{"operation":"document","citation":"CPF 12021064WL","title":"NORTHWEST PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-11-03","effective_on":null,"summary":"CLOSED warning letter citing 192.631(h)(6).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021064wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021064wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021064wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12021064WL","body":"Warning Letter involving NORTHWEST PIPELINE LLC. PHMSA's enforcement data identifies the cited regulation as 192.631(h)(6). The case was opened on 2021-11-03 and is reported as closed as of 2021-11-03. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12021064WL_Warning Letter_11032021_(20-179974).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021064WL/12021064WL_Warning%20Letter_11032021_(20-179974).pdf\n\n12021064WL_Warning Letter_11032021_(20-179974)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021064WL/12021064WL_Warning%20Letter_11032021_(20-179974)_text.pdf\n\n12021064WL_Warning Letter_11032021_(20-179974)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: alan.armstrong@williams.com\nNovember 3, 2021\nMr. Alan Armstrong\nPresident/CEO\nNorthwest Pipeline LLC\n2800 Post Oak Blvd\nHouston, TX 77056\nCPF 1-2021-064-WL\nDear Mr. Armstrong:\nFrom May 11 to May 14, 2020, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nNorthwest Pipeline LLC’s (NWPL) control room management program and Salt Lake City control\nroom.\nAs a result of the inspection/investigation, it is alleged that you have committed a probable\nviolation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The\nitem inspected and the probable violation is:\n1. § 192.631 Control room management.\n(a) …\n(h) Training. Each operator must establish a controller training\nprogram and review the training program content to identify potential\nimprovements at least once each calendar year, but at intervals not to\nexceed 15 months. An operator's program must provide for training\neach controller to carry out the roles and responsibilities defined by the\noperator. In addition, the training program must include the following\nelements:\n(6) Control room team training and exercises that include both\ncontrollers and other individuals, defined by the operator, who would\nreasonably be expected to operationally collaborate with controllers\n(control room personnel) during normal, abnormal, or emergency\n\n\n\nCPF 1-2021-064-WL\nsituations. Operators must comply with the team training requirements\nunder this paragraph by no later than January 23, 2018.\nNWPL failed to provide team training which included individuals other than controllers who\nwould reasonably be expected to operationally collaborate with controllers during normal,\nabnormal, or emergency situations.\nDuring the inspection, the PHMSA inspectors requested records showing that NWPL had\nconducted team training before the deadline required by the regulations. NWPL stated that they\ndid not have records documenting actual team training prior to 1/23/2019.\nTherefore, NWPL failed to comply with the requirements of § 192.631(h)(6).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related\nseries of violations. For violation occurring on or after January 11, 2021 and before May 3, 2021,\nthe maximum penalty may not exceed $222,504 per violation per day the violation persists, up to\na maximum of $2,225,034 for a related series of violations. For violation occurring on or after\nJuly 31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per\nviolation per day the violation persists, up to a maximum of $2,186,465 for a related series of\nviolations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the\nmaximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to\nexceed $2,132,679. For violation occurring on or after November 2, 2015 and before November\n27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum\npenalty not to exceed $2,090,022.\nWe have reviewed the circumstances and supporting documents involved in this case and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the item identified in this letter. Failure to do so will result in\nNorthwest Pipeline LLC being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2021-064-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n12021064WL_Warning Letter_11032021_(20-179974)_text Page 2 of 2","truncated":false,"body_characters":5157}