{"operation":"document","citation":"CPF 120103001M","title":"TRANSCONTINENTAL GAS PIPE LINE COMPANY — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-04-05","effective_on":null,"summary":"CLOSED notice of amendment citing 193.2017(c)(2), 193.2509, 193.2513(b)(4), 193.2513(c)(1), 193.2711, 193.2715, 193.2801, 193.2903(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120103001m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120103001m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120103001m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120103001M","body":"Notice of Amendment involving TRANSCONTINENTAL GAS PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 193.2017(c)(2),  193.2509,  193.2513(b)(4),  193.2513(c)(1),  193.2711,  193.2715,  193.2801,  193.2903(e). The case was opened on 2010-04-05 and is reported as closed as of 2010-11-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120103001M_Closure Letter_11102010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120103001M/120103001M_Closure%20Letter_11102010.pdf\n\n120103001M_Closure Letter_11102010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120103001M/120103001M_Closure%20Letter_11102010_text.pdf\n\n120103001M_Notice of Amendment_04052010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120103001M/120103001M_Notice%20of%20Amendment_04052010_text.pdf\n\n120103001M_Notice of Amendment_04052010_text.pdf\n\nU.S. Department 820 Bear Tavern Road, Suite 306\nOf Transportation West Trenton, NJ 08628\nPipeline and 609.989.2171\nHazardous Materials\nSafety Administration\nNOTICE OF AMENDMENT\nEXPRESS OVERNIGHT DELIVERY\nApril 5, 2010\nMr. Randy Barnard\nVice President\nOperations And Gas Control\nWilliams Gas Pipeline\n2800 Post Oak Boulevard\nHouston, Texas 77056\nCPF 1-2010-3001M\nDear Mr. Barnard:\nOn July 21 to July 25, 2008, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code conducted an\ninspection on Williams/Transco’s Carlstadt, NJ LNG facility.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations found within Williams/Transco plans\nor procedures, as described below:\n1.\n§193.2513 Transfer procedures.\n(b) The transfer procedures must include provisions for personnel to:\n(4) When making bulk transfer of LNG into a partially filled (excluding cool\ndown heel) container, determine any differences in temperature or specific gravity\nbetween the LNG being transferred and the LNG already in the container and, if\nnecessary, provide a means to prevent rollover due to stratification.\nWilliam’s Operations and Maintenance Plan (O&M) procedures do not address conditions when\nmaking bulk transfer of LNG into partially filled (excluding cool down heel) containers. O&M\nprocedures must address the actions that take into account differences in temperature or specific\n\n\n\nCPF 120105001M\ngravity between the LNG being transferred and the LNG already in the container and, if\nnecessary, provide a means to prevent rollover due to stratification.\n2.\n§193.2513 Transfer procedures.\n(c) (1) Be in constant attendance during all cargo transfer operations;\nWilliam’s Operations and Maintenance Plan (O&M) procedures do not address that personnel\nmust be in constant attendance during all cargo transfer operations.\n3. §193.2711 Personnel health.\nEach operator shall follow a written plan to verify that personnel assigned\noperating, maintenance, security, or fire protection duties at the LNG plant do not\nhave any physical condition that would impair performance of their assigned duties.\nThe plan must be designed to detect both readily observable disorders, such as\nphysical handicaps or injury, and conditions requiring professional examination for\ndiscovery.\nWilliam’s Health Plans & Procedures are not comprehensive. The plan does not list doctors. A\nfive year employee health re-evaluation is too long. The plan does not list the various job\ndescriptions for which the MRO is to evaluate employees. The plan does not address what\nhappens if an employee has impairment and/or does not meet the standards that should be\nreflected in the plan.\n4. §193.2715 Training, security\n.\n(a) Personnel responsible for security at an LNG plant must be trained in\naccordance with a written plan of initial instruction to:\n(1) Recognize breaches of security;\n(2) Carry out the security procedures under §193.2903 that relate to their\nassigned duties;\n(3) Be familiar with basic plant operations and emergency procedures, as\nnecessary to effectively perform their assigned duties; and,\n(4) Recognize conditions where security assistance is needed.\n(b) A written plan of continuing instruction must be conducted at intervals of not\nmore than 2 years to keep all personnel having security duties current on the\nknowledge and skills they gained in the program of initial instruction.\nWilliam’s Security Plans & Procedures are inadequate in that they are not based on a written\nplan according to §193.2715 and §193.2903. At the time of the inspection, the operator\nverbalized that all employees act as security personnel. Security training must be based on a\nwritten plan.\n120103001M_Notice of Amendment_04052010 Page 2 of 5\n\n\n\nCPF 120105001M\n5.\n§193.2801 Fire Protections: Scope.\nEach operator must provide and maintain fire protection at LNG plants according\nto sections 9.1 through 9.7 and section 9.9 of NFPA 59A (incorporated by reference,\nsee Sec. 193.2013). However, LNG plants existing on March 31, 2000, need not\ncomply with provisions on emergency shutdown systems, water delivery systems,\ndetection systems, and personnel qualification and training until September 12,\n2005.\nNFPA 59A Section 9.9\n9.2.2 If equipment shutdown will introduce an additional hazard or result in\nsubstantial mechanical damage to equipment, the shutdown of such equipment or\nits auxiliaries shall be permitted to be omitted from the ESD system provided that\nthe effects of the continued release of flammable or combustible fluids are\ncontrolled.\n9.7.4 At least three portable flammable gas indicators shall be readily available.\n9.9.1 Manual emergency depressurizing means shall be provided where necessary\nfor safety. Portions of the plant that can be isolated from storage tanks or other\nsources of supply can be depressurized by venting to the atmosphere. The discharge\nshall be directed so as to minimize exposure to personnel or equipment.\nWilliam’s Security Plans & Procedures are inadequate in that the O&M does not address the\nfollowing from NFPA 59A. Specifically:\n The plan does not address additional hazards as a result of shutting down equipment as\nrequired by NFPA 59A Section 9.2.2.\n The O&M procedures states that two (2) gas detectors are to be available whereas NFPA\n59A Section 9.7.4 requires that three (3) gas detectors shall be readily available.\n The plan does not include procedures how to manually depressurize portions of the plant\nas required by NFPA 59A Section 9.9.1.\n6.\n§193.2903 Security procedures.\n(e) Methods for determining which persons are allowed access to the LNG plant;\nWilliam’s Security Plans & Procedures are inadequate in that they do not address methods for\ndetermining which persons are allowed access to the LNG plant.\n7.\n§193.2509 Emergency procedures.\n(b) To adequately handle each type of emergency identified under paragraph (a)\nof this section and each fire emergency, each operator must follow one or more\nmanuals of written procedures. The procedures must provide for the following:\n(3) Coordinating with appropriate local officials in preparation of an emergency\nevacuation plan, which sets forth the steps required to protect the public in the\nevent of an emergency, including catastrophic failure of an LNG storage tank.\n(4) Cooperating with appropriate local officials in evacuations and emergencies\nrequiring mutual assistance and keeping these officials advised of:\n120103001M_Notice of Amendment_04052010 Page 3 of 5\n\n\n\nCPF 120105001M\n(i) The LNG plant fire control equipment, its location, and quantity of units\nlocated throughout the plant;\n(ii) Potential hazards at the plant, including fires;\n(iii) Communication and emergency control capabilities at the LNG plant; and,\n(iv) The status of each emergency.\nWilliam’s O&M Plans & Procedures are inadequate in that they do not list local officials that\naffect the plant's safety, operations and security, and do not state the frequency these meetings\nare to be held.\n8.\n§193.2017 Plans and procedures.\n(c) Each operator must review and update the plans and procedures required by\nthis part\n(2) At intervals not exceeding 27 months, but at least once every 2 calendar years.\nAt the time of the inspection, the operator was unable to produce documentation to confirm that\nall sections of the plans and procedures were reviewed within the prescribed 27 month interval,\nbut at least once every 2 calendar years.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue a Final Order.\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the inadequacies\n(49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that you submit your\namended procedures to my office within 90 days of receipt of this Notice. This period may be\nextended by written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed.\n120103001M_Notice of Amendment_04052010 Page 4 of 5\n\n\n\nCPF 120105001M\nIn correspondence concerning this matter, please refer to CPF 120103001M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120103001M_Notice of Amendment_04052010 Page 5 of 5\n\n120103001M_Closure Letter_11102010_text.pdf\n\nU.S. Department 820 Bear Tavern Road, Suite 103\nOf Transportation West Trenton, NJ 08628\nPipeline and 609.989.2171\nHazardous Materials\nSafety Administration\nEXPRESS OVERNIGHT DELIVERY\nNovember 10, 2010\nMr. Larry Hjalmarson\nVice President, Safety Environmental and Integrity\nWilliams Gas Pipeline - Transco\n2800 Post Oak Boulevard\nHouston, Texas 77056\nCPF 1-2010-3001M\nDear Mr. Hjalmarson:\nFrom July 21 to July 25, 2008, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code conducted an\ninspection at Williams Gas Pipeline - Transco’s LNG facility in Carlstadt, NJ. As a result of the\ninspection, Williams Gas Pipeline - Transco was issued a Notice of Amendment on April 5,\n2010, which proposed amendment of your procedures.\nWilliams Gas Pipeline - Transco submitted its amended procedures on June 20, 2010. My staff\nreviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of\nAmendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nByron E. Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120103001M_Closure Letter_11102010","truncated":false,"body_characters":11986}