{"operation":"document","citation":"CPF 120191011W","title":"TRANSCONTINENTAL GAS PIPE LINE COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-07-22","effective_on":null,"summary":"CLOSED warning letter citing 192.303.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120191011w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120191011w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120191011w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120191011W","body":"Warning Letter involving TRANSCONTINENTAL GAS PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulation as 192.303. The case was opened on 2019-07-22 and is reported as closed as of 2019-07-22. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120191011W_Operator Response to Notice_02032020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191011W/120191011W_Operator%20Response%20to%20Notice_02032020.pdf\n\n120191011W_Warning Letter_07222019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191011W/120191011W_Warning%20Letter_07222019.pdf\n\n120191011W_Warning Letter_07222019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191011W/120191011W_Warning%20Letter_07222019_text.pdf\n\n120191011W_Warning Letter_07222019_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nJuly 22, 2019\nMr. Mark Cluff\nVP Safety & Operational Discipline\nTranscontinental Gas Pipe Line Company\nOne Williams Center, PO Box 645\nTulsa, OK 74172\nCPF 1-2019-1011W\nDear Mr. Cluff:\nFrom May 16-17, 2017, June 26-27, 2017, and May 9-10, 2018, a representative of the Pipeline\nand Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.) inspected Transcontinental Gas Pipe Line Company’s (Transco) Garden\nState Expansion Project in Princeton, New Jersey.\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 are:\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.\nTransco failed to follow its comprehensive written specifications or standards consistent with Part\n192 for constructing transmission lines. Specifically, Transco failed to document nondestructive\ntesting of welds in accordance with its WilSOP Weld Inspection Film Reports instructions,\ndeveloped to comply with § 192.243(f).\n\n\n\nCPF 1-2019-1011W\nSection 192.243(f) states:\n(f) When nondestructive testing is required under § 192.241(b), each operator must\nretain, for the life of the pipeline, a record showing by milepost, engineering station, or\nby geographic feature, the number of girth welds made, the number nondestructively\ntested, the number rejected, and the disposition of the rejects.\nDuring the inspection, the PHMSA inspector reviewed WilSOP Weld Inspection Film Reports\n(Job Description/Project Name/Purpose of Inspection: Garden State Exp M/S; Inspection Dates:\n9-19-16, 9-20-16, 12-13-16; W.O.:1165551) as evidence of nondestructive test records for\npipeline segments on the Garden State Expansion Project in New Jersey. The records appeared to\nnot be documented to Transco’s WilSOP requirements. The Defect Legend and Grading Scale\nannotations templated in the WilSOP Weld Inspection Film Reports required Grading Scale\nannotations as follows: 1 (small/minor), 2 (moderate/borderline) or 3 (excessive/reject).\nHowever, the records reviewed were marked with a check mark for welding defects and not a 1,\n2 or 3, as was required.\nTherefore, Transco failed to document its nondestructive testing in accordance with its WilSOP\nWeld Inspection Film Report instructions, developed to comply with § 192.243(f).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$213,268 per violation per day the violation persists, up to a maximum of $2,132,679 for a related\nseries of violations. For violation occurring on or after November 2, 2015 and before November\n27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum\npenalty not to exceed $2,090,022. For violations occurring prior to November 2, 2015, the\nmaximum penalty may not exceed $200,000 per violation per day, with a maximum penalty not to\nexceed $2,000,000 for a related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct the\nitem(s) identified in this letter. Failure to do so will result in Transcontinental Gas Pipe Line\nCompany being subject to additional enforcement 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).\n120191011W_Warning Letter_07222019_text Page 2 of 3\n\n\n\nCPF 1-2019-1011W\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, 840 Bear Tavern Road, Suite 300,\nWest Trenton, NJ 08628. Please refer to CPF 1-2019-1011W 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 USB flash drive accompanied by the\noriginal paper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120191011W_Warning Letter_07222019_text Page 3 of 3","truncated":false,"body_characters":5732}