{"operation":"document","citation":"CPF 420175002M","title":"WILLIAMS OLEFINS FEEDSTOCK PIPELINES, LLC — Notice of Amendment","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 amendment citing 195.202, 195.234(e)(1), 195.234(e)(4), 195.234(e)(5), 195.234(f), 195.266, 195.302(a), 195.308, 195.402(a), 195.402(c)(13), 195.402(c)(3), 195.403(c), 195.406(a), 195.424(c), 195.557(b), 195.563(a), 195.573(a)(2), 195.575(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175002m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175002m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175002m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420175002M","body":"Notice of Amendment involving WILLIAMS OLEFINS FEEDSTOCK PIPELINES, LLC. PHMSA's enforcement data identifies the cited regulations as 195.202,  195.234(e)(1),  195.234(e)(4),  195.234(e)(5),  195.234(f),  195.266,  195.302(a),  195.308,  195.402(a),  195.402(c)(13),  195.402(c)(3),  195.403(c),  195.406(a),  195.424(c),  195.557(b),  195.563(a),  195.573(a)(2),  195.575(e). The case was opened on 2017-01-25 and is reported as closed as of 2019-03-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420175002M_Closure Letter_03052019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175002M/420175002M_Closure%20Letter_03052019.pdf\n\n420175002M_Closure Letter_03052019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175002M/420175002M_Closure%20Letter_03052019_text.pdf\n\n420175002M_Notice of Amendment_01252017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175002M/420175002M_Notice%20of%20Amendment_01252017.pdf\n\n420175002M_Notice of Amendment_01252017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175002M/420175002M_Notice%20of%20Amendment_01252017_text.pdf\n\n420175002M_Operator Response to Notice_03012017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175002M/420175002M_Operator%20Response%20to%20Notice_03012017.pdf\n\n420175002M_Closure Letter_03052019_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 5, 2019\nAlan Armstrong\nPresident, Chief Executive Officer\nWilliams Olefins Feedstock Pipelines, LLC\nOne Williams Center\nTulsa, Oklahoma 74172\nCPF 4-2017-5002M\nDear Mr. Armstrong:\nOn August 17–20, 2015, a representative from the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site\npipeline safety inspection of Williams Olefins Feedstock LLC procedures in Houston Texas. As\na result of the inspection, Williams was issued a Notice of Amendment on January 25, 2017, which\nproposed amendment of your procedures.\nWilliams submitted its amended procedures on March 15, 2017. My staff has reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nMary L. McDaniel P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nCC:\nMr. Mark Cluff\nVice President Safety & Operational Discipline\nWilliams Olefins Feedstock Pipeline LLC\n\n420175002M_Notice of Amendment_01252017_text.pdf\n\nNOTICE OF AMENDMENT\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 4-2017-5002M\nDear Mr. Armstrong:\nOn August 17-20 2015, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Williams\nOlefins Feedstock Pipelines’ procedures for operations and maintenance in Houston, Texas.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nWilliams’ plans or procedures, as described below:\n1. §195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive written\nspecifications or standards that are consistent with the requirements of this part.\n§195.266 Construction records.\nA complete record that shows the following must be maintained by the operator\ninvolved for the life of each pipeline facility:\n(a) The total number of girth welds and the number nondestructively tested,\n\n\n\nincluding the number rejected and the disposition of each rejected weld.\n(b) The amount, location; and cover of each size of pipe installed.\n(c) The location of each crossing of another pipeline.\n(d) The location of each buried utility crossing.\n(e) The location of each overhead crossing.\n(f) The location of each valve and corrosion test station.\nWilliams’ Procedure No. 7.13-ADM-002, ‘Pipeline Drawing and Data Management Program’,\nis inadequate in that it does not require retention of some construction records as specified by\n§195.266, for the life of the pipeline.\nWilliams’ procedure indicates that maps and records of (1) crossings of public roads, rivers,\nburied utilities and foreign pipelines, (2) pipeline valves and (3) diameter, grade, type and\nnominal wall thickness of all pipe, will be maintained, but it did not require retaining of these\nrecords for the life of the pipeline.\nMoreover, Williams’ procedure is inadequate in that it does not require retention of (1) the\namount, location and cover of each size of pipe installed, (2) location of each overhead crossing\nand (3) location of each valve and corrosion test station, for the life of the pipeline.\n2. § 195.202 Compliance with specifications or standards.\n(See above)\n§ 195.234 Welds: Nondestructive testing.\n(e) All girth welds installed each day in the following locations must be\nnondestructively tested over their entire circumference, except that when\nnondestructive testing is impracticable for a girth weld, it need not be tested if the\nnumber of girth welds for which testing is impracticable does not exceed 10 percent\nof the girth welds installed that day:\n(1) At any onshore location where a loss of hazardous liquid could reasonably be\nexpected to pollute any stream, river, lake, reservoir, or other body of water, and\nany offshore area;\n(4) Within the limits of any incorporated subdivision of a State government; and\n(5) Within populated areas, including, but not limited to, residential subdivisions,\nshopping centers, schools, designated commercial areas, industrial facilities, public\ninstitutions, and places of public assembly.\n(f) When installing used pipe, 100 percent of the old girth welds must be\nnondestructively tested.\n2\n\n\n\nWilliams’ Procedure No. WE-ADM-002, ‘Scope and Definition’, is inadequate in that it does\nnot require nondestructive testing of girth welds on some of the locations specified by § 195.234\nand it does not require 100 percent nondestructively testing of old girth welds when installing\nused pipe.\nWilliams must revise its procedure to require all girth welds installed each day in the following\nlocations to be nondestructively tested over their entire circumference, except that when\nnondestructive testing is impracticable for a girth weld, it need not be tested if the number of\ngirth welds for which testing is impracticable does not exceed 10 percent of the girth welds\ninstalled that day:\n(1) At any onshore location where a loss of hazardous liquid could reasonably be expected to\npollute any stream, river, lake, reservoir, or other body of water, and any offshore area;\n(2) Within the limits of any incorporated subdivision of a State government; and\n(3) Within populated areas, including, but not limited to, residential subdivisions, shopping\ncenters, schools, designated commercial areas, industrial facilities, public institutions, and places\nof public assembly.\nAlso, Williams must revise its procedure to require that when installing used pipe, 100 percent\nof the old girth welds must be nondestructively tested.\n3. § 195.202 Compliance with specifications or standards.\n(See above)\n§ 195. 302 General requirements\n(a) Except as otherwise provided in this section and in § 195.305(b), no operator\nmay operate a pipeline unless it has been pressure tested under this subpart\nwithout leakage. In addition, no operator may return to service a segment of\npipeline that has been replaced, relocated, or otherwise changed until it has been\npressure tested under this subpart without leakage.\nWilliams’ Procedure No. SIP-ADM-7.07 ‘Pressure Testing’ is inadequate in that it does not\nrequire pressure testing without leakage a segment of pipeline that has been replaced and prior\nto being placed into service.\nWilliams must revise its procedure to require a segment of pipeline that has been replaced,\nrelocated, or otherwise changed not to return to service until it has been pressure tested without\nleakage under Subpart E of the Code.\n3\n\n\n\n4. § 195.202 Compliance with specifications or standards.\n(See above)\n§ 195.308 Testing of tie-ins.\nPipe associated with tie-ins must be pressure tested, either with the section to be tied\nin or separately.\nWilliams’ Procedure No. 7.07-ADM-005 ‘Pressure Testing USA Hazardous Liquids Pipelines’\nand Procedure no. SIP-ADM-7.07 ‘Pressure Testing’ are inadequate in that it does not include\nrequirements specified by § 195.308.\nWilliams must revise its procedures to require pressure testing of pipe, attached fittings and\nattached components associated with tie-ins.\n5. § 195.402 procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and\nmaintenance activities and handling abnormal operations and emergencies.\nThis manual shall be reviewed at intervals not exceeding 15 months, but at least\nonce each calendar year, and appropriate changes made as necessary to insure\nthat the manual is effective. This manual shall be prepared before initial\noperations of a pipeline system commence, and appropriate parts shall be kept\nat locations where operations and maintenance activities are conducted.\n§ 195.424 Pipe movement\n(c) No operator may move any pipeline containing highly volatile liquids where\nmaterials in the line section involved are not joined by welding unless—\n(1) The operator complies with paragraphs (b) (1) and (2) of this section; and\n(2) That line section is isolated to prevent the flow of highly volatile liquid.\nWilliams’ Procedure No. 7.08-ADM-019 ‘Pipeline Movement’, is inadequate in that it does not\ninclude requirements specified by § 195.424 (c).\nWilliams must revise its procedure to require any pipeline containing highly volatile liquids\nwhere materials in the line section involved are not joined by welding not to be moved unless:\n(1) The operator complies with paragraphs § 195.424 (b)(1) and § 195.424 (b)(2) and (2) That\nline section is isolated to prevent the flow of highly volatile liquid.\n4\n\n\n\n6. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) See above.\n§ 195.403 Emergency response training.\n(c) Each operator shall require and verify that its supervisors maintain a thorough\nknowledge of that portion of the emergency response procedures established under\n195.402 for which they are responsible to ensure compliance.\nWilliams’ Procedure No. SIP-ADM-12.01 ‘Emergency Response and Planning’ is inadequate in\nthat it does not include requirement for ensuring supervisors that they are knowledgeable on\nemergency response procedures for which they are responsible.\nWilliams must revise its procedure to require supervisors to be trained on emergency response\nprocedures for which they are responsible.\n7. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n§ 195.406 Maximum operating pressure.\n(a) Except for surge pressures and other variations from normal operations, no\noperator may operate a pipeline at a pressure that exceeds any of the following:\n(1) The internal design pressure of the pipe determined in accordance with §\n195.106. However, for steel pipe in pipelines being converted under § 195.5, if one\nor more factors of the design formula (§ 195.106) are unknown, one of the following\npressures is to be used as design pressure:\n(i) Eighty percent of the first test pressure that produces yield under section N5.0 of\nappendix N of ASME B31.8, reduced by the appropriate factors in §§ 195.106 (a)\nand (e); or\n(ii) If the pipe is 123∕4 inch (324 mm) or less outside diameter and is not tested to\nyield under this paragraph, 200 p.s.i. (1379 kPa) gage.\n(2) The design pressure of any other component of the pipeline.\n(3) Eighty percent of the test pressure for any part of the pipeline which has been\npressure tested under subpart E of this part.\n5\n\n\n\n(4) Eighty percent of the factory test pressure or of the prototype test pressure for\nany individually installed component which is excepted from testing under §\n195.305.\n(5) For pipelines under §§ 195.302(b)(1) and (b)(2)(i) that have not been pressure\ntested under subpart E of this part, 80 percent of the test pressure or highest\noperating pressure to which the pipeline was subjected for 4 or more continuous\nhours that can be demonstrated by recording charts or logs made at the time the\ntest or operations were conducted.\nWilliams’ Procedure No. 7.10-ADM-007 ‘Maximum Operating Pressure’, is inadequate as they\nhad paraphrased §195.406(a).\nWilliams must revise its procedure to include a more robust and detailed process for establishing\nthe maximum operating pressure allowed for Williams’ in accordance with §195.406.\n8. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(c)(3) See above.\n§ 195.557 Which pipelines must have coating for external corrosion control?\nExcept bottoms of above ground breakout tanks, each buried or submerged pipeline\nmust have an external coating for external corrosion control if the pipeline is –\n(b) Converted under § 195.5 and—\n(1) Has an external coating that substantially meets § 195.559 before the pipeline is\nplaced in service; or\n(2) Is a segment that is relocated, replaced, or substantially altered.\nWilliams’ Procedure No. 7.09-ADM-002 ‘Conversion of Service’ is inadequate in that it does\nnot include requirements specified by § 195.557(b).\nWilliams must revise its procedure to require coating of pipelines converted under § 195.5 and\nhas an external coating that substantially meets § 195.559 before the pipeline is placed in service\nor converted under § 195.5 and is a segment that is relocated, replaced, or substantially altered.\n9. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(c)(3) See above.\n§ 195.563 Which pipelines must have cathodic protection?\n(a) Each buried or submerged pipeline that is constructed, relocated, replaced, or\n6\n\n\n\notherwise changed after the applicable date in § 195.401(c) must have cathodic\nprotection. The cathodic protection must be in operation not later than 1 year after\nthe pipeline is constructed, relocated, replaced, or otherwise changed, as applicable.\nWilliams’ Procedure No. 7.04-ADM-016 ‘External Corrosion Control Program’, Section 2.5\nwhich states temporary cathodic system shall be provided as soon as practical during\nconstruction and a permanent Cathodic Protection system shall be provided within one year of\ncompleted construction is inadequate in that it does not specify when cathodic protection must\nbe operational on relocated, replaced, or otherwise changed pipelines.\nWilliams must revise its procedure to require that the cathodic protection must be in operation\nnot later than 1 year after the pipeline is relocated, replaced, or otherwise changed.\n10. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(c)(3) See above.\n§ 195.573 What must I do to monitor external corrosion control?\n(a) Protected pipelines. You must do the following to determine whether cathodic\nprotection required by this subpart complies with § 195.571:\n(2) Identify not more than 2 years after cathodic protection is installed, the\ncircumstances in which a close-interval survey or comparable technology is\npracticable and necessary to accomplish the objectives of paragraph 10.1.1.3 of\nNACE SP 0169 (incorporated by reference, see § 195.3).\nWilliams’ Procedure No. 7.04-ADM-016 ‘External Corrosion Control Program’, Section 2.6.3\ninadequate in that it does not include requirements specified by § 195.573(a)(2).\nWilliams must revise its procedure to identify not more than 2 years after cathodic protection is\ninstalled, the circumstances in which a close-interval survey or comparable technology is\npracticable and necessary to accomplish the objectives of paragraph 10.1.1.3 of NACE SP 0169.\n11. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(c)(3) See above.\n§ 195.575 and safeguards are required?\nWhich facilities must I electrically isolate and what inspections, tests,\n(e) If a pipeline is in close proximity to electrical transmission tower footings,\nground cables, or counterpoise, or in other areas where it is reasonable to foresee\nfault currents or an unusual risk of lightning, you must protect the pipeline against\ndamage from fault currents or lightning and take protective measures at insulating\ndevices.\n7\n\n\n\nWilliams’ Procedure No. 7.04-ADM-016 ‘External Corrosion Control Program’, Section 2.9.6\nis inadequate as they had paraphrased §195.575(e).\nWilliams must revise its procedure to include detailed process to give sufficient guidance for\ndetermining when protection against damage from fault currents or lightning is needed and how\nthat protection must be installed.\n12. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(13) Periodically reviewing the work done by operator personnel to determine the\neffectiveness of the procedures used in normal operation and maintenance and\ntaking corrective action where deficiencies are found.\nWilliams’ Procedure No. SIP-ADM-9.01 ‘Operations and Maintenance’ is inadequate in that it\ndoes not include requirements specified by § 195.402(c)(13).\nWilliams must revise its procedure to require periodic review of the work done by operator\npersonnel to determine the effectiveness of the procedures used in normal operation and\nmaintenance and to require taking corrective action when deficiencies are found during the\nreview process. Also, the procedure must have a detailed process on how to conduct the periodic\nreview of the work done by operator personnel.\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\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue a Final Order.\n8\n\n\n\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the inadequacies\n(49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that you submit your\namended procedures to my office within 45 days of receipt of this Notice. This period may be\nextended by written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that Williams Company maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to R. M. Seeley, Director, Southwest Region, Pipeline\nand Hazardous Materials Safety Administration. In correspondence concerning this matter,\nplease refer to CPF 4-2017-5002M and, for each document you submit, please provide a copy\nin electronic format whenever possible.\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n9","truncated":false,"body_characters":20783}