# NORTH BAJA PIPELINE LLC — Warning Letter

**Citation:** CPF 520191008W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2019-02-12

CLOSED warning letter citing 192.807(a), 192.807(b).

## Document text

Warning Letter involving NORTH BAJA PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 192.807(a),  192.807(b). The case was opened on 2019-02-12 and is reported as closed as of 2019-02-12. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520191008W_Warning Letter_02122019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520191008W/520191008W_Warning%20Letter_02122019.pdf

520191008W_Warning Letter_02122019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520191008W/520191008W_Warning%20Letter_02122019_text.pdf

520191008W_Warning Letter_02122019_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
February 12, 2019
Ms. Sonya Kirby
Vice President, Safety, Quality & Compliance
North Baja Pipeline, LLC
PO Box 1000
Station M
Calgary AB Canada
T2P 4K5
CPF 5-2019-1008W
Dear Mr. Chapman:
From May 14 through 20, 2018, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), Office of Pipeline Safety (OPS), and the State of Arizona’s Corporation
Commission, pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected North Baja
Pipeline, LLC’s (North Baja) natural gas transmission pipeline system near Yuma, Arizona. We also
reviewed your operation, maintenance and emergency response procedures and supporting records at
your Spokane office from April 16 through 20, 2018, and again from September 4 through 6, 2018.
Based on our inspection findings, PHMSA determined that North Baja committed probable violations
of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The deficiencies
noted and the probable violations are:



1. §192.807 Recordkeeping.
Each operator shall maintain records that demonstrate compliance with this subpart.
(a) Qualification records shall include:
(1) Identification of qualified individual(s);
(2) Identification of the covered tasks the individual is qualified to perform; and
(3) Date(s) of current qualification; and
(4) Qualification methods.
(b) Records supporting an individual’s current qualification shall be maintained
while the individual is performing the covered task. Records of prior qualification and
records of individuals no longer performing covered tasks shall be retained for a period
of five years.
Available records did not indicate the company personnel who performed corrosion control work
maintained qualification as required by §192.807. Although the individuals stated that they
remembered being qualified through the OQ program, documentation could not be located.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$209,002 per violation per day the violation persists, up to a maximum of $2,090,022 for a related series
of violations. For violations occurring prior to November 2, 2015, the maximum penalty may not exceed
$200,000 per violation per day, with a maximum penalty not to exceed $2,000,000 for a related series
of violations. 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 correct the item(s) identified in this letter. Failure to do so will result in North
Baja being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF
5-2019-1008W. Be advised that all material you submit in response to this enforcement action is
subject to being 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).
Sincerely,
Chris Hoidal
Acting Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 J. Stahoviak (#159064)
Arizona Corporation Commission
2

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/520191008W>
- Source ID: `phmsa-enforcement`
- SHA-256: `65bf08158bfdb98232d64cf2b3e1c784d6ed02b23e868d742604e64ca8fe703f`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T23:36:58.317Z
- Document slug: `phmsa-enforcement-520191008w`

### Source metadata

```json
{
  "cpf": "520191008W",
  "operator": "NORTH BAJA PIPELINE LLC",
  "region": "Western",
  "pipelineType": "GAS INTERSTATE ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "192.807(a)",
    "192.807(b)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
    {
      "name": "520191008W_Warning Letter_02122019.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520191008W/520191008W_Warning%20Letter_02122019.pdf",
      "bytes": 79948,
      "category": "agency_document"
    },
    {
      "name": "520191008W_Warning Letter_02122019_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520191008W/520191008W_Warning%20Letter_02122019_text.pdf",
      "bytes": 106982,
      "category": "agency_document"
    }
  ],
  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "NORTH BAJA PIPELINE LLC"
}
```
