{"operation":"document","citation":"CPF 120161008W","title":"TRANSCONTINENTAL GAS PIPE LINE COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-11-02","effective_on":null,"summary":"CLOSED warning letter citing 192.303.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120161008w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120161008w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120161008w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120161008W","body":"Warning Letter involving TRANSCONTINENTAL GAS PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulation as 192.303. The case was opened on 2016-11-02 and is reported as closed as of 2016-11-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120161008W_Warning Letter_11022016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120161008W/120161008W_Warning%20Letter_11022016.pdf\n\n120161008W_Warning Letter_11022016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120161008W/120161008W_Warning%20Letter_11022016_text.pdf\n\n120161008W_Warning Letter_11022016_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nNovember 2, 2016\nMs. Stephanie Timmermeyer\nVP, Safety and Regulatory Compliance\nTranscontinental Gas Pipe Line Company\n525 Central Park Drive\nOklahoma City, OK 73105\nCPF 1-2016-1008W\nDear Ms. Timmermeyer:\nFrom September 15 through 19, 2014, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Williams’s\nTranscontinental Gas Pipe Line Company’s (Transco) replacement of sections of mainlines A, B, and C\nwithin Unit #2881 - Elliott City in Owings Mills, MD.\nAs a result of the inspection, it appears that you have committed a probable violation of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable\nviolation is:\n1. §192.303 Compliance with specifications or standards.\nEach transmission line or main must be constructed in accordance with comprehensive\nwritten specifications or standards that are consistent with this part.\nTransco failed to construct each transmission line or main in accordance with comprehensive written\nspecifications or standards that are consistent with this part.\nSpecifically, Transco failed to follow its construction procedures. During the inspection, the PHMSA\ninspector reviewed Transco’s construction specifications and records related to the replacement of a\nsection of transmission line C in Owings Mills, MD.\nTransco’s construction procedure, titled “Volume 890 – Construction Specification for Online Pipeline\nInspection, revised 7/28/14, paragraph 1.1.9,” states in part “. . . poly tanks, made of non-conducting\nmaterial, will not be used for venting, catching, or storing pipeline liquids.”\nDuring a field inspection on 9/16/2014, the PHMSA inspector observed a poly tank connected to the\npipeline at MP 1631.94. Transco’s Construction Daily Progress Report #20 stated, “Manifolds were\nwelded onto both ends of old ML ‘C’ and a cleaning pig was run to check for fluids - no liquids found.”\nPHMSA informed Transco’s Chief Inspector of the failure to follow Transco’s construction\nspecifications. Transco informed PHMSA that the operation did not result in the disposition of any\n\n\n\n1-2016-1008W\ncondensate or liquid from mainline C into the poly tank, and that a decision had been made not to utilize\nthe poly tank for liquid/condensate removal operations, which were pending for the replacement sections\non Line A and Line B.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $205,638 per\nviolation per day the violation persists up to a maximum of $2,056,380 for a related series of violations.\nFor violation occurring between January 4, 2012 to August 1, 2016, the maximum penalty may not\nexceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000 for a related\nseries of violations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a related\nseries of violations. We have reviewed the circumstances and supporting documents involved in this\ncase, and have decided not to conduct additional enforcement action or penalty assessment proceedings at\nthis time. We advise you to correct the item identified in this letter. Failure to do so will result in\nTransco being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 1-\n2016-1008W. Be advised that all material you submit in response to this enforcement action is subject to\nbeing made 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 must\nprovide a second copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nSincerely,\nByron Coy, P.E.\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120161008W_Warning Letter_11022016 Page 2 of 2","truncated":false,"body_characters":4900}