{"operation":"document","citation":"CPF 420172004M","title":"WILLIAMS ENERGY, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-08-24","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(2), 192.605(b)(4), 192.615(a)(3)(i), 192.615(a)(3)(iv), 192.617, 192.805(c), 192.805(i).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420172004m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420172004m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420172004m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420172004M","body":"Notice of Amendment involving WILLIAMS ENERGY, LLC. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(2),  192.605(b)(4),  192.615(a)(3)(i),  192.615(a)(3)(iv),  192.617,  192.805(c),  192.805(i). The case was opened on 2017-08-24 and is reported as closed as of 2017-12-04. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420172004M_Closure Letter_12042017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420172004M/420172004M_Closure%20Letter_12042017.pdf\n\n420172004M_Closure Letter_12042017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420172004M/420172004M_Closure%20Letter_12042017_text.pdf\n\n420172004M_Notice of Amendment_08242017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420172004M/420172004M_Notice%20of%20Amendment_08242017.pdf\n\n420172004M_Notice of Amendment_08242017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420172004M/420172004M_Notice%20of%20Amendment_08242017_text.pdf\n\n420172004M_Operator Response to Notice_10052017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420172004M/420172004M_Operator%20Response%20to%20Notice_10052017.pdf\n\n420172004M_Closure Letter_12042017_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 4, 2017\nMark Cluss\nVP of Operations and Operational Disciplines\nWilliams Energy, LLC\n525 Central Park Drive\nOklahoma City, OK 73105\nCPF 4-2017-2004M\nDear Mr. Cluss:\nOn August 24, 2017, the Pipeline and Hazardous Materials Safety Administration issued to\nWilliams Energy, LLC (Williams), a Notice of Amendment which proposed amendment of your\nprocedures for Williams Energy Discovery (Williams)– Offshore Gas pipeline system\nWilliams submitted its amended procedures between October 5 and December 1, 2017. My staff\nreviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of\nAmendment have been corrected.\nAccordingly, this case is now closed and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nFrank Causey\nActing Director, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n\n420172004M_Notice of Amendment_08242017_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 24, 2017\nStephanie Timmermeyer\nVice President Safety and Regulatory\nWilliams Energy, LLC\n525 Central Park Drive\nOklahoma City, OK 73105\nCPF 4-2017-2004M\nDear Ms. Timmermeyer:\nOn multiple dates between the months of September 2015 and February 2016, a representative of\nthe Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601\nof 49 United States Code inspected your procedures for Williams Energy Discovery – Offshore\nGas pipeline system in Houston, Texas.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nWilliams Energy (Williams) plans or procedures, as described below:\n1. § 192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n(i) After December 16, 2004, notify the Administrator or a state agency participating\nunder 49 U.S.C. Chapter 601 if the operator significantly modifies the program\nafter the Administrator or state agency has verified that it complies with this\nsection.\nThe Williams' OQ Program (implemented on 7/6/2015), section 6: Communication Changes does\n\n\n\nnot direct the operator to send significant change notifications to a state agency. The OQ Program\nmust be amended to address significant notification to Louisiana Department of Natural Resources\n(LADNR).\n2. § 192.605 Procedural manual for operations, maintenance, and emergencies\n(b) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following, if applicable, to provide safety\nduring maintenance and operations.\n(4) Gathering of data needed for reporting incidents under Part 191 of this chapter\nin a timely and effective manner.\nWilliams System Integrity Plan, 6.04-ADM-002 – Release Reporting lacks procedures including\nthe following information to notify National Response Center by telephone to 800-424-8802:\n(1) Names of operator and person making report and their telephone numbers.\n(2) The location of the incident.\n(3) The time of the incident.\n(4) The number of fatalities and personal injuries, if any.\n(5) All other significant facts that are known by the operator that are relevant to the cause of the\nincident or extent of the damages.\nThe Williams System Integrity Plan does not meet the requirements of §192.605(b)(4) and\n§191.5(b). The plan must be amended to ensure that regulatory requirements involving immediate\nnotice of certain incidents are adhered to.\n3. § 192.615 Emergency plans.\n(a) Each operator shall establish written procedures to minimize the hazard resulting\nfrom a gas pipeline emergency. At a minimum, the procedures must provide for the\nfollowing:\n(3) Prompt and effective response to a notice of each type of emergency, including\nthe following:\n(i) Gas detected inside or near a building.\n(iv) Natural disaster.\nThe Williams Discovery Producer Services 2015 Emergency Response Plan does not address\nprocedures for making a prompt and effective response to a notice of emergency including gas\ndetected inside or near a building and a natural disaster.\nWilliams must amend their procedure to ensure the process addresses the prompt and effective\nresponse to a notice of emergency including gas detected inside or near a building and a natural\ndisaster.\n2\n\n\n\n4. § 192.617 Investigation of failures.\nEach operator shall establish procedures for analyzing accidents and failures, including\nthe selection of samples of the failed facility or equipment for laboratory examination,\nwhere appropriate, for the purpose of determining the causes of the failure and\nminimizing the possibility of a recurrence.\nWilliams has a process that includes procedures for analyzing accidents and failures, but it does\nnot include the selection of samples of the failed facility or equipment for laboratory examination,\nwhere appropriate, for the purpose of determining the causes of the failure and minimizing the\npossibility of recurrence.\nWilliams must amend their procedures to address the selection of samples of the failed facility or\nequipment for laboratory examination, where appropriate, for the purpose of determining the\ncauses of the failure and minimizing the possibility of recurrence.\n5. § 192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The program shall\ninclude provisions to:\n(c) Allow individuals that are not qualified pursuant to this subpart to perform a\ncovered task if directed and observed by an individual that is qualified;\nThe Williams OQ Plan failed to establish span-of-control ratios via comparative analysis. As a\nresult, the plan allows more un-qualified individuals to perform a covered task while being directed\nand observed by a qualified individual.\nFor example, while reviewing Williams OQ Plan (effective date: 7/6/2015), Appendix C - Covered\nTask List with Span of Control, the PHMSA inspector learned that covered tasks 603: Compressor\nUnits/Stations: Start-up, Operation, Shutdown and Purging Before Returning to Service; 606:\nLocate and Marked Submerged Pipelines and 607: Damage Prevention: Observation for\nExcavating and Backfilling allows span of control 1:3. Further inquiry revealed that Williams\nadopted Veriforce guidelines of Span of Control. The span of control should be established\nthrough the use of a comparative analysis (one which assesses the relative difficulty, importance,\nand frequency of performance of the various tasks, commonly known as a \"DIF\" analysis).\nThe Williams OQ plan must be amended to establish span-of-control ratios for each task via\ncomparative analysis.\n6. § 192.605 Procedural manual for operations, maintenance, and emergencies\n(b) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following, if applicable, to provide safety\nduring maintenance and operations.\n(2) Controlling corrosion in accordance with the operations and maintenance\nrequirements of Subpart I of this part.\nThe Williams Corrosion Control Procedures fail to state that the corrosion control procedures\n3\n\n\n\nrequired by §192.605(b)(2), including those for the design, installation, operation, and\nmaintenance of cathodic protection systems must be carried out by, or under the direction of, a\nperson qualified in pipeline corrosion control methods as required by §192.453.\nThe Williams Corrosion Control Procedures must be amended to meet the requirements of\n§192.453.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b). If you do not respond within 30 days of receipt of this Notice,\nthis constitutes a waiver of your right to contest the allegations in this Notice and authorizes the\nAssociate Administrator for Pipeline Safety to find facts as alleged in this Notice without further\nnotice to you and to issue a Final Order.\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in this\nNotice, you may be ordered to amend your plans or procedures to correct the inadequacies (49\nC.F.R. § 190.237). If you are not contesting this Notice, we propose that you submit your amended\nprocedures to my office within 30 days of receipt of this Notice. This period may be extended by\nwritten request for good cause. Once the inadequacies identified herein have been addressed in\nyour amended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that Williams Energy, LLC. maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Terri J. Binns, Acting Director, SW Region, Pipeline\nand Hazardous Materials Safety Administration. In correspondence concerning this matter, please\nrefer to CPF 4-2017-2004M and, for each document you submit, please provide a copy in\nelectronic format whenever possible.\nSincerely,\nFrank Causey\nActing Director, SW Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n4","truncated":false,"body_characters":11187}