{"operation":"document","citation":"CPF 52025018WL","title":"MID-CONTINENT FRACTIONATION AND STORAGE, L.L.C. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-12-03","effective_on":null,"summary":"CLOSED warning letter citing 195.446(a), 195.446(e)(2), 195.446(e)(3), 195.446(e)(5), 195.446(e)(6), 195.446(f)(2), 195.446(j)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52025018wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52025018wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52025018wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52025018WL","body":"Warning Letter involving MID-CONTINENT FRACTIONATION AND STORAGE, L.L.C.. PHMSA's enforcement data identifies the cited regulations as 195.446(a),  195.446(e)(2),  195.446(e)(3),  195.446(e)(5),  195.446(e)(6),  195.446(f)(2),  195.446(j)(2). The case was opened on 2025-12-03 and is reported as closed as of 2025-12-03. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52025018WL_Warning Letter_12032025_(24-296573).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025018WL/52025018WL_Warning%20Letter_12032025_(24-296573).pdf\n\n52025018WL_Warning Letter_12032025_(24-296573)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025018WL/52025018WL_Warning%20Letter_12032025_(24-296573)_text.pdf\n\n52025018WL_Warning Letter_12032025_(24-296573)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n12300 W. Dakota Ave., Suite 340\nLakewood, CO 80228\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: chad.zamarin@williams.com\nDecember 3, 2025\nMr. Chad Zamarin\nPresident/CEO\nMid-Continent Fractionation & Storage, LLC\nOne Williams Center\nTulsa, OK 74172\nCPF 5-2025-018-WL\nDear Mr. Zamarin:\nFrom July 15 through 19, 2024, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nthe Williams Mid-Continent Fractionation and Storage (MCFS) Control Room Management and\nProcedures in McPherson, Kansas.\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(a) General\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(2) Identify at least once each calendar month points affecting safety that have been\ntaken off scan in the SCADA host, have had alarms inhibited, generated false\n1\n\n\n\nalarms, or that have had forced or manual values for periods of time exceeding that\nrequired for associated maintenance or operating activities;\nMCFS failed to identify at least once each calendar month points affecting safety that have been\ntaken off scan in the SCADA host, have had alarms inhibited, generated false alarms, or that\nhave had forced or manual values for periods of time exceeding that required for associated\nmaintenance or operating activities, as required by § 195.446(e)(2).\nSpecifically, records for the monthly alarm reviews conducted in June 2021, January 2022,\nSeptember 2023, and February 2024 failed to comprehensively identify and assess all elements\nmandated by the applicable regulation. MCFS focused exclusively on safety-related alarms\n(SRA) during these reviews, neglecting to evaluate the full spectrum of alarms. Furthermore,\ncontrollers demonstrated insufficient understanding of false alarms, resulting in their exclusion\nfrom the monthly alarm review process1. In addition, inhibited alarms were neither\nappropriately defined within the Alarm Management Plan (AMP) nor incorporated into the\nmonthly review procedures.\n2. § 195.446 Control room management.\n(a) General\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(3) Verify the correct safety-related alarm set-point values and alarm descriptions\nwhen associated field instruments are calibrated or changed and at least once each\ncalendar year, but at intervals not to exceed 15 months;\nMCFS failed to verify the correct safety-related alarm set-point values and alarm descriptions\nwhen associated field instruments are calibrated or changed and at least once each calendar year,\nbut at intervals not to exceed 15 months, as required by § 195.446(e)(3).\nSpecifically, records dated October 21, 2021, documented various incorrect setpoint values\nassociated with safety-related alarms (SRAs), wherein the recorded points reflected the existing\nsetpoints rather than the correct, intended values2. Furthermore, records dated November 22,\n2022, pertaining to Management of Change (MOC) UMC 2222289, revealed errors in both\nsetpoint values and alarm descriptions. Similarly, records dated October 24, 2023, identified\ndiscrepancies in setpoint values and alarm descriptions. In addition, records from December 5,\n2023 contained multiple comments regarding whether certain alarms should be classified as\nSRAs, with recommendations to re-rationalize these alarms. MCFS confirmed that, as of July\n17, 2024—the time of the inspection the re-rationalization process had not been completed,\ndespite the lapse of over six months since these issues were initially identified.\n1 Control Room Management FAQ E.02 and E.03\n2 Control Room Management FAQ E.04 and E.05\n2\n\n\n\n3. § 195.446 Control room management.\n(a) General\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(5) Monitor the content and volume of general activity being directed to and\nrequired of each controller at least once each calendar year, but at intervals not\nexceeding 15 months, that will assure controllers have sufficient time to analyze and\nreact to incoming alarms;\nMCFS failed to monitor the content and volume of general activity being directed to and\nrequired of each controller at least once each calendar year, but at intervals not exceeding 15\nmonths, that will assure controllers have sufficient time to analyze and react to incoming alarms,\nas required by § 195.446(e)(5).\nSpecifically, workload study records dated December 21, 2021 and December 14, 2022 failed to\nspecify the time frames during which data was collected, as well as the number of shifts\nmonitored. Consequently, these records do not adequately demonstrate that the content and\nvolume of general activities directed to, and required of, each controller were appropriately\nassessed.\n4. § 195.446 Control room management.\n(a) General\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(6) Address deficiencies identified through the implementation of paragraphs\n(e)(1) through (e)(5) of this section.\nMCFS failed to address deficiencies identified through the implementation of paragraphs (e)(1)\nthrough (e)(5) of this section, as required by § 195.446(e)(6).\nSpecifically, deficiencies identified in the monthly alarm reviews, as well as those noted during\nthe 2023 review of correct safety-related alarm setpoints and alarm descriptions, were not\nremediated in a timely manner. It is imperative that such deficiencies be addressed promptly to\nensure ongoing compliance and operational safety.3\n5. § 195.446 Control room management.\n3 Control Room Management FAQ E.16\n3\n\n\n\n(a) General\n(f) Change management. Each operator must assure that changes that could affect\ncontrol room operations are coordinated with the control room personnel by\nperforming each of the following:\n(1) …\n(2) Require its field personnel to contact the control room when emergency\nconditions exist and when making field changes that affect control room operations.\nMCFS failed to require its field personnel to contact the control room when emergency\nconditions exist and when making field changes that affect control room operations, as required\nby § 195.446(f)(2).\nSpecifically, the documentation associated with the Mitchell Critical DOT Valve Inspection,\nconducted on May 7, 2024 lacks evidence that field personnel established communication with\nthe control room prior to and subsequent to the inspection. In addition, a review of the controller\nlogs from the same date revealed no record of such communications being initiated or received.4\n6. § 195.446 Control room management.\n(a) General\n(j) Compliance and deviations. An operator must maintain for review during\ninspection:\n(1) …\n(2) Documentation to demonstrate that any deviation from the procedures required\nby this section was necessary for the safe operation of the pipeline facility.\nMCFS failed to maintain for review during inspection documentation to demonstrate that any\ndeviation from the procedures required by this section was necessary for the safe operation of the\npipeline facility, as required by § 195.446(j)(2).\nSpecifically, records documenting hours of service (HOS) deviations for December 10, 2021,\nand January 18, 2022, were not provided. On these dates, controllers exceeded the maximum\nallowable hours of service as stipulated in Section 700.502 – Shift Lengths and Rotations, which\nlimits controllers to 63 hours within any sliding seven-day period. The operator has incorrectly\napplied a 35-hour reset provision, which is permissible only following a sequence of two or more\nday shifts.5 Though the operator contends that the FAQs are not enforceable, their control room\nmanual and procedures incorporated language derived from these FAQs, which they\nsubsequently failed to adhere to. This improper application of the 35-hour reset resulted in\nundocumented HOS deviations.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a\n4 Control Room Management FAQ F.01 and F.02\n5 Control Room Management FAQ D.07.\n4\n\n\n\nrelated series of violations. For violation occurring on or after December 28, 2023 and before\nDecember 30, 2024, the maximum penalty may not exceed $266,015 per violation per day the\nviolation persists, up to a maximum of $2,660,135 for a related series of violations. For violation\noccurring on or after January 6, 2023 and before December 28, 2023, the maximum penalty may\nnot exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627\nfor a related 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.\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 Mid-Continent Fractionation and Storage, LLC being subject to additional enforcement\naction.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2025-018-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 D. Fehling (24-296573)\nLyndon Hoel, Manager Pipeline Safety, Mid-Continent Fractionation & Storage, LLC,\nlyndon.hoel@williams.com\n5","truncated":false,"body_characters":12555}