{"operation":"document","citation":"CPF 120183001M","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":"2018-03-26","effective_on":null,"summary":"CLOSED notice of amendment citing 193.2509(b)(2), 193.2605(b)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120183001m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120183001m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120183001m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120183001M","body":"Notice of Amendment involving TRANSCONTINENTAL GAS PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 193.2509(b)(2),  193.2605(b)(1). The case was opened on 2018-03-26 and is reported as closed as of 2019-02-12. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120183001M_Closure Letter_02122019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120183001M/120183001M_Closure%20Letter_02122019.pdf\n\n120183001M_Closure Letter_02122019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120183001M/120183001M_Closure%20Letter_02122019_text.pdf\n\n120183001M_Notice of Amendment_03262018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120183001M/120183001M_Notice%20of%20Amendment_03262018.pdf\n\n120183001M_Notice of Amendment_03262018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120183001M/120183001M_Notice%20of%20Amendment_03262018_text.pdf\n\n120183001M_Operator Response to Notice_04252018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120183001M/120183001M_Operator%20Response%20to%20Notice_04252018.pdf\n\n120183001M_Notice of Amendment_03262018_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nMarch 26, 2018\nMr. Mark Cluff\nVP Safety & Operational Discipline\nTranscontinental Gas Pipe Line Company\nOne Williams Center\nTulsa, OK 74172\nCPF 1-2018-3001M\nDear Mr. Cluff:\nFrom August 15 to 17, 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 (Williams) procedures for Station 240,\nCarlstadt LNG Facility in Carlstadt, NJ.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nWilliams’ plans or procedures, as described below:\n1. § 193.2509 Emergency Procedures.\n(b) To adequately handle each type of emergency identified under paragraph (a) of\nthis section and each fire emergency, each operator must follow one or more manuals\nof written procedures. The procedures must provide for the following:\n(2) Recognizing an uncontrollable emergency and taking action to minimize harm\nto the public and personnel, including prompt notification of appropriate local\nofficials of the emergency and possible need for evacuation of the public in the\nvicinity of the LNG plant.\nWilliams’ manual of written procedures was inadequate with regard to uncontrollable\nemergencies. Specifically, the manuals failed to include prescriptive procedures for recognizing\nan uncontrollable emergency and taking action to minimize harm to the public and personnel,\n\n\n\nCPF 1-2018-3001M\nincluding prompt notification of appropriate local officials of the emergency and possible need for\nevacuation of the public in the vicinity of the LNG plant.\nDuring the inspection, the PHMSA inspector reviewed the following Williams documents:\n Simulated Emergency Action, Station 240-LNG Plant (Plan),\n Procedure Manual, Sections 23 and 28, dated June 2015 (Manual),\n Operations and Maintenance Procedure (Procedure), Section A-8 Emergency Plans and\nPreparedness, dated October 2014.\nThe Plan, Manual, and Procedure failed to differentiate between a controllable and an\nuncontrollable emergency, while providing only cursory reference to notification of appropriate\nlocal officials and evacuation needs.\nTherefore, Williams’ Plan, Manual, and Procedure were inadequate, as they failed to include\nprescriptive procedures for recognizing an uncontrollable emergency and taking action as required\nby § 193.2509(b)(2).\n2. § 193.2605 Maintenance Procedures.\n(b) Each operator shall follow one or more manuals of written procedures for the\nmaintenance of each component, including any required corrosion control. The\nprocedure must include:\n(1) The details of the inspections or tests determined under paragraph (a) of this\nsection and their frequency of performance; and\nWilliams’ manual of written procedures was inadequate in that it failed to include details of the\ninspections or tests under paragraph (a) of § 193.2605 and the frequency of performance.\nSpecifically, Williams’ Operations and Maintenance Procedure (Procedure), Section B-3: Support\nSystems, dated May 2014 failed to: define criteria to evaluate the integrity of the support systems;\nprovide a rationale for the 5-year interval between inspections; and provide guidelines for the\nannual monitoring.\nDuring the inspection, the PHMSA inspector reviewed Williams’ Procedure, which stated in part:\nOnce every 5 years, a visual inspection will be made of all structural supports and foundations,\nincluding the LNG tank pile caps, at the LNG Plant.\n. . .\nSupport systems shall be monitored annually for changes. If changes are found, Operations\nTechnical Support (OTS) shall be notified for further review.\nThe Procedure failed to define criteria on the elements of its support systems. This included, but\nwas not limited to, defining degrees of deterioration, impact on the integrity of the support system,\nand assigning a timeframe to address each concern.\n120183001M_Notice of Amendment_03262018_text Page 2 of 4\n\n\n\nCPF 1-2018-3001M\nThe Procedure failed to provide a rationale for the 5-year interval between visual inspections of\nall structural supports and foundations. Per § 193.2605(a), periodic inspections are to be consistent\nwith generally accepted engineering practice.\nThe Procedure failed to provide guidelines for the annual monitoring of the support systems,\nincluding prescriptive details for performing the activity.\nTherefore, Williams’ Procedure failed to include details of the inspections or tests under paragraph\n(a) of § 193.2605 and the frequency of performance.\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 30 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 Williams 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, Director, PHMSA Eastern Region,\n820 Bear Tavern Road, Suite 103, West Trenton, NJ 08628. Please refer to CPF 1-2018-3001M\non each document you submit, and whenever possible provide a signed PDF copy in electronic\nformat. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should be sent on\na CD accompanied by the original paper copy to the Eastern Region Office.\n120183001M_Notice of Amendment_03262018_text Page 3 of 4\n\n\n\nCPF 1-2018-3001M\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\n120183001M_Notice of Amendment_03262018_text Page 4 of 4\n\n120183001M_Closure Letter_02122019_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nFebruary 12, 2019\nMr. Mark Cluff\nVP Safety & Operational Discipline\nTranscontinental Gas Pipe Line Company\nOne Williams Center\nTulsa, OK 74172\nCPF 1-2018-3001M\nDear Mr. Cluff:\nFrom August 15–17, 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 Williams – Transcontinental Gas Pipe Line Company’s (Williams)\nprocedures for Station 240, Carlstadt LNG Facility in Carlstadt, NJ. As a result of the inspection,\nWilliams was issued a Notice of Amendment on March 26, 2018, which proposed amendment of\nyour procedures.\nWilliams submitted its amended procedures on December 6, 2018. 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\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":9791}