# PINE NEEDLE OPERATING COMPANY,LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 220183001
- **title:** PINE NEEDLE OPERATING COMPANY,LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2018-02-27
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 191.29.
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/220183001
**body:**

Notice of Probable Violation involving PINE NEEDLE OPERATING COMPANY,LLC. PHMSA's enforcement data identifies the cited regulation as 191.29. The case was opened on 2018-02-27 and is reported as closed as of 2018-09-24. Proposed civil penalty: $25,000. Assessed civil penalty: $25,000. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220183001_Final Order_09242018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220183001/220183001_Final%20Order_09242018.pdf

220183001_Final Order_09242018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220183001/220183001_Final%20Order_09242018_text.pdf

220183001_NOPV PCP_02272018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220183001/220183001_NOPV%20PCP_02272018.pdf

220183001_NOPV PCP_02272018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220183001/220183001_NOPV%20PCP_02272018_text.pdf

220183001_Operator Response to Notice_03302018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220183001/220183001_Operator%20Response%20to%20Notice_03302018.pdf

220183001_Final Order_09242018_text.pdf

September 24, 2018
Mr. Alan S. Armstrong
President and Chief Executive Officer
Williams Companies, Inc.
One Williams Center
Tulsa, OK 74172
Re: CPF No. 2-2018-3001
Dear Mr. Armstrong:
Enclosed please find the Final Order issued in the above-referenced case to your subsidiary, Pine
Needle LNG Company, LLC (Pine Needle). It makes one finding of violation and assesses a
civil penalty of $25,000 against Pine Needle. This is to acknowledge receipt of payment of the
full penalty amount, by wire transfer, dated July 12, 2018. This enforcement action is now
closed. Service of the Final Order by certified mail is effective 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. James Urisko, Director, Southern Region, Office of Pipeline Safety, PHMSA
Mr. Larry Legendre, Pipeline Safety and Compliance Manager, Williams Partners, LP,
2800 Post Oak Boulevard, Houston, Texas 77056



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Pine Needle LNG Company, LLC, ) CPF No. 2-2018-3001
a subsidiary of Williams Partners, LP, )
)
)
)
Respondent. )
____________________________________)
FINAL ORDER
From June 27 through June 30, 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 Pine
Needle LNG Company, LLC’s (Pine Needle or Respondent) facility in Stokesdale, North
Carolina. Pine Needle is a subsidiary of Williams Partners, LP (Williams).1 The Stokesdale
facility has two LNG containers with a maximum liquefication rate of 20 million cubic feet per
day (MMcf/d) and a maximum vaporization rate of 400 MMcf/d.2
As a result of the inspection, the Director, Southern Region, OPS (Director), issued to
Respondent, by letter dated February 27, 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 Pine Needle had violated 49 C.F.R. § 191.29 and proposed assessing a civil penalty of
$25,000 for the alleged violation.
Williams, on behalf of its subsidiary, responded to the Notice by email dated March 30, 2018
(Response). The company did not contest the allegation of violation and paid the proposed civil
penalty of $25,000. 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.
1 Pine Needle LNG Company, LLC, is a subsidiary of Williams Partners, LP, which is a subsidiary of Williams
Companies, Inc. See, Williams Companies, Inc., Form 10-K, available at
http://app.quotemedia.com/data/downloadFiling?ref=12075170&type=HTML&symbol=WMB&companyName=Wi
lliams+Companies+Inc.+%28The%29&formType=10-
K&formDescription=Annual+report+with+a+comprehensive+overview+of+the+company&dateFiled=2018-02-22
(last accessed August 9, 2018).
2 Pipeline Safety Violation Report (Violation Report), (February 1, 2018) (on file with PHMSA), at 1.



CPF No. 2-2018-3001
Page 2
FINDING OF VIOLATION
In its Response, Pine Needle did not contest the allegation in the Notice that it violated 49 C.F.R.
Part 191, as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 191.29, which states:
§ 191.29 National Pipeline Mapping System.
(a) Each operator of a gas transmission pipeline or liquefied natural gas
facility must provide the following geospatial data to PHMSA for that
pipeline or facility:
(1) Geospatial data, attributes, metadata and transmittal letter
appropriate for use in the National Pipeline Mapping System. Acceptable
formats and additional information are specified in the NPMS Operator
Standards Manual available at www.npms.phmsa.dot.gov or by contacting
the PHMSA Geographic Information Systems Manager at (202) 366-4595.
(2) The name of and address for the operator.
(3) The name and contact information of a pipeline company employee,
to be displayed on a public Web site, who will serve as a contact for
questions from the general public about the operator's NPMS data.
(b) The information required in paragraph (a) of this section must be
submitted each year, on or before March 15, representing assets as of
December 31 of the previous year. If no changes have occurred since the
previous year's submission, the operator must comply with the guidance
provided in the NPMS Operator Standards manual available at
www.npms.phmsa.dot.gov or contact the PHMSA Geographic Information
Systems Manager at (202) 366-4595.
The Notice alleged that Respondent violated 49 C.F.R. § 191.29 by failing to submit each year,
on or before March 15, geospatial data representing its assets as of December 31 of the previous
year. Specifically, the Notice alleged that Pine Needle failed to submit geospatial data,
attributes, metadata and transmittal letter appropriate for use in the National Pipeline Mapping
System in a timely manner for calendar years 2014, 2015, 2016, and 2017. The Notice alleged
that Pine Needle’s geospatial data submittals exceeded the annual March 15 deadline as follows:
Calendar Year Submittal Date Duration of
Exceedance (days)
2014 March 27, 2014 11
2015 March 17, 2015 1
2016 March 24, 2016 8
2017 May 9, 2017 54
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. § 191.29 by failing to submit each
year, on or before March 15, geospatial data representing its assets as of December 31 of the
previous year.



CPF No. 2-2018-3001
Page 3
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.3 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 $25,000 for the violation cited above.
Item 1: The Notice proposed a civil penalty of $25,000 for Respondent’s violation of 49 C.F.R.
§ 191.29, for failing to submit each year, on or before March 15, geospatial data representing its
assets as of December 31 of the previous year. Respondent neither contested the allegation nor
presented any evidence or argument justifying a reduction in, or elimination of, the proposed
penalty. Accordingly, having reviewed the record and considered the assessment criteria, I
assess Pine Needle a civil penalty of $25,000 for violation of 49 C.F.R. § 191.29, which amount
was paid in full by wire transfer on July 12, 2018.
The terms and conditions of this Final Order are effective upon service in accordance with
49 C.F.R. § 190.5.
September 24, 2018
___________________________________ __________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety
3 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).
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