CPF 120121020W
CPF 120121020W
120121020W_Warning Letter_09212012_text.pdf, page 1Official PDFU.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.#
120121020W_Warning Letter_09212012_text.pdf, page 2CPF 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 120121020W_WL_09212012 Page 2 of 2#
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