{"operation":"document","citation":"CPF 520071012W","title":"NORTHWEST PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-07-09","effective_on":null,"summary":"CLOSED warning letter citing 192.467(c), 192.479.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520071012w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520071012w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520071012w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520071012W","body":"Warning Letter involving NORTHWEST PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 192.467(c),  192.479. The case was opened on 2007-07-09 and is reported as closed as of 2007-07-09. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520071012W_warning letter_07092007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520071012W/520071012W_warning%20letter_07092007.pdf\n\n520071012w_warning letter_07092007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520071012W/520071012w_warning%20letter_07092007_text.pdf\n\n520071012w_warning letter_07092007_text.pdf\n\nS NT TO COMPLIANCE REGIS'\nE\nHardcopy Electrontca y 4j Oa\n0 of Copies&i Date\nO\nU. S Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n12300 W Dakota Ave, SuIte 110\nLakewood, CO 80228\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT RE UESTKD\nJuly 9, 2007\nMr. Randy Barnard\nVice President, Operations\nNorthwest Pipeline Corporation\n2800 Post Oak Blvd.\n,\nMail Stop 21\nHouston, TX 77056\nCPF 5-2007-1012W\nDear Mr. Barnard:\nDuring the week of May 21-27, 2007, a representative of the Washington Utilities and\nTransportation Commission (WUTC), pursuant to Chapter 601 of 49 CFR United States Code,\nconducted an inspection of Northwest Pipeline Corporation (WGP) Sumas District in and near\nSumas, Washington. The WUTC acts as an agent of the Western Region, Pipeline and\nHazardous Material Safety Administration (PHMSA).\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violation(s) are:\n1. $192. 467 External corrosion control: Electrical isolation.\n(c) Except for unprotected copper inserted in a ferrous pipe, each pipeline must be\nelectrically isolated from metallic casings that are a part of the underground system.\nHowever, if isolation is not achieved because it is impractical, other measures must be\ntaken to minimize corrosion of the pipeline inside the casing.\n(d) Inspection and electrical tests must be made to assure that electrical isolation is\nadequate.\n\n\n\nThe casing under the road crossing of Highway 99 for the 6\" diameter Stanwood Lateral is\nshorted. WGP had previously installed a dielectric gel between the camer pipe and casing\nin an attempt to mitigate this short. However, the short still exists since both the earner\npipe and casing having identical \"structure-to-soil\" readings of — 1. 095 Volts DC. The\nvoltage test readings were obtained with a Cu/CuS04 half cell. The test data is listed\nbelow:\nPipe (Volts) ~Costa\nDate Location\n05/23/2007 6\" Stanwood Lateral P/S of the 6\" -1 095\nline under Highway 99\nComments\n-1. 095 The casing was\nshorted.\n2. $192. 479 Atmospheric corrosion control; General.\n(a) Each operator must clean and coat each pipeline or portion of pipeline that is\nexposed to the atmosphere, except pipelines under paragraph (c) of this section.\n(b) Coating material must be suitable for the prevention of atmospheric corrosion.\n(c) Except portions of pipelines in offshore splash zones or soil-to-air interfaces, the\noperator need not protect from atmospheric corrosion any pipeline for which the\noperator demonstrates by test, investigation, or experience appropriate to the\nenvironment of the pipeline that corrosion will—\n(1) Only be a light surface oxide; or\n(2) Not affect the safe operation of the pipeline before the next scheduled inspection.\nDuring the field inspection, the pipe coating at the \"air-to-soil\" transition had failed at two\nlocations in the Mt. Vernon compressor station. Even though there were no signs of\ncorrosion under the disbonded coating, the transitions need to be coated m order to prevent\nthe possibility of external, atmospheric corrosion.\nUnder 49 United States Code, ) 60122, you are subject to a civil penalty not to exceed\n$100, 000 for each violation for each day the violation persists up to a maximum of $1, 000, 000\nfor any related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement\naction or penalty assessment proceedings at this time. We advise you to correct the items\nidentified in this letter. Failure to do so will result in Northwest Pipehne Corporation (WGP)\nbeing subject to additional enforcement action. No reply to this letter is required. If you\nchoose to reply, in your correspondence please refer to CPF 5-2007-1012W. Be advised that\nall material you submit in response to this enforcement action is sub3ect to bemg made\npubhcly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U. S. C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you beheve qualify for\n\n\n\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U. S. C. 552(b).\nSincerely,\nj\nChris oidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nCC: PHP-60 Compliance Registry\nPHP-500 T. Finch (¹118850)\nA. Rathbun, P. E.\nWUTC\n,\nD. Lykken, WUTC\nJoseph P. Robertson, P. E.\n,\nWilliams Gas Pipeline","truncated":false,"body_characters":5358}