{"operation":"document","citation":"CPF 52023026WL","title":"WILLIAMS FIELD SERVICES — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2023-04-21","effective_on":null,"summary":"CLOSED warning letter citing 195.402(a), 195.5(d).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52023026wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52023026wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52023026wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52023026WL","body":"Warning Letter involving WILLIAMS FIELD SERVICES. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.5(d). The case was opened on 2023-04-21 and is reported as closed as of 2023-04-21. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52023026WL_Warning Letter_04212023_(22-234737).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023026WL/52023026WL_Warning%20Letter_04212023_(22-234737).pdf\n\n52023026WL_Warning Letter_04212023_(22-234737)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023026WL/52023026WL_Warning%20Letter_04212023_(22-234737)_text.pdf\n\n52023026WL_Warning Letter_04212023_(22-234737)_text.pdf\n\nWARNING LETTER\nVIA E-MAIL TO MR. ALAN ARMSTRONG\nApril 21, 2023\nMr. Alan Armstrong\nPresident\nThe Williams Companies, Inc.\nOne Williams Center\nP.O. Box 2400\nTulsa, OK 74172\nCPF 5-2023-026-WL\nDear Mr. Armstrong:\nFrom June 21, 2022, to September 1, 2022, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code\n(U.S.C.), inspected The Williams Companies, Inc.’s (Williams) Overland Pass hazardous liquid\npipeline and Parachute to Greasewood Express (PGX) hazardous liquid pipeline.\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. § 195.5 Conversion to service subject to this part.\n(a) . . . .\n(d) An operator converting a pipeline from service not previously covered by this\npart must notify PHMSA 60 days before the conversion occurs as required by §\n195.64.\n\n\n\nWilliams failed to notify PHMSA 60 days before converting a pipeline from service not\npreviously covered by Part 195 as required by § 195.64. Specifically, Williams did not notify\nPHMSA 60 days before the 4\" and 6\" NGL lines from the exit of the plant boundaries to the\nPGX pipeline (Line ID # 20003 and 20004) were converted to service. During the PHMSA\ninspection, Williams failed to produce any records demonstrating that they notified PHMSA 60\ndays before converting these lines to service. PHMSA also confirmed that this change was not\nmade on its National Registry of Operators, available at https://portal.phmsa.dot.gov.1\n2. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall be\nreviewed at intervals not exceeding 15 months, but at least once each calendar year,\nand appropriate changes made as necessary to insure that the manual is effective.\nThis manual shall be prepared before initial operations of a pipeline system\ncommence, and appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\nWilliams failed to follow a manual of written procedures for conducting normal operations and\nmaintenance activities. Specifically, Williams’ procedure entitled 07.11.01.05 Valve Inspection\nand Maintenance Procedure states that each hazardous liquid DOT Valve must be inspected and\npartially operated to determine if it is functioning properly at least twice per calendar year, not to\nexceed 7 ½ months.2 During the PHMSA inspection, Williams’ valve inspection record entitled\nF07-812 Valve Inspection Report indicated Williams failed to partially operate 16 of the 18\nmainline valves on their PGX-HVL system on 4/21/2020 and 4/22/2020.3\nValve ID Valve Operation\nXV-1306, XV-4925B XV-4623, XV-4627,\nXV-8002, XV-9500,\nXV-9501, B0031,\nB0032, MOV-9504,\nXV-9505, XV-9701,\nMOV-1004, MOV-1104,\nMOV-1005, MOV-1105,\nXV-9700, B6001\nFully Operated\nNot Operated\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a\n1 See § 195.64(c)(iv) (requiring operators to notify PHMSA electronically through the National Registry of\nOperators at https://portal.phmsa.dot.gov 60 days prior to converting a pipeline to service under § 195.5).\n2 See Exhibit A-1 (attached and on file with PHMSA).\n3 See Exhibit A-2 (attached and on file with PHMSA).\n\n\n\nrelated series of violations. For violation occurring on or after March 21, 2022 and before\nJanuary 6, 2023, the maximum penalty may not exceed $239,142 per violation per day the\nviolation persists, up to a maximum of $2,391,142 for a related series of violations. For violation\noccurring on or after May 3, 2021 and before March 21, 2022, the maximum penalty may not\nexceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for\na related series of violations. For violation occurring on or after January 11, 2021 and before\nMay 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation\npersists, up to a maximum of $2,225,034 for a related series of violations. For violation\noccurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not\nexceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for\na related series of violations. For violation occurring on or after November 27, 2018 and before\nJuly 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a\nmaximum penalty not to exceed $2,132,679. For violation occurring on or after November 2,\n2015 and before November 27, 2018, the maximum penalty may not exceed $209,002 per\nviolation per day, with a maximum penalty not to 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 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 5-2023-026-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, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 L. Green, J. Luo, C. Cordova (#22-234737)","truncated":false,"body_characters":6977}