{"operation":"document","citation":"CPF 120171022W","title":"TRANSCONTINENTAL GAS PIPE LINE COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-12-21","effective_on":null,"summary":"CLOSED warning letter citing 192.229(c)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171022w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171022w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171022w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120171022W","body":"Warning Letter involving TRANSCONTINENTAL GAS PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulation as 192.229(c)(1). The case was opened on 2017-12-21 and is reported as closed as of 2017-12-21. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120171022W_Warning Letter_12212017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171022W/120171022W_Warning%20Letter_12212017.pdf\n\n120171022W_Warning Letter_12212017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171022W/120171022W_Warning%20Letter_12212017_text.pdf\n\n120171022W_Warning Letter_12212017_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nDecember 21, 2017\nMark Cluff\nVP Safety & Operational Discipline\nTranscontinental Gas Pipe Line Company\nOne Williams Center\nTulsa, OK 74172\nCPF 1-2017-1022W\nDear Mr. Cluff:\nFrom May 1-4, 2017, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nTranscontinental Pipe Line Company’s (Williams) records and procedures for the Atlantic Sunrise\nProject in Manassas, VA.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violation(s) are:\n1. § 192.229(c) Limitations on welders and welding operators.\n(c) A welder or welding operator qualified under § 192.227(a)-\n(1) May not weld on pipe to be operated at a pressure that produces a hoop stress of\n20 percent or more of SMYS unless within the preceding 6 calendar months the\nwelder or welding operator has had one weld tested and found acceptable under\neither section 6, section 9, section 12 or Appendix A of API Std 1104 (incorporated by\nreference, see §192.7). Alternatively, welders or welding operators may maintain an\nongoing qualification status by performing welds tested and found acceptable under\nthe above acceptance criteria at least twice each calendar year, but at intervals not\nexceeding 7 ½ months. A welder or welding operator qualified under an earlier\nedition of a standard listed in §192.7 of this part may weld, but may not re-qualify\nunder that earlier edition; and…\n\n\n\nCPF 1-2017-1022W\nWilliams did not properly requalify two welders on the Atlantic Sunrise Project. Specifically,\nWilliams failed to maintain adequate documentation of two welders to support welder\nrequalification, per the requirements of § 192.229(c) ‐ API Std. 1104 (incorporated by reference\n§192.7).\nDuring the inspection, the PHMSA inspector reviewed welder qualification records and Williams’\n“Volume 890 – Construction Specification for ONSHORE PIPELINE CONSTRUCTION\n(Procedure).” The Procedure, Section 9.1.5 – Welder Qualification stated:\n“9.1.5 Company certification duration shall be 6 calendar months. Re‐ certification shall\noccur as follows:\n• Requalification may be by radiography if the welder's previous qualification has not\nexpired. A welder may re‐ qualify indefinitely by radiographic examination as long as that\nwelder's previous qualification has not expired.\n• Requalification by radiography must involve the same welding process as initial\nqualification, but may include any grade of pipe, pipe diameter, or wall thickness.\n• Requalification by radiography may be administered during a welder's current job\nassignment. The welding inspector shall send a copy of the respective radiographic\ninterpretation report (film reader sheet) and Company welder qualification record to the\nCompany Welding Department in Houston, TX.\n• The radiographic acceptance standard for welder requalification and for production\nwork shall be API 1104 (latest DOT approved edition) unless otherwise specified by\nCompany”\nWilliams provided 2016‐2017 welder qualification records, which included Form WGP‐0120\nWilSOP Welder Qualification Records (WGP‐0120), and Form WGP‐0149 WilSOP Weld\nInspection Film Report (WGP‐0149).\nThe WGP‐0120s documented that two welders were destructively qualified under the applicable\nprocedure on September 17, 2016 and/or September 19, 2016 at Station 175. Both welders were\nsubsequently requalified by non‐destructive examination (NDE) on November 23, 2016 per the\nrequirements of § 192.229(c)(1) and Williams Procedure.\nThe WGP‐0149s showed the acceptability of the welds under API 1104 Section 9. However, the\nNovember 23, 2016 form did not properly identify the welders who performed the qualification\nwelds. Typically, the radiographic interpretation report utilized for welder requalification will\ninclude the following information, but not limited to:\n Objective for record keeping purposes\n Welder identification – name and/or last four digits of his social security\n Welder number or an assigned project stencil in order to establish continuity\nDuring the inspection exit meeting and in subsequent follow‐up requests, Williams conveyed that\nit could not provide any documentation directly tying the two welders in question to the\nrequalification welds and/or associated NDE records provided.\nTherefore, Williams failed to maintain adequate documentation of two welders to support welder\nrequalification, per the requirements of § 192.229(c) ‐ API Std. 1104.\n120171022W_Warning Letter_12212017_text\nPage 2 of 3\n\n\n\nCPF 1-2017-1022W\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$209,002 per violation per day the violation persists, up to a maximum of $2,090,022 for a related\nseries of violations. For violations occurring prior to November 2, 2015, the maximum penalty\nmay not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000\nfor a related series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this letter.\nFailure to do so will result in Transcontinental Pipe Line Company being subject to additional\nenforcement action.\nPlease be advised that all material you submit in response to this enforcement action is subject to\nbeing made publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential 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, Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103,\nWest Trenton, NJ 08628. Please refer to CPF 1- 2017-1022W on each document you submit, and\nwhenever possible provide a signed PDF copy in electronic format. Smaller files may be emailed\nto robert.burrough@dot.gov. Larger files should be sent on a CD accompanied by the original\npaper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120171022W_Warning Letter_12212017_text\nPage 3 of 3","truncated":false,"body_characters":7385}