GAS TRANSMISSION NORTHWEST LLC — Warning Letter

520070015w_warning letter_04202007_text.pdf, page 1Official PDFo U S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 12300W Dakota Ave, SUtte tt0 Lakewood, CO 80228 WARNING LETTER CERTIFIED MAIL - RETURN RECEIPT RE UESTED April 20, 2007 Mr. Ross Parker Regional Director GTN and North Baja Systems 1400 SW 5'" Ave. Suite 900 , Portland, WA 97201 SENT TO COMPLIANCE REGISTRY Hardcopy Electromcally ¹ of Copies&/ Date ~Ã CPF No. 5-2007-0015W Dear Mr. Parker: Between November 13 and December 1, 2006, a representative of the Washington Utilities and Transportation Commission (WUTC) acting as an agent for the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Section 60106(a) of Title 49, United States Code, conducted an onsite pipeline safety inspection of your pipeline facilities in Washington State. As a result of the inspection, it appears that you have committed probable violations, as noted below, of the pipeline safety regulations Title 49, Code of Federal Regulations, Part 192. The probable violations are: $192. 619 Maximum allowable operating pressure: Steel or plastic pipelines. (a) Except as provided in paragraph (c) of this section, no person may operate a segment of steel or plastic pipeline at a pressure that exceeds the lowest of the following: (3) The highest actual operating pressure to which the segment was subjected during the 5 years preceding July 1, 1970 (or in the case of offshore gathering lines, July 1, 1976), unless the segment was tested in accordance with paragraph (a) (2) of this section after July 1, 1965 (or in the case of offshore gathering lines, July 1, 1971), or the segment was uprated in accordance with Subpart K of this part. GTN's A-Line (36-inch) was installed and tested in 1960. GTN was unable to provide all pressure records for the 5 year period immediately preceding July 1, 1970. Some partial records were made available from GTN's Portland office. The pipeline segments in Washington State may not have operated at the current MAOP during the 5 years preceding July 1, 1970 and GTN may have a lower regulatory-based MAOP than they are currently using.#

520070015w_warning letter_04202007_text.pdf, page 22. $192. 615(b) Emergency plans. (b) Each operator shall: (1) Furnish its supervisors who are responsible for emergency action a copy of that portion of the latest edition of the emergency procedures established under paragraph (a) of this section as necessary for compliance with those procedures. There was no Emergency manual on-site in the Starbuck compressor station. Apparently the operations supervisor keeps the E-plan in his vehicle which is not always present and on-site. TransCanada procedure OMI V-2 states "each supervisor shall keep the emergency procedures manual in each office in a clearly designated location. It could be argued that TransCanada does not consider the Starbuck compressor station to be an office. The issue is that there are people working there eriodically and the supervisor may or may not be present. Therefore, the manual would not p always be on-site in an emergency until the supervisor arrived. Under 49 United States Code, g 60122, you are subject to a civil penalty not to exceed $100, 000 for each violation for each day the violation persists up to a maximum of $1, 000, 000 for any 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 GTN 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 5-2007-0015W. 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 materia ' I 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 s Hoidal c Director, Western Region Pipeline and Hazardous Materials Safety Administration cc: Alan Rathbun, WUTC David Lykken, WUTC PHP-60 Compliance Registry PHP-500 Tom Finch#