WILLIAMS FIELD SERVICES — Warning Letter

52022044WL_Warning Letter_09082022_(22-232555)_text.pdf, page 1Official PDFWARNING LETTER VIA E-MAIL TO MR. MARK CLUFF September 8, 2022 Mr. Mark Cluff VP Safety & Operational Discipline Williams Field Services One Williams Center Floor 43 Tulsa, OK 74172 CPF 5-2022-044-WL Dear Mr. Cluff: Between April 25, 2022 and June 16, 2022, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected your hazardous liquid transmission pipeline (Oak Grove to Houston Ethane Line) in Claysville, Pennsylvania. As a result of the inspection, it is alleged that you have committed a probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and the probable violation is: 1. § 195.52 Immediate notice of certain accidents. (a) Notice requirements. At the earliest practicable moment following discovery, of a release of the hazardous liquid or carbon dioxide transported resulting in an event described in §195.50, but no later than one hour after confirmed discovery, the operator of the system must give notice, in accordance with paragraph (b) of this section of any failure that: (1)… (2) Resulted in either a fire or explosion not intentionally set by the operator;#

52022044WL_Warning Letter_09082022_(22-232555)_text.pdf, page 2Williams failed to report a failure that resulted in a fire at the earliest practicable moment following discovery, but no later than one hour after confirmed discovery.1 During the inspection, PHMSA discovered that on June 21, 2021 at 21:30 EST, Williams personnel preliminarily identified a release of 10.8 barrels of ethane that resulted in a fire at Main Line Valve 8 in Claysville, Pennsylvania (Accident Report No. 20210213 - 36047). Williams did not notify the NRC of the release until June 22, 2021 at 09:47 EST, over 12 hours later (NRC Incident Report #1308429). Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $239,142 per violation per day the violation persists, up to a maximum of $2,391,142 for a related series of violations. For violation occurring on or after May 3, 2021 and before March 21, 2022, the maximum penalty may not exceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related series of violations. For violation occurring on or after January 11, 2021 and before May 3, 2021, the maximum penalty may not 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 item 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- 2022-044-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, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration cc: PHP-60 Compliance Registry PHP-500 Z. Wynkoop, M. Flaherty (#22-232555) 1 Pursuant to § 195.2, “confirmed discovery” means “when it can be reasonably determined, based on information available to the operator at the time a reportable event has occurred, even if only based on a preliminary evaluation.”#