{"operation":"document","citation":"CPF 520115006W","title":"WILLIAMS FIELD SERVICES — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2011-02-28","effective_on":null,"summary":"CLOSED warning letter citing 195.402(d)(5), 195.412(a), 195.428(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520115006w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520115006w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520115006w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520115006W","body":"Warning Letter involving WILLIAMS FIELD SERVICES. PHMSA's enforcement data identifies the cited regulations as 195.402(d)(5),  195.412(a),  195.428(a). The case was opened on 2011-02-28 and is reported as closed as of 2011-02-28. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520115006W_warning letter_02282011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520115006W/520115006W_warning%20letter_02282011.pdf\n\n520115006W_warning letter_02282011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520115006W/520115006W_warning%20letter_02282011_text.pdf\n\n520115006W_warning letter_02282011_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 28, 2011\nMr. Randy Newcomer\nVice President, Operations Performance\nWilliams Field Services\nOne Williams Center\nMail Drop WRC-2C\nTulsa, OK 74172\nCPF 5-2011-5006W\nDear Mr. Newcomer:\nOn August 16, 2010, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\nPGX HVL pipeline in Parachute, Colorado.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n\n\n\n1. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(d) Abnormal operation. The manual required by paragraph (a) of this section\nmust include procedures for the following to provide safety when operating design\nlimits have been exceeded;\n(5) Periodically reviewing the response of operator personnel to determine the\neffectiveness of the procedures controlling abnormal operation and taking\ncorrective action where deficiencies are found.\nWilliams Field Services had abnormal operations reports for events on dates May 22, 2010; June 8,\n2010; June 11, 2010; July 17, 2010; and August 11, 2010. The reports did not adequately address the\nrequirements of § 195.402(d)(5) for periodically reviewing the effectiveness of the procedures controlling\nabnormal operation.\n2. §195.412 Inspection of rights-of-way and crossings under navigable waters.\n(a) Each operator shall, at intervals not exceeding 3 weeks, but at least 26 times\neach calendar year, inspect the surface conditions on or adjacent to each pipeline\nright-of-way. Methods of inspection include walking, driving, flying or other\nappropriate mean of traversing the right-of-way.\nWilliams Field Services started operations on the 6-inch segment on April 10, 2008. Williams Field\nServices did not have a record of pipeline patrol per § 195.412(a) until June18, 2008.\n3. §195.428 Overpressure safety devices and overfill protection systems\n(a) Except as provided in paragraph (b) of this section, each operator shall, at\nintervals not exceeding 15 months, but at least once each calendar year, or in the\ncase of pipelines used to carry highly volatile liquids, at intervals not to exceed 7½\nmonths, but at least twice each calendar year, inspect and test each pressure limiting\ndevice, relief valve, pressure regulator, or other item of pressure control equipment\nto determine 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.\nThe date of first operation was July 18, 2008. Regarding pressure control per § 195.428(a), Williams\nField Services did not have a record of inspection of tests and calibration on pressure switches until\nOctober 2009, and of pressure transmitters until April 17, 2009.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violation persists up to a maximum of $1,000,000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the items identified in this letter.\n\n\n\nFailure to do so will result in Williams Field Services being subject to additional enforcement\naction.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2011-5006W. 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\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nClaude Allen (#128409)","truncated":false,"body_characters":5051}