# TRANSCONTINENTAL GAS PIPE LINE COMPANY — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 120123002
- **title:** TRANSCONTINENTAL GAS PIPE LINE COMPANY — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2012-06-11
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 193.2503, 193.2635(d), 193.2801.
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-120123002.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-120123002
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120123002
**body:**

Notice of Probable Violation involving TRANSCONTINENTAL GAS PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 193.2503,  193.2635(d),  193.2801. The case was opened on 2012-06-11 and is reported as closed as of 2013-01-24. Proposed civil penalty: $74,300. Assessed civil penalty: $74,300. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120123002_Closure Letter_01242013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120123002/120123002_Closure%20Letter_01242013.pdf

120123002_Closure Letter_01242013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120123002/120123002_Closure%20Letter_01242013_text.pdf

120123002_Final Order_10262012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120123002/120123002_Final%20Order_10262012.pdf

120123002_Final Order_10262012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120123002/120123002_Final%20Order_10262012_text.pdf

120123002_NOPV_PCP PCO_ 06112012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120123002/120123002_NOPV_PCP%20PCO_%2006112012_text.pdf

120123002_NOPV_PCP_PCO_06112012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120123002/120123002_NOPV_PCP_PCO_06112012.pdf

120123002_Final Order_10262012_text.pdf

OCTOBER 26, 2012
Mr. Larry Hjalmarson
Vice President Safety, Environment & Integrity
Transcontinental Gas Pipe Line Company, LLC
2800 Post Oak Blvd
Houston, TX 77056
Re: CPF No. 1-2012-3002
Dear Mr. Hjalmarson:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation, assesses a civil penalty of $74,300, and specifies actions that need to be taken by
Transcontinental Gas Pipe Line Company, LLC, to comply with the pipeline safety regulations.
This letter acknowledges receipt of payment of the full penalty amount, by wire transfer, dated
July 3, 2012. When the terms of the compliance order have been completed, as determined by
the Director, Eastern Region, this enforcement action will be closed. Service of the Final Order
by certified mail is deemed effective upon the date of mailing, or as otherwise provided under
49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Byron Coy, Director, Eastern Region, OPS
Mr. Alan Mayberry, Deputy Associate Administrator for Field Operations, OPS
Mr. Alan S. Armstrong, President, The Williams Companies, Inc., 2800 Post Oak Blvd,
Houston, TX 77056
Ms. Marie G. Sotak, Manager, Pipeline Safety, Transcontinental Gas Pipe Line
Company, LLC
CERTIFIED MAIL - RETURN RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
)
In the Matter of )
)
Transcontinental Gas Pipe Line ) CPF No. 1-2012-3002
Company, LLC, )
)
Respondent. )
____________________________________)
FINAL ORDER
During the week of December 6, 2010, pursuant to 49 U.S.C. § 60117, a representative of the
Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
(OPS), conducted an on-site pipeline safety inspection of the facilities and records of
Transcontinental Gas Pipeline Company, LLC (Transco or Respondent), a subsidiary of The
Williams Companies, Inc., at its liquefied natural gas (LNG) facility in Carlstadt, New Jersey.
The Carlstadt facility is part of the Transco Pipeline, which transports natural gas through a
10,200-mile pipeline system extending from South Texas to New York City.1
As a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Williams
Gas Pipeline - Transco, by letter dated June 11, 2012, a Notice of Probable Violation, Proposed
Civil Penalty, and Proposed Compliance Order (Notice), which also included a warning pursuant
to 49 C.F.R. § 190.205. In accordance with 49 C.F.R. § 190.207, the Notice proposed finding
that Transco had committed various violations of 49 C.F.R. Part 193, proposed assessing a civil
penalty of $74,300 for the alleged violations, and proposed ordering Respondent to take certain
measures to correct the alleged violations. The warning item required no further action, but
warned the operator to correct the probable violation or face possible enforcement action.
Transco responded to the Notice by letter dated September 5, 2012 (Response). The company
did not contest the allegations of violation or the proposed compliance order and paid the
proposed civil penalty of $74,300, as provided in 49 C.F.R. § 190.227. The company also
provided information concerning the corrective actions it had taken and submitted copies of its
revised procedures. Payment of the penalty serves to close the penalty Items with prejudice to
Respondent.
1 See http://co.williams.com/williams/operations/gas-pipeline/transco/ (last accessed September 27, 2012).



2
FINDINGS OF VIOLATION
In its Response, Transco did not contest the allegations in the Notice that it violated 49 C.F.R.
Part 193, as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 193.2801, which states, in
relevant part:
§ 193.2801 Fire protection.
Each operator must provide and maintain fire protection at LNG plants
according to sections 9.1 through 9.7 and section 9.9 of [National Fire
Protection Association (NFPA) Standard] 59A (incorporated by reference,
see § 193.2013). . . .
The Notice alleged that Respondent violated 49 C.F.R. § 193.2801 by failing to provide and
maintain fire protection at its LNG facility at Carlstadt, New Jersey (Facility), in accordance with
sections 9.1 through 9.7 and 9.9 of NFPA 59A. Specifically, the Notice alleged that Transco
used methane gas at a concentration of 50% of the lower explosive limit when calibrating its
propane and ethylene gas detectors at the Facility, resulting in improperly calibrated detectors
and alarm systems. As a result, Transco allegedly could not demonstrate that the Facility
maintained fire protection in accordance with NFPA 59A section 9.3.2, which states that
“[f]lammable gas detection systems shall activate an audible and visual alarm at not more than
25 percent of the lower flammable limit of the gas or vapor being monitored.”
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 193.2801 by failing to provide and
maintain fire protection in accordance with sections 9.1 through 9.7 and 9.9 of NFPA 59A.
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 193.2635(d), which states:
§ 193.2635 Monitoring corrosion control.
Corrosion protection provided as required by this subpart must be
periodically monitored to give early recognition of ineffective corrosion
protection, including the following, as applicable:
(a) . . .
(d) Each component that is protected from atmospheric corrosion
must be inspected at intervals not exceeding 3 years.
The Notice alleged that Respondent violated 49 C.F.R. § 193.2365(d) by failing to inspect each
component protected from atmospheric corrosion at intervals not exceeding 3 years.
Specifically, the Notice alleged that Transco failed to remove insulation on its carbon steel
pipeline during atmospheric corrosion surveys, thereby preventing its staff from performing
visual inspections of all pipe surfaces that were protected from atmospheric corrosion.
Respondent did not contest this allegation of violation but provided a copy of its new
“Atmospheric Corrosion Control (LNG)” procedure and stated that it had begun a full plant



3
atmospheric corrosion survey in accordance with the revised procedure and the proposed
Compliance Order.
2 Accordingly, based upon a review of all of the evidence, I find that
Respondent violated 49 C.F.R. § 193.2635(d) by failing to inspect each component protected
from atmospheric corrosion at intervals not exceeding 3 years.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed
$100,000 per violation for each day of the violation, up to a maximum of $1,000,000 for any
related series of violations. In determining the amount of a civil penalty under
49 U.S.C. § 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature,
circumstances, and gravity of the violation, including adverse impact on the environment; the
degree of Respondent’s culpability; the history of Respondent’s prior offenses; the Respondent’s
ability to pay the penalty and any effect that the penalty may have on its ability to continue doing
business; and the good faith of Respondent in attempting to comply with the pipeline safety
regulations. In addition, I may consider the economic benefit gained from the violation without
any reduction because of subsequent damages, and such other matters as justice may require.
The Notice proposed a total civil penalty of $74,300 for the violations cited above.
Item 1: The Notice proposed a civil penalty of $25,900 for Respondent’s violation of
49 C.F.R. § 193.2801, for failing to provide and maintain fire protection in accordance with
sections 9.1 through 9.7 and 9.9 of NFPA 59A. Transco paid the proposed penalty, which serves
to close this Item with prejudice. Accordingly, having reviewed the record and considered the
assessment criteria, I assess Respondent a civil penalty of $25,900 for violation of
49 C.F.R. § 193.2801.
Item 2: The Notice proposed a civil penalty of $48,400 for Respondent’s violation of
49 C.F.R. § 193.2365(d) for failing to inspect each component protected from atmospheric
corrosion at intervals not exceeding 3 years. Transco paid the proposed penalty, which serves to
close this Item with prejudice. Accordingly, having reviewed the record and considered the
assessment criteria, I assess Respondent a civil penalty of $48,400 for violation of
49 C.F.R. § 193.2365(d).
In summary, having reviewed the record and considered the assessment criteria for each of the
Items cited above, I assess Respondent a total civil penalty of $74,300, which has already been
paid by Respondent.
2 Response at 1.



4
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Item 2 in the Notice for violation of
49 C.F.R. § 193.2635. Under 49 U.S.C. § 60118(a), each person who engages in the
transportation of gas or who owns or operates a pipeline facility is required to comply with the
applicable safety standards established under chapter 601. Pursuant to the authority of
49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following
actions to ensure compliance with the pipeline safety regulations applicable to its operations:
1. With respect to the violation of § 193.2635(d) (Item 2), Respondent must:
a. Rewrite its operations and maintenance procedures to provide more detail and
guidance to the corrosion technicians responsible for atmospheric corrosion surveys
at the Carlstadt LNG Facility. The revision must require a listing of the insulated
piping sections and other insulated components subject to § 193.2625 within the
Facility. Transco must develop a methodology to examine each identified insulated
item to reliably categorize its corrosion status in accordance with the requirements of
§ 193.2635(d). This item must be completed within 90 days of receipt of the Final
Order.
b. Conduct a full plant atmospheric corrosion survey in accordance with the revised
procedures within 15 months after receipt of the Final Order.
2. PHMSA requests that Transco maintain documentation of the safety improvement and
compliance costs associated with fulfilling this Compliance Order and submit the total to
Byron Coy, Director, Eastern Region, Pipeline and Hazardous Materials Safety
Administration. It is requested that these costs be reported in two categories: (1) total
cost associated with preparation/revision of plans, procedures, studies, and analyses; and
(2) total cost associated with replacements, additions, and other physical changes to the
pipeline infrastructure.
The Director may grant an extension of time to comply with any of the required items upon a
written request timely submitted by the Respondent and demonstrating good cause for an
extension.
Failure to comply with this Order may result in the administrative assessment of civil penalties
not to exceed $100,000 for each violation for each day the violation continues or in referral to the
Attorney General for appropriate relief in a district court of the United States.
WARNING ITEM
The Notice alleged a probable violation of Part 193 but did not propose a civil penalty or
compliance order. Therefore, this is considered to be a warning item. The warning was for:



5
49 C.F.R. § 193.2503 ─ Respondent’s alleged failure to follow its written
procedures providing for safety in normal operation. Specifically, the Notice
alleged that Transco failed to document its fire drills, which are required by
49 C.F.R. § 193.2717, and as required by Transco’s Procedure Manual, Appendix
H, Section D.2.
If OPS finds a violation of this item in a subsequent inspection, Respondent may be subject to
future enforcement action.
The terms and conditions of this Final Order are effective upon service in accordance with
49 C.F.R. § 190.5.
___________________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

120123002_Closure Letter_01242013_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
OVERNIGHT EXPRESS DELIVERY
January 24, 2013
Mr. Larry Hjalmarson
Vice President Safety, Environment & Integrity
Transcontinental Gas Pipe Line Company, LLC
2800 Post Oak Blvd
Houston, TX 77056
CPF 1-2012-3002
Dear Mr. Hjalmarson:
On October 26, 2012, the Pipeline and Hazardous Materials Safety Administration (PHMSA)
issued to Transcontinental Gas Pipe Line Company, LLC a Final Order in the above-referenced
case. This Order included a Compliance Order and Civil Penalty assessment. Based on our
review of the documentation you provided in your response dated 1/16/2013, and confirmation
of payment of the civil penalty on 7/3/2012, it has been determined that you have complied with
the terms of this Order.
Accordingly, this case is now closed and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
Byron Coy, PE
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
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