{"operation":"document","citation":"CPF 520091001W","title":"NORTH BAJA PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2009-03-17","effective_on":null,"summary":"CLOSED warning letter citing 192.467(b), 192.603(b), 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520091001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520091001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520091001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520091001W","body":"Warning Letter involving NORTH BAJA PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 192.467(b),  192.603(b),  192.605(a). The case was opened on 2009-03-17 and is reported as closed as of 2009-03-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520091001W_warning letter_03172009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520091001W/520091001W_warning%20letter_03172009.pdf\n\n520091001W_warning letter_03172009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520091001W/520091001W_warning%20letter_03172009_text.pdf\n\n520091001W_warning letter_03172009_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 17, 2009\nMr. Ross T. Parker\nRegional Director, US Operations\nTransCanada\n1400 SW 5th Avenue, Suite 900\nPortland, OR 97201\nCPF 5-2009-1001W\nDear Mr. Parker:\nOn November 3-7, 2008, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\nNorth Baja Pipeline in the State of California.\nAs a result of the inspection, it appears that you have committed violations of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n1. §192.603 General provisions.\n(b) Each operator shall keep records necessary to administer the procedures\nestablished under §192.605.\nTransCanada’s procedures for cathodic protection (CP) criteria specify that the pipeline\npipe-to-soil potential will meet either -0.850 V (instant-off) or 100 mV shift criteria as\nrequired by 192.463(a). However, the annual survey record for 2008 did not have\nsufficient analysis to indicate adequate protection for all test stations per TransCanada’s\n\n\n\nprocedures. There were many test stations where the instant off pipe-to-soil potential\nreading was less than -0.850 V. In addition, the annual survey did not evaluate the\ninstant-off, pipe-to-soil potential and the native pipe-to-soil potential to determine if 100\nmV shift criterion was met.\n2. §192.603 General provisions.\n(b) Each operator shall keep records necessary to administer the procedures\nestablished under §192.605.\nand,\n§192.467 External corrosion control: Electrical isolation.\n(b) One or more insulating devices must be installed where electrical isolation of a\nportion of a pipeline is necessary to facilitate the application of corrosion control.\nAt the time of inspection, there was no record of electrical isolation for the Socal/North\nBaja connection at the Socal meter station in Blyth, California, as required by\n§192.467(d).\n3. §192.605 Procedural manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline, a manual\nof written procedures for conducting operations and maintenance activities and for\nemergency response.\nA TransCanada employee was observed not following TransCanada’s procedures for\nHot Work that require monitoring the atmosphere for natural gas when using the cell\nphone near the valve, or moving outside of the valve yard and more than 5 meters from\nthe piping and valves.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violation persists up to a maximum of $1,000,000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this\nletter. Failure to do so will result in TransCanada being subject to additional enforcement\naction.\n2\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2009-1001W. 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\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 C. Allen (#’s 120757 and 122431)\n3","truncated":false,"body_characters":4598}