{"operation":"document","citation":"CPF 420139001W","title":"WILLIAMS FIELD SERVICES - GULF COAST COMPANY, LP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-08-14","effective_on":null,"summary":"CLOSED warning letter citing 191.22(c)(1), 195.64(c)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420139001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420139001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420139001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420139001W","body":"Warning Letter involving WILLIAMS FIELD SERVICES - GULF COAST COMPANY, LP. PHMSA's enforcement data identifies the cited regulations as 191.22(c)(1),  195.64(c)(1). The case was opened on 2013-08-14 and is reported as closed as of 2013-08-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420139001W_Operator Response to Notice_09172013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420139001W/420139001W_Operator%20Response%20to%20Notice_09172013.pdf\n\n420139001W_Warning Letter_08142013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420139001W/420139001W_Warning%20Letter_08142013.pdf\n\n420139001W_Warning Letter_08142013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420139001W/420139001W_Warning%20Letter_08142013_text.pdf\n\n420139001W_Warning Letter_08142013_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 14, 2013\nMr. Robert Cronk\nVice President, Technical Services\nWilliams Field Services – Gulf Coast\nOne Williams Center\nTulsa, Oklahoma 74101\nCPF 4-2013-9001W\nDear Mr. Cronk:\nA representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA)\npursuant to Chapter 601 of 49 United States Code have reviewed your notification that was\nsubmitted to PHMSA. As a result of this review, it appears that you have committed probable\nviolations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items\ninspected and the probable violations are:\n1. §191.22 National Registry of Pipeline and LNG Operators.\n(c) Changes. Each operator of a gas pipeline, gas pipeline facility, LNG plant or\nLNG facility must notify PHMSA electronically through the National Registry of\nPipeline and LNG Operators at http://opsweb.phmsa.dot.gov, of certain events.\n(1) An operator must notify PHMSA of any of the following events not later than 60\ndays before the event occurs:\n(i) Construction or any planned rehabilitation, replacement, modification,\nupgrade, uprate, or update of a facility other than a section of line pipe, that\ncosts $10 million or more. If 60 day notice is not feasible because of an\nemergency, an operator must notify PHMSA as soon as practicable;\n(ii) Construction of 10 or more miles of a new hazardous liquid pipeline;\n\n\n\nWilliams Field Services did not submit an Operator Registry Notification, PHMSA F 1000.2 60\ndays before the start of construction of the offshore gas pipeline.\nPHMSA received a New Construction Notification that Williams Field Services is to construct a\n17 mile offshore gas pipeline in the Gulf of Mexico. The information that was submitted states\nthat “The natural gas gathering offshore export pipeline will transport gas the Gulfstar 1 FPS\nSPAR located in the Mississippi Block 724 to the existing Blind Faith export pipeline system\nlocated in Mississippi Block 728. The new construction is 12-inch diameter pipe and consists of\na 1 mile SCR section that ties in to the existing Canyon Chief 18-inch gas pipeline system.” The\ndate of the notification was May 3, 2013. The date of the ‘Anticipated start date of field\nconstruction activities’ was dated May 13, 2013.\nThrough conversations with company personnel, this office understands that Williams Field\nServices started construction activities on May 13, 2013. The Notification was received 10 days\nbefore the construction date.\n2. §195.64 National Registry of Pipeline and LNG Operators.\n(c ) Changes. Each operator must notify PHMSA electronically through the\nNational Registry of Pipeline and LNG Operators at http://opsweb.phmsa.dot.gov,\nof certain events.\n(1) An operator must notify PHMSA of any of the following events not later than 60\ndays before the event occurs:\n(i) Construction or any planned rehabilitation, replacement, modification,\nupgrade, uprate, or update of a facility other than a section of line pipe, that\ncosts $10 million or more. If 60 day notice is not feasible because of an\nemergency, an operator must notify PHMSA as soon as practicable;\n(ii) (iii) Construction of 10 or more miles of a new hazardous liquid pipeline;\nConstruction of a new pipeline facility.\nWilliams Field Services did not submit an Operator Registry Notification, PHMSA F 1000.2 60\ndays before the start of construction of the offshore liquid pipeline.\nPHMSA received a New Construction Notification that Williams Field Services is to construct a\n17 mile offshore crude oil pipeline in the Gulf of Mexico. The information that was submitted\nstates that “The crude oil offshore export pipelines will transport oil from the Gulfstar 1 FPS\nSPAR located in Mississippi Block 724 to the existing Blind Faith export pipeline system located\nin Mississippi Block 728. The pipeline is 12-inch diameter and consists of a 1 mile SCR section.\nThe oil export ties into the existing Mountaineer 18-inch oil pipeline system.” The date of the\nnotification was May 3, 2013. The date of the ‘Anticipated start date of field construction\nactivities’ was dated May 13, 2013.\n2\n\n\n\nThrough conversations with company personnel, this office understands that Williams Field\nServices started construction activities on May 13, 2013. The Notification was received 10 days\nbefore the construction date.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the items identified in this letter.\nFailure to do so will result in Williams Field Services – Gulf Coast being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2013-9001W. 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\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Compliance Proceedings\n3","truncated":false,"body_characters":6874}