{"operation":"document","citation":"CPF 220171002","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":"2017-05-12","effective_on":null,"summary":"CLOSED notice of probable violation citing 191.5(a), 192.475(a), 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220171002.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220171002.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220171002","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220171002","body":"Notice of Probable Violation involving TRANSCONTINENTAL GAS PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 191.5(a),  192.475(a),  192.605(a). The case was opened on 2017-05-12 and is reported as closed as of 2018-01-23. Proposed civil penalty: $53,500. Assessed civil penalty: $53,500. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220171002_Closure Letter_01232018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220171002/220171002_Closure%20Letter_01232018.pdf\n\n220171002_Closure Letter_01232018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220171002/220171002_Closure%20Letter_01232018_text.pdf\n\n220171002_Final Order_10312017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220171002/220171002_Final%20Order_10312017.pdf\n\n220171002_Final Order_10312017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220171002/220171002_Final%20Order_10312017_text.pdf\n\n220171002_NOPV PCP PCO_05122017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220171002/220171002_NOPV%20PCP%20PCO_05122017.pdf\n\n220171002_NOPV PCP PCO_05122017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220171002/220171002_NOPV%20PCP%20PCO_05122017_text.pdf\n\n220171002_Operator Response to Notice_06162017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220171002/220171002_Operator%20Response%20to%20Notice_06162017.pdf\n\n220171002_Final Order_10312017_text.pdf\n\nOctober 31, 2017\nMr. Alan S. Armstrong\nPresident and Chief Executive Officer\nTranscontinental Pipeline Company, LLC\nWilliams Partners, LP\nOne Williams Center\nTulsa, OK 74172\nRe: CPF No. 2-2017-1002\nDear Mr. Armstrong:\nEnclosed please find the Final Order issued in the above-referenced case. It makes findings of\nviolation, assesses a civil penalty of $53,500, and specifies actions that need to be taken by\nTranscontinental Pipeline Company, LLC, a subsidiary of Williams Partners, LP, to comply with\nthe pipeline safety regulations. This is to acknowledge receipt of payment of the full penalty\namount, by wire transfer, dated July 19, 2017. When the terms of the compliance order are\ncompleted, as determined by the Director, Southern Region, this enforcement action will be\nclosed. Service of the Final Order by certified mail is effective upon the date of mailing as\nprovided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. James A. Urisko, Director, Southern Region, Office of Pipeline Safety, PHMSA\nMr. Mark Cluff, Vice President, Safety and Operational Discipline, Williams Partners,\nLP, 2800 Post Oak Boulevard, Houston, Texas 77056\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n_____________________________________\nIn the Matter of )\nTranscontinental Pipeline Company, LLC, ) CPF No. 2-2017-1002\na subsidiary of Williams Partners, LP, )\n)\n)\n)\nRespondent. )\n_____________________________________ )\nFINAL ORDER\nFrom October 24 through November 17, 2016, pursuant to 49 U.S.C. § 60117, representatives of\nthe Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS), conducted an on-site pipeline safety inspection of the facilities and records of\nTranscontinental Pipeline Company, LLC (Transco or Respondent), in Mississippi, Georgia, and\nSouth Carolina. Transco, a subsidiary of Williams Partners, LP (Williams), operates\napproximately 10,200 miles of gas pipelines in the United States.1\nAs a result of the inspection, the Director, Southern Region, OPS (Director), issued to\nRespondent, by letter dated May 12, 2017, a Notice of Probable Violation, Proposed Civil\nPenalty, and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the\nNotice proposed finding that Transco had committed a violation of 49 C.F.R. § 191.5(a) and\nproposed assessing a civil penalty of $53,500 for the alleged violation. The Notice also proposed\nfinding that Transco had committed a violation of 49 C.F.R. § 192.475(a) and proposed ordering\nRespondent to take certain measures to correct the alleged violation. Finally, the Notice alleged\ntwo probable violations and, pursuant to § 190.205, warned the operator to correct them or face\npossible enforcement action.\nWilliams, on behalf of Transco, responded to the Notice by letter dated June 16, 2017\n(Response). The company did not contest the allegations of violation and subsequently paid the\nproposed civil penalty of $53,500 by wire transfer on July 19, 2017. In accordance with\n49 C.F.R. § 190.208(a)(1), such payment authorizes the Associate Administrator to make\nfindings of violation and to issue this final order.\n1 Transco website, available at http://co.williams.com/gulf coast/transco/ (last accessed August 30, 2017).\n\n\n\nCPF No. 2-2017-1002\nPage 2\nFINDINGS OF VIOLATION\nIn its Response, Williams, on behalf of Transco, did not contest the allegations in the Notice that\nTransco violated 49 C.F.R. Parts 191 and 192, as follows:\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 191.5(a), which states:\n§ 191.5 Immediate notice of certain incidents.\n(a) At the earliest practicable moment following discovery, but no later\nthan one hour after confirmed discovery, each operator must give notice in\naccordance with paragraph (b) of this section of each incident as defined in\n§ 191.3.\nThe Notice alleged that Respondent violated 49 C.F.R. § 191.5(a) by failing to give notice of an\nincident at the earliest practicable moment following discovery, but no later than one hour after\nconfirmed discovery.2 Specifically, the Notice alleged that Transco failed to notify the National\nResponse Center of the unintentional release of natural gas exceeding 3 million cubic feet that\noccurred on August 11, 2016.3\nRespondent did not contest this allegation of violation. Accordingly, based upon a review of all\nof the evidence, I find that Respondent violated 49 C.F.R. § 191.5(a) by failing to give notice of\nan incident at the earliest practicable moment following discovery, but no later than one hour\nafter confirmed discovery.\nItem 2: The Notice alleged that Respondent violated 49 C.F.R. § 192.475(a), which states:\n§ 192.475 Internal corrosion control: General.\n(a) Corrosive gas may not be transported by pipeline, unless the\ncorrosive effect of the gas on the pipeline has been investigated and steps\nhave been taken to minimize internal corrosion.\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.475(a) by failing to investigate the\neffect of corrosive gas on the pipeline and failing to take steps to minimize internal corrosion.\nSpecifically, the Notice alleged that Transco operates a natural gas storage field at Station 77 in\nSeminary, Mississippi, but did not investigate the corrosive effects of the gas being transported\nbetween the storage caverns and dehydration plants, or take any steps necessary to minimize\ninternal corrosion of any pipelines within these storage fields.\nRespondent did not contest this allegation of violation. Accordingly, based upon a review of all\n2 49 C.F.R. § 191.3(1)(iii) defines the term “Incident” to include the “[u]nintentional estimated gas loss of three\nmillion cubic feet or more.”\n3 On August 11, 2016, a relief valve at the Clarke County Exchange facility unintentionally released an estimated\n3.2 million cubic feet of natural gas.\n\n\n\nCPF No. 2-2017-1002\nPage 3\nof the evidence, I find that Respondent violated 49 C.F.R. § 192.475(a) by failing to investigate\nthe effect of corrosive gas on the pipeline and failing to take steps to minimize internal corrosion.\nThese findings of violation will be considered prior offenses in any subsequent enforcement\naction taken against Respondent.\nASSESSMENT OF PENALTY\nUnder 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed\n$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any\nrelated series of violations.4 In determining the amount of a civil penalty under 49 U.S.C.\n§ 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature,\ncircumstances, and gravity of the violation, including adverse impact on the environment; the\ndegree of Respondent’s culpability; the history of Respondent’s prior offenses; and any effect\nthat the penalty may have on its ability to continue doing business; and the good faith of\nRespondent in attempting to comply with the pipeline safety regulations. In addition, I may\nconsider the economic benefit gained from the violation without any reduction because of\nsubsequent damages, and such other matters as justice may require. The Notice proposed a total\ncivil penalty of $53,500 for Item 1.\nItem 1: The Notice proposed a civil penalty of $53,500 for Respondent’s violation of 49 C.F.R.\n§ 191.5(a), for failing to give notice, at the earliest practicable moment following discovery but\nno later than one hour after confirmed discovery, of an incident. Transco neither contested the\nallegation nor the proposed penalty amount. Accordingly, Respondent is assessed a civil penalty\nof $53,500 for violation of §191.5(a), which has already been paid by wire transfer on July 19,\n2017.\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Item 2 in the Notice for violation of\n49 C.F.R. § 192.475(a). Under 49 U.S.C. § 60118(a), each person who engages in the\ntransportation of gas or who owns or operates a pipeline facility is required to comply with the\napplicable safety standards established under chapter 601. Pursuant to the authority of 49 U.S.C.\n§ 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following actions to\nensure compliance with the pipeline safety regulations applicable to its operations:\n1. With respect to the violation of § 192.475(a) (Item 2), Respondent must:\na. Investigate the corrosive effects of gas on the pipelines between the\ndehydration plants and the storage caverns at Station 77 within 30 days of\nreceipt of the Final Order;\n4 These amounts are adjusted annually for inflation. See, e.g., Pipeline Safety: Inflation Adjustment of Maximum\nCivil Penalties, 82 Fed. Reg. 19325 (April 27, 2017).\n\n\n\nCPF No. 2-2017-1002\nPage 4\nb. c. Determine what steps, if any, are necessary to minimize internal corrosion\non the pipelines between the compressor station and the storage caverns or\nstorage field piping based on its investigation of the corrosive effects of\nthe gas in Item 1(a) above within 60 days of receipt of this Final Order,\nand implement them within 120 days of receipt of the Final Order; and\nSubmit to the Director, Southern Region, OPS, PHMSA, documentation\ndemonstrating satisfactory completion of Items 1(a) and 1(b) above within\n150 days of receipt of the Final Order.\nIt is requested, but not mandated, that Transco maintain documentation of the safety\nimprovement costs associated with fulfilling this Compliance Order and submit the total to the\nDirector, Southern Region, OPS, PHMSA. It is further requested that these costs be reported in\ntwo categories: (1) total cost associated with preparation/revision of plans, procedures, studies\nand analyses; and (2) total cost associated with replacements, additions, and other changes to\npipeline infrastructure.\nThe Director may grant an extension of time to comply with any of the required items upon a\nwritten request timely submitted by the Respondent and demonstrating good cause for an\nextension.\nFailure to comply with this Order may result in the administrative assessment of civil penalties\nnot to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), for each violation for\neach day the violation continues or in referral to the Attorney General for appropriate relief in a\ndistrict court of the United States.\nWARNING ITEMS\nWith respect to Items 3 and 4, the Notice alleged probable violations of Part 192 but did not\npropose a civil penalty or compliance order for these items. Therefore, these are considered to\nbe warning items. The warnings were for:\n49 C.F.R. § 192.605(a) (Item 3) ─ Respondent’s alleged failure to follow its own\nmanual of written procedures for conducting maintenance activities by not\nfollowing Section 60.02.02 of Transco’s Operation & Maintenance Manual for\ncompleting Form WGP 0132C WilSOP Control Valve Inspection Report; and\n49 C.F.R. § 192.605(a) (Item 4) ─ Respondent’s alleged failure to follow its\nmanual of written procedures for conducting maintenance activities by not\nsecuring the block valve and bypass valves at Valve Site SN-20 to prevent\naccidental or unauthorized operation.5\n5 In an email dated June 22, 2017, Respondent provided evidence to PHMSA that the control box on the SN-20\nlateral block valve was locked at the time of the PHMSA inspection.\n\n\n\nCPF No. 2-2017-1002\nPage 5\nIf OPS finds a violation of any of these items in a subsequent inspection, Respondent may be\nsubject to future enforcement action.\nThe terms and conditions of this Final Order are effective upon service in accordance with\n49 C.F.R. § 190.5.\nOctober 31, 2017\n___________________________________ __________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n220171002_Closure Letter_01232018_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 23, 2018\nMr. Alan S. Armstrong\nPresident and Chief Executive Officer\nTranscontinental Pipeline Company, LLC\nWilliams Partners, LP\nOne Williams Center\nTulsa, OK 74172\nCPF 2-2017-1002\nDear Mr. Armstrong:\nFrom October 24 through November 17, 2016, pursuant to 49 U.S.C. § 60117, representatives\nof the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline\nSafety (OPS), conducted on-site pipeline safety inspections of the facilities and records of\nTranscontinental Pipeline Company, LLC (Transco), in Mississippi, Georgia, and South\nCarolina. As a result of the inspections, OPS issued Transco a Final Order with a Civil\nPenalty and Compliance Order (CO) on October 31, 2017. The CO required Transco to\nundertake certain actions to ensure compliance with the federal pipeline safety regulations.\nTransco paid the Civil Penalty on July 19, 2017, and OPS Southern received documentation\non January 18, 2018, confirming that the CO Items have been completed.\nBased upon payment of the Civil Penalty and our review of the actions taken by Transco (as\nwell as the supporting documentation), we have determined that Transco has complied with\nthe terms of the CO and the Final Order. This case is now closed and no further action is\nnecessary with respect to the matters involved in this case.\nPlease be advised that this letter refers only to the referenced order (CPF 2-2017-1002) and\nnot to any other PHMSA cases, if any.\nSincerely,\nJames A. Urisko\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n\n220171002_NOPV PCP PCO_05122017_text.pdf\n\nNOTICE OF PROBABLE VIOLATION\nPROPOSED CIVIL PENALTY\nand\nPROPOSED COMPLIANCE ORDER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 12, 2017\nMr. Alan S. Armstrong\nPresident and Chief Executive Officer\nTranscontinental Pipeline Company\nWilliams Partners, L.P.\nOne Williams Center\nTulsa, OK 74172\nCPF 2-2017-1002\nDear Mr. Armstrong:\nFrom October 24 to November 17, 2016, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety, inspected\nTranscontinental Pipeline Company (Transco) facilities in Mississippi, Georgia, and South\nCarolina, pursuant to Chapter 601 of 49 United States Code.\nAs a result of the inspections, it is alleged that Transco has committed probable violations of\nthe Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected\nand the probable violations are:\n1. § 191.5 Immediate notice of certain incidents.\n(a) At the earliest practicable moment following discovery, but no later than one\nhour after confirmed discovery, each operator must give notice in accordance\nwith paragraph (b) of this section of each incident as defined in §191.3.\nTransco failed to give notice in accordance with §191.5(b) at the earliest practicable\nmoment following the discovery of an incident, as defined in §191.3. Specifically,\nTransco failed to notify the National Response Center (NRC) of the unintentional release\nof natural gas exceeding three million cubic feet that occurred on August 11, 2016.\n\n\n\n2. 3. Transco records documented that on August 11, 2016, a relief valve at the Clarke County\nExchange facility released an estimated 3.2 million cubic feet of natural gas. At the time\nof the release, the pressure at the referenced relief valve was approximately 770 psig.\nThe set point of the relief valve was 800 psig, per Transco records documenting the\nvalve’s previous inspection.\nUnder normal operations, a relief valve with a set point of 800 psig would not be\nexpected to relieve at 770 psig, and any activation under such conditions would be\nconsidered unintentional. Part §191.3 of the Code of Federal Regulations defines an\nincident, in part, as an event with “unintentional estimated gas loss of three million cubic\nfeet or more from a pipeline.” §191.5(a) required Transco to give notice in accordance\nwith §191.5(b) at the earliest practicable moment following discovery of the incident.\nRecords documenting the release volume and the relief device set point were obtained by\nthe PHMSA inspector.\n§ 192.475 Internal corrosion control: General.\n(a) Corrosive gas may not be transported by pipeline, unless the corrosive effect of\nthe gas on the pipeline has been investigated and steps have been taken to\nminimize internal corrosion.\nTransco transported gas in its storage field pipelines at Station 77 in\nSeminary, Mississippi, but did not investigate the corrosive effects of the gas it\ntransported nor did Transco determine if steps were necessary to minimize internal\ncorrosion.\nTransco operates a natural gas storage field at Station 77 but it did not investigate the\ncorrosive effects of the gas being transported between the storage caverns and onsite\ndehydration plants (DHPs). Further, Transco did not identify any steps necessary to\nminimize internal corrosion of any pipelines within the above-referenced storage fields.\n§ 192.605 Procedural manual for operations, maintenance and emergencies.\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 did not follow its manual of written procedures for conducting maintenance\nactivities. Specifically, Transco personnel did not follow established procedure for\ncompleting Form WGP 0132C, titled WilSOP Control Valve Inspection Report, as\nrequired by Section 60.02.02 of Transco’s Operation & Maintenance Manual.\nSection 60.02.02 of Transco’s Operation & Maintenance Manual, titled Operating and\nMaintaining Gas Overpressure Protection Devices, required Transco personnel to:\n“Record observations, test calibration, and repair results on form WGP 0132A,\ntitled WilSOP Control Valve Inspection Report, or form WGP 0132C, titled\nWilSOP Relief Valve Inspection Report, as appropriate. See the Forms Matrix\nfor distribution list of completed forms.”\n2\n\n\n\n4. Transco Form WGP-0132C, referenced above, included a line for denoting whether the\nas found set point of the subject relief device “drifted” in excess of 3% of the previously\nrecorded set point, “indicating a failure.” This data field was annotated with a “*” which\nprovided direction that “if the set point drift exceeds manufacture’s recommendations,\nindicating a failure, check the equipment failure box and document how the set point drift\nis corrected.”\nDuring the inspection, the PHMSA inspector reviewed documentation of the inspection\nof the main relief valves for Compressor Units #2, #3, #6, and #10. These inspections\nwere documented on the above-referenced Transco Form WGP-0132C. On each\nrespective form, the response recorded for the data field “*Does set point drift exceed\n3%, indicating a failure?” was “YES.” While Transco documented that the drifted set\npoints were corrected, it did not document how they were corrected, as required by the\nabove-referenced form.\n§ 192.605 Procedural manual for operations, maintenance, and emergencies.\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. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed\nand updated by the operator at intervals not exceeding 15 months, but at least\nonce each calendar year. This manual must be prepared before operations of a\npipeline system commence. Appropriate parts of the manual must be kept at\nlocations where operations and maintenance activities are conducted.\nTransco did not follow its manual of written operations and maintenance procedures with\nregards to securing the block valve and bypass valves at Valve Site SN-20 to prevent\naccidental or unauthorized operation.\nValve Site SN-20 on Transco’s Tryon Lateral consists of lateral block valve SN-20, as\nwell as bypass valves B1 and B2 (following Transco’s naming convention). Each of the\nvalves is designated as a “critical” or “DOT Emergency Valve,” per Transco Policy\n70.16.00.08, titled DOT Valve Maintenance. The valves are confirmed as such in\nsupporting inspection documentation as well. Section 5.2 of Transco Procedure\n07.10.322-PMR, titled Valve Inspection and Maintenance (Revision Date 07/15/2016),\nrequired that “critical valves must be secured in their normal operating position.” At the\ntime of PHMSA’s inspection, the Valve Site SN-20 bypass valves B1 and B2 had no\nlocking device to secure them in their normal operating position. Furthermore, Section\n8.21 (of the same procedure), titled Automatic Valve Actuation Equipment, requires\nauthorized personnel to “remove or lock out control valve handles to prevent accidental\noperation of the valves.” At the time of PHMSA’s inspection, the SN-20 lateral block\nvalve actuator control handles were not removed or locked out. PHMSA personnel\nphotographed each of the three unsecured valves. It should be noted that Valve Site\nSN-20 was not protected by a fenced enclosure, or otherwise secured from unauthorized\ntampering.\n3\n\n\n\nProposed Civil Penalty\nUnder 49 United States Code, § 60122, Transco is subject to a civil penalty not to exceed\n$209,002 per violation per day the violation persists up to a maximum of $2,090,022 for a\nrelated series of violations. For violations occurring between August 2, 2016 to April 27,\n2017, the maximum penalty may not exceed $205,638 per violation per day, with a maximum\npenalty not to exceed $2,056,380 for a related serious of violations. For violations occurring\nbetween January 4, 2012 to August 1, 2016, the maximum penalty may not exceed $200,000\nper violation per day, with a maximum penalty not to exceed $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with maximum penalty not to exceed $1,000,000 for\nrelated series of violations. The Compliance Officer has reviewed the circumstances and\nsupporting documentation involved in the above probable violation and has recommended\nthat Transco be preliminarily assessed a civil penalty of $53,500 for Item 1 above.\nProposed Compliance Order\nWith respect to Item 2, pursuant to 49 United States Code § 60118, the Pipeline and\nHazardous Materials Safety Administration proposes to issue a Compliance Order to\nTranscontinental Pipeline Company. Please refer to the Proposed Compliance Order, which\nis enclosed and made a part of this Notice.\nWarning Items\nWith respect to Items 3 and 4, we have reviewed the circumstances and supporting documents\ninvolved in this case and have decided not to conduct additional enforcement action or\npenalty assessment proceedings at this time. We advise Transco to promptly correct these\nitems. Failure to do so may result in additional enforcement action.\nResponse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline\nOperators in Compliance Proceedings. Please refer to this document and note the response\noptions. All material submit in response to this enforcement action may be made publicly\navailable. If you believe that any portion of your responsive material qualifies for\nconfidential 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\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond\nwithin 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the\nallegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to\nfind facts as alleged in this Notice without further notice to you and to issue a Final Order.\n4\n\n\n\nIn your correspondence on this matter, please refer to CPF 2-2017-1002 and for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nJames A. Urisko\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Compliance Proceedings\n5\n\n\n\nPROPOSED COMPLIANCE ORDER\nPursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) proposes to issue to Transcontinental Gas Pipeline Company, LLC\n(Transco) a Compliance Order incorporating the following remedial requirements to ensure\nthe compliance of Transco with the pipeline safety regulations:\n1. 2. 3. 4. In regard to Item 2 of the Notice pertaining to Transco’s failure to investigate the\ncorrosive effects of gas on its pipeline and determine steps necessary to minimize\ninternal corrosion at Station 77,\na. Transco must investigate the corrosive effects of gas on the pipelines between the\ndehydration plants (DHPs) and the storage caverns at Station 77.\nb. Transco must determine what steps are necessary, if any, to minimize internal\ncorrosion on the pipelines between the compressor station and the storage caverns\nor storage field piping based on its investigation of the corrosive effects of the gas\nin Item 1a above.\nc. Transco must implement the steps that are determined to be necessary, if any, to\nminimize internal corrosion on the pipelines between the DHPs and the caverns in\nItem 1b.\nTransco must complete the above Items within the following time requirements.\na. Within 30 days of issuance of the Final Order, Transco must complete the\nrequirements of Item 1a above.\nb. Within 60 days of issuance of the Final Order, Transco must complete the\nrequirements of Item 1b above.\nc. Within 120 days of issuance of the Final Order, Transco must complete the\nrequirements of Item 1c above.\nWithin 150 days of issuance of the Final Order, Transco must submit to the Director,\nOffice of Pipeline Safety, PHMSA Southern Region, documentation demonstrating\nsatisfactory completion of Item 1 above.\nIt is requested (not mandated) that Transco maintain documentation of the safety\nimprovement costs associated with fulfilling this Compliance Order and submit the\ntotal to the Director, Office of Pipeline Safety, PHMSA Southern Region.\nIt is requested that these costs be reported in two categories: 1) total cost associated\nwith preparation/revision of plans, procedures, studies and analyses, and 2) total cost\nassociated with replacements, additions and other changes to pipeline infrastructure.\n6","truncated":false,"body_characters":27926}