# WILLIAMS ENERGY, LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 420141002
- **title:** WILLIAMS ENERGY, LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2014-03-03
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 191.22(b), 191.22(c)(1)(ii).
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-420141002.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-420141002
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420141002
**body:**

Notice of Probable Violation involving WILLIAMS ENERGY, LLC. PHMSA's enforcement data identifies the cited regulations as 191.22(b),  191.22(c)(1)(ii). The case was opened on 2014-03-03 and is reported as closed as of 2014-10-14. Proposed civil penalty: $15,800. Assessed civil penalty: $15,800. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420141002_Final Order_09292014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420141002/420141002_Final%20Order_09292014.pdf

420141002_Final Order_09292014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420141002/420141002_Final%20Order_09292014_text.pdf

420141002_NOPV PCP PCO_03032014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420141002/420141002_NOPV%20PCP%20PCO_03032014.pdf

420141002_NOPV PCP PCO_03032014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420141002/420141002_NOPV%20PCP%20PCO_03032014_text.pdf

420141002_Operator Response to Notice_04032014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420141002/420141002_Operator%20Response%20to%20Notice_04032014.pdf

420141002_Final Order_09292014_text.pdf

SEPTEMBER 29, 2014
Mr. Rory L. Miller
Senior Vice President, Williams Energy, LLC
The Williams Companies, Inc.
One Williams Center
Tulsa, OK 74172
Re: CPF No. 4-2014-1002
Dear Mr. Miller:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation, assesses a civil penalty of $15,800, and specifies actions that need to be taken by
Williams Energy, LLC, to comply with the pipeline safety regulations. The penalty payment
terms are set forth in the Final Order. When the civil penalty has been paid this enforcement
action will be closed. Service of the Final Order by certified mail is deemed effective upon the
date of mailing, or as otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. R. M. Seeley, Director, Southwest Region, OPS
Mr. Alan S. Armstrong, President, The Williams Companies, Inc.,
One Williams Center, Tulsa, OK 74172
Ms. Marie G. Sotak, Manager Pipeline Safety, Gas & Liquids, Williams Energy, LLC,
2800 Post Oak Blvd., L-11, Houston, TX 77056
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 Energy, LLC, ) CPF No. 4-2014-1002
)
Respondent. )
____________________________________)
FINAL ORDER
Representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA),
Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code, have
reviewed the reports and notifications that Williams Energy, LLC (Williams or Respondent), a
subsidiary of The Williams Companies, Inc.,1 provided to PHMSA in January 2014 regarding
the construction of a 20-inch offshore gas gathering pipeline running approximately 209 miles in
length and generally referred to as the Keathley Canyon Connector. As of 2012, Williams
reported operating 276 miles of gas transmission and gathering lines in Louisiana and the Gulf of
Mexico and 23 miles of hazardous liquid pipelines in Louisiana.2
As a result of PHMSA’s review of Williams’ 2014 filings, the Director, Southwest Region, OPS
(Director), issued to Respondent, by letter dated March 3, 2014, a Notice of Probable Violation,
Proposed Civil Penalty, and Proposed Compliance Order (Notice). In accordance with 49 C.F.R.
§ 190.207, the Notice proposed finding that Williams had committed two violations of
49 C.F.R. Part 191 and assessing a civil penalty of $15,800 for the alleged violations. The
Notice also proposed ordering Respondent to take certain measures to correct the alleged
violations.
Williams responded to the Notice by letter dated April 3, 2014 (Response). Respondent
contested one of the allegations of violation, provided an explanation of its actions, and
requested that the proposed civil penalty be reduced or eliminated. Respondent did not request a
hearing and therefore has waived its right to one.
1 http://co.williams.com/williams/operations/midstream/ (last accessed July 21, 2014).
2 Pipeline Safety Violation Report (Violation Report), (March 3, 2014) (on file with PHMSA), at 1.



2
FINDINGS OF VIOLATION
The Notice alleged that Respondent violated 49 C.F.R. Part 191, as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 191.22(c)(1)(ii), which states:
§ 191.22 National Registry of Pipeline and LNG operators.
(a) . . .
(c) Changes. Each operator of a gas pipeline, gas pipeline facility,
LNG plant or LNG facility must notify PHMSA electronically through the
National Registry of Pipeline and LNG Operators at
http://opsweb.phmsa.dot.gov of certain events.
(1) An operator must notify PHMSA of any of the following events
not later than 60 days before the event occurs:
(i) …
(ii) Construction of 10 or more miles of a new pipeline; . . . .
The Notice alleged that Respondent violated 49 C.F.R. § 191.22(c)(1)(ii) by failing to timely
notify PHMSA of the construction of 10 or more miles of a new pipeline. Specifically, the
Notice alleged that Williams failed to notify PHMSA at least 60 days before the company began
construction of a 209-mile offshore pipeline in the Gulf of Mexico. Construction of the pipeline
began on October 15, 2013, approximately 83 days prior to the filing of the notification on
January 6, 2014, or 143 days late.
Respondent contested this Item, asserting that it had “created the original PHMSA Notification
Type G in the PHMSA Portal and indicated an anticipated construction start date of October 7,
2013.” It further asserted that “[a]t that time, Williams assumed the notification was submitted
in final,” as indicated in an internal e-mail dated June 4, 2013.3 In support of its position,
Williams provided a screenshot of the PHMSA reporting portal and an internal company e-mail
indicating that company personnel had notified PHMSA of the pending construction. The
screenshot showed the notification type, project status, start date, who entered and/or updated the
information, and the last date the information was updated. The screenshot, however, did not
show when the notification was made.
Based upon the evidence presented by Respondent, it is unclear whether Williams attempted but
failed to timely submit the construction notice in June 2013. It is undisputed, however, that a
complete submission of the construction notice was not made until January 6, 2014.
Accordingly, based upon a review of all of the evidence, I find that Respondent violated
49 C.F.R. § 191.22(c)(1)(ii) by failing to timely notify PHMSA of its construction of a 209-mile
gas gathering pipeline in the Gulf of Mexico.
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 191.22(b), as follows:
3 Response at 1.



3
§ 191.22 National Registry of Pipeline and LNG operators.
(a) . . . .
(b) [Operator Identification Number (OPID)] validation.
An operator who has already been assigned one or more OPID by
January 1, 2011, must validate the information associated with
each OPID through the National Registry of Pipeline and LNG
Operators at http://opsweb.phmsa.dot.gov, and correct that
information as necessary, no later than June 30, 2012.
The Notice alleged that Respondent violated 49 C.F.R. § 191.22(b) by inaccurately updating the
company’s OPID information with the National Registry of Pipeline and LNG Operators.
Specifically, the Notice alleged that Williams failed to accurately update its Contact Information
by listing only one individual and phone number for the following duties: DOT Compliance,
Emergency Contact 24-7, Normal Operations 24-7, Senior Executive, NPMS and User Fee
departments.
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. § 191.22(b) by failing to accurately
update its OPID information with the National Registry of Pipeline and LNG Operators.
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. 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 $15,800 for the violations cited above.
Item 1: The Notice proposed a civil penalty of $15,800 for Respondent’s violation of
49 C.F.R. § 191.22(c)(1)(ii), for failing to timely notify PHMSA of the construction of a new
pipeline. As discussed above, I found that Williams did not report the construction of a new
209-mile pipeline until 143 days after the notification deadline and nearly half of the
construction had been completed. Parties are required to notify PHMSA in advance of new
construction so the agency can review the construction documents and, if necessary, observe
construction to ensure that proper safety and construction protocols are being followed. Thus,
the failure of an operator to make a timely construction notification potentially affects the long-



4
term safety of a pipeline.
While I have considered the evidence that Williams may have made some attempt to file a timely
notification, I do not find this alone warrants a penalty reduction. PHMSA will, on occasion,
reduce a proposed penalty where an operator can show that the violation was based upon the
company’s good-faith reliance on an incorrect interpretation of the regulations. In this case,
however, Williams simply did not file a timely notification and had no system in place to
monitor or assure compliance. Furthermore, this violation does not appear to be an isolated
event. Other subsidiaries of The Williams Companies, Inc., have recently been charged with
filing late reports, which suggests a more systemic problem than the present case alone would
indicate.4 Accordingly, based upon the foregoing, I assess Respondent a civil penalty of $15,800
for violation of 49 C.F.R. § 191.22(c)(1)(ii).
In summary, having reviewed the record and considered the assessment criteria for the Item cited
above, I assess Respondent a total civil penalty of $15,800.
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, P.O. Box 269039, Oklahoma City, Oklahoma 73125. The
Financial Operations Division telephone number is (405) 954-8845.
Failure to pay the $15,800 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.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Item 2 in the Notice for violation of
49 C.F.R. § 191.22(b). Under 49 U.S.C. § 60118(a), each person who engages in the
transportation of gas or who owns or operates a pipeline facility is required to comply with the
applicable safety standards established under chapter 601. The Director indicates that
Respondent has taken the following actions specified in the proposed compliance order:
1. With respect to the violation of § 191.22(b) (Item 2), Respondent updated its
4 The Violation Report states that on August 14, 2013, PHMSA issued: (1) a Warning Letter to Williams Field
Services-Gulf Coast [CPF No. 4-2013-9001W], alleging that the company had filed a late notification on another
pipeline construction project; and (2) a Notice of Probable Violation and Proposed Compliance Order to Williams
Olefins Feedstock Pipelines, LLC [CPF No. 4-2013-5016], alleging that the company had filed a late notification on
the acquisition of a new pipeline The latter case has not yet been adjudicated. Williams has not challenged these
allegations in the Violation Report.



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operator Contact Information, previously provided, with the correct contact
information for the individuals responsible for: DOT Compliance, Emergency
Contact 24-7, Normal Operations Contact 24-7, the named Executive, NPMSA and
User Fee.
Accordingly, I find that compliance has been achieved with respect to this violation. Therefore,
the compliance terms proposed in the Notice are not included in this Order [CPF No. 4-2014-
1002].
Under 49 C.F.R. § 190.215, Respondent has a right to submit a Petition for Reconsideration of
this Final Order. The petition must be sent to: 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. PHMSA
will accept petitions received no later than 20 days after receipt of service of this Final Order by
the Respondent, provided they contain a brief statement of the issue(s) and meet all other
requirements of 49 C.F.R. § 190.215. The filing of a petition automatically stays the payment of
any civil penalty assessed. Unless the Associate Administrator, upon request, grants a stay, all
other terms and conditions of this Final Order are effective upon service in accordance with
49 C.F.R. § 190.5.
___________________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

420141002_NOPV PCP PCO_03032014_text.pdf

NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
AND
PROPOSED COMPLIANCE ORDER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
March 3, 2014
Mr. Alan Armstrong
President, Chief Executive Officer
Williams Energy LLC
One Williams Center
Tulsa, Oklahoma 74172
CPF 4-2014-1002
Dear Mr. Armstrong:
Representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of
Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code have been reviewing your
reports and notifications that have been submitted to PHMSA. As a result of this review, it appears that
you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal
Regulations. The items inspected and the probable violations are:
1. §191.22 National Registry of Pipeline and LNG Operators
(c) Changes. Each operator of a gas pipeline, gas pipeline facility, LNG plant, or LNG facility
must notify PHMSA electronically through the National Registry of Pipeline and LNG
Operators at http:/opsweb.phmsa.dot.gov, of certain events.
(1) An operator must notify PHMSA of any of the following events not later than 60 days
before the event occurs:
(ii) Construction of 10 or more miles of a new pipeline
Williams Field Services did not notify PHMSA of the construction of a new pipeline within the proper
timeframe. On January 6, 2014 Williams Field Services submitted an Operator Registry Notification G-
20140106-2328 for construction of 209 miles of 20” offshore gas gathering pipeline in the Gulf of
Mexico. The information that was submitted states that “The Gas Export Pipeline component of the



Keathley Canyon Connector (KCC) system consists of an approximately 209 mile 20-inch OD pipeline
originating at a Pipeline End Termination (PLET) in the vicinity of KC-831 and terminating at a newly
built junction platform in the vicinity of South Timbalier Area (ST) Block 283.” According to the
notification, anticipated start date of field construction activities was October 7, 2013; however, through
conversation with company personnel, actual construction on October 15, 2013. The original
notification was filed approximately 143 days after construction began and not 60 days prior to
construction.
On February 13, 2014, Williams Energy LLC submitted Operator Registry Notification G-20140213-
4263. In it Williams stated that the earlier notification G 20140106-2328 incorrectly stated that the
pipeline was being constructed by Williams Field Services LLC. Williams Energy LLC, and not
Williams Field Services, was the entity constructing the pipeline. All other information was unchanged
from the earlier notification from Williams Field Services.
2. §191.22 National Registry of Pipeline and LNG Operators
(b) OPID Validation. An operator who has already been assigned one or more OPID by January
1, 2011, must validate the information associated with each OPID through the National Registry of
Pipeline and LNG Operators http://opsweb.phmsa.dot.gov and correct that information as
necessary, no later than June 30, 2012.
Williams Energy LLC has inaccurately updated the information with the National Registry of Pipeline
and LNG Operators. The operator Contact Information has one named individual, with the same phone
number for: DOT Compliance, the Emergency Contact 24-7, and contact for Normal Operations 24-7,
the Senior Executive, NPMS, and User Fee. The date of the most recent revision that PHMSA received
was September 24, 2012.
Proposed Civil Penalty
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per
violation per day the violation persists up to a maximum of $2,000,000 for a related series of violations.
For violations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per
violation per day, with a maximum penalty not to exceed $1,000,000 for a related series of violations.
The Compliance Officer has reviewed the circumstances and supporting documentation involved in the
above probable violation and has recommended that you be preliminarily assessed a civil penalty of
$15,800 for item 1.
2



Proposed Compliance Order
With respect to item 2, and pursuant to 49 United States Code § 60118, the Pipeline and Hazardous
Material Safety Administration proposes to issue a Compliance Order to Williams Energy LLC. Please
refer to the Proposed Compliance Order, which is enclosed and made a part of this Notice.
Response to this Notice
Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in
Compliance Proceedings. Please refer to this document and note the response options. All material
submit in response to this enforcement action may be 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). If you do not respond
within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations
in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in
this Notice without further notice to you and to issue a Final Order.
In your correspondence on this matter, please refer to CPF 4-2014-1002 and for each document you
submit, please provide a copy in electronic format whenever possible.
Sincerely,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
Enclosures: Response Options for Pipeline Operators in Compliance Proceedings
3



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration
(PHMSA) proposes to issue to Williams Energy LLC a Compliance Order incorporating the following
remedial requirement to ensure the compliance of Williams Energy LLC with the pipeline safety
regulations:
1. In regard to Item 2 of the Notice pertaining to the inaccurately updated information with the
National Registry of Pipeline and LNG Operators. Williams Energy LLC is to update their
Operator Contact information with the correct contacts for their: DOT Compliance, the
Emergency Contact 24-7, Normal Operations Contact 24-7, the Executive, NPMS and User Fee.
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