# TRANSCONTINENTAL GAS PIPE LINE COMPANY — Warning Letter

- **operation:** document
- **citation:** CPF 120071008W
- **title:** TRANSCONTINENTAL GAS PIPE LINE COMPANY — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2007-09-07
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.605(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-120071008w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-120071008w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-120071008w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120071008W
**body:**

Warning Letter involving TRANSCONTINENTAL GAS PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2007-09-07 and is reported as closed as of 2007-09-07. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120071008W_Warning Letter_09072007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120071008W/120071008W_Warning%20Letter_09072007.pdf

120071008w_warning letter_09072007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120071008W/120071008w_warning%20letter_09072007_text.pdf

120071008w_warning letter_09072007_text.pdf

U 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. . . .



In 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
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- **body characters:** 4167
