# WILLIAMS OIL GATHERING, LLC — Warning Letter

- **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:** Not available
- **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.

Official case documents:

420207001W_Operator Response to Notice_04092020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420207001W/420207001W_Operator%20Response%20to%20Notice_04092020.pdf

420207001W_Warning Letter_01092020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420207001W/420207001W_Warning%20Letter_01092020.pdf

420207001W_Warning Letter_01092020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420207001W/420207001W_Warning%20Letter_01092020_text.pdf

420207001W_Warning Letter_01092020_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
January 9, 2020
Mark Cluff
Vice President Safety & Operational Discipline
Williams Oil Gathering LLC
One Williams Center
Tulsa, Oklahoma 74172
CPF 4-2020-7001W
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
(U.S.C.) inspected your offshore hazardous liquid pipelines in the Gulf of Mexico.
As a result of the inspection, it is alleged that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and
the probable violation is:
1. §195.54 Accident reports.
(a) Each operator that experiences an accident that is required to be reported under §195.50 must,
as soon as practicable, but not later than 30 days after discovery of the accident, file an accident
report on DOT Form 7000-1.
Williams failed to file a written accident report on DOT Form 7000-1 within 30 days of discovery
of a reportable accident.
Williams discovered a reportable accident at a subsea tie-in on its Mississippi Canyon 728
Platform on June 14, 2018. This accident was not reported to PHMSA until August 20, 2018, 37
days beyond the required 30 days.



Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related
series of violations. For violation occurring on or after November 27, 2018 and before July 31,
2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum
penalty not to exceed $2,132,679. For violation occurring on or after November 2, 2015 and before
November 27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a
maximum penalty not to exceed $2,090,022. For violations occurring prior to November 2, 2015,
the maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty
not to exceed $2,000,000 for a related series of violations. We have reviewed the circumstances
and supporting documents involved in this case, and have decided not to conduct additional
enforcement action or penalty assessment proceedings at this time. We advise you to correct the
item(s) identified in this letter. Failure to do so will result in Williams Oil Gathering, LLC being
subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 4-2020-7001W. 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).
Sincerely,
Mary L. McDaniel, P.E.
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
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