# WILLIAMS FIELD SERVICES — Warning Letter

- **operation:** document
- **citation:** CPF 52022044WL
- **title:** WILLIAMS FIELD SERVICES — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2022-09-08
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.52(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-52022044wl.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-52022044wl.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-52022044wl
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/52022044WL
**body:**

Warning Letter involving WILLIAMS FIELD SERVICES. PHMSA's enforcement data identifies the cited regulation as 195.52(a). The case was opened on 2022-09-08 and is reported as closed as of 2022-09-08. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

52022044WL_Warning Letter_09082022_(22-232555).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022044WL/52022044WL_Warning%20Letter_09082022_(22-232555).pdf

52022044WL_Warning Letter_09082022_(22-232555)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022044WL/52022044WL_Warning%20Letter_09082022_(22-232555)_text.pdf

52022044WL_Warning Letter_09082022_(22-232555)_text.pdf

WARNING 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;



Williams 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.”
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