# TRANSCONTINENTAL GAS PIPE LINE COMPANY — Warning Letter

- **operation:** document
- **citation:** CPF 120121020W
- **title:** TRANSCONTINENTAL GAS PIPE LINE COMPANY — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2012-09-21
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.605(a).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120121020W
**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 2012-09-21 and is reported as closed as of 2012-09-21. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120121020W_Warning Letter_09212012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120121020W/120121020W_Warning%20Letter_09212012_text.pdf

120121020W_Warning Letter_09212012_text.pdf

U.S. Department of Transportation Pipeline and 609.989.2171
Hazardous Materials
Safety Administration
820 Bear Tavern Road, Suite 103
West Trenton, NJ 08628
WARNING LETTER
OVERNIGHT EXPRESS MAIL
September 21, 2012
Mr. Randy Barnard
Vice President, Operations
Transcontinental Gas Pipe Line Company, LLC
2800 Post Oak Blvd.
Houston, TX 77056
CPF 1-2012-1020W
Dear Mr. Barnard:
During the week of March 26, 2012, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your
pipeline facilities in White Haven, PA.
As a result of the inspection, it appears that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the
probable violation is:
1. 192.605 Procedural manual for operations, maintenance, and emergencies
Each operator shall include the following in its operating and maintenance plan:
(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. For transmission lines, the manual must also include procedures
for handling abnormal operations. This manual must be reviewed and updated by the
operator at intervals not exceeding 15 months, but at least one each calendar year.
This manual must be prepared before operations of a pipeline system commence.
Appropriate parts of the manual must be kept at locations where operations and
maintenance activities are conducted.
Transcontinental Gas Pipe Line Company, LLC failed to follow its Operations and Maintenance
(O&M) Manual that requires the review of each policy, procedure and form, the date the reviews
were completed, and be documented on an Annual Manual Review Assignment Spreadsheet forms.
The reviews are to be completed annually, but not to exceed a 15 month interval.



CPF 1-2012-1020W
WGP Safety Training Record showed that this procedure was not followed since pages 17 and 18
did not show who reviewed each policy and procedure, and the form was not dated or signed.
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. 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 Transcontinental Gas Pipe Line Company, LLC 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 1-2012-1020W. 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 E. Coy, P.E.
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
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