# GAS TRANSMISSION NORTHWEST LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 520101005
- **title:** GAS TRANSMISSION NORTHWEST LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2010-09-21
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 192.465(d).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520101005.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520101005.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520101005
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520101005
**body:**

Notice of Probable Violation involving GAS TRANSMISSION NORTHWEST LLC. PHMSA's enforcement data identifies the cited regulation as 192.465(d). The case was opened on 2010-09-21 and is reported as closed as of 2011-05-27. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520101005_FinalOrder_05272011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520101005/520101005_FinalOrder_05272011.pdf

520101005_FinalOrder_05272011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520101005/520101005_FinalOrder_05272011_text.pdf

520101005_NOPV PCO_09212010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520101005/520101005_NOPV%20PCO_09212010.pdf

520101005_NOPV PCO_09212010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520101005/520101005_NOPV%20PCO_09212010_text.pdf

520101005_operator response_10182010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520101005/520101005_operator%20response_10182010.pdf

520101005_FinalOrder_05272011_text.pdf

MAY 27 2011
Mr. Ken Leier
Region Director
U.S. Western Pipe Region
TransCanada Corporation
201 West North River Drive, Suite 505
Spokane, WA 99201
Re: CPF No. 5-2010-1005
Dear Mr. Leier:
Enclosed please find the Final Order issued in the above-referenced case. It makes a finding of
violation and finds that TransCanada has completed the actions specified in the Notice to comply
with the pipeline safety regulations. Therefore, this case is now closed. Service of the Final
Order by certified mail is deemed effective upon the date of mailing, or as otherwise provided
under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Chris Hoidal, Director, Western Region, PHMSA
CERTIFIED MAIL - RETURN RECEIPT REQUESTED [7005 1160 0001 0075 9312]



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
)
In the Matter of )
)
TransCanada Corporation, ) CPF No. 5-2010-1005
)
Respondent. )
____________________________________)
FINAL ORDER
Between August 24 to 27, 2009, and September 8 to 11, 2009, pursuant to 49 U.S.C. § 60117, a
representative of the Washington Utilities Commission (WUTC), as agent for the Pipeline and
Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),
conducted an on-site pipeline safety inspection of the facilities and records of TransCanada
TransCanada’s Rosalia District, an area in the eastern part of the State that includes
approximately 201 miles of interstate natural gas transmission lines in Spokane and Whitman
Corporation (TransCanada or Respondent) in the State of Washington.1 The inspection covered
Counties.
As a result of the inspection, the Director, Western Region, OPS (Director), issued to
Respondent, by letter dated September 21, 2010, a Notice of Probable Violation and Proposed
Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed
finding that TransCanada had violated 49 C.F.R. § 192.465(d) and proposed ordering
Respondent to take certain measures to correct the alleged violation.
TransCanada responded to the Notice by letters dated October 18, 2010, and December 8, 2010
(Response). The company did not contest the allegation of violation but provided information
concerning the corrective actions it had taken. Respondent did not request a hearing and
therefore has waived its right to one.
FINDING OF VIOLATION
In its Response, TransCanada did not contest the allegation in the Notice that it violated 49
C.F.R. Part 192, as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.465(d), which states:
§ 192.465 External corrosion control: Monitoring.
(a) . . .
1 http://www.transcanada.com/ (last accessed on May 10, 2011).



2
(d) Each operator shall take prompt remedial action to correct any
deficiencies indicated by the monitoring.
The Notice alleged that Respondent violated 49 C.F.R. § 192.465(d) by failing to take prompt
remedial action to correct deficiencies indicated by corrosion control monitoring. Specifically,
the Notice alleged that TransCanada failed to take prompt action to correct deficiencies in the
pipe-to-soil readings discovered at the Spokane Gate/Meter Station in 2007. The Notice alleged
that the 6-inch buried piping between the heater unit and meter building had a pipe-to-soil “on”
potential value of approximately -443 mv DC at the time of the 2009 inspection, and that the
native potential at that location had been measured at -229 mv DC in 2006. The Notice further
alleged that this location had an “off” potential value of -210 mv DC at the time of the 2009
inspection, and that TransCanada had not taken any steps to remediate its cathodic protection
system since 2007.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 192.465(d) by failing to take prompt
remedial action to correct deficiencies indicated by corrosion control monitoring.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Item 1 in the Notice for a violation of 49
C.F.R. § 192.465(d). Under 49 U.S.C. § 60118(a), each person who engages in the
transportation of gas or who owns or operates a pipeline facility is required to comply with the
applicable safety standards established under chapter 601. The Director indicates that
Respondent has taken the following actions specified in the proposed compliance order:
1. With respect to the violation of § 192.465(d) (Item 1), Respondent has taken steps
to address the deficiencies identified in its corrosion control monitoring. Specifically,
TransCanada has installed additional anodes and a flange insulation kit to improve the
performance of its cathodic protection system and performed testing to ensure that its
pipe-to-soil potential at the location meets the specified criteria. In March 2011,
WUTC confirmed that these measures had been properly implemented in a follow-up
inspection of the Rosalia District.
Accordingly, I find that compliance has been achieved with respect to this violation. Therefore,
the compliance terms proposed in the Notice are not included in this Order.
The terms and conditions of this Final Order are effective upon service in accordance with 49
C.F.R. § 190.5.
___________________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety
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