{"operation":"document","citation":"CPF 520070015W","title":"GAS TRANSMISSION NORTHWEST LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-04-20","effective_on":null,"summary":"CLOSED warning letter citing 192.615(b)(1), 192.619(a)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520070015w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520070015w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520070015w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520070015W","body":"Warning Letter involving GAS TRANSMISSION NORTHWEST LLC. PHMSA's enforcement data identifies the cited regulations as 192.615(b)(1),  192.619(a)(3). The case was opened on 2007-04-20 and is reported as closed as of 2007-04-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520070015W_Warning Letter_04202007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520070015W/520070015W_Warning%20Letter_04202007.pdf\n\n520070015w_warning letter_04202007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520070015W/520070015w_warning%20letter_04202007_text.pdf\n\n520070015w_warning letter_04202007_text.pdf\n\no\nU S. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n12300W Dakota Ave, SUtte tt0\nLakewood, CO 80228\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nApril 20, 2007\nMr. Ross Parker\nRegional Director\nGTN and North Baja Systems\n1400 SW 5'\" Ave.\nSuite 900\n,\nPortland, WA 97201\nSENT TO COMPLIANCE REGISTRY\nHardcopy Electromcally\n¹ of Copies&/ Date ~Ã\nCPF No. 5-2007-0015W\nDear Mr. Parker:\nBetween November 13 and December 1, 2006, a representative of the Washington Utilities and\nTransportation Commission (WUTC) acting as an agent for the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Section 60106(a) of Title 49, United States Code,\nconducted an onsite pipeline safety inspection of your pipeline facilities in Washington State.\nAs a result of the inspection, it appears that you have committed probable violations, as noted below,\nof the pipeline safety regulations Title 49, Code of Federal Regulations, Part 192. The probable\nviolations are:\n$192. 619 Maximum allowable operating pressure: Steel or plastic pipelines.\n(a) Except as provided in paragraph (c) of this section, no person may operate a segment\nof steel or plastic pipeline at a pressure that exceeds the lowest of the following:\n(3) The highest actual operating pressure to which the segment was subjected\nduring the 5 years preceding July 1, 1970 (or in the case of offshore gathering\nlines, July 1, 1976), unless the segment was tested in accordance with paragraph\n(a) (2) of this section after July 1, 1965 (or in the case of offshore gathering lines,\nJuly 1, 1971), or the segment was uprated in accordance with Subpart K of this\npart.\nGTN's A-Line (36-inch) was installed and tested in 1960. GTN was unable to provide all\npressure records for the 5 year period immediately preceding July 1, 1970. Some partial\nrecords were made available from GTN's Portland office. The pipeline segments in\nWashington State may not have operated at the current MAOP during the 5 years preceding\nJuly 1, 1970 and GTN may have a lower regulatory-based MAOP than they are currently\nusing.\n\n\n\n2. $192. 615(b) Emergency plans.\n(b) Each operator shall:\n(1) Furnish its supervisors who are responsible for emergency action a copy of\nthat portion of the latest edition of the emergency procedures established\nunder paragraph (a) of this section as necessary for compliance with those\nprocedures.\nThere was no Emergency manual on-site in the Starbuck compressor station. Apparently the\noperations supervisor keeps the E-plan in his vehicle which is not always present and on-site.\nTransCanada procedure OMI V-2 states \"each supervisor shall keep the emergency procedures\nmanual in each office in a clearly designated location. It could be argued that TransCanada does not\nconsider the Starbuck compressor station to be an office. The issue is that there are people working\nthere eriodically and the supervisor may or may not be present. Therefore, the manual would not\np\nalways be on-site in an emergency until the supervisor arrived.\nUnder 49 United States Code, g 60122, you are subject to a civil penalty not to exceed $100, 000 for\neach violation for each day the violation persists up to a maximum of $1, 000, 000 for any related\nseries of violations. We have reviewed the circumstances and supporting documents involved in\nthis case, and have decided not to conduct additional enforcement action or penalty assessment\nproceedings at this time. We advise you to correct the item(s) identified in this letter. Failure to do so\nwill result in GTN being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF\n5-2007-0015W. Be advised that all material you submit in response to this enforcement action is\nsubject to being made publicly available. If you believe that any portion of your responsive materia '\nI\nqualifies for confidential treatment under 5 U. S. C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U. S. C, 552(b).\nSincerely\ns Hoidal c\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: Alan Rathbun, WUTC\nDavid Lykken, WUTC\nPHP-60 Compliance Registry\nPHP-500 Tom Finch","truncated":false,"body_characters":5143}