{"operation":"document","citation":"CPF 32021020NOA","title":"TRANSCONTINENTAL GAS PIPE LINE COMPANY — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-04-28","effective_on":null,"summary":"CLOSED notice of amendment citing 192.631(a)(1), 192.631(b)(5), 192.631(h)(6).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021020noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021020noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021020noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32021020NOA","body":"Notice of Amendment involving TRANSCONTINENTAL GAS PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 192.631(a)(1),  192.631(b)(5),  192.631(h)(6). The case was opened on 2021-04-28 and is reported as closed as of 2022-01-12. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32021020NOA_Closure Letter_01122022_(20-173057).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021020NOA/32021020NOA_Closure%20Letter_01122022_(20-173057).pdf\n\n32021020NOA_Closure Letter_01122022_(20-173057)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021020NOA/32021020NOA_Closure%20Letter_01122022_(20-173057)_text.pdf\n\n32021020NOA_Notice of Amendment_04282021_(20-173057).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021020NOA/32021020NOA_Notice%20of%20Amendment_04282021_(20-173057).pdf\n\n32021020NOA_Notice of Amendment_04282021_(20-173057)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021020NOA/32021020NOA_Notice%20of%20Amendment_04282021_(20-173057)_text.pdf\n\n32021020NOA_Operator Response to Notice_05272021_(20-173057).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021020NOA/32021020NOA_Operator%20Response%20to%20Notice_05272021_(20-173057).pdf\n\n32021020NOA_Closure Letter_01122022_(20-173057)_text.pdf\n\nVIA ELECTRONIC MAIL TO: alan.armstrong@williams.com , clint.ratke@williams.com,\njoseph.carey@williams.com\nJanuary 12, 2022\nMr. Alan Armstrong\nPresident & CEO\nTranscontinental Gas Pipeline Company\nOne Williams Center\nPO Box 2400\nTulsa, OK 74102-2400\nRe: CPF 3-2021-020-NOA\nDear Mr Armstrong:\nFrom May 4 – 8, 2020, a representative from the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-\nsite pipeline safety inspection of OPID’s 19750/Transcontinental Gas Pipeline Company, 31565/Gulf\nStream Management & Operating Services, LLC, 32684/Pine Needle Operating Company, LLC and\n32657/Cardinal Operating Company, LLC (Transco) Houston, Texas. As a result of the inspection,\nTransco was issued a Notice of Amendment on April 28, 2021, which proposed amendment of\nyour procedures.\nTransco submitted its amended procedures on January 11, 2022. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Clint Ratke, Manager Pipeline Safety clint.ratke@williams.com\n\n32021020NOA_Notice of Amendment_04282021_(20-173057)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: alan.armstrong@williams.com and edgar.x.rodriguez@williams.com\nApril 28, 2021\nMr. Alan Armstrong\nPresident & CEO\nTranscontinental Gas Pipeline Company\nOne Williams Center\nPO Box 2400\nTulsa, OK 74102-2400\nCPF 3-2021-020-NOA\nDear Mr. Armstrong:\nFrom May 4 through 8, 2020, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) and New York State Department of Public Service pursuant to Chapter 601 of\n49 United States Code (U.S.C.) inspected your Control Room Management Plan and Control Room\nRecords in Houston, TX. The inspection pertained to OPID’s 19750/Transcontinental Gas Pipeline\nCompany, 31565/Gulf Stream Management & Operating Services, LLC, 32684/Pine Needle Operating\nCompany, LLC and 32657/Cardinal Operating Company, LLC.\nThis Notice is in response to PHMSA’s Control Room Management (CRM) Initiative, which is a national\nlevel program that includes inspectors from every region. As a result, you may have received this Notice\nfrom a different Regional Director than typical because the CRM Initiative inspections are currently\nseparate from the standard inspection program. Notices and correspondence from other types of\ninspections will remain unchanged.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nTranscontinental Gas Pipeline Company’s (TransCo) plans or procedures, as described below:\n\n\n\n1. § 192.631 Control room management.\n(a) General. (1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline facility\nthrough a SCADA system. Each operator must have and follow written control room\nmanagement procedures that implement the requirements of this section, except that for\neach control room where an operator's activities are limited to either or both of:\n(i) Distribution with less than 250,000 services, or\n(ii) Transmission without a compressor station, the operator must have and follow written\nprocedures that implement only paragraphs (d) (regarding fatigue), (i) (regarding\ncompliance validation), and (j) (regarding compliance and deviations) of this section.\nTransCo's procedure titled, Williams Control Room Management Plan Revision 14 Effective 2/11/2020\n(CRM Plan), is inadequate because it did not provide guidance or structure to determine which of its\nfacilities are control rooms. During the inspection, TransCo indicated that internal discussions were held\nand a review was made to determine which facilities qualified as control rooms. The results of this study\nwere not available for review during the inspection. TransCo also stated that the main criteria for control\nroom determination was \"if the location operated assets outside the fence.\" However, this criteria was not\nfound in the CRM Plan.\nIn addition to the identified control rooms that include backup and interim facilities, TransCo states in its\nprocedure, 07.71.007-OG Control Room Evacuation Procedures Step 1.5, \"[t]he on-call Pipeline Control\nperson will remotely operate the pipeline, or perform manual operations .... until the Backup Control\nCenter or Interim Site, or Control Room is operational.\" The intent of this procedure is for supervisors\nand managers to log on to SCADA and operate remotely from their homes until a controller is relocated\nto the backup center or has access to the control room. Because the on-call controller can operate from\nhis/her home, TransCo needs to consider this in its control room determination process. All control\nrooms, regardless of location, are subject to the CRM regulations, as well as all procedures related to\ncontrol room operations.\nTransCo’s CRM Plan must be amended to include guidance and structure for a consistent process of\ncontrol room determination.\n2. § 192.631 Control room management.\n(a) . . . .\n(b) Roles and responsibilities. Each operator must define the roles and responsibilities of a\ncontroller during normal, abnormal, and emergency operating conditions. To provide for a\ncontroller's prompt and appropriate response to operating conditions, an operator must\ndefine each of the following:\n(1) . . . .\n(5) The roles, responsibilities and qualifications of others with the authority to direct or\nsupersede the specific technical actions of a controller.\nTransCo's CRM Plan is inadequate because it does not clearly provide the roles and responsibilities for\nothers with the authority to direct or supersede the specific technical actions of a controller. While the\nCRM Plan offers a process for superseding a controller, it does not support the described or\nexpected process, as described by TransCo personnel during the inspection.\nTransCo's CRM Plan stated that only qualified controllers can supersede a controller. TransCo has\nrecently qualified individuals as \"reserve\" controllers to serve as pandemic backup staffing. However,\n2\n\n\n\naccording to TransCo personnel, these individuals would never be considered someone who could\nsupersede a controller. The CRM Plan did not prohibit “reserve” controllers from directing or\nsuperseding controllers. TransCo personnel described the process of shift-change to requires a “verbal\nshift turnover” and “log onto the SCADA system”, however, there is no process in the CRM plan that\ncovers the requirements for a “verbal shift turnover” during a shift change. The CRM plan does not\ncontain any requirements for what should be covered during the verbal shift turnover, or how the\ndirecting or superseding documentation should be recorded and maintained.\nTransCo must review its process related to superseding a controller and update its CRM Plan to include\nspecific guidance for prohibitions on “reserve” controllers from being able to direct or supersede the\nspecific technical actions of a controller; to include requirements for what is to be reviewed during the\nshift turnover, and how the shift change process is to be documented.\n3. § 192.631 Control room management.\n(a) . . . .\n(h) Training. Each operator must establish a controller training program and review the\ntraining program content to identify potential improvements at least once each calendar\nyear, but at intervals not to exceed 15 months. An operator’s program must provide for\ntraining each controller to carry out the roles and responsibilities defined by the operator.\nIn addition, the training program must include the following elements:\n(1) . . . .\n(6) Control room team training and exercises that include both controllers and other\nindividuals, defined by the operator, who would reasonably be expected to operationally\ncollaborate with controllers (control room personnel) during normal, abnormal or\nemergency situations. Operators must comply with the team training requirements under\nthis paragraph by no later than January 23, 2018.\nTransCo's CRM Plan process is inadequate because the procedure does not clearly define the content\nfor control room team training and exercises that include both controllers and other individuals, defined\nby the operator, who would reasonably be expected to operationally collaborate with controllers (control\nroom personnel) during normal, abnormal or emergency situations. While TransCo provides controllers\ntraining for Smart Communications, the procedure does not lay out any requirements for soft skills\ntraining. Additionally, the procedure states, \"[i]ndividuals who may collaborate with the control room\nmay participate in annual team trainings.\" The procedure is missing requirements that the training\nprogram must include team training that include both controllers and other individuals, defined by the\noperator, who would reasonably be expected to operationally collaborate with controllers.\nThe procedure must be amended to include the content for team training, and require both controllers and\nother individuals, defined by the operator, who would reasonably be expected to operationally collaborate\nwith controllers (control room personnel) during normal, abnormal or emergency situations participate in\nteam training.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as part of\nthis Notice is a document entitled Response Options for Pipeline Operators in Enforcement\nProceedings. Please refer to this document and note the response options. Be advised that all material\nyou submit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C.\n3\n\n\n\n552(b), along with the complete original document you must provide a second copy of the document with\nthe portions you believe qualify for confidential treatment redacted and an explanation of why you\nbelieve the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or\na request for a hearing under § 190.211. If you do not respond within 30 days of receipt of this Notice,\nthis constitutes a 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 you and\nto issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R.\n§ 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures\nto my office within 30 days of receipt of this Notice. This period may be extended by written request for\ngood cause. Once the inadequacies identified herein have been addressed in your amended procedures,\nthis enforcement action will be closed.\nIt is requested that TransCo maintain documentation of the safety improvement costs associated with\nfulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to\nGregory A. Ochs, Director, Central Region, Pipeline and Hazardous Materials Safety Administration. In\ncorrespondence concerning this matter, please refer to CPF 3-2021-020-NOA and, for each document\nyou submit, please provide a copy in electronic format whenever possible.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: Edgar X. Rodriguez, Regulatory Compliance Specialist Sr. edgar.x.rodriguez@williams.com\n4","truncated":false,"body_characters":13489}