# ANR PIPELINE CO — Notice of Probable Violation

**Citation:** CPF 320161001  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2016-01-28

CLOSED notice of probable violation citing 191.15(a), 191.5(a), 191.5(b), 192.479(a), 192.603(b), 192.605(a), 192.605(b)(8), 192.625(a), 192.625(b), 192.736(c), 199.105(b), 199.225(a)(1).

## Document text

Notice of Probable Violation involving ANR PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 191.15(a),  191.5(a),  191.5(b),  192.479(a),  192.603(b),  192.605(a),  192.605(b)(8),  192.625(a),  192.625(b),  192.736(c),  199.105(b),  199.225(a)(1). The case was opened on 2016-01-28 and is reported as closed as of 2019-08-01. Proposed civil penalty: $220,200. Assessed civil penalty: $220,200. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320161001_Closure Letter_08012019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320161001/320161001_Closure%20Letter_08012019.pdf

320161001_Closure Letter_08012019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320161001/320161001_Closure%20Letter_08012019_text.pdf

320161001_Final Order_10242017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320161001/320161001_Final%20Order_10242017.pdf

320161001_Final Order_10242017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320161001/320161001_Final%20Order_10242017_text.pdf

320161001_NOPV PCP PCO_01282016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320161001/320161001_NOPV%20PCP%20PCO_01282016.pdf

320161001_NOPV PCP PCO_01282016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320161001/320161001_NOPV%20PCP%20PCO_01282016_text.pdf

320161001_Operator Response to Notice and Request for Hearing_03012016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320161001/320161001_Operator%20Response%20to%20Notice%20and%20Request%20for%20Hearing_03012016.pdf

320161001_Final Order_10242017_text.pdf

October 24, 2017
Mr. Russell Girling
President and CEO
TransCanada Corporation
450 1st St. SW
Calgary, Alberta, Canada T2P 5Hl
Re: CPF No. 3-2016-1001
Dear Mr. Girling:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation, assesses a civil penalty of $220,200, and specifies actions that need to be taken by
ANR Pipeline Company, a wholly owned pipeline subsidiary of TransCanada Corporation, to
comply with the pipeline safety regulations. The penalty payment terms are set forth in the Final
Order. When the civil penalty has been paid and the terms of the compliance order completed,
as determined by the Director, Central Region, this enforcement action will be closed. Service of
the Final Order by certified mail is deemed effective upon the date of mailing, or as otherwise
provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Allan C. Beshore, Director, Central Region, Office of Pipeline Safety, PHMSA
Ms. Sonya Kirby, Vice President, Safety, Quality & Compliance, TransCanada
Corporation, 700 Louisiana, Suite 700, Houston, TX 77002
CERTIFIED MAIL - RETURN RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
__________________________________________
In the Matter of )
ANR Pipeline Company, ) CPF No. 3-2016-1001
a subsidiary of TransCanada Corporation, )
)
)
)
Respondent. )
__________________________________________)
FINAL ORDER
On June 24-28, July 15-19, August 5-19, August 26-30, October 22-25, and December 2-6,
2013, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA), Office of Pipeline Safety (OPS), the Ohio Public Utilities
Commission, and the Iowa Utilities Board conducted an on-site pipeline safety inspection of the
facilities and records of ANR Pipeline Company (ANR or Respondent) in Texas, Iowa, Missouri,
Kansas, Ohio, Illinois, Indiana, and Wisconsin. The Michigan Public Service Commission (MI-
PSC) also inspected ANR’s facilities in Michigan during several weeks in 2012. ANR’s system
delivers natural gas from Louisiana, Texas, and Oklahoma to customers throughout the Midwest.
It has approximately 10,600 miles of pipe and owns and operates four storage fields in Michigan
with 64 billion cubic feet of capacity.1
As a result of the inspection, the Director, Central Region, OPS (Director), issued to Respondent,
by letter dated January 28, 2016, a Notice of Probable Violation, Proposed Civil Penalty, and
Proposed Compliance Order (Notice), which also included a warning pursuant to 49 C.F.R.
§ 190.205. In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that ANR had
committed 10 violations of 49 C.F.R. Parts 191, 192, and 199, and proposed assessing a civil
penalty of $220,200 for the alleged violations. The Notice also proposed ordering Respondent to
take certain measures to correct the alleged violations. The warning item required no further
action, but warned the operator to correct the probable violation or face future potential
enforcement action.
Respondent responded to the Notice by letters dated March 1, 2016 and June 20, 2016
(collectively, Response). ANR did not contest the allegations of violations, but presented
information seeking modification of the proposed compliance order through a potential consent
agreement; if were not possible, the company requested a hearing. By letter dated August 24,
2016, Respondent withdrew its request for a hearing and thereby authorized the entry of this
1 Pipeline Safety Violation Report (Violation Report), (Jan. 28, 2016) (on file with PHMSA), at 1.



CPF No. 3-2016-1001
Page 2
Final Order without further notice.
FINDINGS OF VIOLATION
In its Response, ANR did not contest the allegations in the Notice that it violated 49 C.F.R. Parts
191, 192, and 199, as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 191.5, which states:
§ 191.5 Immediate notice of certain incidents.
(a) At the earliest practicable moment following discovery, each operator
shall give notice in accordance with paragraph (b) of this section of each
incident as defined in §191.3.
(b) Each notice required by paragraph (a) of this section must be made to
the National Response Center either by telephone to 800-424- 8802 (in
Washington, D.C., 202-267-2675) or electronically at http://www.nrc.uscg.mil
and must include the following information:
(1) Names of operator and person making report and their telephone
numbers.
(2) The location of the incident.
(3) The time of the incident.
(4) The number of fatalities and personal injuries, if any.
(5) All other significant facts that are known by the operator that are relevant
to the cause of the incident or extent of the damages.
The Notice also referenced 49 C.F.R. § 191.3, which states, in relevant part:
§ 191.3 Definitions.
….
Incident means any of the following events:
(1) An event that involves a release of gas from a pipeline, or of liquefied
natural gas, liquefied petroleum gas, refrigerant gas, or gas from an LNG
facility, and that results in one or more of the following consequences:
(i) A death, or personal injury necessitating in-patient hospitalization;
(ii) Estimated property damage of $50,000 or more, including loss to the
operator and others, or both, but excluding cost of gas lost;
(iii) Unintentional estimated gas loss of three million cubic feet or more;
(2) An event that results in an emergency shutdown of an LNG facility.
Activation of an emergency shutdown system for reasons other than an actual
emergency does not constitute an incident.
(3) An event that is significant in the judgment of the operator, even though
it did not meet the criteria of paragraphs (1) or (2) of this definition.
The Notice alleged that Respondent violated 49 C.F.R. § 191.5 by failing to notify the National
Response Center (NRC) of a 2012 “incident,” as defined in § 191.3, that occurred at ANR’s



CPF No. 3-2016-1001
Page 3
compressor station in Sandwich, Illinois. Specifically, the Notice alleged that on July 13, 2012,
an incident occurred at the Sandwich compressor station, but the company made no notification
to the NRC. The property damage, excluding cost of any gas lost, was over $50,000.
The incident involved a release of natural gas from a valve in the pipeline system into the
silencer on Compressor Unit 1009 and the resulting ignition of gas. The released gas ignited at
the silencer resulted in an uncontrolled burn that damaged the silencer and exhaust piping, and
the silencer fell over and damaged the compressor building as well. Despite this damage to its
pipeline facility caused by a natural gas fire, ANR did not contact the NRC.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 191.5 by failing to give notice to the
NRC of a 2012 incident that occurred at the ANR compressor station in Sandwich, Illinois.
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 191.5, as quoted above, by
failing to notify the NRC of another 2013 “incident,” as defined in § 191.3, that occurred at
ANR’s compressor station in Sandwich, Illinois. Specifically, the Notice alleged that on August
9, 2013, at 13:30 MDT, ANR experienced a second reportable incident at the Sandwich
compressor station where the company made no notification to the NRC. The property damage,
excluding the cost of lost gas, was over $50,000.
The incident involved a release of natural gas when gas leaked past pressure and wiper packing
of the compressor unit during maintenance of the unit. After leaking past the compressor
packing, the natural gas entered the crankcase of the compressor unit. The leak into the
crankcase (which is not a part of the pipeline system that moves gas in transportation) resulted in
the ignition and explosion of the gas, causing substantial damage to equipment and the
compressor building. Despite the damage to its pipeline facility caused by a natural gas
explosion, ANR failed to contact the NRC.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 191.5 by failing to give notice to the
NRC of a 2013 incident that occurred at the ANR compressor station in Sandwich, Illinois.
Item 3: The Notice alleged that Respondent violated 49 C.F.R. § 191.15(a), which states:
§ 191.15 Transmission systems; gathering systems; and liquefied natural
gas facilities; Incident report.
(a) Transmission or Gathering. Each operator of a transmission or a
gathering pipeline system must submit DOT Form PHMSA F 7100.2 as soon
as practicable but not more than 30 days after detection of an incident required
to be reported under §191.5 of this part.
The Notice alleged that Respondent violated 49 C.F.R. § 191.15(a) by failing to submit a written
report, as soon as practicable but not more than 30 days after detection of an incident that was
required to be reported under § 191.5. Specifically, the Notice alleged that ANR failed to submit



CPF No. 3-2016-1001
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a written report to PHMSA as soon as practicable but not more than 30 days after detection of
the 2012 incident described in Item 1 above and that was required to be reported under § 191.5.
Based on information provided by ANR during PHSMA’s 2013 inspection, the costs of this
incident totaled over $200,000. According to ANR’s root cause analysis report provided during
that same inspection, natural gas released from a valve in the pipeline system into the engine and
silencer creating a combustible mixture in the silencer that ignited and resulted in an
uncontrolled burning of gas at the silencer.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 191.15(a) by failing to submit a
written report to PHMSA as soon as practicable but not more than 30 days after detection of an
incident that was required to be reported under § 191.5.
Item 4: The Notice alleged that Respondent violated 49 C.F.R. § 191.15(a), as quoted above, by
failing to submit a written report to PHMSA as soon as practicable but not more than 30 days
after detection of an incident that was required to be reported under § 191.5. Specifically, the
Notice alleged that ANR failed to submit a written report to PHMSA as soon as practicable but
not more than 30 days after detection of the 2013 incident described in Item 2 and that was
required to be reported under §191.5. According to the Notice, the damage was significant and
the total cost of the incident was $580,205.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 191.15(a) by failing to submit a
written report to PHMSA as soon as practicable but not more than 30 days after detection of an
incident that was required to be reported under § 191.5.
Item 5: The Notice alleged that Respondent violated 49 C.F.R. § 192.605(b)(8), which states in
relevant part:
§ 192.605 Procedural manual for operations, maintenance, and
emergencies.
(a) General. Each operator shall prepare and follow for each pipeline, a
manual of written procedures for conducting operations and maintenance
activities and for emergency response. . .
(b) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following, if
applicable, to provide safety during maintenance and operations. . .
(8) Periodically reviewing the work done by operator personnel to
determine the effectiveness and adequacy of the procedures used in normal
operation and maintenance and modifying the procedure when deficiencies are
found.
The Notice alleged that Respondent violated 49 C.F.R. § 192.605(b)(8) by failing to follow its
own manual of written procedures for conducting operations and maintenance activities.
Specifically, it alleged that ANR failed to follow its written “walk-along” procedure throughout



CPF No. 3-2016-1001
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the company to review the work done by its personnel to determine the effectiveness and
adequacy of the procedures being used in normal operation and maintenance. According to the
Notice, ANR was unable to provide sufficient records to the PHMSA inspectors demonstrating
that the walk-along program was being used throughout the company. The MI-PSC inspections
in 2012 also identified the same issue. ANR personnel indicated in 2012 and in 2013 that final
procedures were still under development, but a form had been established and was being used
during the interim period. ANR provided examples of the form that was being used in 2013 in
Michigan and another one that was used in Wisconsin in 2011; however, there were no other
records indicating that the walk-along program and forms were being used elsewhere on the
ANR system.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 192.605(b)(8) by failing to follow its
own manual of written procedures for conducting operations and maintenance activities.
Item 6: The Notice alleged that Respondent violated 49 C.F.R. § 192.603(b), which states:
§ 192.603 General provisions.
(a) …
(b) Each operator shall keep records necessary to administer the procedures
established under §192.605.
The Notice also referenced § 192.605, which states, in relevant part:
§ 192.605 Procedural manual for operations, maintenance, and
emergencies.
(a) General. Each operator shall prepare and follow for each pipeline, a
manual of written procedures for conducting operations and maintenance
activities and for emergency response . . . .
(c) Abnormal operation. For transmission lines, the manual required by
paragraph (a) of this section must include procedures for the following to
provide safety when operating design limits have been exceeded:
(1) Responding to, investigating, and correcting the cause of:
(i) Unintended closure of valves or shutdowns;
(ii) Increase or decrease in pressure or flow rate outside normal operating
limits;
(iii) Loss of communications;
(iv) Operation of any safety device; and
(v) Any other foreseeable malfunction of a component, deviation from
normal operation, or personnel error, which may result in a hazard to persons
or property. . . .
The Notice alleged that Respondent violated 49 C.F.R. § 192.603(b) by failing to keep records to
administer the procedures it had established under § 192.605. Specifically, it alleged that ANR
failed to document the follow-up investigation of multiple abnormal operations that occurred on
its pipeline system. A review of the company’s Incident and Issue Tracking (IIT) database



CPF No. 3-2016-1001
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showed several instances when documentation of further investigation and corrective measures
had not occurred. Specifically, the Notice alleged that IIT #237072 was for a leak of lube oil
from a broken pressure gauge and IIT #255422 involved a pressure increase outside normal
limits at ANR’s Rapid River Compressor Station. The IIT entries indicated that procedures were
not completely effective in responding to the abnormal operations; however, no further
documentation was provided to show what corrections, if any, had been made.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 192.603(b) by failing to keep
records to administer the procedures it had established under § 192.605.
Item 7: The Notice alleged that Respondent violated 49 C.F.R. § 192.625(a-b), which states, in
relevant part:
§ 192.625 Odorization of gas.
(a) A combustible gas in a distribution line must contain a natural odorant
or be odorized so that at a concentration in air of one-fifth of the lower explosive
limit, the gas is readily detectable by a person with a normal sense of smell.
(b) After December 31, 1976, a combustible gas in a transmission line in a
Class 3 or Class 4 location must comply with the requirements of paragraph
(a)of this section . . .
The Notice alleged that Respondent violated 49 C.F.R. § 192.625(a-b) by failing to odorize
combustible gas in its transmission pipeline facilities in Wisconsin so that at a concentration in
air of one-fifth of the lower explosive limit, the gas was readily detectable by a person with a
normal sense of smell. Specifically, the Notice alleged that for ANR’s odorized transmission-
line facilities in Wisconsin, the company’s records did not demonstrate that the gas was odorized
to the proper concentration level.
According to the Notice, PHMSA’s review of the odorization records identified multiple
locations where the readings taken did not meet the one-fifth gas-in-air (0.9%) of the lower
explosive limit of natural gas (4.5% gas-in-air). On the Green Bay 350 line, the percent gas-in-
air readings taken from November 2012 to July 2013 ranged from 1.06% to 1.29%. On the
Green Bay 350-1 line, the readings taken from January 2013 to July 2013 varied from 1.11%
to1.28%, and on the Green Bay 350-2 line, the readings ranged from 0.93% to 1.29% during the
same time period. Finally, on the Oshkosh 1-355 line, the readings were all above 0.9% from
May 2013 to September 2013.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 192.625(a) by failing to odorize the
natural gas in its transmission facilities in Wisconsin so that at a concentration in air of one-fifth
of the lower explosive limit, the gas was readily detectable by a person with a normal sense of
smell.
Item 8: The Notice alleged that Respondent violated 49 C.F.R. § 192.479(a), which states:



CPF No. 3-2016-1001
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§ 192.479 Atmospheric corrosion control: General.
(a) Each operator must clean and coat each pipeline or portion of pipeline
that is exposed to the atmosphere, except pipelines under paragraph (c) of this
section.
The Notice alleged that Respondent violated 49 C.F.R. § 192.479(a) by failing to clean and
coat a pipeline at the pipe supports where it was exposed to the atmosphere. Specifically, the
Notice alleged that at the Milan Tap and Meter Station in Michigan, ANR failed to clean and
coat the pipeline at the pipe supports where it was exposed to the atmosphere. The MI-PSC field
evaluation found atmospheric corrosion at these supports.
The pipeline supports could not be lowered so ANR can properly inspect and address the pipe on
the supports. As a result, actual metal loss from atmospheric corrosion was noted during MI-
PSC’s field inspection.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 192.479(a) by failing to clean and
coat a pipeline at the pipe supports where it was exposed to the atmosphere.
Item 10: The Notice alleged that Respondent violated 49 C.F.R. § 199.105(b), which states in
relevant part:
§ 199.105 Drug tests required.
Each operator shall conduct the following drug tests for the presence of a
prohibited drug:
(a) . . .
(b) Post-accident testing. As soon as possible but no later than 32 hours
after an accident, an operator shall drug test each employee whose performance
either contributed to the accident or cannot be completely discounted as a
contributing factor to the accident. An operator may decide not to test under
this paragraph but such a decision must be based on the best information
available immediately after the accident that the employee’s performance could
not have contributed to the accident or that, because of the time between that
performance and the accident, it is not likely that a drug test would reveal
whether the performance was affected by drug use.
The Notice alleged that Respondent violated 49 C.F.R. § 199.105(b) by failing to administer
post-accident drug tests to three employees involved in the August 2013 crankcase-explosion
incident that occurred at the ANR compressor station in Sandwich, Illinois. Specifically, the
Notice alleged that on August 9, 2013, at 13:30 MDT, compressor unit #1009 in Sandwich,
Illinois, experienced an explosion of natural gas in the crankcase that resulted in significant
damage to the compressor unit and building. As mentioned above in Item 4, during maintenance
of the compressor unit, a torch was utilized by an ANR employee to remove a seal. The Notice
alleged that, based on the best information available immediately after the incident, it was not
reasonable for the operator to make the decision that the employees’ performance could be
completely discounted as a contributing factor. In fact, ANR’s subsequent root-cause analysis



CPF No. 3-2016-1001
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confirmed that employee performance during the maintenance activity contributed to the
incident.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 199.105(b) by failing to administer
post-accident drug tests to three employees involved in the August 2013 crankcase-explosion
incident that occurred at the company’s compressor station in Sandwich, Illinois.
Item 11: The Notice alleged that Respondent violated 49 C.F.R. § 199.225(a)(1), which states in
relevant part:
§ 199.225 Alcohol tests required.
Each operator shall conduct the following types of alcohol tests for the
presence of alcohol:
(a) Post-accident. (1) As soon as practicable following an accident, each
operator shall test each surviving covered employee for alcohol if that
employee's performance of a covered function either contributed to the accident
or cannot be completely discounted as a contributing factor to the accident. The
decision not to administer a test under this section shall be based on the
operator’s determination, using the best available information at the time of the
determination, that the covered employee’s performance could not have
contributed to the accident.
The Notice alleged that Respondent violated 49 C.F.R. § 199.225(a)(1) by failing to administer
post-accident alcohol tests to three employees involved in the August 2013 crankcase-explosion
incident that occurred at the ANR compressor station in Sandwich, Illinois. Specifically, the
Notice alleged that on August 9, 2013, at 13:30 MDT, compressor unit #1009 in Sandwich,
Illinois, experienced an explosion of natural gas in the crankcase that resulted in obviously
significant damage to the compressor unit and building. The Notice alleged that during
maintenance of the compressor unit, a torch had been utilized by an ANR employee to remove a
seal. According to the Notice, based on the best information available immediately after the
incident, it was not reasonable for the operator to make the decision that the employees’
performance could be completely discounted as a contributing factor. In fact, ANR’s subsequent
root-cause analysis confirmed that employee performance during the maintenance activity
contributed to the incident.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 199.225(a)(1) by failing to
administer post-accident alcohol tests to three employees involved in the August 2013 crankcase-
explosion incident that occurred at the compressor station in Sandwich, Illinois.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.



CPF No. 3-2016-1001
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ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed
$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any
related series of violations.2 In determining the amount of a civil penalty under 49 U.S.C.
§ 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature,
circumstances, and gravity of the violation, including adverse impact on the environment; the
degree of Respondent’s culpability; the history of Respondent’s prior offenses; and any effect
that the penalty may have on its ability to continue doing business; and the good faith of
Respondent in attempting to comply with the pipeline safety regulations. In addition, I may
consider the economic benefit gained from the violation without any reduction because of
subsequent damages, and such other matters as justice may require. The Notice proposed a total
civil penalty of $220,200 for the violations cited above.
Item 1: The Notice proposed a civil penalty of $47,500 for Respondent’s violation of 49 C.F.R.
§ 191.5, for failing to notify the NRC of a 2012 incident that occurred at the ANR compressor
station in Sandwich, Illinois. ANR neither contested the allegation nor presented any evidence
or argument justifying elimination or reduction of the proposed penalty. Accordingly, having
reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of
$47,500 for violation of 49 C.F.R. § 191.5.
Item 2: The Notice proposed a civil penalty of $47,500 for Respondent’s violation of 49 C.F.R.
§ 191.5, for failing to notify the NRC of a 2013 incident that occurred at the ANR compressor
station in Sandwich, Illinois. ANR neither contested the allegation nor presented any evidence
or argument justifying elimination or reduction of the proposed penalty. Accordingly, having
reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of
$47,500 for violation of 49 C.F.R. § 191.5.
Item 3: The Notice proposed a civil penalty of $40,300 for Respondent’s violation of 49 C.F.R.
§ 191.15(a), for failing to submit a written report, as soon as practicable but not more than 30
days, after detection of an incident that was required to be reported under § 191.5. ANR neither
contested the allegation nor presented any evidence or argument justifying elimination or
reduction of the proposed penalty. Accordingly, having reviewed the record and considered the
assessment criteria, I assess Respondent a civil penalty of $40,300 for violation of 49 C.F.R.
§ 191.15(a).
Item 4: The Notice proposed a civil penalty of $40,300 for Respondent’s violation of 49 C.F.R.
§ 191.15(a), for failing to submit a written report, as soon as practicable but not more than 30
days, after detection of an incident that was required to be reported under § 191.5. ANR neither
contested the allegation nor presented any evidence or argument justifying elimination or
reduction of the proposed penalty. Accordingly, having reviewed the record and considered the
assessment criteria, I assess Respondent a civil penalty of $40,300 for violation of 49 C.F.R.
§ 191.15(a).
2 These amounts are adjusted annually for inflation. See, e.g., Pipeline Safety: Inflation Adjustment of Maximum
Civil Penalties, 82 Fed. Reg. 19325 (April 27, 2017).



CPF No. 3-2016-1001
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Item 10: The Notice proposed a civil penalty of $22,300 for Respondent’s violation of 49
C.F.R. § 199.105(b), for failing to administer post-accident drug tests to three employees
involved in the August 2013 crankcase-explosion incident that occurred at the compressor station
in Sandwich, Illinois. ANR neither contested the allegation nor presented any evidence or
argument justifying elimination or reduction of the proposed penalty. Accordingly, having
reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of
$22,300 for violation of 49 C.F.R. § 199.105(b).
Item 11: The Notice proposed a civil penalty of $22,300 for Respondent’s violation of 49
C.F.R. § 199.225(a)(1), for failing to administer post-accident alcohol tests to three employees
involved in the August 2013 crankcase-explosion incident that occurred at the compressor station
in Sandwich, Illinois. ANR neither contested the allegation nor presented any evidence or
argument justifying elimination or reduction of the proposed penalty. Accordingly, having
reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of
$22,300 for violation of 49 C.F.R. § 199.225(a)(1).
In summary, having reviewed the record and considered the assessment criteria for each of the
Items cited above, I assess Respondent a total civil penalty of $220,200.
Payment of the civil penalty must be made within 20 days of service. Federal regulations
(49 C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer through the Federal
Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed
instructions are contained in the enclosure. Questions concerning wire transfers should be
directed to: Financial Operations Division (AMK-325), Federal Aviation Administration, 6500 S
MacArthur Blvd., Oklahoma City, Oklahoma 79169. The Financial Operations Division
telephone number is (405) 954-8845.
Failure to pay the $220,200 civil penalty will result in accrual of interest at the current annual
rate in accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to
those same authorities, a late penalty charge of six percent (6%) per annum will be charged if
payment is not made within 110 days of service. Furthermore, failure to pay the civil penalty
may result in referral of the matter to the Attorney General for appropriate action in a district
court of the United States.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Items 3, 4, 5, 6, 7, and 8 in the Notice
for violations of 49 C.F.R. Parts 191 and 192. Under 49 U.S.C. § 60118(a), each person who
engages in the transportation of gas or who owns or operates a pipeline facility is required to
comply with the applicable safety standards established under chapter 601. The Director has
indicated that Respondent has taken the following actions to address some of the cited violations:
1. With respect to the violation of § 191.15(a) (Items 3 and 4), Respondent
submitted the required 30-day written reports for the incidents that occurred on



2. 3. 4. CPF No. 3-2016-1001
Page 11
July 13, 2012, and August 9, 2013. OPS Central Region staff reviewed the two
reports [Nos. 20160051 & 20160052], and the reports are now final in the Online
Data Entry System (ODES) database, with no further action required.
With respect to the violation of § 191.15(a) (Items 3 and 4), Respondent
developed a plan to review all sources of data, including, but not limited to:
ANR’s IIT database, root-cause analysis reports, unaccounted-for gas reports,
leak databases, etc., and submitted required original and supplemental incident
reports through ODES. Since the date of the Notice, ANR also reviewed events
occurring on the ANR pipeline system between January 1, 2010, and May 31,
2016, and determined that no other events required additional reporting under
§§ 191.5 and 191.15. ANR submitted a listing of the 233 events in the June 2016
response. With the submission of such information, ANR has satisfied the terms
of the proposed compliance order for these items.
With respect to the violation of § 192.603(b) (Item 6), Respondent reviewed the
database for abnormal operations that occurred on or after May 19, 2009, through
May 31, 2016. The review found 460 abnormal-operation records for the ANR
pipeline system. Of the 460 abnormal operations reviewed, 59 records had
documented the corrective measures. Review of the 59 records found deficiencies
for five records within the IIT database and two records within the Systems
Applications Products database. These deficient records were updated to include
proper documentation and pertinent information. ANR submitted the list of seven
abnormal operations that required further documentation in its June 2016
response. ANR has therefore completed the proposed item and satisfied the terms
of the proposed compliance order for this item.
With respect to the violation of § 192.625 (Item 7), Respondent re-trained
personnel taking odorant readings and completed the training on May 4, 2016. It
submitted a copy of the training records to the Director with its June 2016
response. ANR has therefore completed the proposed item and satisfied the terms
of the proposed compliance order for this item.
Accordingly, I find that compliance has been achieved with respect to these violations.
Therefore, the compliance terms proposed in the Notice for Items 3, 4, 6 and 7 are not included
in this Order.
As for the remaining compliance terms, pursuant to the authority of 49 U.S.C. § 60118(b) and
49 C.F.R. § 190.217, Respondent is ordered to take the following actions to ensure compliance
with the pipeline safety regulations applicable to its operations:
1. With respect to the violation of § 192.605 (Item 5), Respondent must
provide a detailed written procedure to address the periodic review of work done to
determine the effectiveness of its operations and maintenance procedures. The
procedure must encompass all aspects of the outline provided by ANR in its June
2016 response, with emphasis on how the review of the work will be accomplished



CPF No. 3-2016-1001
Page 12
and thoroughly describe how the program will be documented. Respondent must
submit the written program to the Director within 90 days of the issuance of the Final
Order, implement the revised procedure within 180 days of the Final Order, and
provide semi-annual reports to the Director on the results of the revised program for a
period of one year from the implementation date.
2. With respect to the violation of § 192.479(a) (Item 8), Respondent must conduct
an atmospheric-corrosion inspection of all meter stations in the Michigan operating
area that have similar pipe supports, and submit a remedial action plan with a
schedule and listing of facilities still requiring remediation to the Director for
approval no later than 120 days after issuance of the Final Order.
All required written submissions shall be sent to the attention of the Director, Central Region,
Office of Pipeline Safety, 901 Locust Street, Room 462, Kansas City, MO 64106.
It is requested (not mandated) that ANR Pipeline Company maintain documentation of the safety
improvement costs associated with fulfilling this Compliance Order and submit the total to the
Director, Central Region, Office of Pipeline Safety, Pipeline and Hazardous Materials Safety
Administration. It is requested that these costs be reported in two categories: 1) total cost
associated with preparation/revision of plans, procedures, studies and analyses; and 2) total cost
associated with replacements, additions and other changes to pipeline infrastructure.
The Director may grant an extension of time to comply with any of the required items upon a
written request timely submitted by the Respondent and demonstrating good cause for an
extension.
Failure to comply with this Order may result in administrative assessment of civil penalties not
to exceed $200,000 for each violation for each day the violation continues or in referral to the
Attorney General for appropriate relief in a district court of the United States.
WARNING ITEM
With respect to Item 9, the Notice alleged a probable violation of § 192.736 but did not propose a
civil penalty or compliance order for this item. Therefore, this is considered to be a warning
item. The warning was for:
49 C.F.R. § 192.736(c) (Item 9) ─ Respondent’s alleged failure to maintain the
gas detectors at the Bridgeman Compressor Station for units 1206 to 1209.
ANR presented information in its Response showing that it had taken certain actions to address
the cited item. If OPS finds a violation of this provision in a subsequent inspection, Respondent
may be subject to future enforcement action.
Under 49 C.F.R. § 190.243, Respondent has a right to submit a Petition for Reconsideration of
this Final Order. The petition must be sent to: Associate Administrator, Office of Pipeline



CPF No. 3-2016-1001
Page 13
Safety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC
20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address. PHMSA
will accept petitions received no later than 20 days after receipt of service of this Final Order by
the Respondent, provided they contain a brief statement of the issue(s) and meet all other
requirements of 49 C.F.R. § 190.243. The filing of a petition automatically stays the payment of
any civil penalty assessed. Unless the Associate Administrator, upon request, grants a stay, all
other terms and conditions of this Final Order are effective upon service in accordance with
49 C.F.R. § 190.5.
October 24, 2017
___________________________________ __________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety

320161001_NOPV PCP PCO_01282016_text.pdf

NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPLIANCE ORDER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
January 28, 2016
Mr. Vern Meier
Vice President, Field Operations
ANR Pipeline Company / TransCanada
717 Texas Avenue
Houston, Texas 77002
CPF 3-2016-1001
Dear Mr. Meier:
On June 24-28, July 15-19, August 5-19, August 26-30, October 22-25, and December 2-6,
2013, representatives of the Pipeline and Hazardous Materials Safety Administration
(PHMSA), Office of Pipeline Safety (OPS), the Ohio Public Utilities Commission, and the
Iowa Utilities Board, pursuant to Chapter 601 of 49 United States Code inspected ANR
Pipeline Company’s (ANR) records and procedures in Houston, Texas, and ANR facilities
in Iowa, Missouri, Kansas, Ohio, Illinois, Indiana, and Wisconsin. The Michigan Public
Service Commission (MI PSC) inspected your records and facilities in Michigan during
several weeks in 2012.
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 violation(s) are:
In 2007, ANR Pipeline company became a wholly owned pipeline subsidiary of TransCanada.



1. §191.5 Immediate notice of certain incidents.
(a) At the earliest practicable moment following discovery, each operator shall
give notice in accordance with paragraph (b) of this section of each incident as
defined in §191.3.
(b) Each notice required by paragraph (a) of this section must be made
to the National Response Center either by telephone to 800-424- 8802 (in
Washington, D.C., 202-267-2675) or electronically at
http://www.nrc.uscg.mil and must include the following information:
(1) Names of operator and person making report and their telephone
numbers.
(2) The location of the incident.
(3) The time of the incident.
(4) The number of fatalities and personal injuries, if any.
(5) All other significant facts that are known by the operator that are
relevant to the cause of the incident or extent of the damages.
ANR Pipeline Company (ANR) did not give notice to the National Response Center
of a 2012 incident as defined in §191.3 that occurred at the compressor station in
Sandwich, Illinois.
49 C.F.R. §191.3 defines “incident” as the following:
(1) An event that involves a release of gas from a pipeline, or of
liquefied natural gas, liquefied petroleum gas, refrigerant gas, or gas
from an LNG facility, and that results in one or more of the following
consequences:
(i) A death, or personal injury necessitating in-patient hospitalization;
(ii) Estimated property damage of $50,000 or more, including loss to
the operator and others, or both, but excluding cost of gas lost;
(iii) Unintentional estimated gas loss of three million cubic feet or
more;
(2) An event that results in an emergency shutdown of an LNG facility.
Activation of an emergency shutdown system for reasons other than an
actual emergency does not constitute an incident.
(3) An event that is significant in the judgment of the operator, even
though it did not meet the criteria of paragraphs (1) or (2) of this
definition.
On July 13, 2012, an incident occurred at the Sandwich compressor station where no
notification was made to the National Response Center (NRC). The property
damage, excluding cost of any gas lost, was over $50,000.
2



2. The incident involved a release of natural gas from a part of the pipeline system and
the resulting ignition of natural gas. Natural gas leaked from a valve in the pipeline
system into the silencer, on Compressor Unit 1009. An ignition and uncontrolled
burning of the gas occurred following the leak into the silencer, which is not a part
of the pipeline system that moves gas in transportation. Released gas ignited at the
silencer resulted in an uncontrolled burn that damaged the silencer and exhaust
piping, and the silencer fell over and damaged the compressor building as well.
Despite this damage to its pipeline facility caused by a natural gas fire, ANR did not
contact the National Response Center as required.
§191.5 Immediate notice of certain incidents.
(a) At the earliest practicable moment following discovery, each operator shall
give notice in accordance with paragraph (b) of this section of each incident as
defined in §191.3.
(b) Each notice required by paragraph (a) of this section must be made
to the National Response Center either by telephone to 800-424- 8802 (in
Washington, D.C., 202-267-2675) or electronically at
http://www.nrc.uscg.mil and must include the following information:
(1) Names of operator and person making report and their telephone
numbers.
(2) The location of the incident.
(3) The time of the incident.
(4) The number of fatalities and personal injuries, if any.
(5) All other significant facts that are known by the operator that are
relevant to the cause of the incident or extent of the damages.
ANR Pipeline Company (ANR) did not give notice to the National Response Center
of a 2013 incident as defined in §191.3 that occurred at the compressor station in
Sandwich, Illinois.
On August 9, 2013, at 13:30 MDT, ANR experienced another incident at the
Sandwich compressor station where no notification was made to the National
Response Center (NRC). The property damage, excluding cost of lost gas, was over
$50,000.
The incident involved a release of natural gas when natural gas leaked past pressure
and wiper packing of the compressor unit during maintenance of the unit. After
leaking past the compressor packing, the natural gas entered the crankcase of the
compressor unit. The leak into the crankcase, which is not a part of the pipeline
3



3. 4. system that moves gas in transportation, resulted in the ignition and explosion of the
gas. The resultant explosion of released natural gas caused substantial damage to
equipment and the compressor building.
Despite the damage to its pipeline facility caused by a natural gas explosion, ANR
did not contact the National Response Center as required.
§191.15 Transmission systems, gathering systems, and liquefied natural gas
facilities; Incident report.
(a) Transmission or Gathering. Each operator of a transmission or a gathering
pipeline system must submit DOT Form PHMSA F 7100.2 as soon as
practicable but not more than 30 days after detection of an incident
required to be reported under §191.5 of this part.
ANR did not submit a written report, as soon as practicable but not more than 30
days after detection of an incident that was required to be reported under §191.5, for
the Sandwich compressor station incident that occurred on July 13, 2012, as
described in Item 1 above.
Based on information provided by ANR during PHSMA’s 2013 inspection, the costs
of this incident totaled over $200,000. According to ANR’s root cause analysis
report provided during PHMSA’s 2013 inspection, natural gas released from a valve
in the pipeline system into the engine and silencer creating a combustible mixture in
the silencer that ignited and resulted in an uncontrolled burning of gas at the
silencer.
§191.15 Transmission systems, gathering systems, and liquefied natural gas
facilities; Incident report.
(a) Transmission or Gathering. Each operator of a transmission or a gathering
pipeline system must submit DOT Form PHMSA F 7100.2 as soon as
practicable but not more than 30 days after detection of an incident
required to be reported under §191.5 of this part.
ANR did not submit a written report within 30-days for the Sandwich compressor
station explosion that occurred on August 9, 2013, that was required to be reported
under §191.5. This incident occurred during maintenance of the compressor unit as
described in Item 2 above.
The damage was significant and the total cost of the incident was $580,205.
4



According to ANR’s root cause analysis report provided during PHMSA’s 2013
inspection, this incident involved natural gas that leaked past pressure and wiper
packing of the pipeline system compressor into the crankcase. When maintenance
personnel applied heat to a seal to facilitate its removal, the leak into the crankcase
resulted in an ignition and explosion of the gas. The resultant explosion of released
natural gas caused substantial damage to equipment and the compressor building.
5. §192.605 Procedural manual for operations, maintenance, and emergencies
(a) General. Each operator shall prepare and follow for each pipeline, a
manual of written procedures for conducting operations and maintenance
activities and for emergency response.
(b) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following,
if applicable, to provide safety during maintenance and operations.
(8) Periodically reviewing the work done by operator personnel to
determine the effectiveness and adequacy of the procedures used in
normal operation and maintenance and modifying the procedure when
deficiencies are found.
ANR did not implement and follow its own “walk-along” procedure throughout the
company to review the work done by its personnel to determine the effectiveness
and adequacy of the procedures being used in normal operation and maintenance.
During PHMSA’s review, ANR did not provide sufficient records to
demonstrate that the walk-along program was being used throughout the
company. The MI-PSC inspections in 2012 also identified the same issue.
ANR personnel indicated in 2012 and in 2013 that final procedures were still
under development, but a form had been established and was being used
during the interim period. ANR provided examples of the form used in 2013
in Michigan and another used in Wisconsin in 2011; however, there were no
other records indicating that the “walk along” program and forms were used
elsewhere on the ANR system.
6. §192.603 General provisions
(b) Each operator shall keep records necessary to administer the
procedures established under §192.605.
5



This states:
§192.605 Procedural manual for operations, maintenance, and
emergencies
(c) Abnormal operation. For transmission lines, the manual
required by paragraph (a) of this section must include
procedures for the following to provide safety when operating
design limits have been exceeded:
(1) Responding to, investigating, and correcting the cause of:
(i) Unintended closure of valves or shutdowns;
(ii) Increase or decrease in pressure or flow rate outside normal
operating limits;
(iii) Loss of communications;
(iv) Operation of any safety device; and,
(v) Any other foreseeable malfunction of a component, deviation
from normal operation, or personnel error which may result in a
hazard to persons or property.
ANR did not document the follow-up investigation of multiple abnormal
operations that occurred on the pipeline system. A review of the Incident
and Issue Tracking (ITT) database showed instances when documentation of
further investigation and corrective measures did not occur.
Specifically, IIT #237072 was for a leak of lube oil from a broken pressure
gauge, and IIT #255422 involved a pressure increase outside normal limits at
the Rapid River Compressor station. The IIT entry indicated that procedures
were not completely effective in responding to the abnormal operation;
however, no further documentation was provided to show what corrections
were made.
7. §192.625 Odorization of gas.
a) A combustible gas in a distribution line must contain a natural
odorant or be odorized so that at a concentration in air of one-fifth of
the lower explosive limit, the gas is readily detectable by a person with a
normal sense of smell.
(b) After December 31, 1976, a combustible gas in a transmission line in a
Class 3 or Class 4 location must comply with the requirements of paragraph (a)
of this section unless:
6



8. 9. For odorized transmission line facilities in Wisconsin, ANR’s records did
not demonstrate that the natural gas was odorized to a concentration in air of
one-fifth of the lower explosive limit as described in §192.625(a).
Review of the odorization records identified multiple locations where the
readings taken did not meet one-fifth gas-in-air (0.9%) of the lower
explosive limit of natural gas (4.5% gas-in-air). On the Green Bay 350 line,
the percent gas-in-air readings taken from 11/2012 to 7/2013 were 1.06% to
1.29%. On the Green Bay 350-1 line the readings taken from 1/2013 to
7/2013 varied from 1.11% to 1.28%, and on the Green Bay 350-2 line, the
readings were from 0.93% to 1.29% during the same time period.
Additionally, on the Oshkosh 1-355 line, the readings were all above 0.9%
from 5/2013 to 9/2013.
§192.479 Atmospheric corrosion control – General
(a) Each operator must clean and coat each pipeline or portion of
pipeline that is exposed to the atmosphere, except pipelines under
paragraph (c) of this section.
At the Milan Tap and Meter Station in Michigan, ANR did not clean and
coat the pipeline at the supports where it was exposed to the atmosphere.
The MI-PSC field evaluation found atmospheric corrosion at these supports.
The pipeline supports could not be lowered so ANR can properly inspect and
address the pipe on the supports. As a result, actual metal loss from
atmospheric corrosion was noted during MI-PSC’s field inspection.
§192.736 Compressor stations: Gas detection.
(c) Each gas detection and alarm system required by this section must
be maintained to function properly. The maintenance must include
performance tests.
ANR did not maintain the gas detectors at the Bridgeman Compressor station for
units 1206 to 1209.
Review of the gas detection records found that the gas detectors for Units 1206 to
1209 were not being inspected. ANR documentation indicated that personnel were
unable to access detectors for units 1206 to1209 for cleaning and malfunction
testing.
7



10. §199.105 Drug tests required.
Each operator shall conduct the following drug tests for the presence of a
prohibited drug:
(b) Post-accident testing. As soon as possible but no later than 32 hours after
an accident, an operator shall drug test each employee whose performance
either contributed to the accident or cannot be completely discounted as a
contributing factor to the accident. An operator may decide not to test under
this paragraph but such a decision must be based on the best information
available immediately after the accident that the employee's performance could
not have contributed to the accident or that, because of the time between that
performance and the accident, it is not likely that a drug test would reveal
whether the performance was affected by drug use.
ANR Pipeline Company (ANR) did not administer post-accident drug tests to three
employees involved in the August 2013 crankcase explosion incident that occurred
at the compressor station in Sandwich, Illinois.
On August 9, 2013, at 13:30 MDT, compressor unit #1009 in Sandwich, Illinois,
experienced an explosion of natural gas in the crankcase that resulted in obviously
significant damage to the compressor unit and building. As mentioned above in
Item 4, during maintenance of the compressor unit, a torch was utilized by an ANR
employee to remove a seal. Based on the best information available immediately
after the incident, it was not reasonable for the operator to make a decision that the
employee’s performance could be completely discounted as a contributing factor.
ANR’s Root Cause Analysis confirmed that employee performance during the
maintenance activity contributed to the incident.
11. §199.225 Alcohol tests required.
Each operator shall conduct the following types of alcohol tests for the presence
of alcohol:
(a) Post-accident.
(1) As soon as practicable following an accident, each operator shall test each
surviving covered employee for alcohol if that employee's performance of a
covered function either contributed to the accident or cannot be completely
discounted as a contributing factor to the accident. The decision not to
administer a test under this section shall be based on the operator's
8



determination, using the best available information at the time of the
determination, that the covered employee's performance could not have
contributed to the accident.
ANR Pipeline Company (ANR) did not administer post-accident alcohol tests to
three employees involved in the August 2013 crankcase explosion incident that
occurred at the compressor station in Sandwich, Illinois.
On August 9, 2013, at 13:30 MDT, compressor unit #1009 in Sandwich, Illinois,
Proposed Civil Penalty
Under 49 United States Code, §60122, you are subject to a civil penalty not to exceed
related series violinion pes othe violation persis up to a maniary 4,2012, the maxima
elated series of violations.
violation(s) and has recommended that you be preliminarily assessed a civil penalty of
$220,200 as follows:
Item number
PENALTY
1
$47,500
2
$47,500
3
$40,300
4
$40,300
10
$22,300
11
$22,300
Warning Items
With respect to item nine (9), 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 promptly correct
this item. Failure to do so may result in additional enforcement action.
9



Proposed Compliance Order
With respect to items three (3), four (4), five (5), six (6), seven (7), and eight (8) pursuant to
49 United States Code §60118, the Pipeline and Hazardous Materials Safety Administration
proposes to issue a Compliance Order to ANR Pipeline Company. Please refer to the
Proposed Compliance Order, which is enclosed and made a part of this Notice.
Response to this Notice
Enclosed as part of this Notice is a document entitled Response Options for Pipeline
Operators in Compliance Proceedings. Please refer to this document and note the response
options. All material you submit in response to this enforcement action may be 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). If you do not
respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to
contest the allegations in this Notice and authorizes the Associate Administrator for
Pipeline Safety to find facts as alleged in this Notice without further notice to you and to
issue a Final Order.
In your correspondence on this matter, please refer to CPF 3-2016-1001 and for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
Allan C. Beshore
Director, Central Region, OPS
Pipeline and Hazardous Materials Safety Administration
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Compliance Proceedings
10



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to ANR Pipeline Company a Compliance Order
incorporating the following remedial requirements to ensure the compliance of ANR
Pipeline Company with the pipeline safety regulations:
1. 2. 3. 4. 5. In regard to Item Numbers 3 and 4 of the Notice pertaining to not submitting
the written reports for the incidents that occurred on July 13, 2012, and
August 9, 2013, ANR must submit the required reports through PHMSA’s
Online Data Entry System (ODES) within 30 days of issuance of the Final
Order, and notify the Central Region Director that the reports have been
submitted to ODES.
In regard to Item Numbers 3 and 4 of the Notice pertaining to not submitting
reports for incidents occurring on the ANR pipeline system, ANR must
develop a plan to review all sources of data, including but not limited to: the
IIT database, root cause analysis reports, unaccounted for gas reports, leak
databases, etc. and submit required original and supplemental reports
through ODES within 180 days of issuance of the Final Order. The scope of
the review shall be for all events occurring on or after January 1, 2010,
through the date of issuance of the Final Order. In addition to submitting the
reports through ODES, ANR shall provide to the Central Region Director a
complete listing of all data and events that were reviewed indicating whether
the event met the criteria for reporting (and why certain events did not meet
criteria for reporting) including the date when the required reports were
submitted to ODES.
In regard to Item Number 5 of the Notice pertaining to not implementing the
“walk-along” program to meet the requirements of 192.605(b)(8), ANR must
complete development of the program and procedures as needed, and begin
implementation of the program throughout the ANR system. The written
program must be submitted to the Central Region Director within 60 days of
issuance of the Final Order, the implementation begun within 90 days of the
Final Order, and a documentation of the program results submitted within
180 days of the Final Order.
In regard to Item Number 6 of the notice pertaining to not documenting the
results and follow-up of the abnormal operations in the IIT database, ANR
must conduct a comprehensive review of the IIT database to identify
deficient documentation and update the reports with all pertinent
information. The review and update of the IIT database must be completed
no later than 180 days after issuance of the Final Order, and written
documentation demonstrating compliance submitted to the Central Region
Director within 30 days of completing the review and update.
In regard to Item Number 7 of the Notice pertaining to deficient odorant
readings, ANR must re-train personnel taking the readings and submit a copy
of the training records to the Central Region Director within 180 days of
issuance of the Final Order.
11



6. 7. 8. In regard to Item Number 8 of the Notice pertaining to atmospheric
corrosion of the pipe at the Milan Tap and Meter Station, ANR must
complete remedial action and submit documentation to the Central Region
Director within 30 days of issuance of the Final Order. Additionally, within
90 days of issuance of the Final Order ANR must conduct an atmospheric
inspection of all meter stations in the Michigan operating area that have
similar supports, and submit a remedial action plan with a schedule and
listing of facilities requiring remediation to the Central Region Director for
approval no later than 120 days after issuance of the Final Order.
For Items 1 through 6 of this compliance order, all required written
submissions shall be sent to the attention of Allan C. Beshore, Director,
Central Region, at 901 Locust Street, Room 462, Kansas City, MO 64106.
It is requested (not mandated) that ANR Pipeline Company maintain
documentation of the safety improvement costs associated with fulfilling this
Compliance Order and submit the total to Allan C. Beshore, Director,
Central Region, Pipeline and Hazardous Materials Safety Administration. It
is requested that these costs be reported in two categories: 1) total cost
associated with preparation/revision of plans, procedures, studies and
analyses, and 2) total cost associated with replacements, additions and other
changes to pipeline infrastructure.
12

320161001_Closure Letter_08012019_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
August 1, 2019
Mr. Stanley Chapman
Executive Vice President & President, US Pipelines
ANR Pipeline Company
700 Louisiana Street
Suite 700
Houston, TX, 77002
CPF 3-2016-1001
Dear Mr. Chapman:
On October 24, 2017, the Pipeline and Hazardous Materials Safety Administration (PHMSA)
issued to ANR Pipeline Company a Final Order in the above-referenced case. This Order
included a Compliance Order and Civil Penalty assessment. Based on our review of the
documentation you provided and confirmation of payment of the civil penalty, it has been
determined that you have complied with the terms of this Order.
Accordingly, this case is now closed and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
Allan C. Beshore
Director, Central Region, OPS
Pipeline and Hazardous Materials Safety Administration

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/320161001>
- Source ID: `phmsa-enforcement`
- SHA-256: `9a25a6fff3fd7064c491b5f39c44af5f04a465defd42ca80d2a7666962d1ec21`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T17:27:53.323Z
- Document slug: `phmsa-enforcement-320161001`

### Source metadata

```json
{
  "cpf": "320161001",
  "operator": "ANR PIPELINE CO",
  "region": "Central",
  "pipelineType": "GAS INTERSTATE ONSHORE",
  "caseStatus": "CLOSED",
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}
```