{"operation":"document","citation":"CPF 420207001W","title":"WILLIAMS OIL GATHERING, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-01-09","effective_on":null,"summary":"CLOSED warning letter citing 195.54(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420207001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420207001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420207001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420207001W","body":"Warning Letter involving WILLIAMS OIL GATHERING, LLC. PHMSA's enforcement data identifies the cited regulation as 195.54(a). The case was opened on 2020-01-09 and is reported as closed as of 2020-01-09. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420207001W_Operator Response to Notice_04092020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420207001W/420207001W_Operator%20Response%20to%20Notice_04092020.pdf\n\n420207001W_Warning Letter_01092020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420207001W/420207001W_Warning%20Letter_01092020.pdf\n\n420207001W_Warning Letter_01092020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420207001W/420207001W_Warning%20Letter_01092020_text.pdf\n\n420207001W_Warning Letter_01092020_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 9, 2020\nMark Cluff\nVice President Safety & Operational Discipline\nWilliams Oil Gathering LLC\nOne Williams Center\nTulsa, Oklahoma 74172\nCPF 4-2020-7001W\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\n(U.S.C.) inspected your offshore hazardous liquid pipelines in the Gulf of Mexico.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and\nthe probable violation is:\n1. §195.54 Accident reports.\n(a) Each operator that experiences an accident that is required to be reported under §195.50 must,\nas soon as practicable, but not later than 30 days after discovery of the accident, file an accident\nreport on DOT Form 7000-1.\nWilliams failed to file a written accident report on DOT Form 7000-1 within 30 days of discovery\nof a reportable accident.\nWilliams discovered a reportable accident at a subsea tie-in on its Mississippi Canyon 728\nPlatform on June 14, 2018. This accident was not reported to PHMSA until August 20, 2018, 37\ndays beyond the required 30 days.\n\n\n\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related\nseries of violations. For violation occurring on or after November 27, 2018 and before July 31,\n2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum\npenalty not to exceed $2,132,679. For violation occurring on or after November 2, 2015 and before\nNovember 27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a\nmaximum penalty not to exceed $2,090,022. For violations occurring prior to November 2, 2015,\nthe maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty\nnot to exceed $2,000,000 for a related series of violations. We have reviewed the circumstances\nand supporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct the\nitem(s) identified in this letter. Failure to do so will result in Williams Oil Gathering, LLC being\nsubject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2020-7001W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n2","truncated":false,"body_characters":4090}