# WILLIAMS PARTNERS OPERATING LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 520183001
- **title:** WILLIAMS PARTNERS OPERATING LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2018-02-12
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 193.2017(c)(1), 193.2503(f)(4), 193.2517.
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520183001
**body:**

Notice of Probable Violation involving WILLIAMS PARTNERS OPERATING LLC. PHMSA's enforcement data identifies the cited regulations as 193.2017(c)(1),  193.2503(f)(4),  193.2517. The case was opened on 2018-02-12 and is reported as closed as of 2019-05-23. Proposed civil penalty: $864,000. Assessed civil penalty: $200,000. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520183001_Final Order_05162019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520183001/520183001_Final%20Order_05162019.pdf

520183001_Final Order_05162019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520183001/520183001_Final%20Order_05162019_text.pdf

520183001_NOPV PCP_02122018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520183001/520183001_NOPV%20PCP_02122018.pdf

520183001_NOPV PCP_02122018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520183001/520183001_NOPV%20PCP_02122018_text.pdf

520183001_Operator Response to Notice_04192018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520183001/520183001_Operator%20Response%20to%20Notice_04192018.pdf

520183001_Final Order_05162019_text.pdf

May 16, 2019
Mr. Alan S. Armstrong
President and Chief Executive Officer
The Williams Companies, Inc.
One Williams Center
Tulsa, Oklahoma 74172
Re: CPF No. 5-2018-3001
Dear Mr. Armstrong:
Enclosed please find the Final Order issued in the above-referenced case against your subsidiary
Williams Partners Operating, LLC. It withdraws two of the allegations of violation, makes one
finding of violation, and assesses a reduced civil penalty of $200,000. The penalty payment
terms are set forth in the Final Order. This enforcement action closes automatically upon receipt
of payment. Service of the Final Order by certified mail is effective upon the date of mailing as
provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Chris Hoidal, Director, Western Region, Office of Pipeline Safety, PHMSA
Mr. Jason Lambert, Manager, Pipeline Safety, Williams Partners Operating, LLC, 295
Chipeta Way, Salt Lake City, Utah, 84108
CERTIFIED MAIL - RETURN RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
___________________________________________
)
In the Matter of )
)
Williams Partners Operating, LLC, ) CPF No. 5-2018-3001
a subsidiary of The Williams Companies, Inc., )
)
Respondent. )
___________________________________________)
FINAL ORDER
On March 31, 2014, pursuant to 49 U.S.C. § 60117, representatives of the Pipeline and
Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),
conducted an on-site incident investigation and pipeline safety inspection of the facilities and
records of Williams Partners Operating, LLC’s (Williams or Respondent), Plymouth Liquefied
Natural Gas Peak Shaving Plant (Plymouth Plant) near the Columbia River in Plymouth,
Washington. The Plymouth Plant is a liquefied natural gas (LNG) storage facility in the middle
of William's Northwest Pipeline System that takes gas from the pipeline system in the spring and
summer months, liquefies it, stores it, and then vaporizes it during periods of high demand in the
fall and winter months. The Plymouth Plant consists of two separate LNG plants, known
generally as “LNG-1” and “LNG-2.”1
At approximately 8:19 a.m. PDT on March 31, 2014, the Plymouth Plant experienced a failure,
resulting in an explosion and fire on a portion of its LNG-1 Purification and Regeneration
System (Incident). The LNG-1 Purification and Regeneration System (P&R System) is a
subsystem of the LNG process at the Plymouth Plant that removes water vapor and carbon
dioxide prior to the gas being liquefied.
Following the Incident, PHMSA initiated a joint investigation of the Incident with the
Washington Utilities and Transportation Commission. The investigation revealed that the
Incident occurred during routine annual liquefaction start-up operations. In preparation for the
start-up, a piece of equipment known as the Regeneration Salt Bath Heater D-40 (Salt Bath
Heater) was started on March 30, 2014, and slowly brought to its process set point of 550° F.
The following day, on March 31, Plymouth Plant personnel began taking steps to start up the
P&R System. After reviewing the applicable procedure, Williams personnel took final steps for
start-up, which included bringing the system up to full operating pressure and starting the
1 Pipeline Safety Violation Report (Violation Report) (Feb. 12, 2018) (on file with PHMSA), at 1.



CPF No. 5-2018-3001
Page 2
regeneration compressor D-70. Upon confirmation of these steps, the board operator gave a
command via the distributed control system to align certain automated control valves and to
permit normal gas flow through the system. As flow began, a flammable mixture of air and
natural gas entered the Salt Bath Heater, where the mixture auto-ignited and resulted in a rolling
detonation that went against the flow of gas in the direction of the Adsorber D-20A. The
pressure wave generated by the detonation entered the Adsorber D-20A and caused the vessel to
fail catastrophically by rapid over-pressurization, releasing natural gas into the atmosphere,
producing additional deflagrations.
At 9:27 a.m. PDT, a Williams representative called the National Response Center (Report
Number 1078325), and reported that an explosion had occurred at a natural gas compressor
station. Seven employees were stationed within 150 feet of Adsorber D-20A when it exploded
and caught fire. Five Williams employees were injured and treated on-site. One employee was
flown to the hospital for additional treatment for burn injuries, admitted, and released several
days later. The company conducted an emergency shutdown and evacuated all plant personnel.
After emergency responders arrived on-site and talked with Williams’s Plymouth Plant
personnel, a decision was made to evacuate citizens from the village of Plymouth and the
surrounding area within a two-mile radius, due to concerns about gas vapors.
The joint investigation resulted in the publication of a failure investigation report (FIR) issued by
PHMSA on April 28, 2016. The FIR found that the primary cause of the Incident was a
substandard purge performed after leaving the LNG-1 purification loop open to the atmosphere
from November 1, 2013 to March 18, 2014. A flammable gas-air mixture remained in the
system, which then entered the Salt Bath Heater and auto-ignited during start-up. Specifically,
the FIR found that Williams failed to have detailed procedures to ensure that the plant’s LNG-1
purification loop, which had been vented to the atmosphere during maintenance activities, was
adequately and safely purged prior to start-up. The valve alignment prescribed by the existing
procedure left large volumes of gas against the closed Hot Valve 0400, which created a “dead-
leg.” As a result, a flammable gas-air mixture remained in the system and then entered the Salt
Bath Heater and auto-ignited during start-up.
As a result of the investigation, the Director, Western Region, OPS (Director), issued to
Respondent, by letter dated February 12, 2018, a Notice of Probable Violation and Proposed
Civil Penalty (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding
that Williams had violated 49 C.F.R. §§ 193.2517, 193.2017, and 193.2503 and proposed
assessing a civil penalty of $864,000 for the alleged violations.
After requesting and receiving an extension, on April 19, 2018, Williams responded to the
Notice (Response). In its Response, Williams did not contest Item 1 and the associated penalty,
but contested Items 2 and 3 and offered additional information in response to the Notice.
Respondent did not request a hearing and therefore has waived its right to one.
FINDING OF VIOLATION
The Notice alleged that Respondent violated 49 C.F.R. Part 193, as follows:



CPF No. 5-2018-3001
Page 3
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 193.2517, which states:
§ 193.2517 Purging.
When necessary for safety, components that could accumulate
significant amounts of combustible mixtures must be purged in accordance
with a procedure which meets the provisions of the AGA “Purging
Principles and Practices” after being taken out of service and before being
returned to service.2
The Notice alleged that Respondent violated 49 C.F.R. § 193.2517 by failing to purge its P&R
System in accordance with a procedure that met the provisions of American Gas Association’s
(AGA) Purging Principles and Practices (incorporated by reference, see § 193.2013), after
being taken out of service and before being returned to service. Specifically, the Notice alleged
that Williams failed to prepare a detailed purge procedure for the purge it conducted on March
18, 2014. Instead, Williams used a general purge procedure that failed to take into account all of
the various aspects of its P&R System, including vessel size, piping configuration, molecular
sieve materials, valves, filters, and other obstructions that could cause an incomplete purge.
Implementation of this general procedure, along with a lack of procedural specificity for a blow-
down pressure, created a low flow or “dead-leg” segment of pipeline on either side of the valve
that could not be properly purged of a combustible air/gas mixture. This incomplete purge
created an explosive oxygen and natural gas mixture that was present immediately prior to the
start-up and resulted in the auto-ignition.
In its Response, Respondent did not contest this allegation of violation. Accordingly, based
upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 193.2517 by
failing to purge its P&R System in accordance with a procedure that met the provisions of
AGA’s Purging Principles and Practices, after being taken out of service and before being
returned to service.
This finding of violation will be considered a prior offense in any subsequent enforcement action
taken against Respondent.
WITHDRAWN ITEMS
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 193.2017(c)(1), which states:
§ 193.2017 Plans and procedures.
(a) ...
(c) Each operator must review and update the plans and procedures
required by this part -
(1) When a component is changed significantly or a new component is
installed; ...
2 This version of § 193.2517 was in effect at the time the alleged violation occurred. The regulation was updated on
Jan. 5, 2015.



CPF No. 5-2018-3001
Page 4
The Notice alleged that Respondent violated 49 C.F.R. § 193.2017(c)(1) by failing to review and
update its plans and procedures when new components were installed at the Plymouth Plant.
Specifically, the Notice alleged that Williams installed three new manual valves in its P&R
System on March 18, 2014. During the investigation, investigators reviewed numerous written
procedures and records, and interviewed employees who were on-site the day of the Incident. In
their review, the investigators found that the documentation provided by Williams did not
demonstrate the company’s compliance with 49 CFR § 193.2017(c)(1) when it installed the three
new manual valves in the purification-loop piping system on March 18, 2014.
In its Response, Williams stated that, contrary to the claim in the Notice, the three at-issue
manual valves were not new, but original equipment valves that had been repaired and then
reinstalled.3 Williams argued that because no new equipment was added or modified and the
process was in no way changed, a review and update of the existing operating procedures was
not required under § 193.2017(c)(1). Respondent also provided additional documentation
indicating that the valves were refurbished and were not new valves.4
Accordingly, after considering all of the evidence, I find there is insufficient evidence to
demonstrate that Williams violated § 193.2017(c)(1). Williams did not install new components
or significantly change existing components, and therefore it was not required under §
193.2017(c)(1) to review and update its plans and procedures at the Plymouth Plant. Based upon
the foregoing, I hereby order that Item 2 be withdrawn.
Item 3: The Notice alleged that Respondent violated 49 C.F.R. § 193.2503(f)(4), which states, in
relevant part:
§ 193.2503 Operating procedures.
Each operator shall follow one or more manuals of written procedures
to provide safety in normal operation and in responding to an abnormal
operation that would affect safety. The procedures must include provisions
for:
(a)…
(f) In the case of liquefaction, maintaining temperatures, pressures,
pressure differentials and flow rates, as applicable, within their design limits
for: ...
(4) Purification and regeneration equipment; …
The Notice alleged that Respondent violated 49 C.F.R. § 193.2503(f)(4) by failing to have
procedures to provide safety during the normal operation start-up process. Specifically, the
Notice alleged that Williams’s operating procedures failed to identify that its P&R equipment
would result in being operated beyond design limits. The Notice alleged the start-up sequence in
Williams’s Regeneration Compressor and Purification Adsorber - LNG I: Remote Start-up and
Shutdown procedure failed to provide safety during normal operation by instructing Williams
3 Response at 2.
4 Invoice for D-45 Valves (See Appendix B to Region Recommendation).



CPF No. 5-2018-3001
Page 5
personnel to start the Salt Bath Heater prior to pressurization. Section C.2 of its procedure
indicated that the start-up of the heating process through completion of the Regeneration Salt
Bath Heater procedures was required prior to starting the regeneration process.
In its Response, Williams argued that its start-up process and procedures were adequate to
provide safety had the purge been completed correctly.5 It contended that had oxygen not been
present in the piping due to the incomplete purge, the existing start-up procedure would have
provided for safety of personnel and equipment. Additionally, Williams asserted that the
existing practice of starting and raising the Salt Bath Heater to temperature prior to introduction
of gas is consistent with historical plant practice, manufacturer recommendations, and industry
practice. Williams also provided additional information clarifying the design limits of the Salt
Bath Heater, demonstrating that they were not exceeded despite the occurrence of the Incident.6
Accordingly, after considering all of the evidence, I find there is insufficient evidence to
demonstrate that Williams violated § 193.2503(f)(4). Williams had operating procedures in
place to provide safety during the start-up process. It was not Respondent’s operating
procedures, but Respondent’s failure to properly purge its system in accordance with purging
procedures (addressed in Item 1) that resulted in the Incident. Based upon the foregoing, I
hereby order that Item 3 be withdrawn.
ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed
$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any
related series of violations.7
In determining the amount of a civil penalty under 49 U.S.C. § 60122 and 49 C.F.R. § 190.225, I
must consider the following criteria: the nature, circumstances, and gravity of the violation,
including adverse impact on the environment; the degree of Respondent’s culpability; the history
of Respondent’s prior offenses; any effect that the penalty may have on its ability to continue
doing business; and the good faith of Respondent in attempting to comply with the pipeline
safety regulations. In addition, I may consider the economic benefit gained from the violation
without any reduction because of subsequent damages, and such other matters as justice may
require. The Notice proposed a total civil penalty of $864,000 for the violations cited above.
Item 1: The Notice proposed a civil penalty of $288,000 for Respondent’s violation of 49
C.F.R. § 193.2517, for failing to purge its P&R System in accordance with a procedure that met
the provisions of AGA’s Purging Principles and Practices, after being taken out of service and
before being returned to service. Williams did not contest the violation or the penalty. Although
5 Response at 3.
6 Response at 3.
7 These amounts are adjusted annually for inflation. See, e.g., Pipeline Safety: Inflation Adjustment of Maximum
Civil Penalties, 82 Fed. Reg. 19325 (April 27, 2017).



CPF No. 5-2018-3001
Page 6
the Violation Report stated that the violation began on October 31, 2013, the date Williams’s
purging procedures were implemented,8 and continued until the date of the Incident, I find that
Respondent’s failure to purge its P&R System was a one-day activity occurring on March 18,
2014.9 Reducing the duration of the violation from multiple days to one day serves to reduce the
amount of the proposed penalty. Accordingly, having reviewed the record and considered the
assessment criteria, I assess Respondent a reduced civil penalty of $200,000 for violation of 49
C.F.R. § 193.2517.
Item 2: The Notice proposed a civil penalty of $288,000 for Respondent’s alleged violation of
49 C.F.R. § 193.2017(c)(1), for failing to review and update its plans and procedures when new
components were installed at the Plymouth Plant. I have withdrawn Item 2, therefore there is no
associated penalty for this item.
Item 3: The Notice proposed a civil penalty of $288,000 for Respondent’s alleged violation of
49 C.F.R. § 193.2503(f)(4), for failing to have procedures in place to provide safety during the
start-up process. I have withdrawn Item 3, therefore there is no associated penalty for this item.
In summary, having reviewed the record and considered the assessment criteria for each of the
Items cited above, I assess Respondent a total civil penalty of $200,000.
Payment of the civil penalty must be made within 20 days of service. Federal regulations (49
C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer through the Federal
Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed
instructions are contained in the enclosure. Questions concerning wire transfers should be
directed to: Financial Operations Division (AMK-325), Federal Aviation Administration, Mike
Monroney Aeronautical Center, 6500 S MacArthur Blvd, Oklahoma City, Oklahoma 79169.
The Financial Operations Division telephone number is (405) 954-8845.
Failure to pay the $200,000 civil penalty will result in accrual of interest at the current annual
rate in accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to
those same authorities, a late penalty charge of six percent (6%) per annum will be charged if
payment is not made within 110 days of service. Furthermore, failure to pay the civil penalty
may result in referral of the matter to the Attorney General for appropriate action in a district
court of the United States.
Under 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this Final
Order to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey
Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of
Chief Counsel, PHMSA, at the same address, no later than 20 days after receipt of service of the
Final Order by Respondent. Any petition submitted must contain a brief statement of the issue(s)
and meet all other requirements of 49 C.F.R. § 190.243. The filing of a petition automatically
stays the payment of any civil penalty assessed. The other terms of the order, including any
corrective action, remain in effect unless the Associate Administrator, upon request, grants a
8 Violation Report at 9, Ex. A.
9 Violation Report at 10.



CPF No. 5-2018-3001
Page 7
stay. If Respondent submits payment of the civil penalty, the Final Order becomes the final
administrative decision and the right to petition for reconsideration is waived.
The terms and conditions of this Final Order are effective upon service in accordance with 49
C.F.R. § 190.5.
May 16, 2019
___________________________________ __________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety
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