{"operation":"document","citation":"CPF 22024014NOPV","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":"2024-10-24","effective_on":null,"summary":"CLOSED notice of probable violation citing 191.17(a)(1), 192.5(b)(4), 192.619(a), 192.905(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-22024014nopv.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-22024014nopv.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-22024014nopv","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/22024014NOPV","body":"Notice of Probable Violation involving TRANSCONTINENTAL GAS PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 191.17(a)(1),  192.5(b)(4),  192.619(a),  192.905(a). The case was opened on 2024-10-24 and is reported as closed as of 2025-07-09. Proposed civil penalty: $59,800. Assessed civil penalty: $59,800. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n22024014NOPV_Final Order_07092025_(23-286844).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024014NOPV/22024014NOPV_Final%20Order_07092025_(23-286844).pdf\n\n22024014NOPV_Final Order_07092025_(23-286844)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024014NOPV/22024014NOPV_Final%20Order_07092025_(23-286844)_text.pdf\n\n22024014NOPV_Operator Response to Notice_11202024_(23-286844).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024014NOPV/22024014NOPV_Operator%20Response%20to%20Notice_11202024_(23-286844).pdf\n\n22024014NOPV_PCP_10242024_(23-286844).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024014NOPV/22024014NOPV_PCP_10242024_(23-286844).pdf\n\n22024014NOPV_PCP_10242024_(23-286844)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024014NOPV/22024014NOPV_PCP_10242024_(23-286844)_text.pdf\n\n22024014NOPV_Final Order_07092025_(23-286844)_text.pdf\n\nJuly 9, 2025\nVIA ELECTRONIC MAIL TO: amy.shank@williams.com\nAmy Shank\nVice President of Safety & Operational Discipline\nTranscontinental Gas Pipeline Company, LLC\nOne Williams Center, MD 43-4\nTulsa, OK, 74172\nRe: CPF No. 2-2024-014-NOPV\nDear Ms. Shank:\nEnclosed please find the Final Order issued in the above-referenced case. It makes a finding of\nviolation and finds that the civil penalty amount of $59,800 has been paid in full. This case is\nnow closed. Service of the Final Order by e-mail is effective upon the date of transmission and\nacknowledgement of receipt as provided under 49 CFR § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nLinda Daugherty\nActing Associate Administrator\nfor Pipeline Safety\nEnclosures (Final Order and NOPV)\ncc: Mr. James Urisko, Director, Southern Region, Office of Pipeline Safety\nMr. Jorge Lopez, Director of Pipeline Safety and Asset Integrity, Safety and Operational\nDiscipline, Williams Partners, LP, Jorge.Lopez2@Williams.com\nCONFIRMATION OF RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n___________________________________________\n)\nIn the Matter of )\n)\nTranscontinental Gas Pipe Line Company, LLC, ) a subsidiary of Williams Partners, LP, )\n)\n)\nCPF No. 2-2024-014-NOPV\nRespondent. )\n___________________________________________)\nFINAL ORDER\nOn October 24, 2024, pursuant to 49 CFR § 190.207, the Director, Southern Region, Office of\nPipeline Safety (OPS), issued a Notice of Probable Violation (Notice) to Transcontinental Gas\nPipe Line Company, LLC (Respondent). The Notice proposed finding that Respondent had\nviolated the pipeline safety regulations in 49 CFR Part 192 and proposed a civil penalty of\n$59,800. Respondent did not contest the allegations of violation and paid the proposed civil\npenalty on November 27, 2024.\nBased upon a review of all of the evidence, pursuant to section 190.213, I find Respondent\nviolated the pipeline safety regulation listed below, as more fully described in the enclosed\nNotice, which is incorporated by reference:\n49 CFR § 192.619(a) (Item 1) ─ Respondent failed to operate a segment of steel or\nplastic pipeline at a pressure below the maximum allowable operating pressure as\ndetermined under section 192.619(c), (d), (e), or the lowest of the four pressures\ncalculated under section 192.619(a)(1), (a)(2), (a)(3), and (a)(4).\nThis finding of violation will be considered a prior offense in any subsequent enforcement action\ntaken against Respondent. In accordance with 49 CFR § 190.223, Respondent is assessed the\nproposed civil penalty amount of $59,800, which Respondent has already paid in full.\nWarning Items\nWith respect to Items 2, 3, and 4, the Notice alleged probable violations of 49 CFR §§\n192.905(a), 192.5(b)(4), and 191.17(a)(1), respectively, but did not propose a civil penalty or\ncompliance order for these items. Therefore, these are considered to be warning items. If OPS\n\n\n\nfinds a violation of any of these items in a subsequent inspection, Respondent may be subject to\nfuture enforcement action.\nThe terms and conditions of this order are effective upon service in accordance with 49 CFR\n§ 190.5.\n___________________________________ _________________________\nLinda Daugherty Date Issued\nActing Associate Administrator\nfor Pipeline Safety\n\n\n\nNOTICE OF PROBABLE VIOLATION\nPROPOSED CIVIL PENALTY\nVIA ELECTRONIC MAIL TO: amy.shank@williams.com; mason.jones@williams.com;\nedgar.x.rodriguez@williams.com; Jorge.Lopez2@williams.com\nOctober 24, 2024\nAmy Shank\nVice President of Safety & Operational Discipline\nTranscontinental Gas Pipeline Company\nOne Williams Center, MD 43-4\nTulsa, OK, 74172\nCPF 2-2024-014-NOPV\nDear Ms. Shank:\nFrom May 1, 2023 to December 1, 2023, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49\nUnited States Code (U.S.C.), inspected Transcontinental Gas Pipeline Company (Transco)\nfacilities, records, and procedures in Delaware, New Jersey, New York, and Pennsylvania.\nAs a result of the inspection, it is alleged that Transco has committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. §192.619 Maximum allowable operating pressure: Steel or plastic pipelines.\n(a) No person may operate a segment of steel or plastic pipeline at a pressure that\nexceeds a maximum allowable operating pressure (MAOP) determined under\nparagraph (c), (d), or (e) of this section, or the lowest of the following….\nTransco failed to comply with 49 C.F.R. § 192.619(a) because it operated a segment of\nsteel pipeline at pressures that exceed the MAOP as determined by § 192.619.\n\n\n\nOn August 31, 2023, Transco submitted a Safety Related Condition Report (SRCR) to\nPHMSA as required by § 191.23 for an MAOP exceedance at the Milltown Regulator\nStation. The SRCR described that the MAOP was exceeded between August 17, 2023 to\nAugust 30, 2023. The line segment’s MAOP is 676psig. After reviewing Milltown\nRegulator Pressure Data from Transco, it was determined that Transco operated the\nsection of pipe at pressures exceeding 110% of MAOP for 11 days, 16 hours between\nAugust 17, 2023 to August 30, 2023. The maximum pressure during this time was\n778.5psig, or 115% of MAOP.\n2. §192.905 How does an operator identify a high consequence area?\n(a) General. To determine which segments of an operator's transmission pipeline\nsystem are covered by this subpart, an operator must identify the high consequence\nareas. An operator must use method (1) or (2) from the definition in § 192.903 to\nidentify a high consequence area. An operator may apply one method to its entire\npipeline system, or an operator may apply one method to individual portions of the\npipeline system. An operator must describe in its integrity management program\nwhich method it is applying to each portion of the operator's pipeline system. The\ndescription must include the potential impact radius when utilized to establish a\nhigh consequence area. (See appendix E.I. for guidance on identifying high\nconsequence areas.)\nTransco failed to comply with 49 C.F.R. §192.905(a) because it did not identify a high\nconsequence area (HCA) on its Harrison Lateral.\nDuring a site visit on November 2, 2023, along the Harrison Lateral in New Jersey, a\nPHMSA inspector observed multiple 5-story apartment buildings and a stadium adjacent\nto Transco’s right-of-way. This location was not classified as an HCA at this time,\ndespite the proximity of the pipeline to the apartment buildings and stadium. The two\napartment buildings have 280 and 286 units, and were built in 2018 and 2017,\nrespectively. The stadium has a seating capacity of 25,000 and hosts the local Major\nLeague Soccer and National Women's Soccer team home games along with other sport,\nconcert, and community events. A subsequent review of Transco’s KMZa files, created\nfrom Williams’b “Pipeline Open Data Standard” (PODS) database, confirmed that the\napartment buildings and the stadium fall within the pipeline’s potential impact radius.\nTransco utilized method 2 under § 192.903 to define its HCAs.\nTransco personnel explained that during an update to the PODS database intended to\nidentify Moderate Consequence Areas in 2021, the HCA was inadvertently excluded and\ndowngraded to a non-HCA. This HCA was dropped sometime between June 7, 2021 and\nJune 6, 2022, and remained as a non-HCA until observed during the field inspection by\na KMZ is a compressed KML file format used to visually display geographic data in an Earth Browser.\nb Transco is a subsidiary of Williams Companies, Inc. (Williams). See Operations, WILLIAMS,\nhttps://www.williams.com/pipeline/transco/ (last accessed Aug. 13, 2024).\n\n\n\nthe PHMSA inspector on November 2, 2023. The HCA was subsequently added back to\nthe system on November 6, 2023.\n3. §192.5 Class locations.\n(a) ….\n(b) Except as provided in paragraph (c) of this section, pipeline locations are\nclassified as follows:\n(1) ….\n(4) A Class 4 location is any class location unit where buildings with four or more\nstories above ground are prevalent.\nTransco failed to comply with 49 C.F.R. §192.5(b)(4) because it did not identify a\nClass 4 location along its Harrison Lateral.\nDuring a site visit on November 2, 2023, along the Harrison Lateral in New Jersey, a\nPHMSA inspector observed four five-story apartment buildings and a multi-story stadium\nadjacent to Transco’s right-of-way. The four apartment buildings were built in 2015,\n2017, 2018, and 2023, and include between 280 and 399 apartments in each building.\nRed Bull arena was built in 2010 and has a seating capacity of 25,000. A review of\nTransco’s KMZ files, created from Williams’ PODS database, confirmed that Transco\nhad listed the referenced area as a Class 1 location.\nTransco subsequently updated this location to a Class 4 location and presented this\ninformation to PHMSA inspectors during the week of November 27, 2023.\n4. §191.17 Transmission systems; gathering systems; liquefied natural gas facilities;\nand underground natural gas storage facilities: Annual report.\n(a) Pipeline systems -\n(1) Transmission, offshore gathering, or regulated onshore gathering. Each operator\nof a transmission, offshore gathering, or regulated onshore gathering pipeline\nsystem must submit an annual report for that system on DOT Form PHMSA F\n7100.2-1. This report must be submitted each year, not later than March 15, for the\npreceding calendar year.\nTransco failed to comply with 49 C.F.R. § 191.17(a)(1) because it did not complete all\nrequired information in its annual reports. Specifically, Transco failed to completely\ndocument all information in Part F of its annual report for calendar years 2020 and 2021.\nTransco submitted Annual Reports to PHMSA for calendar years 2020 and 2021 as\nrequired by § 191.17. In each report, the following information was not populated:\n2020 Annual Report\n• Part F: Section 2c, titled “Total Number of ILI conditions repaired WITHIN AN\nHCA SEGMENT meeting the definition of \"immediate repair conditions,\" \"One-\nyear conditions,\" \"Monitored conditions,\" and \"Other Scheduled conditions\" as\ndefined in 192.933(d).”\n2021 Annual Report\n\n\n\nPart F: Section 2c, titled \"Total Number of ILI conditions repaired WITHIN AN\nHCA SEGMENT meeting the definition of \"immediate repair conditions,\" \"One-\nyear conditions,\" \"Monitored conditions,\" and \"Other Scheduled conditions\" as\ndefined in 192.933(d).\"\nPart F: Section 4c, titled Total Number of DA conditions repaired WITHIN AN\nHCA SEGMENT meeting the definition of \"immediate repair conditions,\" \"One-\nyear conditions,\" \"Monitored conditions,\" and \"Other Scheduled conditions\" as\ndefined in 192.933(d).\"\nFurthermore, the 2021 Annual Report was submitted on 03/16/2022, 1 day after the\ndeadline of March 15, 2022, as required by § 191.17(a)(1).\nProposed Civil Penalty\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$266,015 per violation per day the violation persists, up to a maximum of $2,660,135 for a\nrelated series of violations. For violation occurring on or after January 6, 2023 and before\nDecember 28, 2023, the maximum penalty may not exceed $257,664 per violation per day the\nviolation persists, up to a maximum of $2,576,627 for a related series of violations. For violation\noccurring on or after March 21, 2022 and before January 6, 2023, the maximum penalty may not\nexceed $239,142 per violation per day the violation persists, up to a maximum of $2,391,412 for\na related series of violations. For violation occurring on or after May 3, 2021 and before March\n21, 2022, the maximum penalty may not exceed $225,134 per violation per day the violation\npersists, up to a maximum of $2,251,334 for a related series of violations. For violation\noccurring on or after January 11, 2021 and before May 3, 2021, the maximum penalty may not\nexceed $222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for\na related series of violations. For violation occurring on or after July 31, 2019 and before\nJanuary 11, 2021, the maximum penalty may not exceed $218,647 per violation per day the\nviolation persists, up to a maximum of $2,186,465 for a related series of violations. For violation\noccurring on or after November 27, 2018, and before July 31, 2019, the maximum penalty may\nnot exceed $213,268 per violation per day, with a maximum penalty not to exceed $2,132,679.\nWe have reviewed the circumstances and supporting documentation involved for the above\nprobable violations and recommend that you be preliminarily assessed a civil penalty of $ 59,800\nas follows:\nItem number\nPENALTY\n1\n$ 59,800\nWarning Items\nWith respect to Items 2, 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 penalty\nassessment proceedings at this time. We advise you to promptly correct these items). Failure to\ndo so may result in additional enforcement action.\nResponse to this Notice\n\n\n\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators\nin Enforcement Proceedings. Please refer to this document and note the response options. All\nmaterial you submit in response to this enforcement action may be made publicly available. If\nyou believe that any portion of your responsive material qualifies for confidential treatment\nunder 5 U.S.C. § 552(b), along with the complete original document you must provide a second\ncopy of the document with the portions you believe qualify for confidential treatment redacted\nand an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. § 552(b).\nFollowing your receipt of this Notice, you have 30 days to respond as described in the enclosed\nResponse Options. If you do not respond within 30 days of receipt of this Notice, this constitutes\na waiver of your right to contest the allegations in this Notice and authorizes the Associate\nAdministrator for Pipeline Safety to find facts as alleged in this Notice without further notice to\nyou and to issue a Final Order. If you are responding to this Notice, we propose that you submit\nyour correspondence to my office within 30 days from receipt of this Notice. The Region\nDirector may extend the period for responding upon a written request timely submitted\ndemonstrating good cause for an extension.\nIn your correspondence on this matter, please refer to CPF 2-2024-014-NOPV and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nJames A. Urisko\nDirector, Southern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosures: Response Options for Pipeline Operators in Enforcement Proceedings","truncated":false,"body_characters":16331}