a) … (h) Training. Each operator must establish a controller training program and review the training program content to identify potential improvements at least once each calendar year, but at intervals not to exceed 15 months. An operator's program must provide for training each controller to carry out the roles and responsibilities defined by the operator. In addition, the training program must include the following elements: (6) Control room team training and exercises that include both controllers and other individuals, defined by the operator, who would reasonably be expected to operationally collaborate with controllers (control room personnel) during normal, abnormal, or emergency#

12021064WL_Warning Letter_11032021_(20-179974)_text.pdf, page 2CPF 1-2021-064-WL situations. Operators must comply with the team training requirements under this paragraph by no later than January 23, 2018. NWPL failed to provide team training which included individuals other than controllers who would reasonably be expected to operationally collaborate with controllers during normal, abnormal, or emergency situations. During the inspection, the PHMSA inspectors requested records showing that NWPL had conducted team training before the deadline required by the regulations. NWPL stated that they did not have records documenting actual team training prior to 1/23/2019. Therefore, NWPL failed to comply with the requirements of § 192.631(h)(6). Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related series of violations. For violation occurring on or after January 11, 2021 and before May 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for a related series of violations. For violation occurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related series of violations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to exceed $2,132,679. For violation occurring on or after November 2, 2015 and before November 27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum penalty not to exceed $2,090,022. 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 identified in this letter. Failure to do so will result in Northwest Pipeline LLC being subject to additional enforcement action. No reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 1-2021-064-WL. 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). Sincerely, Robert Burrough Director, Eastern Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration 12021064WL_Warning Letter_11032021_(20-179974)_text Page 2 of 2#