# NORTH BAJA PIPELINE LLC — Warning Letter

- **operation:** document
- **citation:** CPF 520101003W
- **title:** NORTH BAJA PIPELINE LLC — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2010-08-20
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.709(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520101003w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520101003w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520101003w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520101003W
**body:**

Warning Letter involving NORTH BAJA PIPELINE LLC. PHMSA's enforcement data identifies the cited regulation as 192.709(a). The case was opened on 2010-08-20 and is reported as closed as of 2010-08-20. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520101003W_warning letter_08202010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520101003W/520101003W_warning%20letter_08202010.pdf

520101003W_warning letter_08202010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520101003W/520101003W_warning%20letter_08202010_text.pdf

520101003W_warning letter_08202010_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
August 20, 2010
Mr. Ken Leier
US Operations Director
TransCanada, North Baja Pipeline LLC
1400 SW 5th Avenue, Suite 900
Portland, Oregon 97201
CPF 5-2010-1003W
Dear Mr. Leier:
From April 13-16, 2009, representatives of the Arizona Corporation Commission pursuant to
Chapter 601 of 49 United States Code inspected your Arizona Ehrenberg Compressor Station
and mainline pipe to the Colorado River (state line). As part of their inspection, they reviewed
records and performed a field inspection at your Ehrenberg Compressor Station.
As a result of the inspection, it appears that TransCanada, North Baja Pipeline LLC have
committed a probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal
Regulations. The item inspected and the probable violation is:
1. §192.709(a) Transmission lines: Record keeping.
Each operator shall maintain the following records for transmission line for the
periods specified:
(a) The date, location, and description of each repair made to pipe (including pipe-
to-pipe connections) must be retained for as long as the pipe remains in service.



Documentation was not available during the inspection to demonstrate that compressor station
yard piping and coating was repaired following an exposed pipe visual inspection done on
December 18, 2007. The inspection record identifies coating damage and some general
corrosion on the pipe surface. The description of the repair made is required by § 195.709(a).
Under 49 United States Code, § 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 identified in this letter.
Failure to do so will result in TransCanada 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 5-2010-1003W. 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 material 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,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 T. Finch (#123980)
Arizona Corporation Commission-Mr. Robert Miller
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