# TRANSCONTINENTAL GAS PIPE LINE COMPANY — Warning Letter

- **operation:** document
- **citation:** CPF 120103002W
- **title:** TRANSCONTINENTAL GAS PIPE LINE COMPANY — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2010-04-05
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 193.2619(c)(2), 193.2711.
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-120103002w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120103002W
**body:**

Warning Letter involving TRANSCONTINENTAL GAS PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 193.2619(c)(2),  193.2711. The case was opened on 2010-04-05 and is reported as closed as of 2010-04-05. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120103002W_Warning Letter_04052010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120103002W/120103002W_Warning%20Letter_04052010_text.pdf

120103002W_Warning Letter_04052010_text.pdf

U.S. Department 820 Bear Tavern Road, Suite 306
Of Transportation West Trenton, NJ 08628
Pipeline and 609.989.2171
Hazardous Materials
Safety Administration
WARNING LETTER
EXPRESS OVERNIGHT DELIVERY
April 5, 2010
Mr. Randy Barnard
Vice President
Operations And Gas Control
Williams Gas Pipeline
2800 Post Oak Boulevard
Houston, Texas 77056
CPF 120103002W
Dear Mr. Barnard:
On July 21 to July 25, 2008, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code conducted an
inspection on Carlstadt, NJ LNG facility.
As a result of the inspection, it appears that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the
probable violations are:
1. §193.2619 Control systems.
(c) Control systems in service, but not normally in operation, such as relief valves
and automatic shutdown devices, and control systems for internal shutoff valves for
bottom penetration tanks must be inspected and tested once each calendar year, not
exceeding 15 months, with the following exceptions:
(2) Control systems that are intended for fire protection must be inspected and
tested at regular intervals not to exceed 6 months.
Section §193.2619 (c) requires that control systems intended for fire protection must be
inspected and tested at regular intervals not to exceed 6 months.



CPF 120103002W
During a field review at the time of the inspection, the operator stated that two detector heads in
the compressor building are required to activate an Emergency Shutdown. The operator stated
that this was never tried and proven.
2. §193.2711 Personnel 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
physical handicaps or injury, and conditions requiring professional examination for
discovery.
Section §193.2711 Personnel health, requires an operator 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.
At the time of inspection, except for one new employee, no other employee records or
documentation to verify that employees are medically fit to perform their assigned duties.
Under 49 United States Code, § 60122, you are subject 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 series of violations. Also, for LNG facilities, an additional penalty of not more than
$50,000 for each violation may be imposed. 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 this time. We advise you to correct the
item(s) identified in this letter. Failure to do so will result in Williams Gas Pipeline being
subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 120103002W. Be advised that all material you submit in response to this enforcement
action is subject to being made publicly available. If you believe that any portion of your
responsive material qualifies 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 qualify for confidential treatment redacted and an explanation of why you believe
the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).
Sincerely,
Byron Coy, PE
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
120103002W_Warning Letter_04052010 Page 2 of 2
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