{"operation":"document","citation":"CPF 12025035WL","title":"GAS TRANSMISSION NORTHWEST LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-10-10","effective_on":null,"summary":"CLOSED warning letter citing 192.619(a)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025035wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025035wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025035wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12025035WL","body":"Warning Letter involving GAS TRANSMISSION NORTHWEST LLC. PHMSA's enforcement data identifies the cited regulation as 192.619(a)(1). The case was opened on 2025-10-10 and is reported as closed as of 2025-10-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12025035WL_Warning Letter_10102025_(23-263953).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025035WL/12025035WL_Warning%20Letter_10102025_(23-263953).pdf\n\n12025035WL_Warning Letter_10102025_(23-263953)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025035WL/12025035WL_Warning%20Letter_10102025_(23-263953)_text.pdf\n\n12025035WL_Warning Letter_10102025_(23-263953)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: david brast@tcenergy.com\nOctober 10, 2025\nMr. David Brast\nPresident and Chief Executive Officer\nGas Transmission Northwest LLC\n700 Louisiana Street\nHouston, Texas 77002\nCPF 1-2025-035-WL\nDear Mr. Brast:\nFrom March 26, 2023 to April 17, 2024, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.)\ninspected Gas Transmission Northwest LLC’s (GTN) pipeline facility records in Idaho and\nOregon.\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 and\nthe probable violation is:\n1. § 192.619 Maximum allowable operating pressure: Steel or plastic pipelines.\n(a) No person may operate a segment of steel or plastic pipeline at a\npressure that exceeds a maximum allowable operating pressure\n(MAOP) determined under paragraph (c), (d), or (e) of this section, or\nthe lowest of the following:\n(1) The design pressure of the weakest element in the segment,\ndetermined in accordance with subparts C and D of this part. However,\nfor steel pipe in pipelines being converted under § 192.14 or uprated\nunder subpart K of this part, if any variable necessary to determine the\ndesign pressure under the design formula (§ 192.105) is unknown, one\nof the following pressures is to be used as design pressure:\n\n\n\nGTN failed to establish its maximum allowable operating pressure (MAOP) in accordance with\nsection 192.619(a). Specifically, GTN failed to determine the design pressure of all valves, tees,\nand elbows on its A Line, B Line, C Line, and Medford Lateral pipelines as required by section\n192.619(a)(1), and failed to use the correct longitudinal joint factor for pipe with unknown seam\ntype as required by section 192.113(b) when calculating the design pressure.\nDuring the inspection, PHMSA reviewed GTN’s MAOP calculation and test records and\ndetermined that GTN failed to determine the design pressure of all valves, tees, and elbows on its\nA Line, B Line, C Line, and Medford Lateral pipelines. In addition, the required information of\npipe seam type was listed as an unknown property for approximately 500 miles of pipeline.\nHowever, when calculating design pressure under subpart C GTN used a longitudinal joint factor\nof 1.00, contrary to section 192.113(b), which states that if the type of seam is unknown, the\nlongitudinal joint factor cannot exceed .60 or .80, depending on pipe diameter.\nTherefore, GTN failed to establish its MAOP in accordance with section 192.619(a).\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 related\nseries of violations. For violation occurring on or after December 28, 2023 and before December\n30, 2024, the maximum penalty may not exceed $266,015 per violation per day the violation\npersists, up to a maximum of $2,660,135 for a related series of violations. For violation occurring\non or after January 6, 2023 and before December 28, 2023, the maximum penalty may not exceed\n$257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related\nseries of violations. For violation occurring on or after March 21, 2022 and before January 6, 2023,\nthe maximum penalty may not exceed $239,142 per violation per day the violation persists, up to\na maximum of $2,391,142 for a related series of violations. For violation occurring on or after\nMay 3, 2021 and before March 21, 2022, the maximum penalty may not exceed $225,134 per\nviolation per day the violation persists, up to a maximum of $2,251,334 for a related series of\nviolations. For violation occurring on or after January 11, 2021 and before May 3, 2021, the\nmaximum penalty may not exceed $222,504 per violation per day the violation persists, up to a\nmaximum of $2,225,034 for a related series of violations. For violation occurring on or after July\n31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per\nviolation per day the violation persists, up to a maximum of $2,186,465 for a related series of\nviolations.\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 may result in Gas\nTransmission Northwest LLC 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 1-2025-035-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\n\n\n\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,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":6148}