# WILLIAMS FIELD SERVICES - GULF COAST COMPANY, LP — Warning Letter

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

Official case documents:

52021010WL_Warning Letter_03032021_(20-173103).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021010WL/52021010WL_Warning%20Letter_03032021_(20-173103).pdf

52021010WL_Warning Letter_03032021_(20-173103)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021010WL/52021010WL_Warning%20Letter_03032021_(20-173103)_text.pdf

52021010WL_Warning Letter_03032021_(20-173103)_text.pdf

WARNING LETTER
VIA E-MAIL TO MR. MARK CLUFF
March 3, 2021
Mr. Mark Cluff
VP Safety & Operational Discipline
Williams Field Services
One Williams Center
Floor 43
Tulsa, OK 74172
CPF 5-2021-010-WL
Dear Mr. Cluff:
During the week of July 20 through 24, 2020, representatives of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code
(U.S.C.), performed a virtual inspection of the Williams Field Services control room located in
Tulsa, Oklahoma. The inspection covered procedures, records, and virtual observations.
As a result of the inspection, it is alleged that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected
and the probable violations are:
1. § 195.446 - Control room management.
(e) Alarm management. Each operator using a SCADA system must have a written
alarm management plan to provide for effective controller response to alarms. An
operator's plan must include provisions to:
(1) …
(4) Review the alarm management plan required by this paragraph at least once
each calendar year, but at intervals not exceeding 15 months, to determine the
effectiveness of the plan;



Williams did not review their alarm management plan required by § 195.446(e) to determine the
effectiveness of the plan at least once each calendar year, but at intervals not exceeding 15
months. The Williams alarm management plan identifies four bulleted items that are required as
part of the annual review to determine the plan’s effectiveness. These four items are listed on
pages 27 and 28 of Section 700.604 - Control Room Management Plan (revision 14, effective
date 4/01/2020).
The third bullet item requires a review of the safety-related alarm key performance indicators
(KPIs) to determine the effectiveness of the alarm management plan.
The operator failed to complete the annual review of the safety-related alarm KPIs during the
2017, 2018, and 2019 annual review to determine effectiveness in accordance with their
procedures.
During the inspection, the operator agreed that while they did review the alarm management plan
in 2017, 2018, and 2019, they failed to complete the review properly by not following entirety of
the procedure which required them to review the KPI information and to determine the
effectiveness of the alarm management plan.
2. § 195.446 - Control room management.
(h) Training. Each operator must establish a controller training program and review
the training program content to identify potential improvements at least once each
calendar year, but at intervals not to exceed 15 months. An operator's program
must provide for training each controller to carry out the roles and responsibilities
defined by the operator.
Williams controller training program did not provide for training each controller to carry out the
roles and responsibilities defined by the operator. During the inspection, Williams stated that
leak detection training is conducted annually but the training program did not identify leak
detection as a training element.
Williams could not provide records that leak detection training was conducted in 2019. Williams
has subsequently revised their Training Program (Section 700.900, Rev. 5, effective 9/20/2020)
to include the leak detection training element.
Additionally, a review of controller training records failed to record a pass/fail for the January
30, 2019, Control Room Management Plan (CRMP) refresher training for one of the employees.
Per the training program, controllers are required to take a pass/fail examination for all training
courses, where a passing score is 80%. The program states that a pass/fail criterion for all
training elements must be recorded, but it was not recorded for this controller.
3. § 195.446 - Control room management.
(h) Training. Each operator must establish a controller training program and review
the training program content to identify potential improvements at least once each
calendar year, but at intervals not to exceed 15 months. An operator's program
2



must provide for training each controller to carry out the roles and responsibilities
defined by the operator…
Williams did not establish a controller training program and review the training program content
to identify potential improvements at least once each calendar year, but at intervals not to exceed
15 months. Williams did not follow their training procedures within their control room
management plan for completing annual reviews of the training requirements which required
documenting when identified improvements were implemented.
The records associated with the operator's annual review of the training program content for
calendar years 2017, 2018, and 2019 were presented during the inspection.
The October 2018 record indicated that “on the job” training will be revised and formalized
within the next year. However, revisions do not appear to have been completed as no follow up
documentation or revisions were included in the records.
Additionally, the November 2017 record included comments to update the training program to
include team training, but no resolution date was identified and there were no records indicating
that the team training was revised.
4. § 195.446 - Control room management.
(h) Training. Each operator must establish a controller training program and review
the training program content to identify potential improvements at least once each
calendar year, but at intervals not to exceed 15 months. An operator's program
must provide for training each controller to carry out the roles and responsibilities
defined by the operator. In addition, the training program must include the
following elements:
(1)…
(6) Control room team training and exercises that include both controllers and other
individuals, defined by the operator, who would reasonably be expected to
operationally collaborate with controllers (control room personnel) during normal,
abnormal or emergency situations. Operators must comply with the team training
requirements under this paragraph no later than January 23, 2018.
Williams training program did not include control room team training and exercises that include
both controllers and other individuals, defined by the operator, who would reasonably be
expected to operationally collaborate with controllers (control room personnel) during normal,
abnormal or emergency situations. Williams did not comply with the team training requirements
under this paragraph by January 23, 2018. Training records reviewed during the inspection do
not demonstrate that team training was conducted and involved other personnel who would have
been required to attend to meet the regulatory requirement.
The operator only sent out an email notification to employees stating that a new team training
requirement would be implemented, however, no actual training was performed.
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Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for a
related series of violations. For violation occurring on or after July 31, 2019 and before January
11, 2021, the maximum penalty may not 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.
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 items identified in this letter. Failure to do so will result in
Williams Field Services 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 5-2021-010-WL. 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,
Dustin Hubbard
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 D. Fehling (#20-173103)
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