# TRANSCONTINENTAL GAS PIPE LINE COMPANY — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 120183002
- **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:** 2018-03-28
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 193.2719(a)(2).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-120183002.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-120183002.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-120183002
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120183002
**body:**

Notice of Probable Violation involving TRANSCONTINENTAL GAS PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulation as 193.2719(a)(2). The case was opened on 2018-03-28 and is reported as closed as of 2019-03-27. Proposed civil penalty: $48,000. Assessed civil penalty: $48,000. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120183002_Final Order_03272019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120183002/120183002_Final%20Order_03272019.pdf

120183002_Final Order_03272019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120183002/120183002_Final%20Order_03272019_text.pdf

120183002_NOPV-PCP_03282018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120183002/120183002_NOPV-PCP_03282018.pdf

120183002_NOPV-PCP_03282018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120183002/120183002_NOPV-PCP_03282018_text.pdf

120183002_Operator Response to Notice_05012018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120183002/120183002_Operator%20Response%20to%20Notice_05012018.pdf

120183002_Final Order_03272019_text.pdf

March 27, 2019
Mr. Alan S. Armstrong
President and Chief Executive Officer
Williams Partners, LP
One Williams Center
Tulsa, OK 74172
Re: CPF No. 1-2018-3002
Dear Mr. Armstrong:
Enclosed please find the Final Order issued in the above-referenced case to your subsidiary,
Transcontinental Gas Pipe Line Company, LLC. It makes a finding of violation and assesses a
civil penalty of $48,000. This is to acknowledge receipt of payment of the full penalty amount,
by wire transfer, dated May 3, 2018. This enforcement action is now 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. Clint Ratke, Manager, Pipeline Safety, Williams Partners, LP
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 Pipeline Company, LLC, ) CPF No. 1-2018-3002
a subsidiary of Williams Partners, LP, )
)
)
)
Respondent. )
__________________________________________)
FINAL ORDER
From August 15 through August 17, 2017, pursuant to 49 U.S.C. § 60117, a representative of the
Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
(OPS), conducted an on-site pipeline safety inspection of the facilities and records of
Transcontinental Pipeline Gas Company’s (Transco or Respondent) Station 240, Carlstadt
Liquified Natural Gas facility in Carlstadt, New Jersey. Transco, a subsidiary of Williams
Partners, LP (Williams), operates approximately 10,200 miles of gas pipelines throughout the
United States.1
As a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Respondent,
by letter dated March 28, 2018, a Notice of Probable Violation and Proposed Civil Penalty
(Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Transco had
violated 49 C.F.R. § 193.2719, and proposed assessing a civil penalty of $48,000 for the alleged
violation.
Williams, on behalf of Transco, responded to the Notice by letter dated May 1, 2018 (Response).
The company did not contest the allegation of violation and paid the proposed civil penalty of
$48,000 by wire transfer dated May 3, 2018. In accordance with 49 C.F.R. § 190.208(a)(1), such
payment authorizes the Associate Administrator to make a finding of violation and issue this
final order.
FINDING OF VIOLATION
In its Response, Transco did not contest the allegation in the Notice that it violated 49 C.F.R.
Part 193, as follows:
1 Website available at https://co.williams.com/operations-2/atlantic-gulf-operating-area/transco/. (Current as of
October 2, 2018).



CPF No. 1-2018-3002
Page 2
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 193.2719(a)(2), which states:
§ 193.2719 Training: records.
(a) Each operator shall maintain a system of records which –
(1) …
(2) Provide evidence that personnel have undergone and satisfactorily
completed the required training programs.
The Notice alleged that Respondent violated 49 C.F.R. § 193.2719(a)(2) by failing to maintain
records which evidence that personnel had undergone and satisfactorily completed the required
training programs. Specifically, the Notice alleged that Transco could not present evidence that
it had provided continuing instruction to its liquified natural gas (LNG) plant operations and
maintenance personnel at intervals of not more than two years to keep them current on the
knowledge and skills gained as part of their initial training.2 According to the Notice, Transco
enrolls its staff in the Massachusetts Fire Fighting Academy to learn about the characteristics and
hazards of LNG, but could not provide records demonstrating compliance with the continuing
education requirement of § 193.2713(b).
Respondent did not contest this allegation of violation, and stated that it would take corrective
action to ensure training records were kept as required. Accordingly, based upon a review of all
the evidence, I find that Respondent violated 49 C.F.R. § 193.2719(a)(2) by failing to maintain
records which evidence that personnel had undergone and satisfactorily completed the required
training programs.
This finding of violation will be considered a prior offense in any subsequent enforcement action
taken against Respondent.
ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed
$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any
related series of violations.3 In determining the amount of a civil penalty under 49 U.S.C.
§ 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature,
circumstances, and gravity of the violation, including adverse impact on the environment; the
degree of Respondent’s culpability; the history of Respondent’s prior offenses; any effect that
the penalty may have on its ability to continue doing business; and the good faith of Respondent
in attempting to comply with the pipeline safety regulations. In addition, I may consider the
economic benefit gained from the violation without any reduction because of subsequent
damages, and such other matters as justice may require. The Notice proposed a total civil
2 Section 193.2713(b) requires operators to conduct continuing instruction at intervals of not more than two years to
keep all personnel current on the knowledge and skills they gained in the program of initial instruction.
3 These amounts are adjusted annually for inflation. See, e.g., Pipeline Safety: Inflation Adjustment of Maximum
Civil Penalties, 82 Fed. Reg. 19325 (April 27, 2017).



CPF No. 1-2018-3002
Page 3
penalty of $48,000 for the violation cited above.
Item 1: The Notice proposed a civil penalty of $48,000 for Respondent’s violation of 49 C.F.R.
§ 193.2719(a)(2), for failing to maintain records which evidence that personnel had undergone
and satisfactorily completed the required training programs. Transco neither contested the
allegation nor presented any evidence or argument justifying elimination of the proposed
penalty.
Accordingly, having reviewed the record and considered the assessment criteria, I assess
Respondent a civil penalty of $48,000 for violation of 49 C.F.R. § 193.2719(a)(2), which has
already been paid by wire transfer dated May 3, 2018.
The terms and conditions of this Final Order are effective upon service in accordance with 49
C.F.R. § 190.5.
March 27, 2019
___________________________________ __________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety
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