# TRANSCONTINENTAL GAS PIPE LINE COMPANY — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 120171017
- **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:** 2017-11-24
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 192.731(a).
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-120171017
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120171017
**body:**

Notice of Probable Violation involving TRANSCONTINENTAL GAS PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulation as 192.731(a). The case was opened on 2017-11-24 and is reported as closed as of 2019-08-05. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120171017_Closure Letter_08052019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171017/120171017_Closure%20Letter_08052019.pdf

120171017_Closure Letter_08052019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171017/120171017_Closure%20Letter_08052019_text.pdf

120171017_Final Order_05032018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171017/120171017_Final%20Order_05032018.pdf

120171017_Final Order_05032018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171017/120171017_Final%20Order_05032018_text.pdf

120171017_NOPV PCO_11242017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171017/120171017_NOPV%20PCO_11242017.pdf

120171017_NOPV PCO_11242017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171017/120171017_NOPV%20PCO_11242017_text.pdf

120171017_Operator Response to Notice and Request For Time Extension_12212017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171017/120171017_Operator%20Response%20to%20Notice%20and%20Request%20For%20Time%20Extension_12212017.pdf

120171017_Final Order_05032018_text.pdf

May 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



U.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).



CPF 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



CPF 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

OVERNIGHT 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
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