# TRANSCONTINENTAL GAS PIPE LINE COMPANY — Notice of Probable Violation

- **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:** Not available
- **summary:** CLOSED notice of probable violation citing 191.17(a)(1), 192.5(b)(4), 192.619(a), 192.905(a).
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- **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.

Official case documents:

22024014NOPV_Final Order_07092025_(23-286844).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024014NOPV/22024014NOPV_Final%20Order_07092025_(23-286844).pdf

22024014NOPV_Final Order_07092025_(23-286844)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024014NOPV/22024014NOPV_Final%20Order_07092025_(23-286844)_text.pdf

22024014NOPV_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

22024014NOPV_PCP_10242024_(23-286844).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024014NOPV/22024014NOPV_PCP_10242024_(23-286844).pdf

22024014NOPV_PCP_10242024_(23-286844)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024014NOPV/22024014NOPV_PCP_10242024_(23-286844)_text.pdf

22024014NOPV_Final Order_07092025_(23-286844)_text.pdf

July 9, 2025
VIA ELECTRONIC MAIL TO: amy.shank@williams.com
Amy Shank
Vice President of Safety & Operational Discipline
Transcontinental Gas Pipeline Company, LLC
One Williams Center, MD 43-4
Tulsa, OK, 74172
Re: CPF No. 2-2024-014-NOPV
Dear Ms. Shank:
Enclosed please find the Final Order issued in the above-referenced case. It makes a finding of
violation and finds that the civil penalty amount of $59,800 has been paid in full. This case is
now closed. Service of the Final Order by e-mail is effective upon the date of transmission and
acknowledgement of receipt as provided under 49 CFR § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Linda Daugherty
Acting Associate Administrator
for Pipeline Safety
Enclosures (Final Order and NOPV)
cc: Mr. James Urisko, Director, Southern Region, Office of Pipeline Safety
Mr. Jorge Lopez, Director of Pipeline Safety and Asset Integrity, Safety and Operational
Discipline, Williams Partners, LP, Jorge.Lopez2@Williams.com
CONFIRMATION OF RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
___________________________________________
)
In the Matter of )
)
Transcontinental Gas Pipe Line Company, LLC, ) a subsidiary of Williams Partners, LP, )
)
)
CPF No. 2-2024-014-NOPV
Respondent. )
___________________________________________)
FINAL ORDER
On October 24, 2024, pursuant to 49 CFR § 190.207, the Director, Southern Region, Office of
Pipeline Safety (OPS), issued a Notice of Probable Violation (Notice) to Transcontinental Gas
Pipe Line Company, LLC (Respondent). The Notice proposed finding that Respondent had
violated the pipeline safety regulations in 49 CFR Part 192 and proposed a civil penalty of
$59,800. Respondent did not contest the allegations of violation and paid the proposed civil
penalty on November 27, 2024.
Based upon a review of all of the evidence, pursuant to section 190.213, I find Respondent
violated the pipeline safety regulation listed below, as more fully described in the enclosed
Notice, which is incorporated by reference:
49 CFR § 192.619(a) (Item 1) ─ Respondent failed to operate a segment of steel or
plastic pipeline at a pressure below the maximum allowable operating pressure as
determined under section 192.619(c), (d), (e), or the lowest of the four pressures
calculated under section 192.619(a)(1), (a)(2), (a)(3), and (a)(4).
This finding of violation will be considered a prior offense in any subsequent enforcement action
taken against Respondent. In accordance with 49 CFR § 190.223, Respondent is assessed the
proposed civil penalty amount of $59,800, which Respondent has already paid in full.
Warning Items
With respect to Items 2, 3, and 4, the Notice alleged probable violations of 49 CFR §§
192.905(a), 192.5(b)(4), and 191.17(a)(1), respectively, but did not propose a civil penalty or
compliance order for these items. Therefore, these are considered to be warning items. 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 order are effective upon service in accordance with 49 CFR
§ 190.5.
___________________________________ _________________________
Linda Daugherty Date Issued
Acting Associate Administrator
for Pipeline Safety



NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
VIA ELECTRONIC MAIL TO: amy.shank@williams.com; mason.jones@williams.com;
edgar.x.rodriguez@williams.com; Jorge.Lopez2@williams.com
October 24, 2024
Amy Shank
Vice President of Safety & Operational Discipline
Transcontinental Gas Pipeline Company
One Williams Center, MD 43-4
Tulsa, OK, 74172
CPF 2-2024-014-NOPV
Dear Ms. Shank:
From May 1, 2023 to December 1, 2023, representatives of the Pipeline and Hazardous Materials
Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49
United States Code (U.S.C.), inspected Transcontinental Gas Pipeline Company (Transco)
facilities, records, and procedures in Delaware, New Jersey, New York, and Pennsylvania.
As a result of the inspection, it is alleged that Transco has committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected
and the probable violations are:
1. §192.619 Maximum allowable operating pressure: Steel or plastic pipelines.
(a) No person may operate a segment of steel or plastic pipeline at a pressure that
exceeds a maximum allowable operating pressure (MAOP) determined under
paragraph (c), (d), or (e) of this section, or the lowest of the following….
Transco failed to comply with 49 C.F.R. § 192.619(a) because it operated a segment of
steel pipeline at pressures that exceed the MAOP as determined by § 192.619.



On August 31, 2023, Transco submitted a Safety Related Condition Report (SRCR) to
PHMSA as required by § 191.23 for an MAOP exceedance at the Milltown Regulator
Station. The SRCR described that the MAOP was exceeded between August 17, 2023 to
August 30, 2023. The line segment’s MAOP is 676psig. After reviewing Milltown
Regulator Pressure Data from Transco, it was determined that Transco operated the
section of pipe at pressures exceeding 110% of MAOP for 11 days, 16 hours between
August 17, 2023 to August 30, 2023. The maximum pressure during this time was
778.5psig, or 115% of MAOP.
2. §192.905 How does an operator identify a high consequence area?
(a) General. To determine which segments of an operator's transmission pipeline
system are covered by this subpart, an operator must identify the high consequence
areas. An operator must use method (1) or (2) from the definition in § 192.903 to
identify a high consequence area. An operator may apply one method to its entire
pipeline system, or an operator may apply one method to individual portions of the
pipeline system. An operator must describe in its integrity management program
which method it is applying to each portion of the operator's pipeline system. The
description must include the potential impact radius when utilized to establish a
high consequence area. (See appendix E.I. for guidance on identifying high
consequence areas.)
Transco failed to comply with 49 C.F.R. §192.905(a) because it did not identify a high
consequence area (HCA) on its Harrison Lateral.
During a site visit on November 2, 2023, along the Harrison Lateral in New Jersey, a
PHMSA inspector observed multiple 5-story apartment buildings and a stadium adjacent
to Transco’s right-of-way. This location was not classified as an HCA at this time,
despite the proximity of the pipeline to the apartment buildings and stadium. The two
apartment buildings have 280 and 286 units, and were built in 2018 and 2017,
respectively. The stadium has a seating capacity of 25,000 and hosts the local Major
League Soccer and National Women's Soccer team home games along with other sport,
concert, and community events. A subsequent review of Transco’s KMZa files, created
from Williams’b “Pipeline Open Data Standard” (PODS) database, confirmed that the
apartment buildings and the stadium fall within the pipeline’s potential impact radius.
Transco utilized method 2 under § 192.903 to define its HCAs.
Transco personnel explained that during an update to the PODS database intended to
identify Moderate Consequence Areas in 2021, the HCA was inadvertently excluded and
downgraded to a non-HCA. This HCA was dropped sometime between June 7, 2021 and
June 6, 2022, and remained as a non-HCA until observed during the field inspection by
a KMZ is a compressed KML file format used to visually display geographic data in an Earth Browser.
b Transco is a subsidiary of Williams Companies, Inc. (Williams). See Operations, WILLIAMS,
https://www.williams.com/pipeline/transco/ (last accessed Aug. 13, 2024).



the PHMSA inspector on November 2, 2023. The HCA was subsequently added back to
the system on November 6, 2023.
3. §192.5 Class locations.
(a) ….
(b) Except as provided in paragraph (c) of this section, pipeline locations are
classified as follows:
(1) ….
(4) A Class 4 location is any class location unit where buildings with four or more
stories above ground are prevalent.
Transco failed to comply with 49 C.F.R. §192.5(b)(4) because it did not identify a
Class 4 location along its Harrison Lateral.
During a site visit on November 2, 2023, along the Harrison Lateral in New Jersey, a
PHMSA inspector observed four five-story apartment buildings and a multi-story stadium
adjacent to Transco’s right-of-way. The four apartment buildings were built in 2015,
2017, 2018, and 2023, and include between 280 and 399 apartments in each building.
Red Bull arena was built in 2010 and has a seating capacity of 25,000. A review of
Transco’s KMZ files, created from Williams’ PODS database, confirmed that Transco
had listed the referenced area as a Class 1 location.
Transco subsequently updated this location to a Class 4 location and presented this
information to PHMSA inspectors during the week of November 27, 2023.
4. §191.17 Transmission systems; gathering systems; liquefied natural gas facilities;
and underground natural gas storage facilities: Annual report.
(a) Pipeline systems -
(1) Transmission, offshore gathering, or regulated onshore gathering. Each operator
of a transmission, offshore gathering, or regulated onshore gathering pipeline
system must submit an annual report for that system on DOT Form PHMSA F
7100.2-1. This report must be submitted each year, not later than March 15, for the
preceding calendar year.
Transco failed to comply with 49 C.F.R. § 191.17(a)(1) because it did not complete all
required information in its annual reports. Specifically, Transco failed to completely
document all information in Part F of its annual report for calendar years 2020 and 2021.
Transco submitted Annual Reports to PHMSA for calendar years 2020 and 2021 as
required by § 191.17. In each report, the following information was not populated:
2020 Annual Report
• Part F: Section 2c, titled “Total Number of ILI conditions repaired WITHIN AN
HCA SEGMENT meeting the definition of "immediate repair conditions," "One-
year conditions," "Monitored conditions," and "Other Scheduled conditions" as
defined in 192.933(d).”
2021 Annual Report



Part F: Section 2c, titled "Total Number of ILI conditions repaired WITHIN AN
HCA SEGMENT meeting the definition of "immediate repair conditions," "One-
year conditions," "Monitored conditions," and "Other Scheduled conditions" as
defined in 192.933(d)."
Part F: Section 4c, titled Total Number of DA conditions repaired WITHIN AN
HCA SEGMENT meeting the definition of "immediate repair conditions," "One-
year conditions," "Monitored conditions," and "Other Scheduled conditions" as
defined in 192.933(d)."
Furthermore, the 2021 Annual Report was submitted on 03/16/2022, 1 day after the
deadline of March 15, 2022, as required by § 191.17(a)(1).
Proposed Civil Penalty
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$266,015 per violation per day the violation persists, up to a maximum of $2,660,135 for a
related series of violations. For violation occurring on or after January 6, 2023 and before
December 28, 2023, the maximum penalty may not exceed $257,664 per violation per day the
violation persists, up to a maximum of $2,576,627 for a related series of violations. For violation
occurring on or after March 21, 2022 and before January 6, 2023, the maximum penalty may not
exceed $239,142 per violation per day the violation persists, up to a maximum of $2,391,412 for
a related series of violations. For violation occurring on or after May 3, 2021 and before March
21, 2022, the maximum penalty may not exceed $225,134 per violation per day the violation
persists, up to a maximum of $2,251,334 for a related series of violations. For violation
occurring on or after January 11, 2021 and before May 3, 2021, the maximum penalty may not
exceed $222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for
a related series of violations. For violation occurring on or after July 31, 2019 and before
January 11, 2021, the maximum penalty may not exceed $218,647 per violation per day the
violation persists, up to a maximum of $2,186,465 for a related series of violations. For violation
occurring on or after November 27, 2018, and before July 31, 2019, the maximum penalty may
not exceed $213,268 per violation per day, with a maximum penalty not to exceed $2,132,679.
We have reviewed the circumstances and supporting documentation involved for the above
probable violations and recommend that you be preliminarily assessed a civil penalty of $ 59,800
as follows:
Item number
PENALTY
1
$ 59,800
Warning Items
With respect to Items 2, 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 you 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 Enforcement Proceedings. Please refer to this document and note the response options. All
material you 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).
Following your receipt of this Notice, you have 30 days to respond as described in the enclosed
Response Options. 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. If you are responding to this Notice, we propose that you submit
your correspondence to my office within 30 days from receipt of this Notice. The Region
Director may extend the period for responding upon a written request timely submitted
demonstrating good cause for an extension.
In your correspondence on this matter, please refer to CPF 2-2024-014-NOPV and, for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
James A. Urisko
Director, Southern Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Enclosures: Response Options for Pipeline Operators in Enforcement Proceedings
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