# GAS TRANSMISSION NORTHWEST LLC — Warning Letter

- **operation:** document
- **citation:** CPF 520111009W
- **title:** GAS TRANSMISSION NORTHWEST LLC — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2011-11-01
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.705(b).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520111009w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520111009w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520111009w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520111009W
**body:**

Warning Letter involving GAS TRANSMISSION NORTHWEST LLC. PHMSA's enforcement data identifies the cited regulation as 192.705(b). The case was opened on 2011-11-01 and is reported as closed as of 2011-11-01. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520111009W_warning letter_11012011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520111009W/520111009W_warning%20letter_11012011.pdf

520111009W_warning letter_11012011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520111009W/520111009W_warning%20letter_11012011_text.pdf

520111009W_warning letter_11012011_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
November 1, 2011
Mr. Vern Meier
Vice President, US Pipelines
TransCanada Corporation
717 Texas Street
Houston, TX 77002-2761
CPF 5-2011-1009W
Dear Mr. Meier:
On May 24 to 27, 2011, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your Gas
Transmission Northwest (GTN) pipeline procedures and records in Wallula, Washington. Field
inspections of the GTN pipeline facilities between Milepost 360 and 612 were performed.
As a result of the inspection, it appears that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the
probable violation is:
1. §192.705 Transmission lines: Patrolling.
(b) The frequency of patrols is determined by the size of the line, the operating
pressures, the class location, terrain, weather, and other relevant factors, but
intervals between patrols may not be longer than prescribed in the following table:



Class
location
of line
Maximum interval between patrols
At highway and
railroad crossings
At all other places
1, 2 7 1/2 months; but at least twice each
calendar year
15 months; but at least once each
calendar year
3 4 1/2 months; but at least four times
each calendar year
7 1/2 months; but at least twice
each calendar year
4 4 1/2 months; but at least four times
each calendar year
4 1/2 months; but at least four
times each calendar year
At the time of the inspection, GTN could not provide evidence that they completed the required
patrols of their Coyote Lateral railroad crossings at the required frequency. A comprehensive
review of patrolling records provided by GTN indicates that no patrols of the railroad crossings
were conducted from 4/20/2009 to 10/19/2009, a period of six (6) months. The patrolling
requirements for railroad crossings in Class 3 areas require no more than four and one half
months between patrols. Employees of GTN present during the inspection could not confirm that
an interim patrol of the railroad crossings was done in the Class 3 areas.
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 TransCanada Corporation 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 5-2011-1009W. 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 J. Haddow (#132925)
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