# VIKING GAS TRANSMISSION CO — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 32025007NOPV
- **title:** VIKING GAS TRANSMISSION CO — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2025-06-25
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 191.22(c)(1)(i), 192.605(a), 192.907(a), 192.935(a).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/32025007NOPV
**body:**

Notice of Probable Violation involving VIKING GAS TRANSMISSION CO. PHMSA's enforcement data identifies the cited regulations as 191.22(c)(1)(i),  192.605(a),  192.907(a),  192.935(a). The case was opened on 2025-06-25 and is reported as closed as of 2025-12-30. Proposed civil penalty: $53,900. Assessed civil penalty: $53,900. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

32025007NOPV_Closure Letter_12302025_(23-264832).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025007NOPV/32025007NOPV_Closure%20Letter_12302025_(23-264832).pdf

32025007NOPV_Closure Letter_12302025_(23-264832)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025007NOPV/32025007NOPV_Closure%20Letter_12302025_(23-264832)_text.pdf

32025007NOPV_Final Order_09262025_(23-264832).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025007NOPV/32025007NOPV_Final%20Order_09262025_(23-264832).pdf

32025007NOPV_Final Order_09262025_(23-264832)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025007NOPV/32025007NOPV_Final%20Order_09262025_(23-264832)_text.pdf

32025007NOPV_Operator Response to Notice_07252025_(23-264832).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025007NOPV/32025007NOPV_Operator%20Response%20to%20Notice_07252025_(23-264832).pdf

32025007NOPV_PCP PCO_06252025_(23-264832).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025007NOPV/32025007NOPV_PCP%20PCO_06252025_(23-264832).pdf

32025007NOPV_PCP PCO_06252025_(23-264832)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025007NOPV/32025007NOPV_PCP%20PCO_06252025_(23-264832)_text.pdf

32025007NOPV_Closure Letter_12302025_(23-264832)_text.pdf

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
901 Locust Street, Suite 480
Kansas City, MO 64106
VIA ELECTRONIC MAIL TO: david.slater@dtmidstream.com;
chris.zona@dtmidstream.com; philip.coleman@dtmidstream.com;
patrick.raichel@dtmidstream.com
December 30, 2025
David Slater
President and Chief Executive Officer
Viking Gas Transmission Co.
500 Woodward Ave., Suite 2900
Detroit, Michigan 48226
RE: CPF 3-2025-007-NOPV
Dear Mr. Slater:
On September 26, 2025, the Pipeline and Hazardous Materials Safety Administration (PHMSA)
issued to Viking Gas Transmission Co. (VGT) a Final Order, pursuant to 49 CFR § 190.213, in
the above-referenced case. This Order included a Compliance Order and Civil Penalty assessment.
Based on our review of the documentation provided and confirmation of payment of the civil
penalty, it has been determined that VGT has complied with the terms of the Order.
Accordingly, this case is now closed, and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
David Barrett
Acting Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Chris Zona, Chief Operating Officer, VGT, chris.zona@dtmidstream.com
Philip Coleman, Director, Code & Regulatory, VGT philip.coleman@dtmidstream.com
Patrick Rachel, Manager Codes and Compliance, VGT, patrick.raichel@dtmidstream.com
.

32025007NOPV_Final Order_09262025_(23-264832)_text.pdf

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Avenue, SE
Washington, DC 20590
September 26, 2025
VIA ELECTRONIC MAIL TO: david.slater@dtmidstream.com
David Slater
President and Chief Executive Officer
Viking Gas Transmission Co.
500 Woodward Avenue, Suite 2900
Detroit, Michigan 48226
Re: CPF No. 3-2025-007-NOPV
Dear Mr. Slater:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation, assesses a civil penalty of $53,900, and specifies actions that need to be taken by
Viking Gas Transmission Co. to comply with the pipeline safety regulations. The penalty
payment terms are set forth in the Final Order. When the civil penalty has been paid and the
terms of the compliance order completed, as determined by the Director, Central Region, this
enforcement action will be closed. Service of the Final Order by e-mail is effective upon the date
of transmission and acknowledgement of receipt as provided under 49 CFR § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Linda Daugherty
Acting Associate Administrator
for Pipeline Safety
Enclosure
cc: David Barrett, Acting Director, Central Region, Office of Pipeline Safety, PHMSA
Christopher Zona, Chief Operating Officer, Viking Gas Transmission Co.,
chris.zona@dtmidstream.com
Philip Coleman, DTM Director of Codes & Regulatory, Viking Gas Transmission Co.,
philip.coleman@dtmidstream.com



CPF No. 3-2025-007-NOPV
Page 2
Patrick Rachel, DTM Manager of Codes and Compliance, Viking Gas Transmission Co.,
patrick.raichel@dtmidstream.com
CONFIRMATION OF RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Viking Gas Transmission Co., ) CPF No. 3-2025-007-NOPV
a subsidiary of DT Midstream, )
)
)
)
Respondent. )
____________________________________)
FINAL ORDER
From February 27 through October 16, 2023, pursuant to 49 U.S.C. § 60117, representatives of
the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
(OPS), conducted an on-site pipeline safety inspection of the facilities and records of Viking Gas
Transmission Co. (VGT or Respondent) in Wisconsin and North Dakota. Respondent operates
the Viking Gas Transmission pipeline, which is a 674-mile bi-directional interstate gas pipeline
that serves utility customers in Minnesota, Wisconsin, and North Dakota.1
As a result of the inspection, the Acting Director, Central Region, OPS (Director), issued to
Respondent, by letter dated June 25, 2025, a Notice of Probable Violation, Proposed Civil
Penalty, and Proposed Compliance Order (Notice). In accordance with 49 CFR § 190.207, the
Notice proposed finding that VGT had committed four violations of 49 CFR Part 192, proposed
assessing a civil penalty of $53,900 for the alleged violations, and proposed ordering Respondent
to take certain measures to correct the alleged violations. The Notice also included an additional
three warning items pursuant to 49 CFR § 190.205, which warned Respondent to correct the
probable violations or face possible future enforcement action.
VGT responded to the Notice by letter dated July 25, 2025 (Response). Respondent did not
contest the allegations of violation but requested modifications to the proposed compliance order
and that the proposed civil penalty be eliminated. Respondent did not request a hearing and
therefore has waived its right to one.
1 DT Midstream, Viking Gas Transmission, https://dtmidstream.com/asset/viking-gas-transmission/ (last visited
Aug. 11, 2025).



CPF No. 3-2025-007-NOPV
Page 2
FINDINGS OF VIOLATION
In its Response, Respondent did not contest the allegations in the Notice that it violated 49 CFR
Part 192, as follows:
Item 3: The Notice alleged that Respondent violated 49 CFR § 192.907(a), which states:
§ 192.907 What must an operator do to implement this subpart?
(a) General. No later than December 17, 2004, an operator of a covered
pipeline segment must develop and follow a written integrity management
program that contains all the elements described in § 192.911 and that
addresses the risks on each covered transmission pipeline segment. The
initial integrity management program must consist, at a minimum, of a
framework that describes the process for implementing each program
element, how relevant decisions will be made and by whom, a time line for
completing the work to implement the program element, and how
information gained from experience will be continuously incorporated into
the program. The framework will evolve into a more detailed and
comprehensive program. An operator must make continual improvements
to the program.
The Notice alleged that Respondent violated 49 CFR § 192.907(a) by failing to follow its written
integrity management program. Specifically, the Notice alleged that VGT failed to determine the
corrosion growth rate to predict future metal wall loss for the Milaca Station 2217 to Osceola
Station 2222 after a 2017 inline inspection (ILI).
Respondent did not contest this allegation of violation. Accordingly, I find that Respondent
violated 49 CFR § 192.907(a) by failing to follow its written integrity management program.
Item 4: The Notice alleged that Respondent violated 49 CFR § 192.907(a), which states:
§ 192.907 What must an operator do to implement this subpart?
(a) General. No later than December 17, 2004, an operator of a covered
pipeline segment must develop and follow a written integrity management
program that contains all the elements described in § 192.911 and that
addresses the risks on each covered transmission pipeline segment. The
initial integrity management program must consist, at a minimum, of a
framework that describes the process for implementing each program
element, how relevant decisions will be made and by whom, a time line for
completing the work to implement the program element, and how
information gained from experience will be continuously incorporated into
the program. The framework will evolve into a more detailed and
comprehensive program. An operator must make continual improvements
to the program.



CPF No. 3-2025-007-NOPV
Page 3
The Notice alleged that Respondent violated 49 CFR § 192.907(a) by failing to follow its written
integrity management program. Specifically, the Notice alleged that VGT failed to document its
decisions not to investigate or remediate metal wall loss anomalies that exceeded 50%.
Respondent did not contest this allegation of violation. Accordingly, I find that Respondent
violated 49 CFR § 192.907(a) by failing to follow its written integrity management program.
Item 5: The Notice alleged that Respondent violated 49 CFR § 192.907(a), which states:
§ 192.907 What must an operator do to implement this subpart?
(a) General. No later than December 17, 2004, an operator of a covered
pipeline segment must develop and follow a written integrity management
program that contains all the elements described in § 192.911 and that
addresses the risks on each covered transmission pipeline segment. The
initial integrity management program must consist, at a minimum, of a
framework that describes the process for implementing each program
element, how relevant decisions will be made and by whom, a time line for
completing the work to implement the program element, and how
information gained from experience will be continuously incorporated into
the program. The framework will evolve into a more detailed and
comprehensive program. An operator must make continual improvements
to the program.
The Notice alleged that Respondent violated 49 CFR § 192.907(a) by failing to follow its written
integrity management program. Specifically, the Notice alleged that VGT failed to incorporate
ILI data regarding internal and external corrosion in its risk model.
Respondent did not contest this allegation of violation. Accordingly, I find that Respondent
violated 49 CFR § 192.907(a) by failing to follow its written integrity management program.
Item 6: The Notice alleged that Respondent violated 49 CFR § 192.907(a), which states:
§ 192.907 What must an operator do to implement this subpart?
(a) General. No later than December 17, 2004, an operator of a covered
pipeline segment must develop and follow a written integrity management
program that contains all the elements described in § 192.911 and that
addresses the risks on each covered transmission pipeline segment. The
initial integrity management program must consist, at a minimum, of a
framework that describes the process for implementing each program
element, how relevant decisions will be made and by whom, a time line for
completing the work to implement the program element, and how
information gained from experience will be continuously incorporated into
the program. The framework will evolve into a more detailed and
comprehensive program. An operator must make continual improvements
to the program.



CPF No. 3-2025-007-NOPV
Page 4
The Notice alleged that Respondent violated 49 CFR § 192.907(a) by failing to develop and
follow a written integrity management program that contains all the elements described in 49
CFR § 192.911. Specifically, the Notice alleged that VGT failed to develop procedures to
identify threats, conduct risk assessments, and evaluate the merits of additional preventive and
mitigative measures to protect each covered segment as required by 49 CFR § 192.911(c).
Respondent did not contest this allegation of violation. Accordingly, I find that Respondent
violated 49 CFR § 192.907(a) by failing to develop and follow a written integrity management
program that contains all the elements described in 49 CFR § 192.911.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty exceeding
$200,000 per violation for each day of the violation, with a maximum administrative civil
penalty exceeding $2,000,000 for any related series of violations.2
In determining the amount of a civil penalty under 49 U.S.C. § 60122 and 49 CFR § 190.225, I
must consider the following criteria: the nature, circumstances, and gravity of the violation,
including adverse impact on the environment; the degree of Respondent’s culpability; the history
of Respondent’s prior offenses; any effect that the penalty may have on its ability to continue
doing business; the good faith of Respondent in attempting to comply with the pipeline safety
regulations; and self-disclosure or actions to correct a violation prior to discovery by PHMSA.
In addition, I may consider the economic benefit gained from the violation without any reduction
because of subsequent damages, and such other matters as justice may require.
Item 5: The Notice proposed a civil penalty of $53,900 for Respondent’s violation of 49 CFR
§ 192.907(a), for failing to follow its written integrity management program. Respondent argued
the proposed civil penalty should be withdrawn because it is related to conduct that occurred
under the prior owner. The Associate Administrator for Pipeline Safety has determined that a
transfer of ownership does not relieve the acquiring entity of civil penalties for violations of
pipeline safety laws or regulations committed under prior ownership.
3 Moreover, PHMSA
recently emphasized in the July 17, 2025 memo, “Inspection and Enforcement Priorities,” that
“safety and compliance obligations [] persist across transactions” and that any “enforcement
orders … remain applicable to the transferred pipeline and therefore become the responsibility of
2 These amounts are adjusted annually for inflation. See 49 CFR § 190.223 for adjusted amounts.
3 Western Refining Pipeline, LLC, a subsidiary of Marathon Petroleum Corp., CPF No. 4-2018-5014, 2019 WL
6840345, at *2 (July 12, 2019) (“Further, the fact that Andeavor acquired Western after PHMSA’s inspection does
not absolve either entity from culpability for violations of the Pipeline Safety Regulations.”).



CPF No. 3-2025-007-NOPV
Page 5
the buyers as part of the transaction process.”4 Respondent did not otherwise contest the Item 5
allegation of violation or any of the statutory civil penalty assessment factors. I therefore find no
reason to reduce or withdraw the proposed civil penalty. Accordingly, having reviewed the
record and considered the assessment criteria, I assess Respondent a civil penalty of $53,900 for
violation of 49 CFR § 192.907(a).
Payment of the civil penalty must be made within 20 days after receipt of this Final Order.
Federal regulations (49 CFR § 89.21(b)(3)) require such payment to be made by wire transfer
through the Federal Reserve Communications System (Fedwire), to the account of the U.S.
Treasury. Detailed instructions are contained in the enclosure. Questions concerning wire
transfers should be directed to: Financial Operations Division (AMK-325), Federal Aviation
Administration, Mike Monroney Aeronautical Center, 6500 S MacArthur Blvd, Oklahoma City,
Oklahoma 79169. The Financial Operations Division telephone number is (405) 954-8845.
Failure to pay the civil penalty will result in accrual of interest at the current annual rate in
accordance with 31 U.S.C. § 3717, 31 CFR § 901.9 and 49 CFR § 89.23. Pursuant to those same
authorities, a late penalty charge of six percent (6%) per annum will be charged if payment is not
made within 110 days of service. Furthermore, failure to pay the civil penalty may result in
referral of the matter to the Attorney General for appropriate action in a district court of the
United States.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Items 3, 4, and 6 in the Notice for
violations of 49 CFR §§ 192.907(a), 192.907(a), and 192.907(a), respectively. Under 49 U.S.C.
§ 60118(a), each person who engages in the transportation of gas or who owns or operates a
pipeline facility is required to comply with the applicable safety standards established under
chapter 601.
With regard to the violation of section 192.907(a) (Item 3), Respondent requested that it provide
the DT Midstream Transmission Integrity Management Program to satisfy this corrective
measure instead of amending the procedure used by the prior owner and referenced in the Notice.
Respondent also requested an additional 90 days to complete this corrective measure. I find that
the proposed modification is reasonable, however the time extension is not necessary at this time.
Paragraph 4 of the Compliance Order directs the Respondent to provide a status update if the 90-
day deadline is not achieved.
With regard to the violation of section 192.907(a) (Item 4), Respondent requested an additional
180 days to complete the corrective measure. I find that the time extension is not necessary at
this time. Paragraph 4 of the Compliance Order directs the Respondent to provide a status update
if the 90-day deadline is not achieved.
4 PHMSA, Inspection and Enforcement Priorities, at 7 (July 17, 2025), https://www.phmsa.dot.gov/regulatory-
compliance/phmsa-guidance/phmsa-pipeline-safety-inspection-and-enforcement-priorities.



CPF No. 3-2025-007-NOPV
Page 6
With regard to the violation of section 192.907(a) (Item 6), Respondent requested an additional
90 days to complete the corrective measure. I find that the time extension is not necessary at this
time. Paragraph 4 of the Compliance Order directs the Respondent to provide a status update if
the 90-day deadline is not achieved.
For the above reasons, the Compliance Order is modified as set forth below.
Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 CFR § 190.217, Respondent is ordered
to take the following actions to ensure compliance with the pipeline safety regulations applicable
to its operations:
1. With respect to the violation of section 192.907(a) (Item 3), Respondent must
submit its integrity management program that does not allow for an unverified zero-
percent growth rate to the Director within 90 days of receipt of the Final Order.
2. With respect to the violation of section 192.907(a) (Item 4), Respondent must
submit to the Director 1) a run comparison from the 2017 ILI run and the 2024 ILI
run for the Milaca to Osceola segment and 2) an evaluation of each anomaly listed in
the DI Form Table included under Item 5 for the Ada to Frazee segment and the
Frazee to Cushing segment within 90 days of receipt of the Final Order.
3. With respect to the violation of section 192.907(a) (Item 6), Respondent must
submit procedures conforming with the requirements of 49 CFR § 192.911 within 90
days of receipt of the Final Order.
4. If any of the corrective measures in paragraphs 1-3 extend beyond 90 days to
complete, Respondent must submit to the Director on the 90th day a report on all
outstanding work necessary to implement each corrective measure. Respondent must
submit follow-up reports to the Director every 90 days thereafter until all work
necessary to implement each corrective measure is completed.
The Director may grant an extension of time to comply with any of the required items upon a
written request timely submitted by the Respondent and demonstrating good cause for an
extension.
PHMSA requests that Respondent maintain documentation of the safety improvement costs
associated with fulfilling this Compliance Order and submit the total to the Director. It is
requested that these costs be reported in two categories: (1) total cost associated with
preparation/revision of plans, procedures, studies and analyses; and (2) total cost associated with
replacements, additions and other changes to pipeline infrastructure.
Failure to comply with this Order may result in the administrative assessment of civil penalties
exceeding $200,000, as adjusted for inflation (see 49 CFR § 190.223 for adjusted amounts), for
each violation for each day the violation continues or in referral to the Attorney General for
appropriate relief in a district court of the United States.



CPF No. 3-2025-007-NOPV
Page 7
WARNING ITEMS
With respect to Items 1, 2, and 7, the Notice alleged probable violations of Parts 191 and 192,
but identified them as warning items pursuant to section 190.205. The warnings were for:
49 CFR § 191.22(c)(1)(i) (Item 1) ─ Respondent’s alleged failure to notify
PHMSA not later than 60 days before commencing construction that costs $10
million or more;
49 CFR § 192.605(a) (Item 2) ─ Respondent’s alleged failure to follow its a
manual of written procedures for conducting operations and maintenance
activities and for emergency response; and
49 CFR § 192.935(a) (Item 7) ─ Respondent’s alleged failure to take additional
measures beyond those already required by Part 192 to prevent a pipeline failure
and to mitigate the consequences of a pipeline failure in a high consequence area.
If OPS finds a violation of any of these items in a subsequent inspection, Respondent may be
subject to future enforcement action.
Under 49 CFR § 190.243, Respondent may submit a Petition for Reconsideration of this Final
Order to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey
Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of
Chief Counsel, PHMSA, at the same address. The written petition must be received no later than
20 days after receipt of the Final Order by Respondent. Any petition submitted must contain a
statement of the issue(s) and meet all other requirements of 49 CFR § 190.243. The filing of a
petition automatically stays the payment of any civil penalty assessed. The other terms of the
order, including corrective action, remain in effect unless the Associate Administrator, upon
request, grants a stay. The terms and conditions of this Final Order are effective upon service in
accordance with 49 CFR § 190.5.
___________________________________ __________________________
Linda Daugherty Date Issued
Acting Associate Administrator
for Pipeline Safety
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