TRANSCONTINENTAL GAS PIPE LINE COMPANY — Warning Letter

120071008w_warning letter_09072007_text.pdf, page 1Official PDFU 5 Department of Transportation Pipeline ana Hazardous Matenats Safety Administration 409 3rd Street, SW, Surie 300 Washington DC 20024 WARNING LETTER CERTIFIED MAIL - RETURN RECEIPT RE UESTED September 7, 2007 Mr Randy Bernard Vice President, Operations and Gas Control Wtlhams Gas Pipehne 2800 Post Oak Boulevard, Houston, TX 77056 CPF I-2007-1008W Dear Mr Barnard During the week of December 1 1, 2006, a representative of the Pipehne and Hazardous Matenals Safety Admuustration (PHMSA) pursuant to Chapter 601 of 49 Umted States Code inspected your Distnct 520 in Salladasburg, Pennsylvania As a result of the mspechon, it appears that you have committed a probable violation of the Pipehne Safety Regulations, Title 49, Code of Federal Regulatlns The items mspected and the probable violation is %192. 605 (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. . . .#

120071008w_warning letter_09072007_text.pdf, page 2In a review of records for the Wharton meter station, the annual test sheets for 2003 through 2006 indicate that the regulators CVI and CV2 were no longer tested smce the station had been made tnacnve Wilhams procedures, Abandonment or Inactivation of Facilities (Procedure 70 15 01 06) states in Sec 6 0 Deactivating a Meter Station Facility requires that (l) the valve that is closed to prevent the flow of gas must have a lockng device to prevent the opemng of the valve by an unauthonzedperson (2) /the operator shally mstall a mechamcal device or fitting that wdl prevent the flow of gas in the service line or in the meter assembly (3) the piping shall be physically disconnected from the customer's facihties In the secunng of the bidirectional regulators, Williams only closed the four valves (one on each side of the two regulators) and secured them with electncal ties and marling with a "Do not operate" tag This does not satisfy the requirements of your procedures PHMSA's findings are based upon the test records for the regulators in the meter station from 2002 to 2006, photographs of the unsecured valves ad)acent to the regulators and Wilhams procedures for deactivation of factitnes Under 49 United States Code, $ 60122, you are sub)ect to a civil penalty not to exceed $100, 000 for each violation for each day the violation persists up to a maximum of $1, 000, 000 for any related senes of violations 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 tlus time We advise you to correct the item identified in this letter Failure to do so will result in Wdhams being sub)ect to additional enforcement action No reply to this letter is required If you choose to reply, in your correspondence please refer to CPF 1-2007-1008W. Be advised that all matenal you submit in response to this enforcement action is sub)ect to being made pubhcly available If you beheve that any portion of your responsive matenal quahfies for confidential treatment under 5 U S C 552(b), along with the complete ongmal document you must provide a second copy of the document with the portions you beheve quahfy for confidentia treatment redacted and an explananon of why you beheve the redacted mformation qualifies for confidential treatment under 5 U S C 552(b) Sincerely, ~+ Byron Coy, PE Director, Eastern Region Pipehne and Hazardous Matenals Safety Admimstration#