{"operation":"document","citation":"CPF 520121012W","title":"GAS TRANSMISSION NORTHWEST LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-05-17","effective_on":null,"summary":"CLOSED warning letter citing 192.465(d).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520121012w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520121012w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520121012w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520121012W","body":"Warning Letter involving GAS TRANSMISSION NORTHWEST LLC. PHMSA's enforcement data identifies the cited regulation as 192.465(d). The case was opened on 2012-05-17 and is reported as closed as of 2012-05-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520121012W_Warning Letter_05172012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520121012W/520121012W_Warning%20Letter_05172012.pdf\n\n520121012W_Warning Letter_05172012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520121012W/520121012W_Warning%20Letter_05172012_text.pdf\n\n520121012W_Warning Letter_05172012_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 17, 2012\nMr. Ken Leier\nRegional Director\nTransCanada, Gas Transmission Northwest Corporation\nU.S. Western Pipeline Region\n1400 SW 5th Ave., Suite 900\nPortland, OR 97201\nCPF 5-2012-1012W\nDear Mr. Leier:\nOn November 28 through December 2, 2011, a representative of the Washington Utilities and\nTransportation Commission (WUTC), on behalf of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\ninspected Gas Transmission Northwest Corporation’s (GTN) pipeline facilities in Eastern\nWashington. Our representative observed field conditions, reviewed Operation and\nMaintenance (O&M) procedures, and O&M records for the GTN Pipeline’s in the Rosalia\nDistrict.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and\nthe probable violation is:\n1. §192.465(d), Each operator shall take prompt remedial action to correct any\ndeficiencies indicated by the monitoring.\nCFR §192.465(d) requires that each operator shall take prompt remedial action to correct any\ndeficiencies indicated by the monitoring. The proper level of cathodic protection is specified\nin §192.463 and Appendix D to Part 192. The probable violation is for not taking prompt\n\n\n\nremedial action to correct the pipe-to-soil potential with respect to the native potential as\nrequired by Appendix D, I, A, (3).\nDuring the annual surveys for 2010 and 2011, the pipe-to-soil “off” potential was less than\n100 mV with respect to the “native” potentials for the following locations:\nAt MP 110.2 the native potential is -698 mV and 2010 P/S was -669 mV and 2011 P/S\nwas -748 mV, and\nAt MP 110.8 the native potential is -708 mV and 2010 P/S was -640 mV and 2011 P/S\nwas -792 mV.\nThe low cathodic protection level persisted for over a year, indicating the operator has not\ncorrected the deficiency in a prompt manner.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of\n$1,000,000 for any related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct\nthe item identified in this letter. Failure to do so will result in TransCanada, Gas\nTransmission Northwest Corporation (GTN) being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2012-1012W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: David Lykken, Washington UTC\nPHP-60 Compliance Registry\nPHP-500 R. Reineke (#133012)\n2","truncated":false,"body_characters":4137}