{"operation":"document","citation":"CPF 120181006M","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":"2018-02-13","effective_on":null,"summary":"CLOSED notice of amendment citing 192.303.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181006m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181006m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181006m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120181006M","body":"Notice of Amendment involving TRANSCONTINENTAL GAS PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulation as 192.303. The case was opened on 2018-02-13 and is reported as closed as of 2018-05-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120181006M_Closure Letter_05102018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181006M/120181006M_Closure%20Letter_05102018.pdf\n\n120181006M_Closure Letter_05102018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181006M/120181006M_Closure%20Letter_05102018_text.pdf\n\n120181006M_Notice Of Amendment _02132018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181006M/120181006M_Notice%20Of%20Amendment%20_02132018.pdf\n\n120181006M_Notice Of Amendment_02132018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181006M/120181006M_Notice%20Of%20Amendment_02132018_text.pdf\n\n120181006M_Operator Response To Notice_03132018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181006M/120181006M_Operator%20Response%20To%20Notice_03132018.pdf\n\n120181006M_Notice Of Amendment_02132018_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nFebruary 13, 2018\nMr. Mark Cluff\nVP Safety & Operational Discipline\nTranscontinental Gas Pipe Line Company\nOne Williams Center\nTulsa, OK 74172\nCPF 1-2018-1006M\nDear Mr. Cluff:\nFrom June 13-15, 2017, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nTranscontinental Gas Pipe Line Company’s (a subsidiary of Williams Pipeline L.P., ‘Williams’)\nMainline A&C Station 160 to Station 180 (Virginia) – GAP Pipe Replacement in\nAppomattox, Virginia.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nWilliams’ plans or procedures, as described below:\n1. §192.303 Compliance with specifications or standards.\nEach transmission line or main must be constructed in accordance with\ncomprehensive written specifications or standards that are consistent with this part.\nWilliams’ construction standards were inadequate for controlling corrosion in accordance with the\nrequirements of subpart I of 49 CFR Part 192. Specifically, Williams’ Project Standard, Below-\nGround Protective Coatings – Field Applied, Revision 01.00-Publication Date: 12/14/2016\n(Standard), contained conflicting information regarding coating thickness.\nDuring the inspection, the PHMSA inspector reviewed Williams’ Standard for below-ground\nprotective coating application. Williams’ Standard, Section 2.08 New Coating Application,\nincludes the following excerpts:\n\n\n\nCPF 1-2018-1006M\nA. General\n1. Apply according to manufacturer’s instruction.\n…\nB. Fusion-Bonded Epoxy (FBE) Powder…\n6. Machine Application…\ne) Apply the approved powdered coating as rapidly as possible to prevent premature\ncool down of the heated zone and to achieve at least 20 mils and a maximum of\n35 mils DFT.\n…\n2. C. Liquid-Epoxy Coatings…\nSingle-layer, two-layer, or both ARO should achieve at least 20 mils and a maximum\nof 35 mils DFT.\nThe Standard did not provide clear written coating specifications on coating thickness, as\nmanufacturer’s instructions typically contain a recommended coating thickness application range.\nThe Standard fails to address circumstances where a conflict occurs between this thickness range\nand the coating thicknesses ranges specified in Sections B and C, which could lead to confusion\nfor a coating crew on what thickness range is acceptable.\nTherefore, Williams’ construction standards were inadequate per the requirements of §192.303.\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.\n120181006M_Notice Of Amendment_02132018_text Page 2 of 3\n\n\n\nCPF 1-2018-1006M\nIt is requested (not mandated) that Transcontinental Gas Pipe Line Company maintain\ndocumentation of the safety improvement costs associated with fulfilling this Notice of\nAmendment (preparation/revision of plans, procedures) and submit the total to Robert Burrough,\nDirector, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103, West Trenton, NJ 08628.\nPlease refer to CPF 1-2018-1006M on each document you submit, and whenever possible provide\na signed PDF copy in electronic format. Smaller files may be emailed to robert.burrough@dot.gov.\nLarger files should be sent on a CD accompanied by the original paper copy to the Eastern Region\nOffice.\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\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120181006M_Notice Of Amendment_02132018_text Page 3 of 3\n\n120181006M_Closure Letter_05102018_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nMay 10, 2018\nMr. Mark Cluff\nVP Safety & Operational Discipline\nTranscontinental Gas Pipe Line Company\nOne Williams Center\nTulsa, OK 74172\nCPF 1-2018-1006M\nDear Mr. Cluff:\nFrom June 13-15, 2017, a representative from the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site\npipeline safety inspection of Transcontinental Gas Pipe Line Company’s (a subsidiary of Williams\nPipeline L.P., (Williams)) procedures in Appomattox, Virginia. As a result of the inspection,\nTranscontinental Gas Pipe Line Company was issued a Notice of Amendment on\nFebruary 13, 2018, which proposed amendment of your procedures.\nTranscontinental Gas Pipe Line Company submitted its amended procedures on March 14, 2018.\nMy staff reviewed the amended procedures, and it appears that the inadequacies outlined in this\nNotice of Amendment have been corrected.\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\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n120181006M_Notice Of Amendment _02132018.pdf\n\nU.S. Department\nof Transportation\n820 Bear Tavern Road, Suite 103\nWest Trenton, NJ 08628\nPipeline and\n609.771.7800\nSafety Administration\nHazardous Materials\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nFebruary 13, 2018\nMr. Mark Cluff\nVP Safety & Operational Discipline\nTranscontinental Gas Pipe Line Company\nOne Williams Center\nTulsa, OK 74172\nCPF 1-2018-1006M\nDear Mr. Cluff:\nFrom June 13-15, 2017, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nTranscontinental Gas Pipe Line Company's (a subsidiary of Williams Pipeline L.P., ' Williams')\nMainline A&C Station 160 to Station\n180 (Virginia) - GAP Pipe Replacement in\nAppomattox, Virginia.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nWilliams plans or procedures, as described below:\n1. §192.303 Compliance with specifications or standards.\nEach transmission line or main must be constructed in accordance with\ncomprehensive written specifications or standards that are consistent with this part.\nWilliams' construction standards were inadequate for controlling corrosion in accordance with the\nrequirements of subpart 1 of 49 CFR Part 192. Specifically, Williams' Project Standard, Below-\nGround Protective Coatings - Field Applied, Revision 01.00-Publication Date: 12/14/2016\n(Standard), contained conflicting information regarding coating thickness.\nDuring the inspection, the PHMSA inspector reviewed Williams\" Standard for below-ground\nprotective coating application. Williams\" Standard, Section 2.08 New Coating Application,\nincludes the following excerpts:\n\n\n\nCPF 1-2018-1006M\nA. General\n1. Apply according to manufacturer's instruction.\nTrE\nB. Fusion-Bonded Epoxy (FBE) Powder...\n6. Machine Application....\ne) Apply the approved powdered coating as rapidly as possible to prevent premature\ncool down of the heated zone and to achieve at least 20 mils and a maximum of\n35 mils DFT.\nC. Liquid-Epoxy Coatings...\n2. Single-layer, two-layer, or both ARO should achieve at least 20 mils and a maximum\nof 35 mils DFT.\nThe Standard did not provide clear written coating specifications on coating thickness, as\nmanufacturer's instructions typically contain a recommended coating thickness application range.\nThe Standard fails to address circumstances where a conflict occurs between this thickness range\nand the coating thicknesses ranges specified in Sections B and C, which could lead to confusion\nfor a coating crew on what thickness range is acceptable.\nTherefore, Williams' construction standards were inadequate per the requirements of $192.303.\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.\n120181006M_NOA_02132018 (155769)\nPage 2 of 3\n\n\n\nCPF 1-2018-1006M\nIt is requested (not mandated) that Transcontinental Gas Pipe Line Company maintain\ndocumentation of the safety improvement costs associated with fulfilling this Notice of\nAmendment (preparation/revision of plans, procedures) and submit the total to Robert Burrough,\nDirector, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103, West Trenton, NJ 08628.\nPlease refer to CPF 1-2018-1006M on each document you submit, and whenever possible provide\na signed PDF copy in electronic format. Smaller files may be emailed to robert.burrough@dot.gov.\nLarger files should be sent on a CD accompanied by the original paper copy to the Eastern Region\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,\nDIBu\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120181006M_NOA_02132018 (155769)\nPage 3 of 3","truncated":false,"body_characters":13387}