TRANSCONTINENTAL GAS PIPE LINE COMPANY — Notice of Amendment

party submissionOfficial PDF120071005M_operator response_11012007.pdf#

120071005m_notice of amendment_070307_text.pdf, page 1Official PDFu S Department of Transportation Pipeline and Hazardous Materials Safety Administration 409 3rd Street, SW Suite 300 Washington, OC 20024 NOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT RE UESTED July 3, 2007 Mr Randall Barnard Vice President of Operations Wilhams Gas Pipeline-Transco 2800 South Post Oak Road Houston, TX 77251 CPF I-2007-1005M Dear Mr Bernard On December 13 and 14, 2006, a representative of the Pipehne and Hazardous Matenals Safety Administration (PHMSA) pursuant to Chapter 601 of 49 Umted States Code investigated the incident that took place on December 12, 2006 at Wilhams Gas Pipelme — Transco (Williams) Compressor Station Buildmg at the Elhcott City, MD Station 190 On the basis of the investigation, PHMSA has identified apparent inadequacies found witlun Wilhams' plans or procedures, as descnbed below#

120071005m_notice of amendment_070307_text.pdf, page 21. I1192. 605 Procedural manual for operations, maintenance, and emergencies. (a) GeneraL Each operator shall prepare and follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. For transnussion lmes, the manual must also include procedures for handling abnormal operations. This manual must be reviewed and updated by the operator at intervals not exceeding 15 months, but at least once each calendar year. This manual must be prepared before operations of a pipelme system commence. Appropriate parts of the manual must be kept at locations where operations and mamtenance activities are conducted. Wilhams responded to PHMSA's request for specific information (letter dated April 5, 2007) by letter dated May 17, 2007 which discussed Wilhams' post incident root cause analysis Based on the investigation of the incident and information provided by Wilhams, changes need to be incorporated in Williams' operating and maintenance procedures that address the following I Activities involving the use of welding and torch cutting should be avoided inside the compressor building 2 The need for the lead person responsible for specific mamtenance activities to msure that necessary detailed steps to isolate the main compressor umts are communicated to maintenance personnel including welders 3 Training of employees and any other personnel responsible for completing the hot work permit for compressor station miuntenance activihes Res onse to this Notice This Notice is provided pursuant to 49 U S C $ 60108(a) and 49 C F R g 190 237 Enclosed as part of this Notice is a document entitled Response Options for Prpelme Operators m Compliance ProceeCkngs Please refer to this document and note the response options Be advised that all matenal you submit in response to this enforcement action is sub]ect to being made pubhcly avadable If you beheve that any portion of your responsive material qualifies for confidential treatment under 5 U S C 552(b), along with the complete ortgmal document you must provide a second copy of the document with the portions you beheve qualify for confidenttal treatment redacted and an explanatiou of why you beheve the redacted information quahfies for confidentia treatment under 5 U S C 552(b) If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authonzes the Associate Admuustrator for Pipehne Safety to find facts as alleged in this Notice without further notice to you and to issue a Final Order#

120071005m_notice of amendment_070307_text.pdf, page 3If, atter opportunity for a heanng, your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C F R $ 190 237) If you are not contesting this Notice, we propose that you submit your amended procedures to my office withm 120 days of receipt of this Notice This penod may be extended by wntten request for good cause Once the madequacies identified herein have been addressed in your amended procedures, this enforcement action wdl be closed In correspondence concerning this matter, please refer to CPF I-2007-1005M and, for each document you submit, please provide a copy in electromc format whenever possible Sincerely, Byro Coy, PE Director, Eastern Region Pipehne and Hazardous Matenals Safety Adnuiustration Enclosure Response Options for Pipehne Operators tn Comphanee Proceedings#