TRANSCONTINENTAL GAS PIPE LINE COMPANY — Warning Letter

120073003w_warning letter_09072007_text.pdf, page 1Official PDFu s Department of Transportation Pipeline and Hazardous Materials Safety Administration 409 3rd Street, SW, Suite 300 Waahmgton, OC 20024 WARNING LETTER CERTIFIED MAIL - RETURN RECEIPT RE UESTED September 7, 2007 Mr Randy Bamard Vice President Operations and Gas Control Wtlhams Gas Ptpehne 2800 Post Oak Boulevard Houston, Texas 77056 CPF 1-2007-3003W Dear Mr Barnard From May 3 to May 6 and on October 12, 2005, a representative of the Pipelme and Hazardous Matenals Safety Admiiustration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your procedures, records and facihties at the Station 240 LNG plant in Carlstadt, New Jersey As a result of the inspection, it appears that you have committed probable violations of the Pipehne Safety Regulations, Title 49, Code of Federal Regulations The items inspected and the probable violations are tt 193. 2711 Personal health. Each operator shall follow a written plan to verify that personnel assigned operating, maintenance, security, or fire protection duties at the LNG plant do not have any physical condition that would impair performance of their assigned duties. The plan must be designed to detect both readily observable disorders, such as#

120073003w_warning letter_09072007_text.pdf, page 2physical handicaps or mIury, and conditions requiring professional examination for discovery. I a Williams Gas Pipehne's (Williams') written plan requires that the "physical examination records related to this procedure be retamed at the LNG Plant Office " During the inspection, only one record of an employee physical examination (physical) was at the LNG Plant Office Wilhams stated that it retains its employee health records in its Houston headquarters Tins is not consistent with the wntten plan Subsequent to the 2005 inspection, Wdliams miuntained the employee health records at the LNG Plant Office lb Williams' written plan requires that at the time of initial employment, each applicant will be admiiustered a physical examination performed by a company-approved physician On the hst of plant employees that Wdhams later provided to the inspector, there were three employees that had not received a pre-employment physical I c Wilhams' wntten plan reqiures that all employees at the LNG plant pass a physical examination at five-year intervals by a company-approved physician On the hst of plant employees that Wilhams provided to the inspector (same hst as lb above), seventeen (17) employees were not hsted as having passed a physical examination administered at five-year intervals between 1999 and 2005 Dunng the 2007 inspection, all of Wdhams' employees had been admimstered physical exammations wittun the preceding five years by a company-approved physician Under 49 Uruted States Code, f 60122, you are sub)ect to a civd 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 Also, for LNG famhties, an additional penalty of not more than $50, 000 for each violation may be imposed We have reviewed the circumstances and supportmg 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 items identified in this letter Failure to do so will result in Wdliams being sub1ect to additional enforcement action No reply to this letter is reqmred If you choose to reply, m your correspondence please refer to CPF 1-2007-3002W. Be advised that all material you submit in response to this enforcement action is sub1ect to bemg made pubhcly aviulable 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 original document you must provide a second copy of the document with the portions you believe quah fy for confidential treatment redacted and an explanation of why you beheve the redacted information quahfies for confidential treatment under 5 U S C 552(b)#

120073003w_warning letter_09072007_text.pdf, page 3Byron Coy, PE Director, Eastern Region Ptpehne and Hazardous Matenals Safety Admuustratton#