# NORTHWEST PIPELINE LLC — Warning Letter

- **operation:** document
- **citation:** CPF 520111003W
- **title:** NORTHWEST PIPELINE LLC — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2011-07-27
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.603(b), 192.739(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520111003w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520111003w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520111003w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520111003W
**body:**

Warning Letter involving NORTHWEST PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 192.603(b),  192.739(a). The case was opened on 2011-07-27 and is reported as closed as of 2011-07-27. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520111003W_warning letter_072722011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520111003W/520111003W_warning%20letter_072722011.pdf

520111003W_warning letter_072722011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520111003W/520111003W_warning%20letter_072722011_text.pdf

520111003W_warning letter_072722011_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
July 27, 2011
Mr. Randall L. Barnard
President, Gas Pipeline
Williams
P.O. Box 1396
Houston, TX 77251-1396
CPF 5- 2011-1003W
Dear Mr. Barnard:
On April 25-28, 2011, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected
your Eugene District pipeline facilities. The inspection also included review of your
operation and maintenance (O&M) manual as well as supporting O&M records.
As a result of the inspection, it appears that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected
and the probable violations are:
1. §192.603 General provisions.
(b) Each operator shall keep records necessary to administer the procedures
established under §192.605.
Two sections of the procedural manual were not reviewed as required by §192.605(a) in a
timely manner, according to the company’s own documentation. Sections pertaining to



telecommunications and measurement were reviewed annually by the assigned work
groups, but not within the maximum fifteen-month interval. The measurement section was
reviewed February 4, 2009, and then on September 1, 2010; this measurement section was
late by three months and 26 days. The telecommunications section was reviewed on June
29, 2009 and then on October 31, 2010; this section was late by one month and two days.
Procedures included in these portions of the manual could affect SCADA, emergency
response, and leak detection.
2. §192.739 Pressure limiting and regulating stations: Inspection and testing.
(a) Each pressure limiting station, relief device, (except rupture discs), and
pressure regulating station and its equipment must be subjected at intervals
not exceeding 15 months, but at least once each calendar year, to
inspections and tests to determine that it is –
(1) In good mechanical condition;
(2) Adequate from the standpoint of capacity and reliability of operation for
the service in which it is employed;
(3) Except as provided in paragraph (b) of this section, set to control or relieve
at the correct pressure consistent with the pressure limits of §192.201(a);
and
(4) Properly installed and protected from dirt, liquids, or other conditions that
might prevent proper operation.
The Williams’ Klamath Falls Lateral has no pressure regulating or limiting equipment
installed, and operates at the same pressure as the GTN mainlines that deliver gas to
Williams’ lateral. Williams must install adequate overpressure protection, or obtain
documentation verifying the adequacy of the overpressure protection devices on the GTN
system, meeting the requirements of §192.739.
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 items identified in this letter. Failure to do so will result in Williams 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 5-2011-1003W. 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,
Christopher Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 J. Stahoviak (#132878)
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