TRANSCONTINENTAL GAS PIPE LINE COMPANY — Notice of Probable Violation

case documentOfficial PDF120171017_NOPV PCO_11242017.pdf#

case documentOfficial PDF120171017_NOPV PCO_11242017_text.pdf#

party submissionOfficial PDF120171017_Operator Response to Notice and Request For Time Extension_12212017.pdf#

120171017_Final Order_05032018_text.pdf, page 1Official PDFMay 3, 2018 Mr. Alan S. Armstrong President and Chief Executive Officer The Williams Companies, Inc. One Williams Center Tulsa, Oklahoma 74172 Re: CPF No. 1-2017-1017 Dear Mr. Armstrong: Enclosed please find the Final Order issued in the above-referenced case. It makes one finding of violation and specifies actions that need to be taken by Transcontinental Gas Pipe Line Company, LLC, a subsidiary of Williams Partners, LP, to comply with the pipeline safety regulations. When the terms of the compliance order have been completed, as determined by the Director, Eastern Region, this enforcement action will be 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: Mr. Robert Burrough, Director, Eastern Region, Office of Pipeline Safety, PHMSA Mr. Larry Legendre, Manager Pipeline Safety, Williams Atlantic Gulf, 2800 Post Oak Boulevard, Houston, Texas 77056 CERTIFIED MAIL - RETURN RECEIPT REQUESTED#

120171017_Final Order_05032018_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, LLC, a subsidiary of Williams Partners, LP, ) ) Respondent. ) ___________________________________________ ) ) CPF No. 1-2017-1017 FINAL ORDER On several dates between July 11 and October 14, 2016, pursuant to 49 U.S.C. § 60117, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), conducted on-site pipeline safety inspections of the facilities and records of Transcontinental Gas Pipe Line Company, LLC (Transco or Respondent), in Virginia, Pennsylvania, and New Jersey. Transco, a subsidiary of Williams Partners, LP (Williams), operates approximately 10,200 miles of gas pipelines in the United States.1 As a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Respondent, by letter dated November 24, 2017, a Notice of Probable Violation and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Transco had violated 49 C.F.R. § 192.731 and proposed ordering Respondent to take certain measures to correct the alleged violation. Williams, on behalf of Transco, responded to the Notice by letter dated December 21, 2017 (Response). The company did not contest the allegation of violation, but provided information concerning the corrective actions it had taken and requested additional time to comply with the proposed corrective actions. Respondent did not request a hearing and therefore has waived its right to one. FINDING OF VIOLATION In its Response, Transco did not contest the allegation in the Notice that it violated 49 C.F.R. Part 192, as follows: Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.731(a), which states: 1 Transco website, available at http://co.williams.com/gulfcoast/transco/ (last accessed Jan. 16, 2018).#

120171017_Final Order_05032018_text.pdf, page 3CPF No. 1-2017-1017 Page 2 § 192.731 Compressor stations: Inspection and testing of relief devices. (a) Except for rupture discs, each pressure relieving device in a compressor station must be inspected and tested in accordance with §§ 192.739 and 192.743, and must be operated periodically to determine that it opens at the correct set pressure. The Notice alleged that Respondent violated 49 C.F.R. § 192.731(a) by failing to inspect and test each pressure relieving device in a compressor station in accordance with § 192.743. Specifically, the Notice alleged that Transco failed to determine if nine relief devices located in compressor stations were adequate from the standpoint of capacity, by failing to consider the magnitude of built up back pressure in the capacity calculations required under § 192.743. During the inspection, the PHMSA inspector requested records for capacity calculations of certain relief devices at compressor stations for 2013 through 2015. The PHMSA inspector reviewed capacity calculations for nine relief valves located at Stations 165, 200, 505, and 515. The records indicated that Transco failed to consider built-up back pressure in the capacity calculations on nine relief valves located at compressor stations. 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. § 192.731(a) by failing to inspect and test each pressure relieving device in a compressor station in accordance with § 192.743. This finding of violation will be considered a prior offense in any subsequent enforcement action taken against Respondent. COMPLIANCE ORDER The Notice proposed a compliance order with respect to Item 1 in the Notice for violation of 49 C.F.R. § 192.731(a). Under 49 U.S.C. § 60118(a), each person who engages in the transportation of gas or who owns or operates a pipeline facility is required to comply with the applicable safety standards established under chapter 601. In its Response, Respondent requested additional time to comply with the terms of the proposed compliance order. The Director has recommended incorporating such additional time into this Order. Accordingly, pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following actions to ensure compliance with the pipeline safety regulations applicable to its operations: 1. With respect to the violation of § 192.731(a) (Item 1), Respondent must complete relief-valve capacity calculations for all DOT relief devices in compressor stations within the “Williams North” inspection system (South Carolina to New York), with vent piping and the magnitude of built-up back pressure considered. This shall be accomplished within 180 days of receipt of the Final Order. 2. Transco must provide PHMSA a spreadsheet or report summarizing the data from#

120171017_Final Order_05032018_text.pdf, page 4CPF No. 1-2017-1017 Page 3 the calculations performed in Item l, and including identification of any relief devices that are determined to have inadequate capacity. This shall be accomplished within 180 days of receipt of the Final Order. 3. Transco must remediate or replace any devices that were determined to be inadequate by the calculations in Item 1 above, within 365 days of receipt of the Final Order. 4. All documentation demonstrating compliance with the compliance action items above must be submitted to the Director, Eastern Region, PHMSA, 820 Bear Tavern Road, Suite 103, West Trenton, New Jersey 08628, for review within the time frames stated for each item. The Director may grant an extension of time to comply with any of the required items upon a written request timely submitted by the Respondent and demonstrating good cause for an extension. It is requested (not mandated) that Respondent maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to the Director. It is requested that these costs be reported in two categories: (1) total cost associated with preparation/revision of plans, procedures, studies and analyses; and (2) total cost associated with replacements, additions and other changes to pipeline infrastructure. Failure to comply with this Order may result in the administrative assessment of civil penalties not to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), for each violation for each day the violation continues or in referral to the Attorney General for appropriate relief in a district court of the United States. The terms and conditions of this Final Order are effective upon service in accordance with 49 C.F.R. § 190.5. May 3, 2018 ___________________________________ __________________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety#

120171017_Closure Letter_08052019_text.pdf, page 1Official PDFOVERNIGHT EXPRESS DELIVERY August 5, 2019 Mr. Alan S. Armstrong President and Chief Executive officer The Williams Companies, Inc. One Williams Center Tulsa, Oklahoma 74172 CPF 1-2017-1017 Dear Mr. Armstrong: On May 3, 2018, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to Williams – Transcontinental Gas Pipe Line Company, LLC (Williams) a Final Order in the above- referenced case. This Order included a Compliance Order. Based on our review of the documentation you provided, it has been determined that you have complied with the terms of this Order. Accordingly, this case is now closed and no further action is contemplated with respect to the matters involved in this case. Thank you for your cooperation in this matter. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration#