{"operation":"document","citation":"CPF 520151006W","title":"GAS TRANSMISSION NORTHWEST LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-06-05","effective_on":null,"summary":"CLOSED warning letter citing 192.603(b), 192.921(a)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520151006w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520151006w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520151006w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520151006W","body":"Warning Letter involving GAS TRANSMISSION NORTHWEST LLC. PHMSA's enforcement data identifies the cited regulations as 192.603(b),  192.921(a)(4). The case was opened on 2015-06-05 and is reported as closed as of 2015-06-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520151006W_warning letter_06052015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520151006W/520151006W_warning%20letter_06052015.pdf\n\n520151006W_warning letter_06052015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520151006W/520151006W_warning%20letter_06052015_text.pdf\n\n520151006W_warning letter_06052015_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 5, 2015\nMr. Vern Meier\nVice President – Pipeline Safety & Compliance\nTransCanada Pipeline\n700 Louisiana Street\nHouston, TX 77002-2700\nCPF 5-2015-1006W\nDear Mr. Meier:\nBetween May 19 and November 20, 2014, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) and the Washington Utilities and Transportation\nCommission (WUTC), pursuant to Chapter 601 of 49 United States Code, inspected the\nTransCanada (TCPL) Gas Transmission Northwest pipeline system (GTN) in the states of\nIdaho, Oregon and, Washington.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violations are:\n\n\n\n1. §192.921 How is the baseline assessment to be conducted?\n(a) Assessment methods. An operator must assess the integrity of the line\npipe in each covered segment by applying one or more of the following methods\ndepending on the threats to which the covered segment is susceptible. An\noperator must select the method or methods best suited to address the threats\nidentified to the covered segment (See § 192.917).\n(b) ... (4) Other technology that an operator demonstrates can provide an\nequivalent understanding of the condition of the line pipe. An operator choosing\nthis option must notify the Office of Pipeline Safety (OPS) 180 days before\nconducting the assessment, in accordance with §192.949. An operator must also\nnotify a State or local pipeline safety authority when either a covered segment is\nlocated in a State where OPS has an interstate agent agreement, or an intrastate\ncovered segment is regulated by that State.\nTCPL employed an \"Other Technology\" assessment method in their evaluation of Stress\nCorrosion Cracking (SCC) on the GTN system, prior to demonstrating that that the \"Other\nTechnology\" can provide an equivalent understanding of the condition of the line pipe.\nTCPL uses \"Other Technology\", Active Integrated Condition Monitoring (AICM), to assess,\nevaluate and monitor High Consequence Area (HCA) pipeline segments that have been\ncategorized as having a “low” threat level for Stress Corrosion Cracking (SCC) through\napplication of the process documented in TEP-ITM-SCC Stress Corrosion Cracking (SCC)\nThreat Management Program US, EDMS 006878841. TCPL noticed (GT IM Notification\n#300) PHMSA on 06/15/2012 according to §49CFR192.92 (a)(4). On December 17, 2014,\nPHMSA changed the status of TCPL GT IM Notification #300 to \"Objections Noted.\" TCPL\ndid not have finalized (signed) procedures for all AICM procedures. The AICM procedures\ndid not fully detail how segments were prioritized, selected, and how and when remediation\nprocedures such as excavation, pressure tests or in-inline inspection tools were used. Re-\ninspection intervals including how they are determined were not outlined in the procedures.\n2. §192.603 General provisions\n(b) Each operator shall keep records necessary to administer the procedures\nestablished under §192.605.\nTCPL could not provide documentation that the Emergency plan required by §49CFR192.615\nwas reviewed and updated once each calendar, not to exceed 15 months, in accordance with\n§49CFR192.605(a). A signature page approving the plan annual review and update could not\nbe located.\n\n\n\nUnder 49 United States Code, §60122, you are subject to a civil penalty not to exceed\n$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the maximum\npenalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a related series of violations.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2015-1006W and for each document you submit, please provide a copy in\nelectronic format to PHP-WRADMIN@dot.gov whenever possible. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 Jason Dunphy\nWUTC","truncated":false,"body_characters":5385}