{"operation":"document","citation":"CPF 12021014NOA","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":"2021-04-14","effective_on":null,"summary":"CLOSED notice of amendment citing 193.2503(c), 193.2605(b), 193.2717(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021014noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021014noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021014noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12021014NOA","body":"Notice of Amendment involving TRANSCONTINENTAL GAS PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 193.2503(c),  193.2605(b),  193.2717(b). The case was opened on 2021-04-14 and is reported as closed as of 2021-12-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12021014NOA_Closure Letter_12102021_(20-172062).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021014NOA/12021014NOA_Closure%20Letter_12102021_(20-172062).pdf\n\n12021014NOA_Closure Letter_12102021_(20-172062)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021014NOA/12021014NOA_Closure%20Letter_12102021_(20-172062)_text.pdf\n\n12021014NOA_Notice of Amendment_04142021_(20-172062).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021014NOA/12021014NOA_Notice%20of%20Amendment_04142021_(20-172062).pdf\n\n12021014NOA_Notice of Amendment_04142021_(20-172062)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021014NOA/12021014NOA_Notice%20of%20Amendment_04142021_(20-172062)_text.pdf\n\n12021014NOA_Operator Response to Notice_05132021_(20-172062).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021014NOA/12021014NOA_Operator%20Response%20to%20Notice_05132021_(20-172062).pdf\n\n12021014NOA_Notice of Amendment_04142021_(20-172062)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: Mark.Cluff@williams.com\nApril 14, 2021\nMr. Mark Cluff\nVP Safety & Operational Discipline\nTranscontinental Gas Pipeline Company\nOne Williams Center\nP.O. Box 645\nTulsa, OK 74172\nCPF 1-2021-014-NOA\nDear Mr. Cluff:\nFrom October 19, 2020 - November 4, 2020, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) inspected Transcontinental Gas Pipeline Company’s (Transco) procedures for its Station\n240 LNG plant in Carlstadt, New Jersey.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nTransco’s plans or procedures, as described below:\n1. § 193.2717 Training, fire protection.\n(a) …\n(b) A written plan of continuing instruction, including plant fire\ndrills, must be conducted at intervals of not more than 2 years to keep\npersonnel current on the knowledge and skills they gained in the\ninstruction under paragraph (a) of this section.\nTransco’s procedures for training were inadequate. Specifically, Transco’s 53.00.04.2-Emergency\nPlans and Preparedness Manual Review & Training and 53.00.04.1-Conduct Fire Drill (Fire\nProtection Procedures) failed to include details on fire protection training for operation,\nmaintenance, and supervisory personnel.\nDuring the inspection, the PHMSA inspector requested Transco’s procedures regarding refresher\n\n\n\nCPF 1-2021-014-NOA\nfire protection training for operation, maintenance, and supervisory personnel. Transco provided\nits Fire Protection Procedures which discuss emergency plans and fire drills. However, the written\nprocedures did not include provisions requiring operations, maintenance and supervisory\npersonnel to receive refresher fire protection training addressing the knowledge and skills\nrequirements in § 193.2717(a). The written procedures also failed to include provisions requiring\nplant fire drills.\nWhen the PHMSA inspector requested if there were additional procedures or guidance related to\nthe fire drill training requirement, Transco stated there was no such requirement in the Fire\nProtection Procedures.\nTherefore, Transco failed to include details on fire protection training for operation, maintenance,\nand supervisory personnel in accordance with § 193.2717(b). Transco must revise its procedures\nto include requirements for these personnel to participate in refresher fire protection training,\nincluding fire drills.\n2. § 193.2605 Maintenance procedures.\n(a) …\n(b) Each operator shall follow one or more manuals of written\nprocedures for the maintenance of each component, including any\nrequired corrosion control…\nTransco’s maintenance procedures were inadequate. Specifically, Transco’s 53.00.18- LNG Tank\nInspections (Tank Inspection Procedure) failed to provide details for inspecting or testing liquefied\nnatural gas storage tanks in accordance with § 193.2623(b).\nDuring the inspection, the PHMSA inspector requested Transco’s procedures regarding inspecting\nliquefied natural gas storage tanks, and Transco provided its Tank Inspection Procedure. Section\nC of the Tank Inspection Procedure discussed frequencies and limited details for performing\ncertain inspection or testing activities relative to foundation and tank movement, inner tank leakage\nand effectiveness of insulation. However, it lacked detailed procedures addressing how these\nliquefied natural gas storage tank inspections or tests are actually performed, particularly regarding\ninner tank leakage, frost heave, and effectiveness of insulation.\nWhen the PHMSA inspector requested if there were additional procedures or guidance related to\nliquefied natural gas storage tank inspection or tests, Transco was not able to provide any\nadditional information.\nTherefore, Transco failed to include details in its maintenance procedures of its process to inspect\nor test liquefied natural gas storage tanks in accordance with § 193.26231, as required by\n1 § 193.2623 Inspecting LNG storage tanks.\nEach LNG storage tank must be inspected or tested to verify that each of the following conditions does not impair\nthe structural integrity or safety of the tank:\n(a) Foundation and tank movement during normal operation and after a major meteorological or geophysical\ndisturbance.\n(b) Inner tank leakage.\n(c) Effectiveness of insulation.\n12021014NOA_Notice of Amendment_04142021_(20-172062)_text Page 2 of 5\n\n\n\nCPF 1-2021-014-NOA\n§ 193.2605(b). Transco must revise its Procedure to include details on its required inspections and\ntests.\n3. § 193.2605 Maintenance procedures.\n(a) …\n(b) Each operator shall follow one or more manuals of written\nprocedures for the maintenance of each component, including any\nrequired corrosion control…\nTransco’s maintenance procedures were inadequate. Specifically, Transco’s 07.47.501.OG\nAtmospheric Special Consideration Plan, dated 10/24/19 (SC AC Plan) failed to state the required\ninspection frequencies for atmospheric corrosion inspections, in accordance with § 193.2635(d)2\n.\nSection 193.2635(d) states that “Each component that is protected from atmospheric corrosion\nmust be inspected at intervals not exceeding 3 years.”\nDuring the inspection, the PHMSA inspector requested Transco’s procedure regarding inspecting\nfor atmospheric corrosion. Transco provided the following procedures:\n 07.47.501.OG Atmospheric Special Consideration Plan, dated 10/24/19\n 07.47.007-OG Onshore Atmospheric Corrosion Inspection, dated 01/02/20 (OG AC\nProcedure)\n 53.00.21- Corrosion – Atmospheric Inspection\n 07.47.50.28 Gas Pipes Atmospheric and Offshore Splash Zone Corrosion Inspections,\ndated 12/13/18\nTransco’s procedures were contradictory to one another in that they required different inspection\nfrequencies for the inspection of atmospheric corrosion. Specifically, the SC AC Plan discussed\na 9-year frequency for inspecting certain piping, while the OG AC Procedure specified a 3-year\ninterval for onshore LNG facilities. Additionally, the 9-year inspection frequency of Transco’s\nspecial consideration piping failed to meet the 3-year inspection interval requirement for\ncomponents protected from atmospheric corrosion.\nWhen the PHMSA inspector asked Transco about the 9-year inspection interval for special\nconsideration piping, Transco re-iterated that this piping was inspected per its procedure, at the\nrequired 9-year frequency.\nTherefore, Transco failed to state in its maintenance procedures the required inspection frequencies\nfor inspection of atmospheric corrosion in accordance with § 193.2635(d), as required by\n§ 193.2605(b). Transco must revise its maintenance procedures to require consistent frequencies\nfor atmospheric corrosion inspections at intervals complying with § 193.2635(d).\n(d) Frost heave.\n2 § 193.2635 Monitoring corrosion control.\n(a) …\nyears.\n(d) Each component that is protected from atmospheric corrosion must be inspected at intervals not exceeding 3\n12021014NOA_Notice of Amendment_04142021_(20-172062)_text Page 3 of 5\n\n\n\nCPF 1-2021-014-NOA\n4. § 193.2503 Operating procedures.\nEach operator shall follow one or more manuals of written\nprocedures to provide safety in normal operation and in responding\nto an abnormal operation that would affect safety. The procedures\nmust include provisions for:\n(a) …\n(c) Recognizing abnormal operating conditions.\nTransco’s operating procedures were inadequate. Specifically, Transco’s 53.00.03-Monitoring for\nHazardous Conditions and LNG Plant Procedures Manual Station 240, dated 11/27/18,\n(collectively, Procedures) failed to include details for recognizing abnormal operating conditions.\nDuring the inspection, the PHMSA inspector requested Transco’s procedures regarding abnormal\noperating conditions. Transco provided its Procedures which mention abnormal operation\nconditions. The Procedures discussed tank and vaporizer abnormal operating conditions.\nHowever, the Procedures did not provide guidance on how Transco personnel recognize abnormal\noperating conditions, nor do they define or list abnormal operating conditions that may exist at\nother portions of the LNG plant.\nWhen the PHMSA inspector requested if there were additional procedures or guidance related to\nabnormal operating conditions, Transco was not able to provide any additional information.\nTherefore, Transco failed to include details in its operating procedures for recognizing abnormal\noperating conditions in accordance with § 193.2503(c). Transco must amend its Procedures to\ninclude these details.\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 Enforcement\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. 552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 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\n12021014NOA_Notice of Amendment_04142021_(20-172062)_text Page 4 of 5\n\n\n\nCPF 1-2021-014-NOA\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 Transcontinental Gas Pipeline 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, Eastern Region, Pipeline and Hazardous Materials Safety Administration, 840 Bear\nTavern Road, Suite 300, West Trenton, NJ 08628. In correspondence concerning this matter,\nplease refer to CPF 1-2021-014-NOA and, for each document you submit, please provide a copy\nin electronic format whenever possible. Smaller files may be emailed to robert.burrough@dot.gov.\nLarger files should be sent on USB flash drive accompanied by the original paper copy to the\nEastern Region Office.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n12021014NOA_Notice of Amendment_04142021_(20-172062)_text Page 5 of 5\n\n12021014NOA_Closure Letter_12102021_(20-172062)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nDecember 10, 2021\nMr. Mark Cluff\nVice President, Safety & Operational Discipline\nTranscontinental Gas Pipeline Company, LLC\nOne Williams Center\nP.O. Box 645\nTulsa, OK 74172\nCPF 1-2021-014-NOA\nDear Mr. Cluff:\nFrom October 19, 2021 through November 4, 2021, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected Transcontinental Gas Pipeline Company’s (Transco) procedures for its Station 240 LNG\nplant in Carlstadt, New Jersey. As a result of the inspection, Transco was issued a Notice of\nAmendment (NOA) on April 14, 2021, which proposed amendment of your procedures. Transco\nrequested a 60-day time extension for its response on May 13, 2021. On May 20, 2021, PHMSA\ngranted this time extension for Transco to provide its written response by July 19, 2021. Transco\nsubmitted its amended procedures on July 16, 2021. On October 5, 2021 and November 5, 2021\nPHMSA held meetings to address its questions and concerns with Transco regarding the\ninadequacies identified in the amended procedures. Transco re-submitted its amended procedures\non November 11, 2021. My staff reviewed the amended procedures, and it appears that the\ninadequacies outlined in this Notice 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","truncated":false,"body_characters":14360}