{"operation":"document","citation":"CPF 42021004NOA","title":"WILLIAMS OLEFINS FEEDSTOCK PIPELINES, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-03-02","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(a), 195.402(c)(13), 195.402(c)(3), 195.422(a), 195.426, 195.428(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021004noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021004noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021004noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42021004NOA","body":"Notice of Amendment involving WILLIAMS OLEFINS FEEDSTOCK PIPELINES, LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.402(c)(13),  195.402(c)(3),  195.422(a),  195.426,  195.428(a). The case was opened on 2021-03-02 and is reported as closed as of 2021-10-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42021004NOA_Closure Letter_10072021_(20-172609).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021004NOA/42021004NOA_Closure%20Letter_10072021_(20-172609).pdf\n\n42021004NOA_Closure Letter_10072021_(20-172609)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021004NOA/42021004NOA_Closure%20Letter_10072021_(20-172609)_text.pdf\n\n42021004NOA_Notice of Amendment_03022021_(20-172609).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021004NOA/42021004NOA_Notice%20of%20Amendment_03022021_(20-172609).pdf\n\n42021004NOA_Notice of Amendment_03022021_(20-172609)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021004NOA/42021004NOA_Notice%20of%20Amendment_03022021_(20-172609)_text.pdf\n\n42021004NOA_Operator Response to Notice_03302021_(20-172609).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021004NOA/42021004NOA_Operator%20Response%20to%20Notice_03302021_(20-172609).pdf\n\n42021004NOA_Notice of Amendment_03022021_(20-172609)_text.pdf\n\nNOTICE OF AMENDMENT\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nMarch 2, 2021\nAlan Armstrong\nPresident & Chief Executive Officer\nWilliams Olefins Feedstock Pipelines, LLC\nP.O. Box 645\nTulsa, Oklahoma 74172\nCPF 4-2021-004 NOA\nDear Mr. Armstrong:\nFrom February 24, 2020 through September 9, 2020, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States\nCode (U.S.C.) inspected Williams Olefins Feedstock Pipeline, LLC’s (Williams) Bayou Ethane\nPipeline operations and maintenance procedures in Houston, Texas.\nDuring the inspection, PHMSA identified the apparent inadequacies found within Williams’ plans\nor procedures, as described below:\n1. § 195.402 - Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall be\nreviewed at intervals not exceeding 15 months, but at least once each calendar year,\nand appropriate changes made as necessary to insure that the manual is effective.\nThis manual shall be prepared before initial operations of a pipeline system\ncommence, and appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(1) . . .\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n§ 195.426 - Scraper and sphere facilities.\n\n\n\n2. 2\nNo operator may use a launcher or receiver that is not equipped with a relief device\ncapable of safely relieving pressure in the barrel before insertion or removal of\nscrapers or spheres. The operator must use a suitable device to indicate that pressure\nhas been relieved in the barrel or must provide a means to prevent insertion or\nremoval of scrapers or spheres if pressure has not been relieved in the barrel.\nWilliams’ procedure for scraper and sphere facilities is inadequate. Williams Project\nStandards - LF16 NGL Pipeline Facilities Design Guide - 33 51 12E, which was last\nrevised on April 21, 2017, does not include a procedure for safely relieving pressure in the\nbarrel of a launcher or the receiver before the insertion or removal of scrapers or spheres\nas required under § 195.426. Williams was unable to provide a procedure that provided\nguidance for safely relieving pressure in the barrel or receiver of a launcher or receiver for\nreview during the inspection.\nWilliams Project Standards - LF16 NGL Pipeline Facilities Design Guide and/or its\nassociated procedures must be amended to provide guidance for safely relieving pressure\nin the barrel or the receiver of a launcher or receiver.\n§ 195.402 - Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(1) . . .\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n§ 195.428 - Overpressure safety devices and overfill protection systems.\n(a) Except as provided in paragraph (b) of this section, each operator shall, at intervals\nnot exceeding 15 months, but at least once each calendar year, or in the case of\npipelines used to carry highly volatile liquids, at intervals not to exceed 7½ months,\nbut at least twice each calendar year, inspect and test each pressure limiting device,\nrelief valve, pressure regulator, or other item of pressure control equipment to\ndetermine that it is functioning properly, is in good mechanical condition, and is\nadequate from the standpoint of capacity and reliability of operation for the service\nin which it is used.\nWilliams’ procedure for inspection and testing of regulators is inadequate to address the\nrequirements of § 195.428. Williams Operating Standards - Midstream Tests and\nInspections of Overpressure Protection and Pressure Limiting Devices - 07.05.70.12, last\nrevised on April 1, 2020, does not include inspection and testing procedures for regulators,\nhigh or low pressure shutdowns, high/high or low/low pressure shutdowns, and automatic\n\n\n\n3. 4. 3\nshutoff devices for the devices in the O&M manual. While the procedure does guide the\ntesting and inspection of the other mentioned devices, it lacks procedures for the testing of\nthe devices mentioned above.\nWilliams Operating Standards - Midstream Tests and Inspections of Overpressure\nProtection and Pressure Limiting Devices must be amended to provide guidance for\nconducting the inspection and testing of regulators, high or low pressure shutdowns,\nhigh/high or low/low pressure shutdowns, and automatic shutoff devices.\n§ 195.402 - Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(1) . . .\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n§ 195.422 - Pipeline Repairs.\n(a) Each operator shall, in repairing its pipeline systems, insure that the repairs are\nmade in a safe manner and are made so as to prevent damage to persons or property.\nWilliams Operating Requirements - Gas Pipes Installation and Removal of Stopples -\n07.55.50.08, dated December 14, 2017, is inadequate as it only applied to its gas assets and\nnot the hazardous liquids assets. Williams personnel stated that a similar procedure was in\ndevelopment for use on its liquid assets. The procedure under development is required as\npart of the pipeline safety regulation in §195.422 to insure that repairs on the pipeline are\ndone in a safe manner and to prevent damage to persons and property.\nWilliams must complete its procedures for the installations and removal of stopples during\nhot tapping for its liquid pipelines.\n§ 195.402 - Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(1) . . .\n\n\n\n4\n(13) Periodically reviewing the work done by operator personnel to determine the\neffectiveness of the procedures used in normal operation and maintenance and taking\ncorrective action where deficiencies are found.\nWilliams Operating Requirements - WIMS Reviews – 12.02.00.03, dated July 1, 2019, does\nnot meet the requirement of § 195.402(c)(13). Specifically, the WIMS procedure on page\none and subsequently in Section 2.4 requires that the “Periodic Operations and\nMaintenance Procedure Reviews” (PPR) be carried out every five years. Section 2.5 of\nthe procedure also includes appropriate methods for carrying out the review, which\nincludes “Performance on the Job” and “Review of Completed Work.” Reviewing the work\ncompleted by employees once every five years is inadequate and does not meet the\nregulatory requirement of § 195.402(c)(13). The review required under § 195.402(c)(13)\nis intended to allow an operator to take corrective actions where deficiencies are found.\nSection 195.402(c) references the manual of written procedures in § 195.402(a), which\nrequires an annual review that is not to exceed 15 months.\nTherefore, the requirements of § 195.402(c), including § 195.402(c)(13), are supposed to\nbe reviewed within a timeframe of a calendar year and not to exceed 15 months. Reviewing\nthe work done by operator personnel is an activity that needs to be carried out each calendar\nyear, not exceed 15 months. Procedures that require a review of the work done by operator\npersonnel on a five-year interval does not meet the intent of the regulation.\nWilliams must revise its procedure to ensure that the review of work done by operator\npersonnel meets the requirement of § 195.402(c)(13).\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).\n\n\n\n5\nIf you are not contesting this Notice, we propose that you submit your amended procedures to my\noffice within 30 days of receipt of this Notice. This period may be extended by written request for\ngood cause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested (not mandated) that Williams Olefins Feedstock Pipeline, L.L.C. maintain\ndocumentation of the safety improvement costs associated with fulfilling this Notice of\nAmendment (preparation/revision of plans, procedures) and submit the total to Mary L. McDaniel,\nDirector, Southwest Region, Pipeline and Hazardous Materials Safety Administration. In\ncorrespondence concerning this matter, please refer to CPF 4-2021-004 NOA, and for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Tyson Green, Manager Pipeline Safety, Williams, tyson.green@williams.com\n\n42021004NOA_Closure Letter_10072021_(20-172609)_text.pdf\n\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nOctober 7, 2021\nAlan Armstrong\nPresident & Chief Executive Officer\nWilliams Olefins Feedstock Pipelines, LLC\nP.O. Box 645\nTulsa, Oklahoma 74172\nCPF 4-2021-004-NOA\nDear Mr. Armstrong:\nFrom February 24, 2020, through September 9, 2020, a representative from the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code, conducted an on-site pipeline safety inspection of Williams Olefins Feedstock\nPipeline, LLC’s (Williams) Bayou Ethane Pipeline procedures in Houston, Texas. As a result of\nthe inspection, Williams was issued a Notice of Amendment on March 2, 2021, which proposed\namendment of your procedures.\nWilliams submitted copies of its amended procedures on April 1, 2021, and October 1, 2021. Staff\nhas reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice\nof Amendment have been corrected.\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":13571}