{"operation":"document","citation":"CPF 220161002W","title":"TRANSCONTINENTAL GAS PIPE LINE COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-09-02","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220161002w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220161002w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220161002w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220161002W","body":"Warning Letter involving TRANSCONTINENTAL GAS PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2016-09-02 and is reported as closed as of 2016-09-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220161002W_Warning Letter_09022016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220161002W/220161002W_Warning%20Letter_09022016.pdf\n\n220161002W_Warning Letter_09022016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220161002W/220161002W_Warning%20Letter_09022016_text.pdf\n\n220161002W_Warning Letter_09022016_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 2, 2016\nMs. Stephanie Timmermeyer\nVice President, Safety & Regulatory Compliance\nTranscontinental Pipeline Company\nWilliams Partners, L.P.\nOne Williams Center\nTulsa, OK 74172\nCPF 2-2016-1002W\nDear Ms. Timmermeyer:\nOn June 6-9, 2016, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your\nTranscontinental (Transco) pipeline facility in Alabama and Georgia.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violations are:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies. Each\noperator shall include the following in its operating and maintenance plan:\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response.\nTransco failed to meet the regulation because it did not follow its manual of written\nprocedures for conducting maintenance activities as follows:\n\n\n\n1. 2. Transco’s Operations & Maintenance Manual, Section 620.15, titled “Portable Gas\nDetection Equipment Calibration,” stated that Transco personnel are required to\n“…perform full calibration checks and maintenance according to the equipment\nmanufacturer’s instructions. Note: The schedule set forth in the manufacturer’s\ninstruction and full calibration tests of gas detection instruments are minimum\nrequirements. Perform functional tests before each use and perform full calibration\nanytime the accuracy of the instrument reading is questionable.”\nRecords reviewed by PHMSA personnel indicate that a model 46 Hawk leak detection\ndevice (Serial Number 07121224) was used to conduct a February 9, 2015 leak\nsurvey. Page 12 of the manufacture’s instruction manual for 46 Hawk leak detection\ninstrument provided the following instructions:\nNote: Provided response testing (bump test) is performed daily, calibration should\nbe performed monthly in a clean air environment.”\nThe “Specifications” section of the manufacturer’s instruction manual further stated:\nTests: Monthly Calibration testing with 1000 PPM Methane; Daily Response testing\nrecommended\nPHMSA review of records documenting calibration for the above-referenced 46 Hawk\ndevice (Transco form titled “WilSOP Instrument Maintenance Record”) indicates that\nTransco personnel did not perform the manufacturer-recommended daily response test\n(bump test) prior to conducting the above-referenced instrumented leak survey.\nMoreover, the date of calibration for the referenced device, as documented on\nTransco’s form titled “WilSOP Land Patrol Report” for the February 9, 2015\ninstrumented leak survey, was recorded as October 20, 2015, over 8 months after the\ndate of the instrumented leak survey.\nTransco’s Operations & Maintenance Manual, Section 620.15, titled “Portable Gas\nDetection Equipment Calibration,” required Transco personnel to “…before\nbeginning the calibration process, ensure the test gas has not expired as the test gas\nconcentration needs to be high enough to trigger the instrument alarm.”\nPer Transco records documenting the maintenance and calibration of the above-\nreferenced 46 Hawk leak detection device (Transco form titled “WilSOP Instrument\nMaintenance Record”), Transco personnel used expired calibration gas to conduct the\ndaily response test (bump test) for the above-referenced 46 Hawk device. The above-\nreferenced form documents that Gas Lot 2-335-66, with an expiration date of\nDecember 20, 2015, was used for several bump tests conducted from January 6 to\nJanuary 12, 2016.\n2\n\n\n\n3. Transco’s Operations & Maintenance Manual, Section 60.02.00.16, titled “Regulator\nand Overpressure Protection Systems,” stated in Part 2.1.3:\nIt is the policy of Williams to inspect and test each regulator, relief valve and other\noverpressure protection device, and high gas pressure shutdown device (electric or\npneumatic) used in natural gas service once each calendar year, not to exceed 15\nmonths.\nTransco did not inspect and test the overpressure protection (OPP) device at Magnolia\n(Station 100) once each calendar year, not to exceed 15 months. Transco’s Valve\nA350 at Magnolia (Station 100) was originally installed as a high-pressure shut-in\nvalve, with all the functionality/capability of an OPP device. Transco personnel were\nnot able to produce records to demonstrate that Valve A350 had been inspected as an\nOPP device, in accordance with its pressure protecting capabilities. Further, Transco\npersonnel stated that Valve A350 was not considered an OPP device prior to the\nPHMSA inspection, despite its capabilities as installed. Per subsequent discussions\nwith Transco personnel, it is PHMSA’s understanding that the subject Transco system\nis used only intermittently, and that, when in use, the upstream interconnecting\npipeline delivers coal seam gas at pressures lower than the Transco system’s\nmaximum allowable operating pressure. Transco effectively relied upon the\noperational characteristics of the upstream interconnecting pipeline to ensure its\nsystem was not over pressured.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$205,638 per violation per day the violation persists up to a maximum of $2,056,380 for a\nrelated series of violations. For violation occurring between January 4, 2012 to August 1,\n2016, the maximum penalty may not exceed $200,000 per violation per day, with a maximum\npenalty not to exceed $2,000,000 for a related series of violations. For violations occurring\nprior to January 4, 2012, the maximum penalty may not exceed $100,000 per violation per\nday, with a maximum penalty not to exceed $1,000,000 for a related series of violations. We\nhave reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at\nthis time. We advise you to correct the items identified in this letter. Failure to do so will\nresult in Transco being subject to additional enforcement action.\n3\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 2-2016-1002W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nJames A. Urisko\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n4","truncated":false,"body_characters":7679}