{"operation":"document","citation":"CPF 420205002M","title":"WILLIAMS OIL GATHERING, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-01-13","effective_on":null,"summary":"CLOSED notice of amendment citing 195.573(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420205002m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420205002m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420205002m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420205002M","body":"Notice of Amendment involving WILLIAMS OIL GATHERING, LLC. PHMSA's enforcement data identifies the cited regulation as 195.573(e). The case was opened on 2020-01-13 and is reported as closed as of 2020-02-24. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420205002M_Closure Letter_02242020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205002M/420205002M_Closure%20Letter_02242020.pdf\n\n420205002M_Closure Letter_02242020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205002M/420205002M_Closure%20Letter_02242020_text.pdf\n\n420205002M_Notice of Amendment_01132020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205002M/420205002M_Notice%20of%20Amendment_01132020.pdf\n\n420205002M_Notice of Amendment_01132020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205002M/420205002M_Notice%20of%20Amendment_01132020_text.pdf\n\n420205002M_Operator Response to Notice_02032020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205002M/420205002M_Operator%20Response%20to%20Notice_02032020.pdf\n\n420205002M_Notice of Amendment_01132020_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 13, 2020\nMark Cluff\nVice President Safety & Operational Discipline\nWilliams Oil Gathering, LLC\nOne Williams Center\nTulsa, Oklahoma 74172\nCPF 4-2020-5002M\nDear Mr. Cluff:\nFrom December 10, 2018 to July 11, 2019, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected Williams Oil Gathering, LLC’s (Williams’) procedures for external corrosion control in\nHouston, Texas.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within\nWilliams’ plans or procedures, as described below:\n1. §195.573 What must I do to monitor external corrosion control?\n(e) Corrective action. You must correct any identified deficiency in corrosion control\nas required by §195.401(b). However, if the deficiency involves a pipeline in an\nintegrity management program under §195.452, you must correct the deficiency as\nrequired by §195.452(h).\nWilliams’ procedure fails to require corrective action when deficiencies are identified in external\ncorrosion control as required by §195.401(b) or §195.452(h).\n\n\n\nWilliams’ procedure titled Corrosion Control for Hazardous Liquid Pipelines does not require\ncorrection or repair when deficiencies are noted in cathodic protection levels, rectifiers, or bonds.\nWilliams must amend its procedure to require correction of deficiencies and define a reasonable\ntime for doing so.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 60 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Williams maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Mary L. McDaniel, Director, Southwest Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please\nrefer to CPF 4-2020-5002M and, for each document you submit, please provide a copy in\nelectronic format whenever possible.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n2\n\n420205002M_Closure Letter_02242020_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 24, 2020\nMark Cluff\nVice President Safety & Operational Discipline\nWilliams Oil Gathering, LLC\nOne Williams Center\nTulsa, Oklahoma 74172\nCPF 4-2020-5002M\nDear Mr. Cluff:\nFrom December 10, 2018 to July 11, 2019, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\nconducted an inspection of Williams Oil Gathering, LLC’s (Williams’) procedures in Houston,\nTexas. As a result of the inspection, Williams was issued a Notice of Amendment on January 13,\n2020, which proposed amendment of it’s procedures.\nWilliams submitted its amended procedures on February 3, 2020. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\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","truncated":false,"body_characters":6263}