{"operation":"document","citation":"CPF 22025003WL","title":"TRANSCONTINENTAL GAS PIPE LINE COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-07-18","effective_on":null,"summary":"CLOSED warning letter citing 192.5(a)(1), 192.5(b)(1), 192.5(b)(2), 192.5(b)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-22025003wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-22025003wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-22025003wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/22025003WL","body":"Warning Letter involving TRANSCONTINENTAL GAS PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 192.5(a)(1),  192.5(b)(1),  192.5(b)(2),  192.5(b)(3). The case was opened on 2025-07-18 and is reported as closed as of 2025-07-18. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n22025003WL_Warning Letter_07182025_(23-286844).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22025003WL/22025003WL_Warning%20Letter_07182025_(23-286844).pdf\n\n22025003WL_Warning Letter_07182025_(23-286844)_txt.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22025003WL/22025003WL_Warning%20Letter_07182025_(23-286844)_txt.pdf\n\n22025003WL_Warning Letter_07182025_(23-286844).pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n230 Peachtree Street N.W.\nSuite 2100\nAtlanta, GA 30303\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: amy.shank@williams.com; mason.jones@williams.com;\nedgar.x.rodriguez@williams.com; Jorge.Lopez2@williams.com\nJuly 18, 2025\nAmy Shank\nVice President of Safety & Operational Discipline\nTranscontinental Gas Pipe Line Company\nOne Williams Center\nMD 43-4\nTulsa, OK, 74172\nCPF 2-2025-003-WL\nDear Ms. Shank:\nFrom May 1, 2023 to December 1, 2023, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter\n601 of 49 United States Code (U.S.C.), inspected Transcontinental Gas Pipe Line Company\n(Transco) procedures, records, and facilities in Delaware, New Jersey, New York, and\nPennsylvania.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected\nand the probable violation is:\n1. § 192.5 Class Locations.\n(a) This section classifies pipeline locations for purposes of this part. The following\ncriteria apply to classifications under this section.\n\n\n\n(1) A “class location unit” is an onshore area that extends 220 yards (200 meters)\non either side of the centerline of any continuous 1- mile (1.6 kilometers) length of\npipeline.\n(2)….\n(b) Except as provided in paragraph (c) of this section, pipeline locations are\nclassified as follows:\n(1) A Class 1 location is:\n(i) An offshore area; or\n(ii) Any class location unit that has 10 or fewer buildings intended for human\noccupancy.\n(2) A Class 2 location is any class location unit that has more than 10 but fewer\nthan 46 buildings intended for human occupancy.\n(3) A Class 3 location is:\n(i) Any class location unit that has 46 or more buildings intended for human\noccupancy; or\n(ii) An area where the pipeline lies within 100 yards (91 meters) of either a\nbuilding or a small, well-defined outside area (such as a playground,\nrecreation area, outdoor theater, or other place of public assembly) that\nis occupied by 20 or more persons on at least 5 days a week for 10 weeks\nin any 12-month period. (The days and weeks need not be consecutive.)\nTransco failed to comply with 49 CFR § 192.5(b) because it failed to properly classify\ncertain Class 2 and Class 3 locations.\nAt the time of PHMSA's inspection, Transco presented its current class locations graphically\nthrough KMZ files generated from Williams’sa PODS database. Two locations, one just\nnorth of Dallas Township, Pennsylvania, and the other just northeast of Spring House,\nPennsylvania, were noted as Class 1 and 2 locations in the KMZ files, respectively.\nHowever, each of these locations met the definition of a Class 2 and Class 3 location,\nrespectively.\nEach location consisted of a main line with a branch line extending laterally from the main\nline. The main line near Dallas Township at the Springville Lateral was listed as a Class 1\nlocation, while the branch line was also listed as a Class 1 location. However, Buildings\nIntended for Human Occupancy (BIHOs) were located within 220 yards of the centerline on\nthe mainline and branch line such that more than 10 BIHOs were contained within the class\nlocation unit extending from the main line to the branch line. The main line near Spring\na Transco is a subsidiary of Williams and uses its programs and procedures. See\nhttps://www.williams.com/pipeline/transco/ (last accessed May 30, 2025).\n2\n\n\n\nHouse at the Oreland Lateral was listed as a Class 3 location, while the branch line was listed\nas a Class 2 location. However, Buildings Intended for Human Occupancy (BIHOs) were\nlocated within 220 yards of the centerline on the mainline and branch line such that 46 or\nmore BIHOs were contained within the class location unit extending from the main line to\nthe branch line. The transition from the main to the branch line is a continuous length of\npipeline under § 192.5(a)(1).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a\nrelated series of violations. For violation occurring on or after December 28, 2023 and before\nDecember 30, 2024, the maximum penalty may not exceed $266,015 per violation per day the\nviolation persists, up to a maximum of $2,660,135 for a related series of violations. For violation\noccurring on or after January 6, 2023 and before December 28, 2023, the maximum penalty may\nnot exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627\nfor a related series of violations. For violation occurring on or after March 21, 2022 and before\nJanuary 6, 2023, the maximum penalty may not exceed $239,142 per violation per day the\nviolation persists, up to a maximum of $2,391,142 for a related series of violations. For violation\noccurring on or after May 3, 2021 and before March 21, 2022, the maximum penalty may not\nexceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for\na related series of violations. For violation occurring on or after January 11, 2021 and before\nMay 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation\npersists, up to a maximum of $2,225,034 for a related series of violations. For violation\noccurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not\nexceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for\na related series of violations.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the item identified in this letter. Failure to do so will result in\nTranscontinental Gas Pipe Line Company being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 2-2025-003-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. § 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. § 552(b).\n3\n\n\n\nSincerely,\nJames A. Urisko\nDirector, Southern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n4\n\n22025003WL_Warning Letter_07182025_(23-286844)_txt.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n230 Peachtree Street N.W.\nSuite 2100\nAtlanta, GA 30303\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: amy.shank@williams.com; mason.jones@williams.com;\nedgar.x.rodriguez@williams.com; Jorge.Lopez2@williams.com\nJuly 18, 2025\nAmy Shank\nVice President of Safety & Operational Discipline\nTranscontinental Gas Pipe Line Company\nOne Williams Center\nMD 43-4\nTulsa, OK, 74172\nCPF 2-2025-003-WL\nDear Ms. Shank:\nFrom May 1, 2023 to December 1, 2023, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter\n601 of 49 United States Code (U.S.C.), inspected Transcontinental Gas Pipe Line Company\n(Transco) procedures, records, and facilities in Delaware, New Jersey, New York, and\nPennsylvania.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected\nand the probable violation is:\n1. § 192.5 Class Locations.\n(a) This section classifies pipeline locations for purposes of this part. The following\ncriteria apply to classifications under this section.\n\n\n\n(1) A “class location unit” is an onshore area that extends 220 yards (200 meters)\non either side of the centerline of any continuous 1- mile (1.6 kilometers) length of\npipeline.\n(2)….\n(b) Except as provided in paragraph (c) of this section, pipeline locations are\nclassified as follows:\n(1) A Class 1 location is:\n(i) An offshore area; or\n(ii) Any class location unit that has 10 or fewer buildings intended for human\noccupancy.\n(2) A Class 2 location is any class location unit that has more than 10 but fewer\nthan 46 buildings intended for human occupancy.\n(3) A Class 3 location is:\n(i) Any class location unit that has 46 or more buildings intended for human\noccupancy; or\n(ii) An area where the pipeline lies within 100 yards (91 meters) of either a\nbuilding or a small, well-defined outside area (such as a playground,\nrecreation area, outdoor theater, or other place of public assembly) that\nis occupied by 20 or more persons on at least 5 days a week for 10 weeks\nin any 12-month period. (The days and weeks need not be consecutive.)\nTransco failed to comply with 49 CFR § 192.5(b) because it failed to properly classify\ncertain Class 2 and Class 3 locations.\nAt the time of PHMSA's inspection, Transco presented its current class locations graphically\nthrough KMZ files generated from Williams’sa PODS database. Two locations, one just\nnorth of Dallas Township, Pennsylvania, and the other just northeast of Spring House,\nPennsylvania, were noted as Class 1 and 2 locations in the KMZ files, respectively.\nHowever, each of these locations met the definition of a Class 2 and Class 3 location,\nrespectively.\nEach location consisted of a main line with a branch line extending laterally from the main\nline. The main line near Dallas Township at the Springville Lateral was listed as a Class 1\nlocation, while the branch line was also listed as a Class 1 location. However, Buildings\nIntended for Human Occupancy (BIHOs) were located within 220 yards of the centerline on\nthe mainline and branch line such that more than 10 BIHOs were contained within the class\nlocation unit extending from the main line to the branch line. The main line near Spring\na Transco is a subsidiary of Williams and uses its programs and procedures. See\nhttps://www.williams.com/pipeline/transco/ (last accessed May 30, 2025).\n2\n\n\n\nHouse at the Oreland Lateral was listed as a Class 3 location, while the branch line was listed\nas a Class 2 location. However, Buildings Intended for Human Occupancy (BIHOs) were\nlocated within 220 yards of the centerline on the mainline and branch line such that 46 or\nmore BIHOs were contained within the class location unit extending from the main line to\nthe branch line. The transition from the main to the branch line is a continuous length of\npipeline under § 192.5(a)(1).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a\nrelated series of violations. For violation occurring on or after December 28, 2023 and before\nDecember 30, 2024, the maximum penalty may not exceed $266,015 per violation per day the\nviolation persists, up to a maximum of $2,660,135 for a related series of violations. For violation\noccurring on or after January 6, 2023 and before December 28, 2023, the maximum penalty may\nnot exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627\nfor a related series of violations. For violation occurring on or after March 21, 2022 and before\nJanuary 6, 2023, the maximum penalty may not exceed $239,142 per violation per day the\nviolation persists, up to a maximum of $2,391,142 for a related series of violations. For violation\noccurring on or after May 3, 2021 and before March 21, 2022, the maximum penalty may not\nexceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for\na related series of violations. For violation occurring on or after January 11, 2021 and before\nMay 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation\npersists, up to a maximum of $2,225,034 for a related series of violations. For violation\noccurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not\nexceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for\na related series of violations.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the item identified in this letter. Failure to do so will result in\nTranscontinental Gas Pipe Line Company being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 2-2025-003-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. § 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. § 552(b).\n3\n\n\n\nSincerely,\nJames A. Urisko\nDirector, Southern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n4","truncated":false,"body_characters":14495}