{"operation":"document","citation":"CPF 520191006W","title":"GAS TRANSMISSION NORTHWEST LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-01-23","effective_on":null,"summary":"CLOSED warning letter citing 192.147(b), 192.481(b), 192.481(c), 192.745, 192.947(d).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520191006w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520191006w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520191006w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520191006W","body":"Warning Letter involving GAS TRANSMISSION NORTHWEST LLC. PHMSA's enforcement data identifies the cited regulations as 192.147(b),  192.481(b),  192.481(c),  192.745,  192.947(d). The case was opened on 2019-01-23 and is reported as closed as of 2019-01-23. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520191006W_Warning Letter_01232019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520191006W/520191006W_Warning%20Letter_01232019.pdf\n\n520191006W_Warning Letter_01232019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520191006W/520191006W_Warning%20Letter_01232019_text.pdf\n\n520191006W_Warning Letter_01232019_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 11, 2019\nMs. Sonya Kirby\nVice President, Safety, Quality & Compliance\nTransCanada\nP.O. Box 1000\nStation M\nCalgary AB, Canada\nT2P 4K5\nCPF 5-2019-1006W\nDear Ms. Kirby:\nFrom November 27, 2017 through September 7, 2018, representatives of the Pipeline &\nHazardous Materials Safety Administration (PHMSA) and the Washington Utilities and\nTransportation Commission, pursuant to Chapter 601 of 49 United States Code, inspected the\nTransCanada Gas Transmission Northwest Pipeline System (GTN) in the states of\nWashington, Oregon, and Idaho.\nDuring the inspection, the following probable violations of the Pipeline Safety Regulations,\nTitle 49, Code of Federal Regulations (CFR) were noted. The potential regulatory\ndeficiencies observed and probable violation(s) are:\n1. §192.147 Flanges and flange accessories.\n(b) Each flange assembly must be able to withstand the maximum pressure at\nwhich the pipeline is to be operated and to maintain its physical and chemical\nproperties at any temperature to which it is anticipated that it might be subjected\nin service.\nA flange at the Schweitzer Meter station, in Idaho was improperly installed to\nwithstand anticipated service conditions. All of the studs on one side of the flange\n\n\n\nwere too short to go all the way through some of the nuts. Without the studs going all\nthe way through the nut, maximum strength is not achieved and the applicable flange\nfitting may not provide the design strength for the flanges or the strength needed for\nthe applicable Maximum Allowable Operating Pressure.\n2. §192.947 What records must an operator keep?\n(d) Documents to support any decision, analysis and process developed and used\nto implement and evaluate each element of the baseline assessment plan and\nintegrity management program. Documents include those developed and used in\nsupport of any identification, calculation, amendment, modification, justification,\ndeviation and determination made, and any action taken to implement and\nevaluate any of the program elements.\nDocuments to support GTN’s analysis and decision making process used to conduct\ntheir risk analysis of its pipeline to identify additional measures to protect their high\nconsequences areas per §192.935 were not provided to our inspectors. The list of\nPreventative and Mitigative Measures (P&M Measures) implemented on the pipeline\nsystem and presented to the inspection team did not include any documents that GTN\nused to support the decisions, analysis, processes, or developed to support the\nidentification, applicable calculations, amendments, modifications, justifications,\ndeviations and determinations made by GTN to justify any action taken regarding the\nprogram elements on the P&M Measures list. The operator is required to keep records\nused to implement and evaluate each element to their Integrity Management program\nincluding their P&M Measures per §192.935.\n3. §192.745 Valve maintenance: Transmission lines.\n(a) Each transmission line valve that might be required during any emergency\nmust be inspected and partially operated at intervals not exceeding 15 months,\nbut at least once each calendar year.\n(b) Each operator must take prompt remedial action to correct any valve found\ninoperable, unless the operator designates an alternative valve.\nValve 20-A, line bypass at Starbuck Compressor #7, (Wallula District, WA), leaked or\nsprayed oil over the all of the external surfaces of the valve assembly. GTN personnel\nstated that the valve was still operational but believed it needs a new poppet valve.\nDuring the last valve inspection, the GTN inspection noted that between 5 and 10\ngallons of hydraulic oil had to be added to the valve’s oil reservoir.\n4\n§192.481(b) Atmospheric corrosion control: Monitoring.\n(b) During inspections the operator must give particular attention to pipe at soil-\nto-air interfaces, under thermal insulation, under disbonded coatings, at pipe\nsupports, in splash zones, at deck penetrations, and in spans over water.\n1) The A-Line pig bypass line at the Starbuck Compressor station #7, (Wallula\n2\n\n\n\nDistrict, WA) had areas of disbonded tape wrap at the soil to air interface. The tape\nwrap appeared to be sagging off the bottom of the pipeline where it entered the\nsoil. It could not be determined whether this visible tape wrap is a secondary\nprotective coating over, for example a Fusion Bound Epoxy (FBE) coating, or it is\nthe primary coating at the soil/air interface. If the tape wrap is the primary coating,\nthere is the possibility that water and soil could be in direct contact with the pipe\nand cause corrosion issues.\n2) The A-Line pig receiver piping at the Rosalia Compressor station (Rosalia District,\nWA) showed signs of surface rust through the coating at the soil to air interface. It\nappears that there is only a paint coating where the pipe is partially resting on soil\nand is a wrap coating. It could not be determined whether this visible tape wrap is\na secondary protective coating over, for example a Fusion Bound Epoxy (FBE)\ncoating, or it is the primary coating at the soil/air interface. If the tape wrap is the\nprimary coating, there is the possibility that water and soil could be in direct\ncontact with the pipe and cause corrosion issues. It could not be determined\nduring the inspection whether the rust is bleeding through paint or through an FBE\ncoating.\n3) The crossover blowdown at the top of an in-line tee fitting at the soil to air\ninterface at the Rosalia Compressor station (Rosalia District, WA) had visible rust\nand possible corrosion. The tape wrap was peeled away and was disbonded from\nthe pipe leaving the potential for moisture under the wrap and potential corrosion.\nSome type of sealant or filler was previously applied around the pipe at the top of\nthe tape wrap. The sealant has cracked away from the pipe and wrap leaving a\nportion of the pipe above the wrap exposed to what appears to be bare pipe.\n5. §192.481(b) Atmospheric corrosion control: Monitoring.\n(c) If atmospheric corrosion is found during an inspection, the operator must\nprovide protection against the corrosion as required by §192.479.\nThe A-Line pig bypass line at the Starbuck Compressor station #7, (Wallula District,\nWA) had an area above the soil/air interface where the coating appears to have been\nknocked off the pipeline. Surface rust was visible as are signs of possible early\ncorrosion where the coating was missing and appeared to be chipped off of the pipe.\nThere were areas of cracking in the remaining coating where moisture could wick\nunder the coating and be trapped causing corrosion issues.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to\nexceed $209,002 per violation per day the violation persists, up to a maximum of $2,090,022\nfor a related series of violations. For violations occurring prior to November 2, 2015, the\nmaximum penalty may not exceed $200,000 per violation per day, with a maximum penalty\nnot to exceed $2,000,000 for a related series of violations. We have reviewed the\n3\n\n\n\ncircumstances and supporting documents involved in this case, and have decided not to\nconduct additional enforcement action or penalty assessment proceedings at this time.\nWe advise you to correct the item(s) identified in this letter during future construction\nactivities. Failure to do so will result in Gas Transmission Northwest Pipeline System being\nsubject to additional enforcement action. No reply to this letter is required. If you choose to\nreply, in your correspondence please refer to CPF 5-2019-1006W. 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\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP 60 Compliance Registry\nPHP-500 B. Brown (#157147, 160064, 160666, 160063, 160062, 164173)\n4","truncated":false,"body_characters":9056}