{"operation":"document","citation":"CPF 32021021WL","title":"TRANSCONTINENTAL GAS PIPE LINE COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-04-07","effective_on":null,"summary":"CLOSED warning letter citing 192.631(a)(1), 192.631(c)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021021wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021021wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021021wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32021021WL","body":"Warning Letter involving TRANSCONTINENTAL GAS PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 192.631(a)(1),  192.631(c)(4). The case was opened on 2021-04-07 and is reported as closed as of 2021-04-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32021021WL_Warning Letter_04072021_(20-173057).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021021WL/32021021WL_Warning%20Letter_04072021_(20-173057).pdf\n\n32021021WL_Warning Letter_04072021_(20-173057)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021021WL/32021021WL_Warning%20Letter_04072021_(20-173057)_text.pdf\n\n32021021WL_Warning Letter_04072021_(20-173057)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: alan.armstrong@williams.com & edgar.x.rodriguez@williams.com\nApril 7, 2021\nMr. Alan Armstrong\nPresident & CEO\nTranscontinental Gas Pipeline Company\nOne Williams Center\nPO Box 2400\nTulsa, OK 74102-2400\nCPF-3-2021-021-WL\nDear Mr. Armstrong:\nOn May 4 – 8, 2020, a representative of the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) and New York State Department of Public Service pursuant to Chapter 601 of 49 United States\nCode (U.S.C.) inspected your Control Room Management Plan and Control Room Records in Houston, TX.\nThe inspection pertained to OPID’s 19750/Transcontinental Gas Pipeline Company, 31565/Gulf Stream\nManagement & Operating Services, LLC, 32684/Pine Needle Operating Company, LLC and\n32657/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 inspections\nwill remain unchanged.\nAs a result of the inspection, it is alleged that you have committed probable violations of the Pipeline Safety\nRegulations, Title 49, Code of Federal Regulations (CFR). The item(s) inspected and the probable\nviolation(s) are:\n\n\n\n1. 192.631 Control room management\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller working in a\ncontrol room who monitors and controls all or part of a pipeline facility through a SCADA\nsystem. Each operator must have and follow written control room management procedures\nthat implement the requirements of this section, except that for each control room where an\noperator’s activities are limited to either or both of:\nTransCo failed to adequately implement their procedure to review and determine effectiveness of their\nAlarm Management Plan as required in Section §192.631(e)(4). A review of the records, presented for\ninspection, for the annual review of TransCo's Alarm Management Plan, for 2017, 2018 and 2019, revealed\nthat the review did not meet TransCo's procedural requirements defined in Section 700.604 in Williams\nControl Room Management Plan Revision 14 Effective 2/11/2020 to evaluate the effectiveness of their\nAlarm Management Plan. The procedure provides four bullet points that the procedure states the annual\nreview will include in the review. The records, for the annual reviews, indicated the review process missed\naddressing these bullet points and simply completed a review of the language of the procedure. During\ndiscussion, it was stated that they used their kpi metric to determine if the plan was effective. A review of\nthe monthly report to officers, used as an evaluation metric for the Alarm Management Plan effectiveness,\nstill did not cover the four bullet points.\n2. 192.631 Control room management\nc) Provide adequate information. Each operator must provide its controllers with the\ninformation, tools, processes and procedures necessary for the controllers to carry out the\nroles and responsibilities the operator has defined by performing each of the following:\n(1)…\n(2) …\n(3) …\n(4) Test any backup SCADA systems at least once each calendar year, but at intervals not to\nexceed 15 months; and\nTransCo failed to test the Station 35 Interim back up facility in 2017 and 2019. Station 35 Interim control\nroom back up is a facility that is logistically very close to the primary control room and only intended for\nshort duration use. It shares a secure space within Compressor Station 35 building facilities and was listed\nas a backup control center/interim site in procedure 07.71.007-OG Control Room Evacuation Procedures\nStep 2.0. The backup interim site/Station 35 was tested, subsequently, in 2018, as part of the control room\nevacuation test.\nAdditionally, in November 2018, TransCo brought up the SCADA servers at their back up Station\n200/Pennsylvania, transferred control to those servers and operated from the Station 35 Interim Site due to a\nfire on the floor above the control room. This actual operation served as the backup test.\nTransCo stated they did not perform the full test at Station 200/Pennsylvania, primary back up, in May\n2018, because in 2017 they operated from the station during Hurricane Harvey. They only transferred to the\nprimary servers and operated under that system to verify the Pennsylvania servers function and connection.\n2\n\n\n\nThe purpose of testing back up control centers is intended to test the whole process of building access,\ntravel to the site, making sure utilities are working, systems and applications are functional. In other words,\nat that point in time, of the test, the facility was proven to be fully functional as intended and any issues\nidentified will be corrected and addressed. It does not matter if it is considered a minor facility or if it was\noperated long term the year before, the language is clear, backup SCADA systems (HMI’s, servers, printers,\ncommunications, building security, etc.) must be tested at least once each calendar year, but at intervals not\nto exceed 15 months.\nFollow up by TransCo: After the inspection, TransCo relocated the back up control room from Station 200\nto Tulsa, Oklahoma. This was also reflected in their CRM Plan.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for a related\nseries of violations. For violation occurring on or after July 31, 2019 and before January 11, 2021,\nthe maximum penalty may not exceed $218,647 per violation per day the violation persists, up to a\nmaximum of $2,186,465 for a related series of violations. For violation occurring on or after\nNovember 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per\nviolation per day, with a maximum penalty not to exceed $2,132,679. For violation occurring on\nor after November 2, 2015 and before November 27, 2018, the maximum penalty may not exceed\n$209,002 per violation per day, with a maximum penalty not to exceed $2,090,022.\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 time.\nWe advise you to correct the item(s) identified in this letter. Failure to do so will result in\nTranscontinental Gas Pipeline 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 3-2021-021-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 the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nGregory A. Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Edgar X. Rodriguez, Regulatory Compliance Specialist Sr. edgar.x.rodriguez@williams.com\n3","truncated":false,"body_characters":8303}