{"operation":"document","citation":"CPF 52021010WL","title":"WILLIAMS FIELD SERVICES - GULF COAST COMPANY, LP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-03-03","effective_on":null,"summary":"CLOSED warning letter citing 195.446(e)(4), 195.446(h), 195.446(h)(6).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52021010wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52021010wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52021010wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52021010WL","body":"Warning Letter involving WILLIAMS FIELD SERVICES - GULF COAST COMPANY, LP. PHMSA's enforcement data identifies the cited regulations as 195.446(e)(4),  195.446(h),  195.446(h)(6). The case was opened on 2021-03-03 and is reported as closed as of 2021-03-03. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52021010WL_Warning Letter_03032021_(20-173103).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021010WL/52021010WL_Warning%20Letter_03032021_(20-173103).pdf\n\n52021010WL_Warning Letter_03032021_(20-173103)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021010WL/52021010WL_Warning%20Letter_03032021_(20-173103)_text.pdf\n\n52021010WL_Warning Letter_03032021_(20-173103)_text.pdf\n\nWARNING LETTER\nVIA E-MAIL TO MR. MARK CLUFF\nMarch 3, 2021\nMr. Mark Cluff\nVP Safety & Operational Discipline\nWilliams Field Services\nOne Williams Center\nFloor 43\nTulsa, OK 74172\nCPF 5-2021-010-WL\nDear Mr. Cluff:\nDuring the week of July 20 through 24, 2020, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code\n(U.S.C.), performed a virtual inspection of the Williams Field Services control room located in\nTulsa, Oklahoma. The inspection covered procedures, records, and virtual observations.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. § 195.446 - Control room management.\n(e) Alarm management. Each operator using a SCADA system must have a written\nalarm management plan to provide for effective controller response to alarms. An\noperator's plan must include provisions to:\n(1) …\n(4) Review the alarm management plan required by this paragraph at least once\neach calendar year, but at intervals not exceeding 15 months, to determine the\neffectiveness of the plan;\n\n\n\nWilliams did not review their alarm management plan required by § 195.446(e) to determine the\neffectiveness of the plan at least once each calendar year, but at intervals not exceeding 15\nmonths. The Williams alarm management plan identifies four bulleted items that are required as\npart of the annual review to determine the plan’s effectiveness. These four items are listed on\npages 27 and 28 of Section 700.604 - Control Room Management Plan (revision 14, effective\ndate 4/01/2020).\nThe third bullet item requires a review of the safety-related alarm key performance indicators\n(KPIs) to determine the effectiveness of the alarm management plan.\nThe operator failed to complete the annual review of the safety-related alarm KPIs during the\n2017, 2018, and 2019 annual review to determine effectiveness in accordance with their\nprocedures.\nDuring the inspection, the operator agreed that while they did review the alarm management plan\nin 2017, 2018, and 2019, they failed to complete the review properly by not following entirety of\nthe procedure which required them to review the KPI information and to determine the\neffectiveness of the alarm management plan.\n2. § 195.446 - Control room management.\n(h) Training. Each operator must establish a controller training program and review\nthe training program content to identify potential improvements at least once each\ncalendar year, but at intervals not to exceed 15 months. An operator's program\nmust provide for training each controller to carry out the roles and responsibilities\ndefined by the operator.\nWilliams controller training program did not provide for training each controller to carry out the\nroles and responsibilities defined by the operator. During the inspection, Williams stated that\nleak detection training is conducted annually but the training program did not identify leak\ndetection as a training element.\nWilliams could not provide records that leak detection training was conducted in 2019. Williams\nhas subsequently revised their Training Program (Section 700.900, Rev. 5, effective 9/20/2020)\nto include the leak detection training element.\nAdditionally, a review of controller training records failed to record a pass/fail for the January\n30, 2019, Control Room Management Plan (CRMP) refresher training for one of the employees.\nPer the training program, controllers are required to take a pass/fail examination for all training\ncourses, where a passing score is 80%. The program states that a pass/fail criterion for all\ntraining elements must be recorded, but it was not recorded for this controller.\n3. § 195.446 - Control room management.\n(h) Training. Each operator must establish a controller training program and review\nthe training program content to identify potential improvements at least once each\ncalendar year, but at intervals not to exceed 15 months. An operator's program\n2\n\n\n\nmust provide for training each controller to carry out the roles and responsibilities\ndefined by the operator…\nWilliams did not establish a controller training program and review the training program content\nto identify potential improvements at least once each calendar year, but at intervals not to exceed\n15 months. Williams did not follow their training procedures within their control room\nmanagement plan for completing annual reviews of the training requirements which required\ndocumenting when identified improvements were implemented.\nThe records associated with the operator's annual review of the training program content for\ncalendar years 2017, 2018, and 2019 were presented during the inspection.\nThe October 2018 record indicated that “on the job” training will be revised and formalized\nwithin the next year. However, revisions do not appear to have been completed as no follow up\ndocumentation or revisions were included in the records.\nAdditionally, the November 2017 record included comments to update the training program to\ninclude team training, but no resolution date was identified and there were no records indicating\nthat the team training was revised.\n4. § 195.446 - Control room management.\n(h) Training. Each operator must establish a controller training program and review\nthe training program content to identify potential improvements at least once each\ncalendar year, but at intervals not to exceed 15 months. An operator's program\nmust provide for training each controller to carry out the roles and responsibilities\ndefined by the operator. In addition, the training program must include the\nfollowing elements:\n(1)…\n(6) Control room team training and exercises that include both controllers and other\nindividuals, defined by the operator, who would reasonably be expected to\noperationally collaborate with controllers (control room personnel) during normal,\nabnormal or emergency situations. Operators must comply with the team training\nrequirements under this paragraph no later than January 23, 2018.\nWilliams training program did not include control room team training and exercises that include\nboth controllers and other individuals, defined by the operator, who would reasonably be\nexpected to operationally collaborate with controllers (control room personnel) during normal,\nabnormal or emergency situations. Williams did not comply with the team training requirements\nunder this paragraph by January 23, 2018. Training records reviewed during the inspection do\nnot demonstrate that team training was conducted and involved other personnel who would have\nbeen required to attend to meet the regulatory requirement.\nThe operator only sent out an email notification to employees stating that a new team training\nrequirement would be implemented, however, no actual training was performed.\n3\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$222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for a\nrelated series of violations. For violation occurring on or after July 31, 2019 and before January\n11, 2021, the maximum penalty may not exceed $218,647 per violation per day the violation\npersists, up to a maximum of $2,186,465 for a related series of violations. For violation\noccurring on or after November 27, 2018 and before July 31, 2019, the maximum penalty may\nnot exceed $213,268 per violation per day, with a maximum penalty not to exceed $2,132,679.\nFor violation occurring on or after November 2, 2015 and before November 27, 2018, the\nmaximum penalty may not exceed $209,002 per violation per day, with a maximum penalty not\nto exceed $2,090,022.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the items identified in this letter. Failure to do so will result in\nWilliams Field Services being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2021-010-WL. 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,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 D. Fehling (#20-173103)\n4","truncated":false,"body_characters":9743}