{"operation":"document","citation":"CPF 120171013M","title":"TRANSCONTINENTAL GAS PIPE LINE COMPANY — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-05-09","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(a), 192.605(b)(1), 192.605(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171013m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171013m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171013m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120171013M","body":"Notice of Amendment involving TRANSCONTINENTAL GAS PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 192.605(a),  192.605(b)(1),  192.605(b)(2). The case was opened on 2017-05-09 and is reported as closed as of 2017-06-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120171013M_Closure Letter_06152017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171013M/120171013M_Closure%20Letter_06152017.pdf\n\n120171013M_Closure Letter_06152017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171013M/120171013M_Closure%20Letter_06152017_text.pdf\n\n120171013M_Notice of Amendment_05092017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171013M/120171013M_Notice%20of%20Amendment_05092017.pdf\n\n120171013M_Notice of Amendment_05092017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171013M/120171013M_Notice%20of%20Amendment_05092017_text.pdf\n\n120171013M_Operator Response to Notice_06092017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171013M/120171013M_Operator%20Response%20to%20Notice_06092017.pdf\n\n120171013M_Notice of Amendment_05092017_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nMay 9, 2017\nMr. Mark Cluff\nVP Safety & Operational Discipline\nTranscontinental Gas Pipe Line Company\nOne Williams Center\nTulsa, OK 74172\nCPF 1-2017-1013M\nDear Mr. Cluff:\nBetween May 23, 2016 and October 28, 2016, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\ninspected Transcontinental Gas Pipe Line Company’s (Transco) plans and procedures as part of\nan integrated inspection of Transco’s Charlottesville and Princeton Divisions.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nTransco’s plans or procedures, as described below:\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 procedures\nfor handling abnormal operations. This manual must be reviewed and updated by the\noperator at intervals not exceeding 15 months, but at least once each calendar year.\nThis manual must be prepared before operations of a pipeline system commence.\nAppropriate parts of the manual must be kept at locations where operations and\nmaintenance activities are conducted. …\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide safety\nduring maintenance and operations. …\n(1) Operating, maintaining, and repairing the pipeline in accordance with each of the\n\n\n\nCPF 1-2017-1013M\nrequirements of this subpart and subpart M of this part.\nTransco’s written procedure 70.14.01, Pipeline Repair, Rev. 23, dated 11/09/16, is inadequate in\nthat it contains conflicting information regarding methods of repair to be utilized for certain\ndefects.\nTable 1 of Transco’s procedure 70.14.01, Pipeline Repair, Rev. 23, dated 11/09/16, summarizes\nthe repair options available for various types of defects. Section 5.1.1 of this procedure instructs\nthe Asset Integrity Manager to “Determine the appropriate repair method according to Table 1”.\nThe information in Table 1 conflicts with the options provided in the rest of the procedure\nregarding repair options for external corrosion defects that are greater than 80% of the wall\nthickness, but not leaking. The Table indicates that the preferred method for repairing these defects\nis a Type “A” Sleeve or Cut Out. For Type “B” Sleeves it states that they are “optional/not\nrecommended” as a repair method.\nFigure 4 of the procedure provides a decision flow chart for repairing corrosion defects. Following\nthrough the flowchart, it indicates the repair options when less than 20% of the wall thickness\nremains at a corrosion anomaly are a Type “B” Sleeve or Cut Out.\nFinally, Section 4.1.2.3 of the procedure states the following when evaluating corrosion:\n“If the remaining wall thickness is less than 20% of nominal, cut out and replace as a cylinder or\ninstall a type \"B\" sleeve.”\nThe information in Table 1 conflicts with the flowchart found in Figure 4 and with Section 4.1.2.3\nof the procedure. As Table 1 is to be used as reference by the Asset Integrity Manager in\ndetermining the appropriate repair method for a defect under section 5.1.1, there should be no\nconflict between its contents and the repair methods recommended by other portions of the\nprocedure.\n2. §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 procedures\nfor handling abnormal operations. This manual must be reviewed and updated by the\noperator at intervals not exceeding 15 months, but at least once each calendar year.\nThis manual must be prepared before operations of a pipeline system commence.\nAppropriate parts of the manual must be kept at locations where operations and\nmaintenance activities are conducted. …\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide safety\nduring maintenance and operations. …\n(1) Operating, maintaining, and repairing the pipeline in accordance with each of the\nrequirements of this subpart and subpart M of this part.\nTransco’s written Policy 70.16.00.07, DOT Valve Maintenance, Rev. 7, dated 12/31/2012, is\ninadequate in that it does not provide sufficient detail for meeting the requirements of 192.745(a).\n§192.745(a) states in part: “Each transmission line valve that might be required during an\n120171013M_Notice of Amendment_05092017_text Page 2 of 5\n\n\n\nCPF 1-2017-1013M\nemergency must be inspected and partially operated…”\nDuring the inspection, the PHMSA inspectors reviewed Transco’s valve inspection records and\nTransco’s Operation and Maintenance (O&M) procedures.\nTransco’s Policy 70.16.00.07 DOT Valve Maintenance states in part:\n“1.2 It is the policy that the District maintains a list of DOT valves.\n1.2.1 Depending on the facilities in the District, this list may include the following valves that\ncould be utilized during an emergency:\n• Compressor Station Block Valves\n• Compressor Station Side Gate Valves\n• Compressor Station Blowdown Valves\n• Mainline and Lateral Block Valves\n• Mainline and Lateral Crossover Valves (between parallel lines)\n• Mainline and Lateral Block B1 and B2 Valves (bypass)\n• Meter Station Tap Valves\n• Automatic ESD Station Fuel Gas Supply Valves\n• Offshore Platform Isolation Valves\n• Offshore Platform Blowdown Valves\n…\n3.1 The District Manager is responsible for compliance with this policy throughout their assigned\ngeographic region.”\nThe procedure and policy failed to provide details, such as:\n1. Criteria/process for the emergency valve designation process\n2. Individuals responsible for developing the valve designation criteria\n3. Process for keeping the list of emergency valves current\n4. Documentation requirements\n5. Process to review records for completeness and accuracy\n3. §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 procedures\nfor handling abnormal operations. This manual must be reviewed and updated by the\noperator at intervals not exceeding 15 months, but at least once each calendar year.\nThis manual must be prepared before operations of a pipeline system commence.\nAppropriate parts of the manual must be kept at locations where operations and\nmaintenance activities are conducted. …\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide safety\nduring maintenance and operations. …\n(2) Controlling corrosion in accordance with the operations and maintenance\nrequirements of Subpart I of this part.\n120171013M_Notice of Amendment_05092017_text Page 3 of 5\n\n\n\nCPF 1-2017-1013M\nTransco’s written procedures for corrosion control, including 20.06.03, Cathodic Protection\nCriteria, Rev. 13, dated 03/27/2013, and 20.07.01, Annual Cathodic Protection Surveys, Rev. 14,\ndated 1/30/2013, fail to address the requirements of 192.463(c). Specifically, they are inadequate\nin that they do not contain information such as criteria, investigation or remedial measures\nregarding excessive polarization or overprotection of facilities.\nProcedures for controlling corrosion in accordance with the requirements of Subpart I are required\nunder §192.605(b)(2). §192.463(c), found in Subpart I of 49 C.F.R. Part 192, requires that “The\namount of cathodic protection must be controlled so as not to damage the protective coating or the\npipe.”\nThe procedures do not include sufficient guidance on controlling the amount of cathodic\nprotection, such as:\n1. Criteria for what indicates over voltage, such as a threshold polarized potential;\n2. A process for determining if indications of over voltage are a threat to the integrity of a\npipeline or its protective coating; and\n3. Remedial actions if the over voltage is determined to be a threat to the pipeline or its\nprotective coating.\n4. §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 procedures\nfor handling abnormal operations. This manual must be reviewed and updated by the\noperator at intervals not exceeding 15 months, but at least once each calendar year.\nThis manual must be prepared before operations of a pipeline system commence.\nAppropriate parts of the manual must be kept at locations where operations and\nmaintenance activities are conducted. …\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide safety\nduring maintenance and operations. …\n(2) Controlling corrosion in accordance with the operations and maintenance\nrequirements of Subpart I of this part.\nTransco’s written procedure 20.53.04, Insulating Flange Testing, Rev. 6, dated 2/25/2013, is\ninadequate in that it fails to provide sufficient guidance with regards to §192.467(d). Specifically,\nit does not provide guidance consistent with Transco’s current practices for determining when\nfurther testing is required after a potential, unintentional short is discovered.\nProcedures for controlling corrosion in accordance with the requirements of Subpart I are required\nunder §192.605(b)(2). §192.467(d), found in Subpart I of 49 C.F.R. Part 192, requires that\n“Inspection and electrical tests must be made to assure that electrical isolation is adequate.”\nTransco’s procedure 20.53.04, dated 2/25/2013, Section 2.2 states in part “Consider further testing\nas outlined in the following processes in this procedure if the IR drop is less than 100 mV” when\ntesting IR drop across an insulating flange. The procedure lacks specificity on how it is determined\nthat further testing is needed. Transco personnel indicated that after a potential, unintentional short\nat an electrical insulating flange is discovered based on an IR drop across it of less than 100 mV,\n120171013M_Notice of Amendment_05092017_text Page 4 of 5\n\n\n\nCPF 1-2017-1013M\nno further testing or other actions are performed if the cathodic protection levels remain adequate\n(pass utilized cathodic protection criteria). The procedure does not include sufficient guidance for\nmaking this determination.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond 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).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 60 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Transco maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Robert Burrough, Acting Director, PHMSA Eastern Region,\n820 Bear Tavern Road, Suite 103, West Trenton, NJ 08628. In correspondence concerning this\nmatter, please refer to CPF 1-2017-1013M, and for each document you submit, please provide a\ncopy in electronic format whenever possible. Smaller files may be emailed to\nrobert.burrough@dot.gov. Larger files should be sent on a CD accompanied by the original paper\ncopy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nActing Director, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120171013M_Notice of Amendment_05092017_text Page 5 of 5\n\n120171013M_Closure Letter_06152017_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJune 15, 2017\nMark Cluff\nVP Safety & Operational Discipline\nTranscontinental Gas Pipe Line Company\nOne Williams Center\nTulsa, OK 74172\nCPF 1-2017-1013M\nDear Mr. Cluff:\nBetween May 23, 2016 and October 28, 2016, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,\ninspected Transcontinental Gas Pipe Line Company’s (Transco) plans and procedures as part of\nan integrated inspection of Transco’s Charlottesville and Princeton Divisions. As a result of the\ninspection, Transco was issued a Notice of Amendment on May 9, 2017, which proposed\namendment of your procedures.\nTransco submitted its amended procedures on June 9, 2017. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nActing Director, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":16115}