TRANSCONTINENTAL GAS PIPE LINE COMPANY — Notice of Probable Violation

party submissionOfficial PDF220171002_Operator Response to Notice_06162017.pdf#

220171002_Final Order_10312017_text.pdf, page 1Official PDFOctober 31, 2017 Mr. Alan S. Armstrong President and Chief Executive Officer Transcontinental Pipeline Company, LLC Williams Partners, LP One Williams Center Tulsa, OK 74172 Re: CPF No. 2-2017-1002 Dear Mr. Armstrong: Enclosed please find the Final Order issued in the above-referenced case. It makes findings of violation, assesses a civil penalty of $53,500, and specifies actions that need to be taken by Transcontinental Pipeline Company, LLC, a subsidiary of Williams Partners, LP, to comply with the pipeline safety regulations. This is to acknowledge receipt of payment of the full penalty amount, by wire transfer, dated July 19, 2017. When the terms of the compliance order are completed, as determined by the Director, Southern Region, this enforcement action will be 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. James A. Urisko, Director, Southern Region, Office of Pipeline Safety, PHMSA Mr. Mark Cluff, Vice President, Safety and Operational Discipline, Williams Partners, LP, 2800 Post Oak Boulevard, Houston, Texas 77056#

220171002_Final Order_10312017_text.pdf, page 2U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 _____________________________________ In the Matter of ) Transcontinental Pipeline Company, LLC, ) CPF No. 2-2017-1002 a subsidiary of Williams Partners, LP, ) ) ) ) Respondent. ) _____________________________________ ) FINAL ORDER From October 24 through November 17, 2016, pursuant to 49 U.S.C. § 60117, representatives 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 Company, LLC (Transco or Respondent), in Mississippi, Georgia, and South Carolina. Transco, a subsidiary of Williams Partners, LP (Williams), operates approximately 10,200 miles of gas pipelines in the United States.1 As a result of the inspection, the Director, Southern Region, OPS (Director), issued to Respondent, by letter dated May 12, 2017, a Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Transco had committed a violation of 49 C.F.R. § 191.5(a) and proposed assessing a civil penalty of $53,500 for the alleged violation. The Notice also proposed finding that Transco had committed a violation of 49 C.F.R. § 192.475(a) and proposed ordering Respondent to take certain measures to correct the alleged violation. Finally, the Notice alleged two probable violations and, pursuant to § 190.205, warned the operator to correct them or face possible enforcement action. Williams, on behalf of Transco, responded to the Notice by letter dated June 16, 2017 (Response). The company did not contest the allegations of violation and subsequently paid the proposed civil penalty of $53,500 by wire transfer on July 19, 2017. In accordance with 49 C.F.R. § 190.208(a)(1), such payment authorizes the Associate Administrator to make findings of violation and to issue this final order. 1 Transco website, available at http://co.williams.com/gulf coast/transco/ (last accessed August 30, 2017).#

220171002_Final Order_10312017_text.pdf, page 3CPF No. 2-2017-1002 Page 2 FINDINGS OF VIOLATION In its Response, Williams, on behalf of Transco, did not contest the allegations in the Notice that Transco violated 49 C.F.R. Parts 191 and 192, as follows: Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 191.5(a), which states: § 191.5 Immediate notice of certain incidents. (a) At the earliest practicable moment following discovery, but no later than one hour after confirmed discovery, each operator must give notice in accordance with paragraph (b) of this section of each incident as defined in § 191.3. The Notice alleged that Respondent violated 49 C.F.R. § 191.5(a) by failing to give notice of an incident at the earliest practicable moment following discovery, but no later than one hour after confirmed discovery.2 Specifically, the Notice alleged that Transco failed to notify the National Response Center of the unintentional release of natural gas exceeding 3 million cubic feet that occurred on August 11, 2016.3 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. § 191.5(a) by failing to give notice of an incident at the earliest practicable moment following discovery, but no later than one hour after confirmed discovery. Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 192.475(a), which states: § 192.475 Internal corrosion control: General. (a) Corrosive gas may not be transported by pipeline, unless the corrosive effect of the gas on the pipeline has been investigated and steps have been taken to minimize internal corrosion. The Notice alleged that Respondent violated 49 C.F.R. § 192.475(a) by failing to investigate the effect of corrosive gas on the pipeline and failing to take steps to minimize internal corrosion. Specifically, the Notice alleged that Transco operates a natural gas storage field at Station 77 in Seminary, Mississippi, but did not investigate the corrosive effects of the gas being transported between the storage caverns and dehydration plants, or take any steps necessary to minimize internal corrosion of any pipelines within these storage fields. Respondent did not contest this allegation of violation. Accordingly, based upon a review of all 2 49 C.F.R. § 191.3(1)(iii) defines the term “Incident” to include the “[u]nintentional estimated gas loss of three million cubic feet or more.” 3 On August 11, 2016, a relief valve at the Clarke County Exchange facility unintentionally released an estimated 3.2 million cubic feet of natural gas.#

220171002_Final Order_10312017_text.pdf, page 4CPF No. 2-2017-1002 Page 3 of the evidence, I find that Respondent violated 49 C.F.R. § 192.475(a) by failing to investigate the effect of corrosive gas on the pipeline and failing to take steps to minimize internal corrosion. These findings of violation will be considered prior offenses 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.4 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; and 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 penalty of $53,500 for Item 1. Item 1: The Notice proposed a civil penalty of $53,500 for Respondent’s violation of 49 C.F.R. § 191.5(a), for failing to give notice, at the earliest practicable moment following discovery but no later than one hour after confirmed discovery, of an incident. Transco neither contested the allegation nor the proposed penalty amount. Accordingly, Respondent is assessed a civil penalty of $53,500 for violation of §191.5(a), which has already been paid by wire transfer on July 19, 2017. COMPLIANCE ORDER The Notice proposed a compliance order with respect to Item 2 in the Notice for violation of 49 C.F.R. § 192.475(a). Under 49 U.S.C. § 60118(a), each person who engages in the transportation of gas or who owns or operates a pipeline facility is required to comply with the applicable safety standards established under chapter 601. Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following actions to ensure compliance with the pipeline safety regulations applicable to its operations: 1. With respect to the violation of § 192.475(a) (Item 2), Respondent must: a. Investigate the corrosive effects of gas on the pipelines between the dehydration plants and the storage caverns at Station 77 within 30 days of receipt of the Final Order; 4 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).#

220171002_Final Order_10312017_text.pdf, page 5CPF No. 2-2017-1002 Page 4 b. c. Determine what steps, if any, are necessary to minimize internal corrosion on the pipelines between the compressor station and the storage caverns or storage field piping based on its investigation of the corrosive effects of the gas in Item 1(a) above within 60 days of receipt of this Final Order, and implement them within 120 days of receipt of the Final Order; and Submit to the Director, Southern Region, OPS, PHMSA, documentation demonstrating satisfactory completion of Items 1(a) and 1(b) above within 150 days of receipt of the Final Order. It is requested, but not mandated, that Transco maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to the Director, Southern Region, OPS, PHMSA. It is further requested that these costs be reported in two categories: (1) total cost associated with preparation/revision of plans, procedures, studies and analyses; and (2) total cost associated with replacements, additions, and other changes to pipeline infrastructure. The Director may grant an extension of time to comply with any of the required items upon a written request timely submitted by the Respondent and demonstrating good cause for an extension. Failure to comply with this Order may result in the administrative assessment of civil penalties not to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), for each violation for each day the violation continues or in referral to the Attorney General for appropriate relief in a district court of the United States. WARNING ITEMS With respect to Items 3 and 4, the Notice alleged probable violations of Part 192 but did not propose a civil penalty or compliance order for these items. Therefore, these are considered to be warning items. The warnings were for: 49 C.F.R. § 192.605(a) (Item 3) ─ Respondent’s alleged failure to follow its own manual of written procedures for conducting maintenance activities by not following Section 60.02.02 of Transco’s Operation & Maintenance Manual for completing Form WGP 0132C WilSOP Control Valve Inspection Report; and 49 C.F.R. § 192.605(a) (Item 4) ─ Respondent’s alleged failure to follow its manual of written procedures for conducting maintenance activities by not securing the block valve and bypass valves at Valve Site SN-20 to prevent accidental or unauthorized operation.5 5 In an email dated June 22, 2017, Respondent provided evidence to PHMSA that the control box on the SN-20 lateral block valve was locked at the time of the PHMSA inspection.#

220171002_Final Order_10312017_text.pdf, page 6CPF No. 2-2017-1002 Page 5 If OPS finds a violation of any of these items in a subsequent inspection, Respondent may be subject to future enforcement action. The terms and conditions of this Final Order are effective upon service in accordance with 49 C.F.R. § 190.5. October 31, 2017 ___________________________________ __________________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety#

220171002_Closure Letter_01232018_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED January 23, 2018 Mr. Alan S. Armstrong President and Chief Executive Officer Transcontinental Pipeline Company, LLC Williams Partners, LP One Williams Center Tulsa, OK 74172 CPF 2-2017-1002 Dear Mr. Armstrong: From October 24 through November 17, 2016, pursuant to 49 U.S.C. § 60117, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), conducted on-site pipeline safety inspections of the facilities and records of Transcontinental Pipeline Company, LLC (Transco), in Mississippi, Georgia, and South Carolina. As a result of the inspections, OPS issued Transco a Final Order with a Civil Penalty and Compliance Order (CO) on October 31, 2017. The CO required Transco to undertake certain actions to ensure compliance with the federal pipeline safety regulations. Transco paid the Civil Penalty on July 19, 2017, and OPS Southern received documentation on January 18, 2018, confirming that the CO Items have been completed. Based upon payment of the Civil Penalty and our review of the actions taken by Transco (as well as the supporting documentation), we have determined that Transco has complied with the terms of the CO and the Final Order. This case is now closed and no further action is necessary with respect to the matters involved in this case. Please be advised that this letter refers only to the referenced order (CPF 2-2017-1002) and not to any other PHMSA cases, if any. Sincerely, James A. Urisko Director, Office of Pipeline Safety PHMSA Southern Region#

220171002_NOPV PCP PCO_05122017_text.pdf, page 1Official PDFNOTICE OF PROBABLE VIOLATION PROPOSED CIVIL PENALTY and PROPOSED COMPLIANCE ORDER CERTIFIED MAIL - RETURN RECEIPT REQUESTED May 12, 2017 Mr. Alan S. Armstrong President and Chief Executive Officer Transcontinental Pipeline Company Williams Partners, L.P. One Williams Center Tulsa, OK 74172 CPF 2-2017-1002 Dear Mr. Armstrong: From October 24 to November 17, 2016, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety, inspected Transcontinental Pipeline Company (Transco) facilities in Mississippi, Georgia, and South Carolina, pursuant to Chapter 601 of 49 United States Code. As a result of the inspections, it is alleged that Transco has committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable violations are: 1. § 191.5 Immediate notice of certain incidents. (a) At the earliest practicable moment following discovery, but no later than one hour after confirmed discovery, each operator must give notice in accordance with paragraph (b) of this section of each incident as defined in §191.3. Transco failed to give notice in accordance with §191.5(b) at the earliest practicable moment following the discovery of an incident, as defined in §191.3. Specifically, Transco failed to notify the National Response Center (NRC) of the unintentional release of natural gas exceeding three million cubic feet that occurred on August 11, 2016.#

220171002_NOPV PCP PCO_05122017_text.pdf, page 22. 3. Transco records documented that on August 11, 2016, a relief valve at the Clarke County Exchange facility released an estimated 3.2 million cubic feet of natural gas. At the time of the release, the pressure at the referenced relief valve was approximately 770 psig. The set point of the relief valve was 800 psig, per Transco records documenting the valve’s previous inspection. Under normal operations, a relief valve with a set point of 800 psig would not be expected to relieve at 770 psig, and any activation under such conditions would be considered unintentional. Part §191.3 of the Code of Federal Regulations defines an incident, in part, as an event with “unintentional estimated gas loss of three million cubic feet or more from a pipeline.” §191.5(a) required Transco to give notice in accordance with §191.5(b) at the earliest practicable moment following discovery of the incident. Records documenting the release volume and the relief device set point were obtained by the PHMSA inspector. § 192.475 Internal corrosion control: General. (a) Corrosive gas may not be transported by pipeline, unless the corrosive effect of the gas on the pipeline has been investigated and steps have been taken to minimize internal corrosion. Transco transported gas in its storage field pipelines at Station 77 in Seminary, Mississippi, but did not investigate the corrosive effects of the gas it transported nor did Transco determine if steps were necessary to minimize internal corrosion. Transco operates a natural gas storage field at Station 77 but it did not investigate the corrosive effects of the gas being transported between the storage caverns and onsite dehydration plants (DHPs). Further, Transco did not identify any steps necessary to minimize internal corrosion of any pipelines within the above-referenced storage fields. § 192.605 Procedural manual for operations, maintenance and emergencies. (a) General. Each operator shall prepare and follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. Transco did not follow its manual of written procedures for conducting maintenance activities. Specifically, Transco personnel did not follow established procedure for completing Form WGP 0132C, titled WilSOP Control Valve Inspection Report, as required by Section 60.02.02 of Transco’s Operation & Maintenance Manual. Section 60.02.02 of Transco’s Operation & Maintenance Manual, titled Operating and Maintaining Gas Overpressure Protection Devices, required Transco personnel to: “Record observations, test calibration, and repair results on form WGP 0132A, titled WilSOP Control Valve Inspection Report, or form WGP 0132C, titled WilSOP Relief Valve Inspection Report, as appropriate. See the Forms Matrix for distribution list of completed forms.” 2#

220171002_NOPV PCP PCO_05122017_text.pdf, page 34. Transco Form WGP-0132C, referenced above, included a line for denoting whether the as found set point of the subject relief device “drifted” in excess of 3% of the previously recorded set point, “indicating a failure.” This data field was annotated with a “*” which provided direction that “if the set point drift exceeds manufacture’s recommendations, indicating a failure, check the equipment failure box and document how the set point drift is corrected.” During the inspection, the PHMSA inspector reviewed documentation of the inspection of the main relief valves for Compressor Units #2, #3, #6, and #10. These inspections were documented on the above-referenced Transco Form WGP-0132C. On each respective form, the response recorded for the data field “*Does set point drift exceed 3%, indicating a failure?” was “YES.” While Transco documented that the drifted set points were corrected, it did not document how they were corrected, as required by the above-referenced form. § 192.605 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. For transmission lines, the manual must also include procedures for handling abnormal operations. This manual must be reviewed and updated by the operator at intervals not exceeding 15 months, but at least once each calendar year. This manual must be prepared before operations of a pipeline system commence. Appropriate parts of the manual must be kept at locations where operations and maintenance activities are conducted. Transco did not follow its manual of written operations and maintenance procedures with regards to securing the block valve and bypass valves at Valve Site SN-20 to prevent accidental or unauthorized operation. Valve Site SN-20 on Transco’s Tryon Lateral consists of lateral block valve SN-20, as well as bypass valves B1 and B2 (following Transco’s naming convention). Each of the valves is designated as a “critical” or “DOT Emergency Valve,” per Transco Policy 70.16.00.08, titled DOT Valve Maintenance. The valves are confirmed as such in supporting inspection documentation as well. Section 5.2 of Transco Procedure 07.10.322-PMR, titled Valve Inspection and Maintenance (Revision Date 07/15/2016), required that “critical valves must be secured in their normal operating position.” At the time of PHMSA’s inspection, the Valve Site SN-20 bypass valves B1 and B2 had no locking device to secure them in their normal operating position. Furthermore, Section 8.21 (of the same procedure), titled Automatic Valve Actuation Equipment, requires authorized personnel to “remove or lock out control valve handles to prevent accidental operation of the valves.” At the time of PHMSA’s inspection, the SN-20 lateral block valve actuator control handles were not removed or locked out. PHMSA personnel photographed each of the three unsecured valves. It should be noted that Valve Site SN-20 was not protected by a fenced enclosure, or otherwise secured from unauthorized tampering. 3#

220171002_NOPV PCP PCO_05122017_text.pdf, page 4Proposed Civil Penalty Under 49 United States Code, § 60122, Transco is subject to a civil penalty not to exceed $209,002 per violation per day the violation persists up to a maximum of $2,090,022 for a related series of violations. For violations occurring between August 2, 2016 to April 27, 2017, the maximum penalty may not exceed $205,638 per violation per day, with a maximum penalty not to exceed $2,056,380 for a related serious of violations. For violations occurring between January 4, 2012 to August 1, 2016, the maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000 for a related series of violations. For violations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per violation per day, with maximum penalty not to exceed $1,000,000 for related series of violations. The Compliance Officer has reviewed the circumstances and supporting documentation involved in the above probable violation and has recommended that Transco be preliminarily assessed a civil penalty of $53,500 for Item 1 above. Proposed Compliance Order With respect to Item 2, pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration proposes to issue a Compliance Order to Transcontinental Pipeline Company. Please refer to the Proposed Compliance Order, which is enclosed and made a part of this Notice. Warning Items With respect to Items 3 and 4, we have reviewed the circumstances and supporting documents involved in this case and have decided not to conduct additional enforcement action or penalty assessment proceedings at this time. We advise Transco to promptly correct these items. Failure to do so may result in additional enforcement action. Response to this Notice Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings. Please refer to this document and note the response options. All material submit in response to this enforcement action may be made publicly available. If you believe that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original document you must provide a second copy of the document with the portions you believe qualify for confidential treatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue a Final Order. 4#

220171002_NOPV PCP PCO_05122017_text.pdf, page 5In your correspondence on this matter, please refer to CPF 2-2017-1002 and for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, James A. Urisko Director, Office of Pipeline Safety PHMSA Southern Region Enclosures: Proposed Compliance Order Response Options for Pipeline Operators in Compliance Proceedings 5#

220171002_NOPV PCP PCO_05122017_text.pdf, page 6PROPOSED COMPLIANCE ORDER Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposes to issue to Transcontinental Gas Pipeline Company, LLC (Transco) a Compliance Order incorporating the following remedial requirements to ensure the compliance of Transco with the pipeline safety regulations: 1. 2. 3. 4. In regard to Item 2 of the Notice pertaining to Transco’s failure to investigate the corrosive effects of gas on its pipeline and determine steps necessary to minimize internal corrosion at Station 77, a. Transco must investigate the corrosive effects of gas on the pipelines between the dehydration plants (DHPs) and the storage caverns at Station 77. b. Transco must determine what steps are necessary, if any, to minimize internal corrosion on the pipelines between the compressor station and the storage caverns or storage field piping based on its investigation of the corrosive effects of the gas in Item 1a above. c. Transco must implement the steps that are determined to be necessary, if any, to minimize internal corrosion on the pipelines between the DHPs and the caverns in Item 1b. Transco must complete the above Items within the following time requirements. a. Within 30 days of issuance of the Final Order, Transco must complete the requirements of Item 1a above. b. Within 60 days of issuance of the Final Order, Transco must complete the requirements of Item 1b above. c. Within 120 days of issuance of the Final Order, Transco must complete the requirements of Item 1c above. Within 150 days of issuance of the Final Order, Transco must submit to the Director, Office of Pipeline Safety, PHMSA Southern Region, documentation demonstrating satisfactory completion of Item 1 above. It is requested (not mandated) that Transco maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to the Director, Office of Pipeline Safety, PHMSA Southern Region. It is requested that these costs be reported in two categories: 1) total cost associated with preparation/revision of plans, procedures, studies and analyses, and 2) total cost associated with replacements, additions and other changes to pipeline infrastructure. 6#