{"operation":"document","citation":"CPF 120171012W","title":"TRANSCONTINENTAL GAS PIPE LINE COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-05-08","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171012w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171012w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171012w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120171012W","body":"Warning Letter involving TRANSCONTINENTAL GAS PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2017-05-08 and is reported as closed as of 2017-05-08. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120171012W_Warning Letter_05082017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171012W/120171012W_Warning%20Letter_05082017.pdf\n\n120171012W_Warning Letter_05082017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171012W/120171012W_Warning%20Letter_05082017_text.pdf\n\n120171012W_Warning Letter_05082017_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nMay 8, 2017\nMr. Mark Cluff\nVP Safety & Operational Discipline\nTranscontinental Gas Pipe Line Company\nOne Williams Center\nTulsa, OK 74172\nCPF 1-2017-1012W\nDear Mr. Cluff:\nFrom August 1 – 5, 2016, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety, pursuant to Chapter 601 of 49 United States\nCode, inspected Transcontinental Gas Pipe Line Company’s (Transco) VA-North District,\nPHMSA Unit #891 in Manassas, VA.\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. 605 Procedural Manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least one\neach calendar year. This manual must be prepared before operations of a pipeline\nsystem commence. Appropriate parts of the manual must be kept at locations\nwhere operations and maintenance activities are conducted.\nTransco failed to follow for each pipeline, a manual of written procedures for conducting\noperations and maintenance activities and for emergency response. Specifically, Transco failed to\n\n\n\nCPF 1-2017-1012W\nfollow its written procedure 20.06.03, Cathodic Protection Criteria, Rev.13, dated 3/27/2013\n(Procedure), pursuant to 192.463(a).\n§192.463 (a) states “Each cathodic protection system required by this subpart must provide a level\nof cathodic protection that complies with one or more of the applicable criteria contained in\nAppendix D of this part. If none of these criteria is applicable, the cathodic protection system must\nprovide a level of cathodic protection at least equal to that provided by compliance with one or\nmore of these criteria.”\nTransco’s Procedure establishes the CP protection criteria utilized to confirm adequate external\ncorrosion control on their facilities. The 3 criteria listed in this procedure are:\n1. 2. -0.850 Volt Pipe-to-Soil (with IR drop considered),\n100 mV Voltage Shift (Polarization Decay), and\n3. 300 mV Shift.\nSection 1.0. Using the -0.850 Volt Pipe-to-Soil Criteria, paragraph 1.3 states “Consider any voltage\n(IR) drops according to WilSOP O&M 20.06.02 – Methods for IR Drop Correction.”\nDuring the inspection, the PHMSA inspector reviewed annual CP survey records for 2014, 2015\nand 2016 for test points within Transco’s Virginia - North district.\nThe 2014 records at relative station engineering numbers 76599+25, 76599+26 and 76599+27 (test\npoints 30, 31 and 32), located at the V-266 flow control valve within the Tenaska-Antioch M&R\nstation, indicated the following:\n1. Inspection remarks: “Mags not interrupted.”\n2. Structure P/S [Pipe to Soil] and Structure IRF [IR Free]:\na. Values recorded under the “Structure IRF” column were more negative than the\nvalues in the “Structure P/S” column at test points 30 and 31, indicating that current\nsources may have been interrupted and that IR drop had not been considered.\nb. Transco Asset Integrity personnel indicated that there are uninterruptable anodes at\nthis location that are not detached during annual CP surveys.\n3. The “Native P/S” column of the report was blank. The lack of native pipe-to-soil readings\nin the “Native P/S” column prevents application of criterion other than the -0.850 Volt\nPipe-to-Soil criteria, such as the 100 mV Voltage Shift or 300 mV Criteria found in\nTransco’s 20.06.03 procedure for CP criteria.\n120171012W_Warning Letter_05082017_text Page 2 of 3\n\n\n\nCPF 1-2017-1012W\nThus, Transco did not demonstrate that IR-drop was considered at these tests points, or that another\nvalid cathodic protection criterion was utilized at this location in accordance with their written\nprocedures.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $205,638\nper violation per day the violation persists up to a maximum of $2,056,380 for a related series of\nviolations. For violation occurring between January 4, 2012 to August 1, 2016, the maximum\npenalty may not exceed $200,000 per violation per day, with a maximum penalty not to exceed\n$2,000,000 for a related series of violations. For violations occurring prior to January 4, 2012, the\nmaximum penalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct the\nitem identified in this letter. Failure to do so will result in Transco being subject to additional\nenforcement action.\nBe advised that all material you submit in response to this enforcement action is subject to being\nmade 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\nmust provide a second copy of the document with the portions you believe qualify for confidential\ntreatment redacted and an explanation of why you believe the redacted information qualifies for\nconfidential treatment under 5 U.S.C. 552(b).\nNo reply to this letter is required. If you choose to reply, please submit all correspondence in this\nmatter to Robert Burrough, Acting Director, PHMSA Eastern Region, 820 Bear Tavern Road,\nSuite 103, West Trenton, NJ 08628. Please refer to CPF 1- 2017-1012W on each document you\nsubmit, and whenever possible provide a signed PDF copy in electronic format. Smaller files may\nbe emailed to robert.burrough@dot.gov. Larger files should be sent on a CD accompanied by the\noriginal paper copy to the Eastern Region Office.\nAdditionally, if you choose to respond to this (or any other case), please ensure that any response\nletter pertains solely to one CPF case number.\nSincerely,\nRobert Burrough\nActing Director, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120171012W_Warning Letter_05082017_text Page 3 of 3","truncated":false,"body_characters":7132}