{"operation":"document","citation":"CPF 420175001","title":"WILLIAMS OLEFINS FEEDSTOCK PIPELINES, LLC — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-01-25","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.222(a), 195.49, 195.569, 195.579(c), 195.583(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175001.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175001.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175001","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420175001","body":"Notice of Probable Violation involving WILLIAMS OLEFINS FEEDSTOCK PIPELINES, LLC. PHMSA's enforcement data identifies the cited regulations as 195.222(a),  195.49,  195.569,  195.579(c),  195.583(c). The case was opened on 2017-01-25 and is reported as closed as of 2018-10-30. Proposed civil penalty: $253,900. Assessed civil penalty: $253,900. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420175001_Closure Letter_10302018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175001/420175001_Closure%20Letter_10302018.pdf\n\n420175001_Closure Letter_10302018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175001/420175001_Closure%20Letter_10302018_text.pdf\n\n420175001_Final Order_07242017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175001/420175001_Final%20Order_07242017.pdf\n\n420175001_Final Order_07242017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175001/420175001_Final%20Order_07242017_text.pdf\n\n420175001_NOPV PCP PCO_01252017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175001/420175001_NOPV%20PCP%20PCO_01252017.pdf\n\n420175001_NOPV PCP PCO_01252017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175001/420175001_NOPV%20PCP%20PCO_01252017_text.pdf\n\n420175001_Operator Response to Notice_03012017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175001/420175001_Operator%20Response%20to%20Notice_03012017.pdf\n\n420175001_Final Order_07242017_text.pdf\n\nJuly 24, 2017\nMr. Alan Armstrong\nPresident & Chief Executive Officer\nWilliams Olefins Feedstock Pipelines, LLC\nOne Williams Center\nTulsa, Oklahoma 74172\nRe: CPF No. 4-2017-5001\nDear Mr. Armstrong:\nEnclosed please find the Final Order issued in the above-referenced case. It makes findings of\nviolation, assesses a civil penalty of $253,900, and specifies actions that need to be taken by\nWilliams Olefins Feedstock Pipelines, LLC to comply with pipeline safety regulations. This is\nto acknowledge receipt of payment of the full penalty amount, by wire transfer, dated March 21,\n2017. When the terms of the compliance order are completed, as determined by the Director,\nSouthwest Region, this enforcement action will be closed. Service of the Final Order by\ncertified mail is effective upon the date of mailing as provided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Director, Southwest Region, Office of Pipeline Safety, PHMSA\nMr. Larry D. Legendre, Manager, Pipeline Safety – Atlantic-Gulf, 2800 Post Oak Blvd.,\nHouston TX 77056\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\n)\nIn the Matter of )\n)\nWilliams Olefins Feedstock Pipelines, ) CPF No. 4-2017-5001\nLLC, )\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nOn several occasions from August 31, 2015 to December 10, 2015, pursuant to 49 U.S.C.\n§ 60117, representatives of the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety (OPS), conducted an on-site pipeline safety inspection of\nthe records for operations and maintenance of Williams Olefins Feedstock Pipelines, LLC\n(Williams or Respondent), a subsidiary of Williams Partners, LP, in Houston, Texas. PHMSA\nalso conducted field inspections of Williams’ Bayou Ethane System and Iowa to Port Neches 6-\ninch pipeline system. Williams’ interstate gas pipeline and gathering operations span the United\nStates, including pipelines in the Gulf of Mexico, the Rockies, the Pacific Northwest and the\nEastern Seaboard.1\nAs a result of the inspection, the Director, Southwest Region, OPS (Director), issued to\nRespondent, by letter dated January 25, 2017, a Notice of Probable Violation, Proposed Civil\nPenalty, and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the\nNotice proposed finding that Williams had committed five violations of 49 C.F.R. Part 195 and\nproposed assessing a civil penalty of $253,900 for the alleged violations. The Notice also\nproposed ordering Respondent to take certain measures to correct the alleged violations.\nWilliams responded to the Notice by letter dated March 1, 2017 (Response). The company did\nnot contest the allegations of violation and paid the proposed civil penalty of $253,900. In\naccordance with 49 C.F.R. § 190.208(a)(1), such payment authorizes the Associate\nAdministrator to make findings of violation and to issue this final order.\n1 Williams’ website, available at http://co.williams.com/ (last accessed July 20, 2017). On April 17, 2017, Williams\nPartners, LP, announced that it had agreed to sell 100 percent of its interest in Williams Olefins, LLC, the parent of\nRespondent, to NOVA Chemicals.\n\n\n\nCPF No. 4-2017-5001\nPage 2\nFINDINGS OF VIOLATION\nIn its Response, Williams did not contest the allegations in the Notice that it violated 49 C.F.R.\nPart 195, as follows:\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.49, which states:\n§ 195.49 Annual report.\nEach operator must annually complete and submit DOT Form PHMSA\nF 7000-1.1 for each type of hazardous liquid pipeline facility operated at the\nend of the previous year. An operator must submit the annual report by\nJune 15 each year, except that for the 2010 reporting year the report must\nbe submitted by August 15, 2011. A separate report is required for crude\noil, HVL (including anhydrous ammonia), petroleum products, carbon\ndioxide pipelines, and fuel grade ethanol pipelines. For each state a pipeline\ntraverses, an operator must separately complete those sections on the form\nrequiring information to be reported for each state.\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.49 by failing to submit to PHMSA\nan annual report that included information on all its pipeline assets. Specifically, the Notice\nalleged that Williams did not submit a 2014 annual report that included information on the BASF\nConnection pipeline, which was constructed in 2013. Respondent did not contest this allegation\nof violation. Accordingly, based upon a review of all of the evidence, I find that Respondent\nviolated 49 C.F.R. § 195.49 by failing to submit a complete 2014 annual report.\nItem 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.222,\n2 which states:\n§ 195.222 Welders and welding operators: Qualification of welders\nand welding operators.\n(a) Each welder or welding operator must be qualified in accordance\nwith section 6, section 12, Appendix A or Appendix B of API Std 1104\n(incorporated by reference, see § 195.3), or section IX of the ASME Boiler\nand Pressure Vessel Code (ASME BPVC), (incorporated by reference, see\n§ 195.3) except that a welder or welding operator qualified under an earlier\nedition than listed in § 195.3, may weld but may not requalify under that\nearlier edition.\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.222(a) by failing to ensure that its\nwelders were qualified in accordance with section 6 of API 1104 or section IX of the ASME\nBoiler and Pressure Vessel Code. Specifically, the Notice alleged that, in response to a Request\nfor Specific Information, Williams could not produce records sufficient to demonstrate that its\nwelders who worked on the Bayou Ethane Pipeline Rehabilitation Project were qualified to weld\n2 This regulation was amended after issuance of the Notice. Amdt. 195-101, 82 FR 7999 (Jan. 23, 2017).\n\n\n\nCPF No. 4-2017-5001\nPage 3\nin accordance with § 195.222(a).3 Respondent did not contest this allegation of violation.\nAccordingly, based upon a review of all of the evidence, I find that Respondent violated\n49 C.F.R. § 195.222(a) by failing to qualify its welders in accordance with section 6 of API 1104\nor section IX of the ASME Boiler and Pressure Vessel Code.\nItem 3: The Notice alleged that Respondent violated 49 C.F.R. § 195.569, which states:\n§ 195.569 Do I have to examine exposed portions of buried pipelines?\nWhenever you have knowledge that any portion of a buried pipeline is\nexposed, you must examine the exposed portion for evidence of external\ncorrosion if the pipe is bare, or if the coating is deteriorated. If you find\nexternal corrosion requiring corrective action under § 195.585, you must\ninvestigate circumferentially and longitudinally beyond the exposed portion\n(by visual examination, indirect method, or both) to determine whether\nadditional corrosion requiring remedial action exists in the vicinity of the\nexposed portion.\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.569 by failing to examine portions\nof exposed pipelines for evidence of external corrosion.4 Specifically, the Notice alleged that\nduring the construction of new pipelines and pipeline facilities for the Bayou Ethane Pipeline\nRehabilitation Project in 2013 and 2014, Williams failed to examine portions of exposed\npipelines for evidence of external corrosion for six segments of pipe. Respondent did not contest\nthis allegation of violation. Accordingly, based upon a review of all of the evidence, I find that\nRespondent violated 49 C.F.R. § 195.569 by failing to examine portions of exposed pipeline\nsegments for evidence of external corrosion during the Bayou Ethane Pipeline Rehabilitation\nProject in 2013 and 2014.\nItem 4: The Notice alleged that Respondent violated 49 C.F.R. § 195.579, which states:\n§ 195.579 What must I do to mitigate internal corrosion?\n(a) . . .\n(c) Removing pipe. Whenever you remove pipe from a pipeline, you\nmust inspect the internal surface of the pipe for evidence of corrosion. If\nyou find internal corrosion requiring corrective action under § 195.585, you\nmust investigate circumferentially and longitudinally beyond the exposed\nportion (by visual examination, indirect method, or both) to determine\nwhether additional corrosion requiring remedial action exists in the vicinity\nof the exposed portion.\n3 See, generally, Request for Specific Information (August 29, 2016) (requesting information from Williams regarding\nits welding qualification procedures and records, to which Williams responded by providing limited, incomplete\ninformation) (on file with PHMSA).\n4 See, Violation Report at Exhibit B, Williams Procedure No. 7.04-ADM-005, Section 1.2 (requiring that “each time\na buried pipeline or related underground facility is exposed for any reason (intentionally or unintentionally), it must\nbe thoroughly inspected (end-to-end) and the conditions documented on the appropriate form(s).” The procedures\nalso require personnel to perform an inspection of the pipe coating and pipe conditions and to document the findings\non Form 02-OPR-1581-Maintenance Report or 02-LEG-1035-Encroachment Agreement (on file with PHMSA).\n\n\n\nCPF No. 4-2017-5001\nPage 4\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.579(c) by failing to examine\nportions of exposed pipelines for evidence of internal corrosion.5 Specifically, the Notice\nalleged that during the construction of new pipelines and pipeline facilities for the Bayou Ethane\nPipeline Rehabilitation Project in 2013 and 2014, Williams failed to examine portions of exposed\npipelines for evidence of internal corrosion for 10 segments of pipe. Respondent did not contest\nthis allegation of violation. Accordingly, based upon a review of all of the evidence, I find that\nRespondent violated 49 C.F.R. § 195.579(c) by failing to examine portions of exposed pipelines\nfor evidence of internal corrosion.\nItem 5: The Notice alleged that Respondent violated 49 C.F.R. § 195.583, which states, in\npertinent part:\n§ 195.583 What must I do to monitor atmospheric corrosion control?\n(a) . . .\n(c) If you find atmospheric corrosion during an inspection, you must\nprovide protection against corrosion as required by § 195.581.\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.583(c) by failing to provide\nprotection against corrosion after atmospheric corrosion was identified during inspections of\nWilliams’ Iowa to Orange 6-inch pipeline system. Specifically, the Notice alleged that Williams\nconducted valve inspections in April 2014, May 2015, and October 2015 that resulted in\natmospheric corrosion being observed at several valve sites. Williams failed, however, to correct\nall the deficiencies noted from these inspections and to provide protection against corrosion\npursuant to § 195.581.6 Respondent did not contest this allegation of violation. Accordingly,\nbased upon a review of all of the evidence, I find that Respondent violated 49 C.F.R.\n§ 195.583(c) by failing to provide protection against corrosion as required by § 195.581 upon\ndiscovering evidence of atmospheric corrosion during several valve inspections.\nThese findings of violation will be considered prior offenses in any subsequent enforcement\naction taken against Respondent.\nASSESSMENT OF PENALTY\nUnder 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed\n$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any\n5 See also, Williams Procedure No. 7.04-ADM-005, Section 2 (requiring that “[i]f the internal portion of the pipe is\nexposed from being cut, coupon extracted, or other reasons, include the internal surface in the Corrosion examination.”\nThe procedures also state to perform an inspection of the internal pipe conditions and to document the findings on 02-\n0PR-1581-Maintenance Report or 02-LEG-1035-Encroachment Agreement (Short Form)).\n6 Respondent noted that its Iowa Extension, which was experiencing atmospheric corrosion, was idled and a “complete\nand total inspection and rehabilitation of the pipeline, including valve replacement, atmospheric corrosion\nremediation, and in-line inspection” would be completed prior to putting the line back into service. Id. at 7. PHMSA\nregulations, however, do not recognize idle status, and consider pipelines to be either active and fully subject to all\nrelevant parts of the safety regulations or abandoned. See, PHMSA Advisory Bulletin 2016-0075 (August 11, 2016).\n\n\n\nCPF No. 4-2017-5001\nPage 5\nrelated series of violations.7 In determining the amount of a civil penalty under 49 U.S.C.\n§ 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature,\ncircumstances, and gravity of the violation, including adverse impact on the environment; the\ndegree of Respondent’s culpability; the history of Respondent’s prior offenses; and any effect\nthat the penalty may have on its ability to continue doing business; and the good faith of\nRespondent in attempting to comply with the pipeline safety regulations. In addition, I may\nconsider the economic benefit gained from the violation without any reduction because of\nsubsequent damages, and such other matters as justice may require. The Notice proposed a total\ncivil penalty of $253,900 for violations of Items 1-4.\nItem 1: The Notice proposed a civil penalty of $57,000 for Respondent’s violation of 49 C.F.R.\n§ 195.49, for failing to submit a full and complete 2014 annual report to PHMSA. Williams\nneither contested the allegation nor presented any evidence or argument justifying a reduction in\nthe proposed penalty. Although pipeline safety was minimally affected and Williams took steps\nto comply with the requirement, Williams did not achieve compliance and the violation was\ndiscovered by PHMSA. This is a repeat violation.8 Accordingly, having reviewed the record and\nconsidered the assessment criteria, I assess Respondent a civil penalty of $57,000 for violation of\n49 C.F.R. § 195.49.\nItem 2: The Notice proposed a civil penalty of $46,600 for Respondent’s violation of 49 C.F.R.\n§ 195.222(a), for failing to qualify its welders working on the Bayou Ethane Pipeline\nRehabilitation Project, in accordance with Section 6 of API 1104 or Section IX of the ASME\nBoiler and Pressure Vessel Code. Williams neither contested the allegation nor presented any\nevidence or argument justifying a reduction in the proposed penalty. Williams failed to take\nappropriate action to comply with a requirement that was clearly applicable, and as a result,\npipeline integrity was compromised in areas other than an HCA or HCA “could affect” segment.\nThis violation was discovered by PHMSA. Accordingly, having reviewed the record and\nconsidered the assessment criteria, I assess Respondent a civil penalty of $46,600 for violation of\n49 C.F.R. § 195.222(a).\nItem 3: The Notice proposed a civil penalty of $69,100 for Respondent’s violation of 49 C.F.R.\n§ 195.569, for failing to examine portions of exposed pipeline for evidence of external corrosion\nif the pipe is bare or if the coating is deteriorated. Williams neither contested the allegation nor\npresented any evidence or argument justifying a reduction in the proposed penalty. Williams\nfailed to take appropriate action to comply with a requirement that was clearly applicable, and as\na result, pipeline integrity was compromised in areas other than an HCA or HCA “could affect”\nsegment. Further, PHMSA discovered the violation. Accordingly, having reviewed the record\nand considered the assessment criteria, I assess Respondent a civil penalty of $69,100 for\nviolation of 49 C.F.R. § 195.569.\nItem 4: The Notice proposed a civil penalty of $81,200 for Respondent’s violation of 49 C.F.R.\n§ 195.579(c), for failing to examine portions of exposed pipeline for evidence of internal\n7 These amounts are adjusted annually for inflation. See, e.g., Pipeline Safety: Inflation Adjustment of Maximum\nCivil Penalties, 82 Fed. Reg. 19325 (April 27, 2017).\n8 In the Matter of Williams Olefins Feedstock Pipelines, LLC, Final Order, CPF. No. 4-2013-5016 (March 20,\n2014).\n\n\n\nCPF No. 4-2017-5001\nPage 6\ncorrosion. Williams neither contested the allegation nor presented any evidence or argument\njustifying a reduction in the proposed penalty. Williams failed to take appropriate action to\ncomply with a requirement that was clearly applicable, and as a result, pipeline integrity was\ncompromised in areas other than an HCA or HCA “could affect” segment. Further, Williams did\nnot have a credible justification for its actions. PHMSA discovered the violation. Accordingly,\nhaving reviewed the record and considered the assessment criteria, I assess Respondent a civil\npenalty of $81,200 for violation of 49 C.F.R. § 195.579(c).\nIn summary, having reviewed the record and considered the assessment criteria for each of the\nItems cited above, I assess Respondent a total civil penalty of $253,900, which amount has\nalready been paid by Respondent.\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Items 1 and 5 in the Notice for\nviolations of 49 C.F.R. §§ 195.49 and 195.583(c), respectively. Under 49 U.S.C. § 60118(a),\neach person who engages in the transportation of hazardous liquids or who owns or operates a\npipeline facility is required to comply with the applicable safety standards established under\nchapter 601. Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217,\nRespondent is ordered to take the following actions to ensure compliance with the pipeline safety\nregulations applicable to its operations:\n1. With respect to the violation of § 195.49 (Item 1), Respondent must submit a\nsupplemental annual report to PHMSA to include the BASF Connection pipeline\ninformation. This must be completed within 30 days of after receipt of the Final\nOrder.\n2. With respect to the violation of § 195.583(c) (Item 5), Respondent must correct all\ndeficiencies identified in its atmospheric corrosion inspections of the Iowa Extension.\nWilliams must provide a monthly update regarding all deficiencies that have been\ncorrected, beginning 30 days after receipt of the Final Order. All work is to be\ncompleted within 365 days after receipt of the Final Order.\nIt is requested (not mandated) that Williams maintain documentation of the safety improvement\ncosts associated with fulfilling this Compliance Order and submit the total to the Director. It is\nrequested that these costs be reported in two categories: 1) total cost associated with preparation/\nrevision of plans, procedures, studies and analyses; and 2) total cost associated with\nreplacements, additions and other changes to pipeline infrastructure.\nThe Director may grant an extension of time to comply with any of the required items upon a\nwritten request timely submitted by the Respondent and demonstrating good cause for an\nextension. Failure to comply with this Order may result in the administrative assessment of civil\npenalties not to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), for each\nviolation for each day the violation continues or in referral to the Attorney General for\nappropriate relief in a district court of the United States.\n\n\n\nCPF No. 4-2017-5001\nPage 7\nUnder 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this Final\nOrder to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey\nAvenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of\nChief Counsel, PHMSA, at the same address, no later than 20 days after receipt of service of this\nFinal Order by Respondent. Any petition submitted must contain a statement of the issue(s) and\nmeet all other requirements of 49 C.F.R. § 190.243. The filing of a petition automatically stays\nthe payment of any civil penalty assessed. The other terms of the order, including corrective\naction, remain in effect unless the Associate Administrator, upon request, grants a stay. The\nterms and conditions of this Final Order are effective upon service in accordance with 49 C.F.R.\n§ 190.5.\nJuly 24, 2017\n___________________________________ __________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n420175001_NOPV PCP PCO_01252017_text.pdf\n\nNOTICE OF PROBABLE VIOLATION,\nPROPOSED CIVIL PENALTY\nand\nPROPOSED COMPLIANCE ORDER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 25, 2017\nMr. Alan Armstrong\nPresident, Chief Executive Officer\nWilliams Olefins Feedstock Pipelines, LLC\nOne Williams Center\nTulsa, Oklahoma 74172\nCPF 4-2017-5001\nDear Mr. Armstrong:\nOn multiple occasions between August 31 and December 10, 2015, representatives of the\nPipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of\n49 United States Code inspected Williams Olefins Feedstock Pipelines, LLC’s (Williams) plans\nand records for operations and maintenance in Houston, Texas, and conducted field evaluation\nof its Bayou Ethane System and Iowa to Port Neches 6-inch pipeline system.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49 Code of Federal Regulations. The items inspected and the\nprobable violations are:\n1. § 195.49 Annual report.\nEach operator must annually complete and submit DOT Form PHMSA F 7000-1.1\nfor each type of hazardous liquid pipeline facility operated at the end of the previous\nyear. An operator must submit the annual report by June 15 each year, except that\nfor the 2010 reporting year the report must be submitted by August 15, 2011. A\nseparate report is required for crude oil, HVL (including anhydrous ammonia),\npetroleum products, carbon dioxide pipelines, and fuel grade ethanol pipelines. For\n\n\n\neach state a pipeline traverses, an operator must separately complete those sections\non the form requiring information to be reported for each state.\nWilliams did not include the new 10-inch, 0.37 mile BASF Connection pipeline in their 2014\nannual report submittal. Williams had constructed new pipelines and pipeline facilities in 2013\nand 2014 as part of the Bayou Ethane Pipeline Rehabilitation Project, which includes the\nconstruction of 0.37 miles of 10-inch pipeline (BASF Connection) which was completed in 2013.\nAt the time of inspection, Williams stated that the BASF Connection was sold to another\ncompany in 2014, but Williams retained operatorship. Williams’ 2014 Annual Report submitted\nto PHMSA did not include data information on BASF Connections.\nThis is a repeat violation of CPF 4-2013-5016, Items #1, 2, and 3.\n2. § 195.222 Welders: Qualification of welders.\n(a) Each welder must be qualified in accordance with section 6 of API 1104\n(incorporated by reference, see § 195.3) or section IX of the ASME Boiler and\nPressure Vessel Code, (incorporated by reference, see § 195.3) except that a welder\nqualified under an earlier edition than listed in § 195.3 may weld but may not re-\nqualify under that earlier edition.\nWilliams could not demonstrate that welders were qualified in accordance with section 6 of API\n1104 or section IX of the ASME Boiler and Pressure Vessel Code on the Bayou Ethane Pipeline\nRehabilitation Project that was completed in December 2014.\nWilliams constructed new pipelines and pipeline facilities in 2013 and 2014 as part of the Bayou\nEthane Pipeline Rehabilitation Project which included the following activities:\n(1) 3.24 miles of 12-inch steel pipeline (Ethane BASF South).\n(2) 0.49 mile of 12-inch steel pipeline (Ethane BASF North).\n(3) 0.48 mile of 12-inch steel pipeline (Korbe Junction to Explorer Line).\nA Request for Specific Information (RSFI) was sent to Williams on August 29, 2016. The RSFI\nspecifically requested a list of all welders that welded on the projects listed above. The RSFI\nalso specifically requested the welder qualification records to demonstrate that the welders were\nqualified in accordance with section 6 of API or section IX of the ASME Boiler and Pressure\nVessel Code.\nOn September 28, 2016, Williams provided the welding procedure and the procedure\nqualification record for Welding Procedure Specification Sunland-004. Williams provided\nanother welder record which was for a different contractor and company, and it could not be\ndetermined what procedure that the individual was qualified under and if that was approved by\nWilliams, dated November 16, 2012. Williams also provided a procedure qualification record\nTRB1-1, and no welding procedure. It is unclear that these individuals actually welded on the\nprojects and what procedures were utilized.\nThe RSFI also requested the non-destructive test records for the construction projects listed\n2\n\n\n\nabove. On September 28, 2016, Williams provided non-destructive test records for the projects.\nThe records provided did identify the welds being tested and the results of the non-destructive\ntests, but the records did not identify the welders. Williams stated that they were unable to locate\nand provide a weld map or other record that specifically confirms which welders performed each\nweld and the results of the non-destructive tests for those welds.\nWilliams’ Procedure WE-ADM-005, ‘Specification 102 – Welder Performance Qualification’,\nSection 3.1.3, states that “Prior to welding on pipelines, all welders are required to be qualified\nin accordance with one or more of the following: ASME Section IX and/or API 1104 (latest\nDOT-accepted editions).”\nThe information provided by Williams did not confirm how many welders were utilized and if\nthe welders were qualified to weld on activities #1, #2, and #3 above. Williams did not\ndemonstrate that the person(s) who welded on activities #1, #2, and #3 above, were qualified in\naccordance with section 6 of API 1104 or section IX of the ASME Boiler and Pressure Vessel\nCode.\n3. § 195.569 Do I have to examine exposed portions of buried pipelines?\nWhenever you have knowledge that any portion of a buried pipeline is exposed, you\nmust examine the exposed portion for evidence of external corrosion if the pipe is\nbare, or if the coating is deteriorated. If you find external corrosion requiring\ncorrective action under § 195.585, you must investigate circumferentially and\nlongitudinally beyond the exposed portion (by visual examination, indirect method,\nor both) to determine whether additional corrosion requiring remedial action exists\nin the vicinity of the exposed portion.\nWilliams did not examine exposed portions of buried pipe for evidence of external corrosion at\nthe time when Williams had constructed new pipelines and pipeline facilities in 2013 and 2014\nas part of the Bayou Ethane Pipeline Rehabilitation Project.\nWilliams Procedure No. 7.04-ADM-005, ‘Examining and Documenting the Condition of an\nUnderground Pipeline or Related Facility When Exposed for Any Reason’, Section 1, states that\neach time a buried pipeline or related underground facility is exposed for any reason\n(intentionally or unintentionally), it must be thoroughly inspected (end-to-end) and the\nconditions documented on the appropriate form(s).” The procedures also state, to perform an\ninspection of the pipe coating and pipe conditions and to document the findings on Form 02-\nOPR-1581-Maintenance Report or 02-LEG-1035-Encroachment Agreement (Short Form).\nAt the time of inspection, Williams was unable to provide documentation to demonstrate that the\npipelines that were exposed during the following construction activities had been examined for\nevidence of external corrosion:\n1. Replacement of existing valves on the “12-inch Explorer pipeline” segment’s main line\nvalve between Korbe Junction in Port Neches, Texas, and the Lake Charles Pump Station\nin Sulphur, Louisiana. Nine valves were converted to above ground valves and six valves\nremained underground. Williams was unable to provide documentation to demonstrate\nthat they had examined buried sections of the “12-inch Explorer pipeline” segment that\nwere exposed during the valve replacement for evidence of external corrosion.3\n\n\n\n2. Replacement of above ground spans at two locations on the “12-inch, Explorer pipeline”\nsegments. One span, approximately 800 feet in length, was replaced with underground\npipe via Horizontal Directional Drilling; and the other span, approximately 75 feet in\nlength was replaced by open cut technique. Williams was unable to provide\ndocumentation to demonstrate they had examined buried sections of existing “12-inch\nExplorer pipeline” segment that were exposed during the pipeline span replacement for\nevidence of external corrosion.\n3. A 12-inch, 2.5 miles of pipeline was constructed to connect the Lake Charles Pump\nStation to the existing 8-inch pipeline near Sulphur, Louisiana. A new 12-inch pig trap\nwas also installed at the Lake Charles Pump Station Williams was unable to provide\ndocumentation to demonstrate that they had examined the buried section of the existing\n8-inch pipeline for evidence of external corrosion.\n4. A new 12-inch, 0.49 mile pipeline (Ethane BASF North) was constructed and connected\nto the existing “12-inch Explorer pipeline” segment. Williams was unable to provide\ndocumentation to demonstrate that they had examined the buried sections of the existing\n“12-inch Explorer pipeline” segment that were exposed during the construction for\nevidence of external corrosion.\n5. A new 12-inch, 3.24 miles pipeline (Ethane BASF South) was constructed between\nexisting “8-inch, 840 pipeline” segment and the existing “12-inch Explorer pipeline”\nsegment. Williams was unable to provide documentation to demonstrate that they had\nexamined the buried sections of existing “8-inch, 840 pipeline” segment and buried\nsections of existing “12-inch Explorer pipeline” segment that were exposed during the\nconstruction for evidence of external corrosion.\n6. A new 12-inch, 0.48 mile pipeline (Korbe Junction to Explorer) was constructed and\nconnected to the existing “12-inch Explorer pipeline” segment. Williams was unable to\nprovide documentation to demonstrate that they had examined buried sections of existing\n“12-inch Explorer pipeline” segment that were exposed during construction for evidence\nof external corrosion.\n4. § 195.579 What must I do to mitigate internal corrosion?\n(c) Removing pipe. Whenever you remove pipe from a pipeline, you must inspect\nthe internal surface of the pipe for evidence of corrosion. If you find internal\ncorrosion requiring corrective action under § 195.585, you must investigate\ncircumferentially and longitudinally beyond the removed pipe (by visual\nexamination, indirect method, or both) to determine whether additional corrosion\nrequiring remedial action exists in the vicinity of the removed pipe.\nWilliams did not inspect the internal surface of the removed pipe at the time when Williams had\nconstructed new pipelines and pipeline facilities in 2013 and 2014 as part of the Bayou Ethane\nPipeline Rehabilitation Project.\nWilliams Procedure No. 7.04-ADM-005, ‘Examining and Documenting the Condition of an\nUnderground Pipeline or Related Facility When Exposed for Any Reason’, Section 2, states that4\n\n\n\n“If the internal portion of the pipe is exposed from being cut, coupon extracted, or other reasons,\ninclude the internal surface in the Corrosion examination.” The procedures also state, to perform\nan inspection of the internal pipe conditions and to document the findings on 02-OPR-1581 –\nMaintenance Report or 02-LEG-1035-Encroachment Agreement (Short Form).\nAt the time of inspection, Williams did not provide documentation to demonstrate that pipelines\nthat were exposed internally from being cut during the following construction activities had been\nexamined for evidence of internal corrosion:\n1. A new pump station was constructed near Hankamer, Texas, and connected to the\nexisting “8-inch, 840 pipeline” segment. Williams did not provide documentation to\ndemonstrate they had internally examined sections of the “840 pipeline” segment for\nevidence of internal corrosion.\n2. 3. 4. New pump station construction near Port Arthur, Texas, and connected to the existing\n“12-inch Explorer pipeline” segment. Williams did not provide documentation to\ndemonstrate they had internally examined sections of the “12-inch Explorer pipeline”\nsegment for evidence of internal corrosion.\nValve replacement was conducted on the existing “12-inch Explorer pipeline” segment’s\nmain line valve between Korbe Junction in Port Neches, Texas, and the Lake Charles\nPump Station in Sulphur, Louisiana. Nine valves were converted to above ground valves\nand six valves remain underground. Williams did not provide documentation to\ndemonstrate they had internally examined sections of “12-inch Explorer pipeline”\nsegment for evidence of internal corrosion.\nReplacement of above ground spans at two locations on the “12-inch Explorer pipeline”\nsegments. One span, approximately 800 feet in length, was replaced with underground\npipe via Horizontal Directional Drilling; and the other span, approximately 75 feet in\nlength was replaced by open cut technique. Williams did not provide documentation to\ndemonstrate they had internally examined sections of the existing “12-inch Explorer\npipeline” segment that was exposed and cut during the pipeline span replacement for\nevidence of external corrosion.\n5. Replacement of an ethane liquid meter was installed at the Lake Charles Pump Station.\nWilliams did not provide documentation to demonstrate they had internally examined the\nsection of existing above ground pipe connected to the new ethane liquid meter for\nevidence of internal corrosion.\n6. A 12-inch, 2.5 miles of pipeline was constructed to connect Lake Charles Pump Station\nto the existing 8-inch pipeline near Sulphur, Louisiana. A new 12-inch pig trap was also\ninstalled at the Lake Charles Pump Station. Williams did not provide documentation to\n5\n\n\n\ndemonstrate they had internally examined the section of the existing 8-inch pipeline for\nevidence of internal corrosion.\n7. A new pump station was constructed near Bruly, Louisiana, and connected to an existing\n10-inch pipeline. Williams did not provide documentation to demonstrate they had\ninternally examined the section of the existing 10-inch pipeline for evidence of internal\ncorrosion.\n8. 9. A new 12-inch, 0.49 mile pipeline (Ethane BASF North) was constructed and connected\nto existing the “12-inch Explorer pipeline” segment. Williams did not provide\ndocumentation to demonstrate they had internally examined sections of the existing “12-\ninch Explorer pipeline” segment that was exposed for evidence of internal corrosion.\nA new 12-inch, 3.24 miles pipeline (Ethane BASF South) was constructed between an\nexisting “8-inch, 840 pipeline” segment and the existing “12-inch Explorer pipeline”\nsegments. Williams did not provide documentation to demonstrate they had internally\nexamined sections of the existing “8-inch, 840 pipeline” segment and sections of the\nexisting “12-inch Explorer pipeline” segments that were exposed for evidence of internal\ncorrosion.\n10. A new 12-inch, 0.48 mile pipeline (Korbe Junction to Explorer) was constructed and\nconnected to the existing “12-inch Explorer pipeline” segment. Williams did not provide\ndocumentation to demonstrate they had internally examined sections of the existing “12-\ninch Explorer pipeline” segment that was exposed for evidence of internal corrosion.\n5. § 195.583 What must I do to monitor atmospheric corrosion control?\n(c) If you find atmospheric corrosion during an inspection, you must provide\nprotection against the corrosion as required by §195.581.\nWilliams did not provide protection against atmosphere corrosion, after atmospheric corrosion\nwas identified during inspections. During the inspection of the Williams Iowa to Orange 6-inch\npipeline system, the inspector reviewed the inspection of valves and the documentation indicated\nthat there was atmospheric corrosion with repairs, identified at the following locations:\n1) Valve Site #10 Old Ferry Road\n2) Valve Site #9 South Pig Trap.\n3) Valve Site #8 North Pig Trap\n4) Valve Site #6 Global Dr.\n5) 6” Riser off 6” Main Line Targa Valve Site Greywood Parkway.\n6) Valve Site #5 Tank Farm Rd.\n7) Valve Site #4 Ham Reid Rd.\nInspections of the valves noted above were conducted in April 2014; October 2015 and in May\n2015. The Valve Inspection Reports, 02-OPR-1035, indicate ‘Corrosion’ was observed on their\ninspection forms. Under the ‘List Post-Inspection Repairs Needed’ column, comments state that6\n\n\n\nvarious repairs are needed. The deficiencies and repair recommendations noted were the same\nfor all valve inspections.\nWilliams’ Procedure No 9.01-ADM-037 Valve Inspection and Maintenance, states ‘Using 02-\nOPR-1035 – Valve Inspection Report, document any repairs or corrections made and any\ndeficiencies observed which require follow-up.’ A review of records indicated that in 2014 and\n2015, several valves had atmospheric corrosion deficiencies, specifically Valve Site #4 and #10.\nDuring the PHMSA field inspection during the week of December 8-10, 2015, it was discovered\nthat these valve sites had not been maintained. The PHMSA field inspection revealed that\nseveral pipeline and pipeline components showed severe atmospheric corrosion; and pipe\nsupports and valve handles were missing and corroded.\nMoreover, Valve Sites #1, #7 and #11 were physically visited and inspected. Pipeline and\npipeline components at these locations also showed severe atmospheric corrosion. The 2014 and\n2015 annual valve inspection forms did not have any notes on the observations regarding\natmospheric corrosion for these valves. Also, Valve Site #11 was not listed on 2014 and 2015\nannual valve inspection.\nWilliams’ Procedure No. 7.04-ADM-002 - Atmospheric Corrosion Inspection, states that they\nare to visually ‘inspect all surfaces and assign a visual coating condition code on the Atmospheric\nCorrosion Inspection data gather form, generated from the American Innovations Pipeline\nCompliance System (PCS) or in the data logger as either “Adequate” or “Inadequate.” Also, the\nprocedures state that they are to visually ‘inspect all surfaces and assign a visual corrosion\ncondition code on the Atmospheric Corrosion Inspection data gather form (generated from the\nAmerican Innovations Pipeline compliance System (P","truncated":true,"body_characters":46594}