# WILLIAMS OIL GATHERING, LLC — Notice of Amendment

- **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:** Not available
- **summary:** CLOSED notice of amendment citing 195.573(e).
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- **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.

Official case documents:

420205002M_Closure Letter_02242020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205002M/420205002M_Closure%20Letter_02242020.pdf

420205002M_Closure Letter_02242020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205002M/420205002M_Closure%20Letter_02242020_text.pdf

420205002M_Notice of Amendment_01132020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205002M/420205002M_Notice%20of%20Amendment_01132020.pdf

420205002M_Notice of Amendment_01132020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205002M/420205002M_Notice%20of%20Amendment_01132020_text.pdf

420205002M_Operator Response to Notice_02032020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205002M/420205002M_Operator%20Response%20to%20Notice_02032020.pdf

420205002M_Notice of Amendment_01132020_text.pdf

NOTICE 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).



Williams’ 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

CERTIFIED 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
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