{"operation":"document","citation":"CPF 120161009","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":"2016-11-02","effective_on":null,"summary":"CLOSED notice of probable violation citing 192.243(b)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120161009.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120161009.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120161009","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120161009","body":"Notice of Probable Violation involving TRANSCONTINENTAL GAS PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulation as 192.243(b)(1). The case was opened on 2016-11-02 and is reported as closed as of 2017-06-27. Proposed civil penalty: $39,700. Assessed civil penalty: $39,700. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120161009_Final Order_06272017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120161009/120161009_Final%20Order_06272017.pdf\n\n120161009_Final Order_06272017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120161009/120161009_Final%20Order_06272017_text.pdf\n\n120161009_NOPV PCP_11022016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120161009/120161009_NOPV%20PCP_11022016.pdf\n\n120161009_NOPV PCP_11022016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120161009/120161009_NOPV%20PCP_11022016_text.pdf\n\n120161009_Final Order_06272017_text.pdf\n\nJune 27, 2017\nMr. Alan S. Armstrong\nPresident and Chief Executive Officer\nThe Williams Companies, Inc.\nOne Williams Center\nTulsa, OK 74172\nRe: CPF No. 1-2016-1009\nDear Mr. Armstrong:\nEnclosed please find the Final Order issued in the above-referenced case. It makes a finding of\nviolation and assesses a civil penalty of $39,700 against your subsidiary, Transcontinental Gas\nPipe Line Company. This is to acknowledge receipt of payment of the full penalty amount, by\nwire transfer, dated November 16, 2016. This enforcement action is now closed. Service of the\nFinal Order by certified mail is effective upon the date of mailing as provided under 49 C.F.R.\n§ 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Director, Eastern Region, Office of Pipeline Safety, PHMSA\nMs. Stephanie Timmermeyer, VP, Safety and Regulatory Compliance, Transcontinental\nGas Pipe Line Company, 525 Central Park Drive, Oklahoma City, OK 73105\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n_________________________________________\nIn the Matter of )\nTranscontinental Gas Pipe Line Company, ) CPF No. 1-2016-1009\na subsidiary of Williams Partners, LP, )\n)\n)\n)\nRespondent. )\n_________________________________________ )\nFINAL ORDER\nFrom September 15 through 19, 2014, pursuant to 49 U.S.C. § 60117, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS), conducted an on-site pipeline safety inspection of the facilities and records of\nTranscontinental Gas Pipe Line Company, LLC (Transco or Respondent), a subsidiary of\nWilliams Partners, LP, related to Transco’s replacement of sections of mainlines A, B, and C\nwithin Unit 2881 in Owings Mills, Maryland. Transco’s system has approximately 10,200 miles\nof pipeline extending from South Texas to New York City, and is a major provider of natural gas\nto the Eastern United States.1\nAs a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Respondent,\nby letter dated November 2, 2016, a Notice of Probable Violation and Proposed Civil Penalty\n(Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Transco had\nviolated 49 C.F.R. § 192.243, and proposed assessing a civil penalty of $39,700 for the alleged\nviolation.\nRespondent did not contest the allegation of violation and paid the proposed civil penalty of\n$39,700. In accordance with 49 C.F.R. § 190.208(a)(1), such payment authorizes the Associate\nAdministrator to make a finding of violation and to issue this final order.\nFINDING OF VIOLATION\nTransco did not contest the allegation in the Notice that it violated 49 C.F.R. Part 192, as\nfollows:\n1 See http://co.williams.com/gulf_coast/transco/ (last accessed April 20, 2017).\n\n\n\nCPF No. 1-2016-1009\nPage 2\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.243, which states in\nrelevant part:\n§ 192.243 Nondestructive testing.\n(a)…\n(b) Nondestructive testing of welds must be performed:\n(1) In accordance with written procedures; and\n(2) …\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.243(b)(1) by failing to\nnondestructively test a weld in accordance with its written procedure, which references\nAmerican Petroleum Institute Standard (API Std.) 1104. Specifically, Transco did not place an\nimage quality indicator (IQI) across the repaired area of a repair weld as prescribed in API Std.\n1104, subsection 11.1.6, “Placement of IQIs.”\nRespondent’s WilSOP Operations & Maintenance Manual Procedure 90.09.01 – Nondestructive\nTesting of Welds states: “The purpose of this procedure is to establish the minimum requirements\nfor Nondestructive Testing (NDT), inspection, and/or evaluation to meet or exceed NDT\nrequirements as set forth in American Petroleum Institute (API) 1104, latest Pipeline and\nHazardous Materials Safety Administration (PHMSA) accepted edition.” Furthermore, API Std.\n1104, section 11.1.6.1, “Film” describes the placement of IQI on films to be interpreted, and\nstates, in pertinent part, that “[w]hen a repaired weld is radiographed, an additional IQI shall be\nplaced across each repaired area.”\nDuring the inspection, PHMSA requested Line C NDT records for any welds that required\nrepair. Transco provided x-ray files and records associated with ML-20 and its repair, ML-20R.\nUpon review of the files and records, the PHMSA inspector found no evidence of an IQI being\nplaced across the repaired area of the weld. Transco was alerted to this issue and subsequently\nre-radiographed the repaired weld ML-20R with proper IQI placement, as required by its written\nprocedures and API Std. 1104.\nRespondent did not contest this allegation of violation. Accordingly, based upon a review of all\nof the evidence, I find that Respondent violated 49 C.F.R. § 192.243(b)(1) by failing to\nnondestructively test a weld in accordance with its written procedure that references API Std.\n1104, which requires an additional IQI to be placed across each repaired area of a weld that is\nradiographed.\nThis finding of violation will be considered a prior offense in any subsequent enforcement action\ntaken against Respondent.\nASSESSMENT OF PENALTY\nUnder 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed\n$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any\n\n\n\nCPF No. 1-2016-1009\nPage 3\nrelated series of violations.2 In determining the amount of a civil penalty under 49 U.S.C.\n§ 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature,\ncircumstances, and gravity of the violation, including adverse impact on the environment; the\ndegree of Respondent’s culpability; the history of Respondent’s prior offenses; and any effect\nthat the penalty may have on its ability to continue doing business; and the good faith of\nRespondent in attempting to comply with the pipeline safety regulations. In addition, I may\nconsider the economic benefit gained from the violation without any reduction because of\nsubsequent damages, and such other matters as justice may require. The Notice proposed a total\ncivil penalty of $39,700 for the violations cited above.\nItem 1: The Notice proposed a civil penalty of $39,700 for Respondent’s violation of 49 C.F.R.\n§ 192.243(b), for failing to nondestructively test a weld in accordance with its written procedure\nwhich references API Std. 1104. As previously discussed, contrary to respondent’s WilSOP\nOperations & Maintenance Manual Procedure 90.09.01 – Nondestructive Testing of Welds,\nTransco did not utilize an IQI over the repaired area of the weld. Transco neither contested the\nallegation nor presented any evidence or argument justifying a reduction in or elimination of the\nproposed penalty. Accordingly, having reviewed the record and considered the assessment\ncriteria, I assess Respondent a civil penalty of $39,700 for violation of 49 C.F.R.\n§ 192.243(b)(1).\nIn summary, having reviewed the record and considered the assessment criteria for each of the\nItems cited above, I assess Respondent a total civil penalty of $39,700. Transco paid the full\npenalty amount by wire transfer on November 16, 2016.\nThe terms and conditions of this Final Order are effective upon service in accordance with\n49 C.F.R. § 190.5.\nJune 27, 2017\n___________________________________ _________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety\n2 These amounts are adjusted annually for inflation. See Pipeline Safety: Inflation Adjustment of Maximum Civil\nPenalties, 82 Fed. Reg. 19325 (April 27, 2017).","truncated":false,"body_characters":8784}