TRANSCONTINENTAL GAS PIPE LINE COMPANY — Notice of Probable Violation

case documentOfficial PDF120161009_NOPV PCP_11022016.pdf#

case documentOfficial PDF120161009_NOPV PCP_11022016_text.pdf#

120161009_Final Order_06272017_text.pdf, page 1Official PDFJune 27, 2017 Mr. Alan S. Armstrong President and Chief Executive Officer The Williams Companies, Inc. One Williams Center Tulsa, OK 74172 Re: CPF No. 1-2016-1009 Dear Mr. Armstrong: Enclosed please find the Final Order issued in the above-referenced case. It makes a finding of violation and assesses a civil penalty of $39,700 against your subsidiary, Transcontinental Gas Pipe Line Company. This is to acknowledge receipt of payment of the full penalty amount, by wire transfer, dated November 16, 2016. This enforcement action is now closed. Service of the Final Order by certified mail is effective upon the date of mailing as provided under 49 C.F.R. § 190.5. Thank you for your cooperation in this matter. Sincerely, Alan K. Mayberry Associate Administrator for Pipeline Safety Enclosure cc: Director, Eastern Region, Office of Pipeline Safety, PHMSA Ms. Stephanie Timmermeyer, VP, Safety and Regulatory Compliance, Transcontinental Gas Pipe Line Company, 525 Central Park Drive, Oklahoma City, OK 73105 CERTIFIED MAIL - RETURN RECEIPT REQUESTED#

120161009_Final Order_06272017_text.pdf, page 2U.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 Company, ) CPF No. 1-2016-1009 a subsidiary of Williams Partners, LP, ) ) ) ) Respondent. ) _________________________________________ ) FINAL ORDER From September 15 through 19, 2014, 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 Pipe Line Company, LLC (Transco or Respondent), a subsidiary of Williams Partners, LP, related to Transco’s replacement of sections of mainlines A, B, and C within Unit 2881 in Owings Mills, Maryland. Transco’s system has approximately 10,200 miles of pipeline extending from South Texas to New York City, and is a major provider of natural gas to the Eastern United States.1 As a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Respondent, by letter dated November 2, 2016, a Notice of Probable Violation and Proposed Civil Penalty (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Transco had violated 49 C.F.R. § 192.243, and proposed assessing a civil penalty of $39,700 for the alleged violation. Respondent did not contest the allegation of violation and paid the proposed civil penalty of $39,700. In accordance with 49 C.F.R. § 190.208(a)(1), such payment authorizes the Associate Administrator to make a finding of violation and to issue this final order. FINDING OF VIOLATION Transco did not contest the allegation in the Notice that it violated 49 C.F.R. Part 192, as follows: 1 See http://co.williams.com/gulf_coast/transco/ (last accessed April 20, 2017).#

120161009_Final Order_06272017_text.pdf, page 3CPF No. 1-2016-1009 Page 2 Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.243, which states in relevant part: § 192.243 Nondestructive testing. (a)… (b) Nondestructive testing of welds must be performed: (1) In accordance with written procedures; and (2) … The Notice alleged that Respondent violated 49 C.F.R. § 192.243(b)(1) by failing to nondestructively test a weld in accordance with its written procedure, which references American Petroleum Institute Standard (API Std.) 1104. Specifically, Transco did not place an image quality indicator (IQI) across the repaired area of a repair weld as prescribed in API Std. 1104, subsection 11.1.6, “Placement of IQIs.” Respondent’s WilSOP Operations & Maintenance Manual Procedure 90.09.01 – Nondestructive Testing of Welds states: “The purpose of this procedure is to establish the minimum requirements for Nondestructive Testing (NDT), inspection, and/or evaluation to meet or exceed NDT requirements as set forth in American Petroleum Institute (API) 1104, latest Pipeline and Hazardous Materials Safety Administration (PHMSA) accepted edition.” Furthermore, API Std. 1104, section 11.1.6.1, “Film” describes the placement of IQI on films to be interpreted, and states, in pertinent part, that “[w]hen a repaired weld is radiographed, an additional IQI shall be placed across each repaired area.” During the inspection, PHMSA requested Line C NDT records for any welds that required repair. Transco provided x-ray files and records associated with ML-20 and its repair, ML-20R. Upon review of the files and records, the PHMSA inspector found no evidence of an IQI being placed across the repaired area of the weld. Transco was alerted to this issue and subsequently re-radiographed the repaired weld ML-20R with proper IQI placement, as required by its written procedures and API Std. 1104. 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. § 192.243(b)(1) by failing to nondestructively test a weld in accordance with its written procedure that references API Std. 1104, which requires an additional IQI to be placed across each repaired area of a weld that is radiographed. This finding of violation will be considered a prior offense 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 $200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any#

120161009_Final Order_06272017_text.pdf, page 4CPF No. 1-2016-1009 Page 3 related series of violations.2 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; 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 $39,700 for the violations cited above. Item 1: The Notice proposed a civil penalty of $39,700 for Respondent’s violation of 49 C.F.R. § 192.243(b), for failing to nondestructively test a weld in accordance with its written procedure which references API Std. 1104. As previously discussed, contrary to respondent’s WilSOP Operations & Maintenance Manual Procedure 90.09.01 – Nondestructive Testing of Welds, Transco did not utilize an IQI over the repaired area of the weld. Transco neither contested the allegation nor presented any evidence or argument justifying a reduction in or elimination of the proposed penalty. Accordingly, having reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of $39,700 for violation of 49 C.F.R. § 192.243(b)(1). 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 $39,700. Transco paid the full penalty amount by wire transfer on November 16, 2016. The terms and conditions of this Final Order are effective upon service in accordance with 49 C.F.R. § 190.5. June 27, 2017 ___________________________________ _________________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety 2 These amounts are adjusted annually for inflation. See Pipeline Safety: Inflation Adjustment of Maximum Civil Penalties, 82 Fed. Reg. 19325 (April 27, 2017).#