WILLIAMS OIL GATHERING, LLC — Notice of Amendment

party submissionOfficial PDF420205002M_Operator Response to Notice_02032020.pdf#

420205002M_Notice of Amendment_01132020_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED January 13, 2020 Mark Cluff Vice President Safety & Operational Discipline Williams Oil Gathering, LLC One Williams Center Tulsa, Oklahoma 74172 CPF 4-2020-5002M Dear Mr. Cluff: From December 10, 2018 to July 11, 2019, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Williams Oil Gathering, LLC’s (Williams’) procedures for external corrosion control in Houston, Texas. On the basis of the inspection, PHMSA has identified the apparent inadequacy found within Williams’ plans or procedures, as described below: 1. §195.573 What must I do to monitor external corrosion control? (e) Corrective action. You must correct any identified deficiency in corrosion control as required by §195.401(b). However, if the deficiency involves a pipeline in an integrity management program under §195.452, you must correct the deficiency as required by §195.452(h). Williams’ procedure fails to require corrective action when deficiencies are identified in external corrosion control as required by §195.401(b) or §195.452(h).#

420205002M_Notice of Amendment_01132020_text.pdf, page 2Williams’ procedure titled Corrosion Control for Hazardous Liquid Pipelines does not require correction or repair when deficiencies are noted in cathodic protection levels, rectifiers, or bonds. Williams must amend its procedure to require correction of deficiencies and define a reasonable time for doing so. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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. Be advised that all material you submit in response to this enforcement action is subject to being 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). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. 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 an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 60 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that Williams maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Mary L. McDaniel, Director, Southwest Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 4-2020-5002M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Mary L. McDaniel, P.E. Director, Southwest Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings 2#

420205002M_Closure Letter_02242020_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED February 24, 2020 Mark Cluff Vice President Safety & Operational Discipline Williams Oil Gathering, LLC One Williams Center Tulsa, Oklahoma 74172 CPF 4-2020-5002M Dear Mr. Cluff: From December 10, 2018 to July 11, 2019, a representative from the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, conducted an inspection of Williams Oil Gathering, LLC’s (Williams’) procedures in Houston, Texas. As a result of the inspection, Williams was issued a Notice of Amendment on January 13, 2020, which proposed amendment of it’s procedures. Williams submitted its amended procedures on February 3, 2020. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Mary L. McDaniel, P.E. Director, Southwest Region Pipeline and Hazardous Materials Safety Administration#