# TRANSCONTINENTAL GAS PIPE LINE COMPANY — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 12021013NOPV
- **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:** 2021-06-17
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 193.2521, 193.2605(b).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/12021013NOPV
**body:**

Notice of Probable Violation involving TRANSCONTINENTAL GAS PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 193.2521,  193.2605(b). The case was opened on 2021-06-17 and is reported as closed as of 2021-12-15. Proposed civil penalty: $93,900. Assessed civil penalty: $41,000. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

12021013NOPV_Final Order_12012021_(20-172062).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021013NOPV/12021013NOPV_Final%20Order_12012021_(20-172062).pdf

12021013NOPV_Final Order_12012021_(20-172062)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021013NOPV/12021013NOPV_Final%20Order_12012021_(20-172062)_text.pdf

12021013NOPV_Operator Response to Notice_09302021_(20-172062).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021013NOPV/12021013NOPV_Operator%20Response%20to%20Notice_09302021_(20-172062).pdf

12021013NOPV_PCP_06172021_(20-172062).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021013NOPV/12021013NOPV_PCP_06172021_(20-172062).pdf

12021013NOPV_PCP_06172021_(20-172062)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021013NOPV/12021013NOPV_PCP_06172021_(20-172062)_text.pdf

12021013NOPV_Final Order_12012021_(20-172062)_text.pdf

December 1, 2021
VIA ELECTRONIC MAIL TO: mark.cluff@williams.com
Mr. Mark Cluff
Vice President, Safety & Operational Discipline
Transcontinental Gas Pipe Line Company, LLC
One Williams Center
P.O. Box 645
Tulsa, Oklahoma 74172
Re: CPF No. 1-2021-013-NOPV
Dear Mr. Cluff:
Enclosed please find the Final Order issued in the above-referenced case. It makes a finding of
violation and assesses a civil penalty of $41,000. The penalty payment terms are set forth in the
Final Order. This enforcement action closes automatically upon receipt of payment. Service of
the Final Order by e-mail is effective upon the date of transmission 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
Enclosures
cc: Mr. Robert Burrough, Director, Eastern Region, Office of Pipeline Safety, PHMSA
Mr. Alan Armstrong, President and Chief Executive Officer, Williams Partners, LP,
alan.armstrong@williams.com
Mr. Tyson Green, Manager Pipeline Safety, Williams Partners, LP,
tyson.green@williams.com
CONFIRMATION OF 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 Pipe Line Company, LLC, a subsidiary of Williams Partners, LP, )
)
Respondent. )
____________________________________________)
) CPF No. 1-2021-013-NOPV
FINAL ORDER
From October 19, 2020 through November 4, 2020, 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 inspection of the procedures and records of
Transcontinental Gas Pipe Line Company, LLC’s (Transco or Respondent) Station 240 LNG
plant in Carlstadt, New Jersey. Transco, a subsidiary of Williams Partners, LP (Williams),
operates a 10,000-mile interstate transmission pipeline system from south Texas to New York
City.1
As a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Respondent,
by letter dated June 17, 2021, 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. 2605 and proposed assessing a civil penalty of $93,900 for the alleged
violation. The Notice also included an additional warning item pursuant to 49 C.F.R. § 190.205,
which required no further action, but warned the operator to correct the probable violation or
face possible future enforcement action.
On June 25, 2021, Williams, on behalf of Transco, requested the Pipeline Safety Violation
Report and the Proposed Civil Penalty Worksheet, which PHMSA provided on July 1, 2021. On
July 16, 2021, Williams requested an extension of time to respond to the Notice, which PHMSA
granted on July 22, 2021. On August 19, 2021, Williams and OPS Eastern Region (collectively,
the Parties) met telephonically to discuss a possible resolution of the case. During the informal
conference and subsequent follow-up discussions, the Parties offered additional information
regarding the allegation of violation, and an agreement was reached that resolved all of the issues
in the Notice.
1 Williams website, Operations, available at https://www.williams.com/pipeline/transco/ (last accessed November
10, 2021).



CPF No. 1-2021-013-NOPV
Page 2
On September 14, 2021, Williams requested a 30-day time extension to respond to the Notice
and responded to the Notice by letter dated September 30, 2021 (Response). The company did
not contest the allegation of violation but provided additional information and requested that the
proposed civil penalty be reduced. Respondent did not request a hearing and therefore has
waived its right to one.
FINDINGS 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:
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 193.2605, which states:
§ 193.2605 Maintenance procedures.
(a) …
(b) Each operator shall follow one or more manuals of written
procedures for the maintenance of each component, including any required
corrosion control…
The Notice alleged that Respondent violated 49 C.F.R. § 193.2605 by failing to follow its
manual of written procedures for the inspection of support systems. Specifically, the Notice
alleged that Transco failed to follow its 53.00.08 - Inspect Structural Support Systems
(Procedure) for conducting the 5-Year visual inspection of structural supports and foundations at
the LNG Plant.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 193.2605 by failing to follow its
manual of written procedures for the inspection of support systems.
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.2
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
2 These amounts are adjusted annually for inflation. See 49 C.F.R. § 190.223.



CPF No. 1-2021-013-NOPV
Page 3
doing business; the good faith of Respondent in attempting to comply with the pipeline safety
regulations; and self-disclosure or actions to correct a violation prior to discovery by PHMSA.
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 penalty of $93,900 for the violation cited above.
Item 2: The Notice proposed a civil penalty of $93,900 for Respondent’s violation of 49 C.F.R.
§ 193.2605, for failing to follow its manual of written procedures for the inspection of support
systems. Williams provided a written explanation for an adjusted civil penalty amount in its
Response. Specifically, the company noted that during the informal settlement meeting, OPS
agreed that the civil penalty assessment factor for the gravity of the violation should be adjusted
from “the violation is against 49 C.F.R. Part 193” to “pipeline safety was minimally affected.”
Although Item 2 was a Part 193 violation, pipeline safety was minimally affected.3 In 2018, the
company completed a visual inspection of the structural supports and foundations of its LNG
Plant. The subsequent report titled “Year 2018 Station 240 Concrete Support Inspection Report,
dated 12/18/18” (Report) indicated that the concrete supports were found to need minor repairs
but were otherwise structurally sound and presented no immediate safety or operational issues.
However, the Report mistakenly omitted the prioritization of the conditions, as required by the
Procedure. This omission minimally impacted pipeline safety. Based upon the foregoing, I
assess Respondent a reduced civil penalty of $41,000 for violation of 49 C.F.R. § 193.2605.
Payment of the civil penalty must be made within 20 days of service. Federal regulations (49
C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer through the Federal
Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed
instructions are contained in the enclosure. Questions concerning wire transfers should be
directed to: Financial Operations Division (AMK-325), Federal Aviation Administration, Mike
Monroney Aeronautical Center, 6500 S MacArthur Blvd, Oklahoma City, Oklahoma 79169.
The Financial Operations Division telephone number is (405) 954-8845.
Failure to pay the $41,000 civil penalty will result in accrual of interest at the current annual rate
in accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to
those same authorities, a late penalty charge of six percent (6%) per annum will be charged if
payment is not made within 110 days of service. Furthermore, failure to pay the civil penalty
may result in referral of the matter to the Attorney General for appropriate action in a district
court of the United States.
WARNING ITEM
With respect to Item 1, the Notice alleged probable violation of Part 193, but identified it as a
warning item pursuant to § 190.205. The warning was for:
3 See Pipeline Safety Violation Report (Violation Report), June 17, 2021 (on file with PHMSA) at 9 (instructing OPS
to “[s]elect the most severe category that applies to any of the instances of the violation - except select Category 5
regardless of the location if pipeline safety was minimally affected by all instances of the violation.”).



CPF No. 1-2021-013-NOPV
Page 4
49 C.F.R. § 193.2521 (Item 1) ─ Respondent’s alleged failure to maintain records
that personnel responded to indications of abnormal operations.
If OPS finds a violation of this provision in a subsequent inspection, Respondent may be subject
to future enforcement action.
Under 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this Final
Order to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey
Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of
Chief Counsel, PHMSA, at the same address, no later than 20 days after receipt of service of the
Final Order by Respondent. Any petition submitted must contain a brief statement of the issue(s)
and meet all other requirements of 49 C.F.R. § 190.243. The filing of a petition automatically
stays the payment of any civil penalty assessed. The other terms of the order, including any
corrective action, remain in effect unless the Associate Administrator, upon request, grants a
stay. If Respondent submits payment of the civil penalty, the Final Order becomes the final
administrative decision and the right to petition for reconsideration is waived.
The terms and conditions of this Final Order are effective upon service in accordance with 49
C.F.R. § 190.5.
December 1, 2021
___________________________________ __________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety
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