# TC OIL PIPELINE OPERATIONS INC — Notice of Amendment

**Citation:** CPF 420165013M  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2016-04-26

CLOSED notice of amendment citing 190.203(f), 195.402(c)(14), 195.405(a), 195.405(b), 195.430(a), 195.432(b), 195.54(a), 195.567(c), 195.571, 195.579(c), 195.583(a), 195.583(b).

## Document text

Notice of Amendment involving TC OIL PIPELINE OPERATIONS INC. PHMSA's enforcement data identifies the cited regulations as 190.203(f),  195.402(c)(14),  195.405(a),  195.405(b),  195.430(a),  195.432(b),  195.54(a),  195.567(c),  195.571,  195.579(c),  195.583(a),  195.583(b). The case was opened on 2016-04-26 and is reported as closed as of 2019-07-09. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420165013M_Closure Letter_07092019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165013M/420165013M_Closure%20Letter_07092019.pdf

420165013M_Closure Letter_07092019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165013M/420165013M_Closure%20Letter_07092019_text.pdf

420165013M_Notice of Amendment_04262016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165013M/420165013M_Notice%20of%20Amendment_04262016.pdf

420165013M_Notice of Amendment_04262016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165013M/420165013M_Notice%20of%20Amendment_04262016_text.pdf

420165013M_Order Directing Amendment_02042019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165013M/420165013M_Order%20Directing%20Amendment_02042019.pdf

420165013M_Order Directing Amendment_02042019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165013M/420165013M_Order%20Directing%20Amendment_02042019_text.pdf

420165013M_Notice of Amendment_04262016_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
April 26, 2016
Mr. Paul Miller
Executive-Vice President/President, Liquids Pipelines
TC Oil Pipeline Operations Inc.
450-1 Street SW
Calgary, Alberta, Canada
T2P 5H1
CPF 4-2016-5013M
Dear Mr. Miller:
On March 3, 2015 – May 14, 2015, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected TC Oil
Pipeline Operations Inc. (TransCanada) procedures and records for the pipeline facilities of the
Keystone XL – Gulf Coast Pipeline.
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
TransCanada’s plans or procedures, as described below:
1. § 195.402 Procedural manual for operations, maintenance, and emergencies.
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
(14) Taking adequate precautions in excavated trenches to protect personnel from the
hazards of unsafe accumulations of vapor or gas, and making available when needed at
the excavation, emergency rescue equipment, including a breathing apparatus and, a
rescue harness and line.
TransCanada’s operating procedure (Procedure), “Oil Pipelines Pressure Restriction
Implementation Procedure”, section 5.0; page 5 of 8, revision 00, dated 2013/02/07 did not include
adequate requirements for documenting the pressure restrictions specified by the procedures.



TransCanada’s operating procedure (Form), “Excavation Procedure Checklist”; revision 8, dated
2012/07/05 does not include an item requiring documentation of the pressure restriction at the
excavation location. TransCanada must revise the Excavation Procedure Checklist to include
documentation of the pressure restriction.
2. § 195.432 Inspection of in-service breakout tanks.
(b) Each operator must inspect the physical integrity of in-service atmospheric and low-
pressure steel aboveground breakout tanks according to API Standard 653 (incorporated
by reference, see § 195.3). However, if structural conditions prevent access to the tank
bottom, the bottom integrity may be assessed according to a plan included in the
operations and maintenance manual under § 195.402(c)(3).
TransCanada's Procedure 195.432, “Inspection of In-Service Breakout Tanks”, revision 8, dated
2015/02/16, section 3 references API 653, Section 4 for the inspection requirements of
aboveground breakout tanks references the wrong section of API 653. The correct reference is API
653 Standards which deals with inspection of in-service breakout tanks.
TransCanada must amend their procedures to require breakout tank inspections be performed in
accordance to the requirements of API 653 Standard and reference the version of API Standard
653 incorporated in Part 195.
3. § 195.430 Firefighting equipment.
Each operator shall maintain adequate firefighting equipment at each pump station and
breakout tank area. The equipment must be—
(a) In proper operating condition at all times;
TransCanada’s procedure 195.430, “Firefighting Equipment”, revision 8, dated 2015/02/16,
section 4.0, “General” does not include the requirement that firefighting equipment be, “in proper
operating condition at all times”.
TransCanada must revise their procedure to specify how and when maintenance will be performed
on the firefighting equipment at each pump station and breakout tank area.
4. § 195.405 Protection against ignitions and safe access/egress involving floating roofs.
(a) After October 2, 2000, protection provided against ignitions arising out of static
electricity, lightning, and stray currents during operation and maintenance activities
involving aboveground breakout tanks must be in accordance with API Recommended
Practice 2003, unless the operator notes in the procedural manual (§ 195.402(c)) why



compliance with all or certain provisions of API Recommended Practice 2003 is not
necessary for the safety of a particular breakout tank.
TransCanada’s O&M procedure 195.405, – “Protection Against Ignitions…”, 3.0 Reference, does
not indicate which edition (7th edition, January 2008) of API 2003 as the referenced standard
incorporated by 49 CFR 195.3.
TransCanada must amend their procedures to reference the version of API RP 2003 incorporated
in Part 195.
5. § 195.405 Protection against ignitions and safe access/egress involving floating roofs.
(b) The hazards associated with access/egress onto floating roofs of in-service
aboveground breakout tanks to perform inspection, service, maintenance or repair
activities (other than specified general considerations, specified routine tasks or entering
tanks removed from service for cleaning) are addressed in API Publication 2026. After
October 2, 2000, the operator must review and consider the potentially hazardous
conditions, safety practices and procedures in API Publication 2026 for inclusion in the
procedure manual (§ 195.402(c)).
TransCanada’s O&M procedure 195.405, – “Protection Against Ignitions…”, 3.0 Reference, does
not indicate which edition (2nd edition, April 1998, reaffirmed June 2006) of API 2026 as the most
current referenced standard as incorporated by 49 CFR 195.3.
TransCanada must amend their procedures to reference the version of API RP 2026 incorporated
in Part 195.
6. § 195.54 Accident reports.
(a) Each operator that experiences an accident that is required to be reported under §
195.50 must, as soon as practicable, but not later than 30 days after discovery of the
accident, file an accident report on DOT Form 7000-1.
TransCanada's Procedure 195.50 and 195.54 Reporting Accidents, does not meet the requirements
of 105.54(a) which states that an operator must, as soon as practicable, but not later than 30 days
after discovery of the accident, file an accident report on DOT Form 7000-1. TransCanada's
procedure does not require the filing of an accident report not later than 30 days after discovery of
the accident.
TransCanada must revise their procedures to require a DOT Form 7000-1 be filed not later than
30 days after discovery of the accident.



7. Per PHMSA Recommended Conditions for Keystone XL State Department
Presidential Permit, Condition 50 states,
Reporting – Immediate: Keystone must provide immediate notification of all reportable
incidents in accordance with 49 CFR 195, and shall notify the appropriate PHMSA
regional office within twenty-four (24) hours of any non-reportable leaks occurring on
the pipeline.
TransCanada's Procedure 195.52 – “Immediate Notice of Certain Accidents”, Section 4.0 General,
#3, and does not meet the requirements of Special Permit Item #50. The permit states that
TransCanada must provide immediate notification of all reportable incidents in accordance with
49 CFR 195, and non-reportable leaks within 24 hours. TransCanada's procedure does not require
the immediate notification of incidents that meet the requirements per 195.50, 195.54, 195.55, and
195.56. Procedure requires only the immediate notification of incidents meeting the criteria of 195.
52.
TransCanada must revise their procedures to require immediate notification of all reportable
incidents as defined by Part 195 and the occurrence of any non-reportable leaks within 24 hours.
8. § 195.567 Which pipelines must have test leads and what must I do to install and
maintain the leads?
(c) Maintenance. You must maintain the test lead wires in a condition that enables you to obtain
electrical measurements to determine whether cathodic protection complies with §
195.571.
§ 195.571 What criteria must I use to determine the adequacy of cathodic protection?
Cathodic protection required by this Subpart must comply with one or more of the
applicable criteria and other considerations for cathodic protection contained in
paragraphs 6.2 and 6.3 of NACE SP 0169 (incorporated by reference, see § 195.3).
TransCanada’s O&M procedure 195.567 – “Test Leads” does not specify a process for taking
cathodic protection readings when a test lead is found to be broken. Additionally, procedure does
not require broken test leads to be repaired before the next monitoring cycle.
TransCanada must revise their procedures to specify the actions for taking cathodic protection
readings when a test lead is broken, and requires repairs be made to that test lead prior to the next
required monitoring cycle.
9. § 195.583 What must I do to monitor atmospheric corrosion control?
(a) You must inspect each pipeline or portion of pipeline that is exposed to the
atmosphere for evidence of atmospheric corrosion, as follows:



If the pipeline
is
located:
Then the frequency of inspection is:
Onshore At least once every 3 calendar years, but with intervals not exceeding 39
months.
Offshore At least once each calendar year, but with intervals not exceeding 15
months.
(b) During inspections you must give particular attention to pipe at soil-to-air
interfaces, under thermal insulation, under disbonded coatings, at pipe supports, in
splash zones, at deck penetrations, and in spans over water.
TransCanada’s O&M procedure 195.583 – “Atmospheric Corrosion Monitoring” does not
specifically include requirements for the inspection of piping under thermal insulation once every
three calendar years, but with intervals not exceeding 39 months. A significant portion of
TransCanada’s above ground piping on the Gulf Coast is insulated manifold piping. Due to the
increase in viscosity the temperature of the commodity drops. TransCanada made no provisions
for atmospheric corrosion inspections of this piping that is subject to a specialized type of
atmospheric corrosion termed corrosion under insulation or CUI.
TransCanada must provide procedures to inspect the insulated piping for atmospheric corrosion as
required by 195.583.
10. § 195.579 What must I do to mitigate internal corrosion?
(c) Removing pipe. Whenever you remove pipe from a pipeline, you must inspect the
internal surface of the pipe for evidence of corrosion. If you find internal corrosion
requiring corrective action under § 195.585, you must investigate circumferentially
and longitudinally beyond the removed pipe (by visual examination, indirect method,
or both) to determine whether additional corrosion requiring remedial action exists
in the vicinity of the removed pipe.
TransCanada’s O&M procedure 195.579 – “Internal Corrosion Control” does not require removed
pipe found with internal corrosion to be investigated circumferentially and longitudinally beyond
the removed the pipe.
TransCanada must revise their procedures to include requirements to investigate circumferentially
and longitudinally remove pipe remove pipe from a pipeline for evidence of corrosion. The
operator must take appropriate corrective action if corrosion is found.



Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. 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. 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). 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.
If, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in this
Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49
C.F.R. § 190.237). If you are not contesting this Notice, we propose that you submit your amended
procedures to my office within 45 days of receipt of this Notice. This period may be extended by
written request for good cause. Once the inadequacies identified herein have been addressed in
your amended procedures, this enforcement action will be closed.
It is requested (not mandated) that TC Oil Pipeline Operations Inc. maintain documentation of the
safety improvement costs associated with fulfilling this Notice of Amendment
(preparation/revision of plans, procedures) and submit the total to R. M. Seeley, Director,
Southwest Region, Pipeline and Hazardous Materials Safety Administration. In correspondence
concerning this matter, please refer to CPF 4-2016-5013M and, for each document you submit,
please provide a copy in electronic format whenever possible.
Sincerely,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings

420165013M_Closure Letter_07092019_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
July 9, 2019
Paul Miller
Executive Vice-President and President, Liquids Pipelines
TC Oil Pipeline Operations, Inc.
450 1st Street S.W.
Calgary, Alberta, Canada T2P5H1
CPF 4-2016-5013M
Dear Mr. Miller:
From March 3, 2015 to May 14, 2015, representatives of the Pipeline and Hazardous Materials
Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code, conducted an
inspection of TC Oil Pipeline Operations, Inc., a subsidiary of TransCanada Corporation
(TransCanada), including its written procedures and records for the pipeline facilities of the Gulf
Coast Pipeline. TransCanada owns and operates the Keystone Pipeline System, including the Gulf
Coast Pipeline.
As a result of the inspection, TransCanada was issued a Notice of Amendment on April 26, 2016.
TransCanada responded to the Notice by letters dated June 8, 2016 and August 26, 2016 with
procedural revisions. Following further discussion to resolve the remaining issues on October 12,
2016 and February 8, 2017 PHMSA issued an Ordering of Directing Amendment on February 4,
2019.
TransCanada submitted its amended procedures on February 27, 2019. My staff reviewed the
amended procedures, and it appears that the inadequacies outlined in this Order of Directing
Amendment have been corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely,
Mary L. McDaniel, P.E.
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration

420165013M_Order Directing Amendment_02042019_text.pdf

February 4, 2019
Mr. Russell K. Girling
President and Chief Executive Officer
TransCanada Corporation
450-1 Street SW
Calgary, Alberta, Canada
T2P 5H1
Re: CPF No. 4-2016-5013M
Dear Mr. Girling:
Enclosed please find the Order Directing Amendment issued in the above-referenced case. It
makes findings of inadequate procedures and requires that TC Oil Pipeline Operations, Inc., a
subsidiary of TransCanada Corporation, amend certain of its operating and maintenance
procedures. When the amendment of procedures has been completed, as determined by the
Director, Southwest Region, this enforcement action will be closed. Service of the Order
Directing Amendment 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: Ms. Mary McDaniel, Director, Southwest Region, Office of Pipeline Safety, PHMSA
Mr. Paul Miller, Executive Vice President and President, Liquids Pipelines, TC Oil
Pipeline Operations, Inc., 700 Louisiana Street, Suite 700, Houston, TX 77002-2700
Mr. Lee Romack, Manager, U.S. Regulatory Compliance, TransCanada Corporation,
lee_romack@transcanada.com
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 )
TC Oil Pipeline Operations, Inc., ) CPF No. 4-2016-5013M
a subsidiary of TransCanada Corporation, )
)
)
)
Respondent. )
__________________________________________)
ORDER DIRECTING AMENDMENT
From March 3, 2015 to March 14, 2015, pursuant to 49 U.S.C. § 60117, representatives of the
Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
(OPS), conducted an inspection of TC Oil Pipeline Operations, Inc., a subsidiary of TransCanada
Corporation (TransCanada or Respondent), including its written procedures and records for the
pipeline facilities of the Gulf Coast Pipeline. TransCanada owns and operates the Keystone
Pipeline System, including the Gulf Coast Pipeline.
As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to
Respondent, by letter dated April 26, 2016, a Notice of Amendment (Notice), alleging that
TransCanada’s plans and procedures were inadequate to ensure the safe operation of its pipeline
facilities and proposing, in accordance with 49 C.F.R. § 190.206, that Respondent amend its
procedures.
TransCanada responded to the Notice by letter dated June 8, 2016 (Response), and submitted
revised procedures. On August 26, 2016, in response to PHMSA identifying certain alleged
inadequacies that remained in the procedures, TransCanada submitted a second set of revised
procedures to PHMSA, after which Respondent and PHMSA communicated further about the
procedures. Respondent did not request a hearing and therefore has waived its right to one.
Upon review of the amended procedures submitted by Respondent, I find that Respondent has
corrected the identified inadequacies in Items 9 and 10 of the Notice. However, for the reasons
discussed below, I find that Respondent still has not adequately addressed Items 1 through 8 of
the Notice.



CPF No. 4-2016-5013M
Page 2
FINDINGS OF INADEQUATE PROCEDURES
The Notice alleged certain inadequacies in Respondent’s plans and procedures and proposed
requiring TransCanada to amend its procedures to ensure safe operations with regard to the
provisions of 49 C.F.R. Part 195. Pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206, I
find the following procedures to be inadequate:
Item 1: The Notice alleged that Respondent’s procedures were inadequate with regard to
49 C.F.R. § 195.402(c)(14), which states:
§ 195.402 Procedural manual for operations, maintenance, and
emergencies.
(a) . . . .
(c) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following to
provide safety during maintenance and normal operations: . . .
(1) . . . .
(14) Taking adequate precautions in excavated trenches to protect
personnel from the hazards of unsafe accumulations of vapor or gas, and
making available when needed at the excavation, emergency rescue
equipment, including a breathing apparatus and, a rescue harness and line.
The Notice alleged that Respondent’s procedure regarding the documentation of pressure
restrictions in excavated trenches, pursuant to 49 C.F.R. § 195.402(c)(14), was inadequate.
Specifically, the Notice alleged that Respondent’s Operating Procedure, titled “Oil Pipelines
Pressure Restriction Implementation Procedure,” referenced another TransCanada operating
form, titled "Excavation Procedure Checklist"; revision 8, dated 2012/07/05, but did not require
documentation of the pressure restriction at the excavation location.
In its Response, TransCanada did not contest the allegation and stated that it was “amending the
Excavation Procedure Checklist to include documentation of pressure restrictions.” Respondent
submitted a revised “Excavation Procedure Checklist” on August 26, 2016, which included the
following item in the “Planning” section of the checklist: “21. Is a pressure restriction required
for the excavation and if so note the restriction in the comments?”
Having reviewed TransCanada’s revised procedure, I find that although Respondent amended its
Excavation Procedure Checklist to include a question about whether a pressure restriction was
required for excavation, and if so, to note the restriction in the comments, the procedure still does
not clearly state that pressure restrictions are to be implemented and documented before the
excavation. Accordingly, I find that Respondent’s procedures are still inadequate to assure safe
operation of its pipeline system. Respondent is hereby ordered to amend its written procedures
as follows. TransCanada must:
1. Revise its operating procedure, titled "Excavation Procedure Checklist," to
specifically state that pressure restrictions are to be implemented and documented
prior to any excavation activities; and



CPF No. 4-2016-5013M
Page 3
2. Submit the amended procedural manual to the Director within 30 days following
receipt of this Order.
Item 2: The Notice alleged that Respondent’s procedures were inadequate with regard to
49 C.F.R. § 195.432(b), which states:
§ 195.432 Inspection of in-service breakout tanks.
(a) . . . .
(b) Each operator must inspect the physical integrity of in-service
atmospheric and low-pressure steel aboveground breakout tanks according
to API Std 653 (except section 6.4.3, Alternative Internal Inspection
Interval) (incorporated by reference, see § 195.3). However, if structural
conditions prevent access to the tank bottom, its integrity may be assessed
according to a plan included in the operations and maintenance manual
under § 195.402(c)(3). The risk-based internal inspection procedures in
API Std 653, section 6.4.3 cannot be used to determine the internal
inspection interval.
The Notice alleged that Respondent’s procedure regarding the inspection of in-service breakout
tanks pursuant to 49 C.F.R. § 195.432(b) was inadequate because it referenced an incorrect
section of API Standard (Std) 653. Specifically, the Notice alleged that TransCanada’s O&M
Procedure 195.432, "Inspection of In-Service Breakout Tanks", revision 8, dated 2015/02/16,
referenced API Std 653, Section 4, for the inspection requirements of aboveground breakout
tanks. The Notice alleged that the correct reference should have been to API Std 653 in its
entirety.
In its Response, TransCanada did not contest the allegation and acknowledged that its procedure
included an incorrect reference to API Std 653, Section 4. TransCanada stated that it would
amend the procedure to require breakout tank inspections be performed in accordance to the
requirements of API Std 653 and include a reference to the version of API Std 653 that has been
incorporated by reference into 49 C.F.R. Part 195. TransCanada submitted amended procedures
on August 26, 2016, Section 4.0 of which states, “Low pressure steel aboveground tanks are
inspected according to API 653 . . . .” With respect to the version of API Std 653, the procedure
references “API Standard 653, latest edition incorporated by reference (IBR) in
49 CFR § 195.3.” Similarly, the procedures reference certain other API Standards, using the
language “latest edition incorporated by reference in 49 CFR § 195.3.”
Having considered Respondent’s procedure, I find that although TransCanada’s amended
procedure now identifies API Std 653 in its entirety, it still does not clearly identify the specific
version of API Std 653 incorporated by reference in 49 C.F.R. § 195.3. The language of the
procedure, i.e., the “latest edition incorporated by reference in 49 CFR § 195.3,” assumes that
Respondent’s personnel have the most recent version of 49 CFR Part 195 accessible, and may
lead to confusion about the correct edition to use if an individual has an old version of the Code
or if the Code has been recently revised. The version of API Std 653 currently incorporated by
reference in 49 C.F.R. Part 195 is “API Standard 653, ‘Tank Inspection, Repair, Alteration, and



CPF No. 4-2016-5013M
Page 4
Reconstruction,’ 3rd edition, December 2001 (including addendum 1 (September 2003),
addendum 2 (November 2005), addendum 3 (February 2008), and errata (April 2008)).”
Furthermore, the amended procedure does not specifically require that in-service atmospheric
steel aboveground breakout tanks, in addition to low-pressure steel aboveground breakout tanks,
be inspected according to API Std 653. Under 49 C.F.R. § 195.432(b), an operator must follow
all of the requirements of API Std 653, as referenced in 49 C.F.R. § 195.3, except section 6.4.3,
unless structural conditions prevent access to the tank bottom. The Standard details specific
maintenance inspection, repair, alteration, relocation, and reconstruction requirements that
operators must follow with regard to certain in-service tanks. Upon review of Respondent’s
amendment to “O&M Procedure 195.432 Inspection of in-service break out tanks,” as quoted
above, the procedure remains inadequate to ensure safety with regard to § 195.432(b).
Accordingly, I find that Respondent’s procedures are still inadequate to assure safe operation of
its pipeline system. TransCanada is hereby ordered to amend its written procedures as follows.
Respondent must:
1. Revise its procedural manual, titled “O&M Procedure 195.432 Inspection of in-
service break out tanks” part 3.0, to specifically identify API Standard 653,
“Tank Inspection, Repair, Alteration, and Reconstruction,” 3rd edition, December
2001, (including addendum 1 (September 2003), addendum 2 (November 2005)
addendum 3 (February 2008), and errata (April 2008)), as a reference for in-
service atmospheric and low-pressure breakout tank inspections;
2. Revise its procedural manual, titled “O&M Procedure 195.432 Inspection of in-
service break out tanks” part 4.0, subsection 2, to state that in-service
atmospheric and breakout tanks are to be inspected according to API Standard
653, “Tank Inspection, Repair, Alteration, and Reconstruction,” 3rd edition,
December 2001, (including addendum 1 (September 2003), addendum 2
(November 2005); and
3. Submit the amended procedural manual to the Director within 30 days following
receipt of this Order.
Item 3: The Notice alleged that Respondent’s procedures were inadequate with regard to
49 C.F.R. § 195.430(a), which states:
§ 195.430 Firefighting equipment.
Each operator shall maintain adequate firefighting equipment at each
pump station and breakout tank area. The equipment must be—
(a) In proper operating condition at all times; . . . .
The Notice alleged that Respondent’s procedure regarding firefighting equipment pursuant to
49 C.F.R. § 195.430(a) was inadequate because it failed to specify how and when maintenance
would be performed on the firefighting equipment at each pump station and breakout tank to
ensure that it was in proper operating condition at all times. Specifically, the Notice alleged that



CPF No. 4-2016-5013M
Page 5
TransCanada’s Procedure 195.430, "Firefighting Equipment", revision 8, Section 4.0,
“General,” dated 2015/02/16, did not include the requirement that firefighting equipment be “in
proper operating condition at all times” and did not specify how and when maintenance would be
performed on the equipment to ensure proper operating condition.
In its Response, TransCanada did not contest the allegation and stated that it was “in process of
revising [its] procedures to specify how and when maintenance will be performed on the
firefighting equipment at each pump station and breakout tank.”1 Respondent submitted a
revised procedure for its firefighting equipment, by email dated August 26, 2016, and stated that
its revised procedure defined the requirement for maintaining firefighting equipment and the
required maintenance interval. Upon review of the revised procedure, PHMSA personnel
informed Respondent that the company’s procedures still did not explicitly identify the
frequency of inspections for the firefighting equipment at each pump station and breakout-tank
area.
On October 24, 2016, in response to PHMSA identifying inadequacies that remained in the
procedure, TransCanada contended that its amended procedure was adequate because it stated
that the firefighting equipment was to be “inspected on an M01 basis”, and that “M01 Level 1 is
defined as a monthly inspection which is in accordance with NFPA 10 Section 7.2.4.1.4.”
Having considered Respondent’s revised procedure, I find that although it states that inspections
of firefighting equipment are to be performed on an M01 Level 1 basis, the amended procedure
still does not clearly state that M01 Level 1 means monthly inspection intervals. The absence of
such clarification in the procedure can lead to confusion about the intervals required by M01
Level 1.
Accordingly, I find that TransCanada’s procedure is still inadequate to assure safe operation of
its pipeline system. Respondent is hereby ordered to amend its written procedures as follows.
Respondent must:
1. Revise its procedure, titled “O&M document (EDMS# 005713585),” to identify
the frequency of maintenance intervals for firefighting equipment at pump-station
and breakout-tank areas; and
2. Submit the amended procedural manual to the Director within 30 days following
receipt of this Order.
Item 4: The Notice alleged that Respondent’s procedures were inadequate with regard to
49 C.F.R. § 195.405(a), which states:
§ 195.405 Protection against ignitions and safe access/egress involving
floating roofs.
(a) After October 2, 2000, protection provided against ignitions arising
out of static electricity, lightning, and stray currents during operation and
maintenance activities involving aboveground breakout tanks must be in
1 Response, at 1.



CPF No. 4-2016-5013M
Page 6
accordance with API RP 2003 (incorporated by reference, see 49 C.F.R. §
195.3), unless the operator notes in the procedural manual (49 C.F.R. §
195.402(c)) why compliance with all or certain provisions of API RP 2003
is not necessary for the safety of a particular breakout tank.
The Notice alleged that TransCanada’s procedure regarding protection against ignitions and safe
access involving floating tanks pursuant to 49 C.F.R. § 195.405(a) was inadequate because it
failed to indicate which edition of API Recommended Practice (RP) 2003 was the applicable
standard. Specifically, the Notice alleged that Respondent’s O&M Procedure 195.405, -
"Protection Against Ignitions ... ", 3.0 Reference, did not specifically reference which edition of
API RP 2003 was incorporated by reference into 49 C.F.R. § 195.3.
In its Response, TransCanada did not contest the allegation and stated that it would amend its
procedures to reference the correct version of API RP 2003 that was incorporated in Part 195.
Respondent submitted amended procedures to PHMSA, by email dated August 26, 2016, Section
3.0 of which references “API Recommended Practice 2003 Protection Against Ignitions Arising
out of Static, Lightning and Stray Current, latest edition incorporated by reference in
49 CFR § 195.3.”2
Having reviewed TransCanada’s revised procedures, I find that the phrase “latest edition
incorporated by reference in 49 CFR § 195.3,” is still inadequate because it could lead to
confusion. The correct version that is incorporated by reference in the Code is “API
Recommended Practice 2003, ‘Protection against Ignitions Arising out of Static, Lightning, and
Stray Currents,’ 7th edition, January 2008, (API RP 2003).”
Accordingly, I find that TransCanada’s procedures are still inadequate to assure safe operation of
its pipeline system. Respondent is hereby ordered to amend its written procedures as follows.
Respondent must:
1. Revise its procedural manual, titled “O&M procedure 195.405, - "Protection
Against Ignitions ... ", section 3.0, to specifically identify API Recommended
Practice 2003, “Protection against Ignitions Arising out of Static, Lightning, and
Stray Currents,” 7th edition, January 2008, (API RP 2003); and
2. Submit the amended procedural manual to the Director within 30 days following
receipt of this Order.
Item 5: The Notice alleged that Respondent’s procedures were inadequate with regard to
49 C.F.R. § 195.405(b), which states:
§ 195.405 Protection against ignitions and safe access/egress involving
floating roofs.
(a) . . . .
(b) The hazards associated with access/egress onto floating roofs of in-
service aboveground breakout tanks to perform inspection, service,
2 Revisions identified in italics.



CPF No. 4-2016-5013M
Page 7
maintenance, or repair activities (other than specified general
considerations, specified routine tasks or entering tanks removed from
service for cleaning) are addressed in API Pub 2026 (incorporated by
reference, see § 195.3). After October 2, 2000, the operator must review
and consider the potentially hazardous conditions, safety practices, and
procedures in API Pub 2026 for inclusion in the procedure manual
(§ 195.405(c)).
The Notice alleged that TransCanada’s procedure regarding protection against ignitions and safe
access/egress involving floating roofs on breakout tanks pursuant to 49 C.F.R. § 195.405(b) was
inadequate because it did not indicate which edition of API Publication (Pub) 2026 was the
applicable standard. Specifically, the Notice alleged that Respondent’s O&M Procedure
195.405, "Protection Against Ignitions ... ", 3.0 Reference, did not specifically reference the 2nd
Edition, April 1998, reaffirmed June 2006, of API Pub 2026 as the most current standard
incorporated by 49 C.F.R. § 195.3.
In its Response, TransCanada did not contest the allegation and stated that it would amend its
procedures to reference the version of API RP 2026 incorporated in Part 195. Respondent
submitted amended procedures to PHMSA by email on August 26, 2016, Section 3.0 of which
references “API Recommended Practice 2026, Safe Access/Egress Involving Floating Roods of
Storage Tanks in Petroleum Service, latest edition incorporated by reference in
49 CFR § 195.3.”3
Having reviewed TransCanada’s procedures, I find that the language “latest edition incorporated
by reference in 49 CFR § 195.3,” is still inadequate because it could lead to confusion for the
same reason identified above in Items 2 and 4. The correct version that is incorporated by
reference in the Code is “API Publication 2026, ‘Safe Access/Egress Involving Floating Roofs of
Storage Tanks in Petroleum Service,’ 2nd edition, April 1998 (reaffirmed June 2006) (API Pub
2026).”
Accordingly, I find that Respondent’s procedures are still inadequate to assure safe operation of
its pipeline system. TransCanada is hereby ordered to amend its written procedures as follows.
Respondent must:
1. 2. Revise its procedural manual, titled “O&M Procedure 195.405, - "Protection
Against Ignitions ... ", section 3.0, to specifically identify API Publication 2026,
“Safe Access/Egress Involving Floating Roofs of Storage Tanks in Petroleum
Service,” 2nd edition, April 1998 (reaffirmed June 2006) (API Pub 2026); and
Submit the amended procedural manual to the Director within 30 days following
receipt of this Order.
3 Revisions identified in italics.



CPF No. 4-2016-5013M
Page 8
Item 6: The Notice alleged that Respondent’s procedures were inadequate with regard to
49 C.F.R. § 195.54(a), which states:
§ 195.54 Accident reports.
(a) Each operator that experiences an accident that is required to be
reported under § 195.50 must, as soon as practicable, but not later than 30
days after discovery of the accident, file an accident report on DOT Form
7000-1.
The Notice alleged that Respondent’s procedure regarding the filing of accident reports pursuant
to 49 C.F.R. § 195.54(a) was inadequate because the procedure did not require accidents to be
reported within the time period prescribed, using DOT Form 7000-1. Specifically, the Notice
alleged that TransCanada’s “O&M Procedure 195.50 and 190.54 – Reporting Accidents,” did
not require the filing of an accident report within 30 days after the discovery of an accident,
using the DOT Form.
In its Response, TransCanada did not contest the allegation and stated that it was in the process
of revising its procedure to address the deficiencies alleged in the Notice. Respondent submitted
amended procedures to PHMSA by email on August 26, 2016, Section 4.0 of which states that
the “accident report is filed by use of the electronic incident/accident reporting system which can
be accessed by using the following URL: https://portal.phmsa.dot.gov. This report is submitted
as soon as practicable, but not later than 30 days after discovery of the accident.”4
Having reviewed Respondent’s procedures, I find that although TransCanada has amended its
procedure to require the filing of accident reports as soon as practicable, but not later than 30-
days after discovery of the accident, the procedures do not specifically require that accident
reports be filed on DOT Form 7000-1.
Accordingly, I find that Respondent’s procedure is still inadequate to assure safe operation of its
pipeline system. TransCanada is hereby ordered to amend its written procedures as follows.
Respondent must:
1. Revise its procedural manual, titled “O&M Procedure 195.50 and 195.54
Reporting Accidents” section 4.0, subsection 3, to state that DOT Form 7000-1
must be used to file accident reports; and
2. Submit the amended procedural manual to the Director within 30 days following
receipt of this Final Order.
Item 7: The Notice alleged that Respondent’s procedure regarding the reporting of pipeline
incidents under TransCanada’s Keystone XL State Department Presidential Permit, Condition
50, and 49 C.F.R. Part 195, was inadequate. Specifically, Condition 50 states:
Keystone XL State Department Presidential Permit, Condition 50
Reporting - Immediate: Keystone must provide immediate notification
4 Response, at 1. Revisions identified in italics.



CPF No. 4-2016-5013M
Page 9
of all reportable incidents in accordance with 49 CFR Part 195, and shall
notify the appropriate PHMSA regional office within twenty-four (24)
hours of any non-reportable leaks occurring on the pipeline.
The Notice alleged that Respondent’s procedure was inadequate with regard to Condition 50
because it did not require notification of incidents within the time period prescribed. According
to the Notice, Respondent’s procedure for § 195.52, titled “Immediate Notice of Certain
Accidents,” did not require the immediate notification of all incidents that must be reported under
49 C.F.R. Part 195. Rather, TransCanada’s procedure allegedly only required immediate
notification for incidents meeting the criteria of § 195.52.
Respondent submitted amended procedures to PHMSA by email on August 26, 2016. Having
reviewed TransCanada’s procedure, I find that although Respondent’s revised procedure for
§ 195.52 specifically states that all non-reportable leaks “are reported to the appropriate PHMSA
regional office within twenty-four (24) hours, in accordance with the Presidential Permit,
Condition 50,”5 it does not specifically require immediate notification of all incidents that are
reportable under 49 C.F.R. Part 195. The procedure only requires immediate notification of
incidents that are reportable under § 195.52.
Accordingly, I find that Respondent’s procedure is still inadequate to assure safe operation of its
pipeline system. TransCanada is hereby ordered to amend its written procedures as follows.
Respondent must:
1. Revise its procedural manual, titled “O&M Procedure 195.52, Section 1.0 and
4.0,” to reflect that immediate notification of all incidents reportable under 49
C.F.R Part 195 is required, in addition to the requirement that all non-reportable
leaks are to be reported to the appropriate PHMSA regional office within twenty-
four (24) hours, in accordance with the Presidential Permit, Condition 50.
Specific reference to §§ 195.50, 195.52, 195.54, 195.55, and 195.56 must be
included in the procedure; and
2. Submit the amended procedural manual to the Director within 30 days following
receipt of this Order.
Item 8: The Notice alleged that Respondent’s procedures were inadequate with regard to
49 C.F.R. § 195.567(c), which states:
§ 195.567 Which pipelines must have test leads and what must I do to
install and maintain the leads?
(a) . . . .
(c) Maintenance. You must maintain the test lead wires in a condition
that enables you to obtain electrical measurements to determine whether
cathodic protection complies with § 195.571.
5 TransCanada’s O&M Procedure Manual – U.S. Hazardous Liquids Pipelines, 195.52 –Immediate Notice of
Certain Accidents, Revision 8, Effective Date: 2015/2/16 (on file with PHMSA).



CPF No. 4-2016-5013M
Page 10
The Notice alleged that Respondent’s procedure regarding cathodic-protection test leads
pursuant to 49 C.F.R. § 195.567 was inadequate because it did not specify a process for taking
cathodic-protection readings when a test lead was found to be broken. Additionally, the Notice
alleged that the procedure did not require broken test leads to be repaired before the next
monitoring cycle. Specifically, the Notice alleged that TransCanada’s O&M Procedure 195.567
- "Test Leads," did not specify the actions needed for taking cathodic-protection readings when a
test lead was broken.
In its Response, TransCanada contested the allegation and stated that its procedure was adequate
to ensure compliance with § 195.567. Specifically, Respondent stated that its procedure, titled
“TES- CP- SS Cathodic Protection Survey Specification (CDN- US- MEX) EDMS No.:003670956
Section 6.6 Test Station Identification,” and another one, titled “195.573 External Corrosion
Control Monitoring,” taken together, required that all loose or damaged test leads that did not
require excavation to repair, as well as any test leads that did require excavation, be repaired and
documented. Additionally, TransCanada noted the procedures recommended initiating
corrective actions, if necessary, before the next inspection cycle. Respondent contended that,
based upon these two requirements, the procedures did adequately specify the actions needed for
taking cathodic protection readings when a test lead was broken and did adequately specify that
it be repaired prior to the next required monitoring cycle.
Having reviewed the record in its entirety, I find that TransCanada’s procedure for § 195.567
still does not specify what must be documented if lost or damaged test leads are inoperative or
need to be repaired. Such information must be included in the procedure in order to ensure
uniformity regarding the information Respondent must document when test leads are inoperative
or need to be repaired in order to assure that the procedures facilitate compliance with
§ 195.567(c).
Accordingly, I find that Respondent’s procedures are still inadequate to assure safe operation of
its pipeline system. TransCanada is hereby ordered to amend its written procedures as follows.
Respondent must:
1. Revise section 6.6 of its procedural manual, titled “Section 6.6, TES- CP- SS
Cathodic Protection Survey Specification (CDN- US- MEX) EDMS
No.:003670956,” to specify what will be documented if lost or damaged test leads
are inoperative or need to be repaired; and
2. Submit the amended procedural manual to the Director within 30 days following
receipt of this Final Order.
Item 9: The Notice alleged that Respondent’s procedures were inadequate with regard to
49 C.F.R. § 195.583(a), which states:
§ 195.583 What must I do to monitor atmospheric corrosion control?
(a) You must inspect each pipeline or portion of pipeline that is exposed
to the atmosphere for evidence of atmospheric corrosion, as follows:



CPF No. 4-2016-5013M
Page 11
If the pipeline is located: Onshore Offshore Then the frequency of inspection is:
At least once every 3 calendar years, but
with intervals not exceeding 39 months.
At least once every calendar year, but
with interval not exceeding 15 months.
(b) During inspections you must give particular attention to pipe at soil-
to-air interfaces, under thermal insulation, under disbanded coatings, at pipe
supports, in splash zones, at deck penetrations, and in spans over water.
The Notice alleged that Respondent’s procedure regarding the control of atmospheric corrosion
pursuant to 49 C.F.R. § 195.583 was inadequate because it did not require giving particular
attention to pipe under thermal insulation during inspections. Specifically, the Notice alleged
that TransCanada’s “O&M Procedure 195.583 – Atmospheric Corrosion Monitoring” did not
include requirements for the inspection of piping under thermal insulation. According to the
Notice, a significant portion of TransCanada’s above-ground piping on the Gulf Coast is
insulated manifold piping, yet the company made no provision for the inspection of this piping
that is subject to a specialized type of atmospheric corrosion termed “corrosion under
insulation.”
In its Response, TransCanada did not contest the allegation and stated that it would revise its
procedures to address the deficiencies alleged in the Notice. By email dated August 26, 2016, in
response to PHMSA identifying inadequacies that remained in the amended procedures,
Respondent submitted a document titled, “TransCanada Operating Procedure (Task Package) –
Atmospheric Corrosion Inspection” (EDMS# 004266539). The document purported to address
the inadequacies identified in the Notice regarding TransCanada’s O&M Procedure for
§ 195.583 Atmospheric Corrosion Monitoring. Respondent, however, did not submit a revised
version of the procedure specifically identified in the Notice as being inadequate.
On October 24, 2016, again in response to PHMSA identifying inadequacies that still remained
in the amended procedures, TransCanada provided a statement of clarification regarding its
procedure for § 195.583, and identified areas where the procedures had been modified to address
the inadequacies alleged in the Notice. TransCanada modified its procedure for § 195.583 to
specifically state that separate inspections were to be performed at each location of insulated
piping. Respondent further modified its procedures to state that if corrosion were found under
thermal insulation, the corrosion was to be repaired and the pipe coated in accordance with O&M
Procedures §§ 195.585 and 195.581, respectively. Finally, Respondent stated that its procedure
for § 195.583, in conjunction with “TransCanada Operating Procedure (Task Package) –
Atmospheric Corrosion Inspection” (EDMS# 004266539), which is specifically referenced in the
procedure for § 195.583, addressed all of the issues identified in the Notice and subsequent
correspondence from PHMSA.6
Having reviewed the record in its entirety, I find that Respondent has satisfactorily revised its
procedure for § 195.583 to address the allegations contained in the Notice. Specifically, the
6 Operator NOA Follow Up Response Email, dated October 24, 2016.



CPF No. 4-2016-5013M
Page 12
revised procedure now includes a requirement that piping under thermal insulation be inspected
once every three calendar years, but with intervals not exceeding 39 months. Further, the revised
procedure directs the reader to another procedure, titled “TransCanada Operating Procedure
(Task Package) – Atmospheric Corrosion Inspection” (EDMS# 004266539), which is
incorporated into Part 195 by reference and includes provisions for atmospheric corrosion
inspections of above-ground insulated manifold piping. I find Respondent’s argument
persuasive that its “Atmospheric Corrosion Inspection” procedure provides sufficient guidance
for performing atmospheric corrosion inspections on insulated piping.7
Accordingly, I find that TransCanada’s original procedures were inadequate, but that the
inadequacies identified in the Notice have been corrected, and the amended procedures for
§ 195.583 are adequate to assure the safe operation of its pipeline system.
Item 10: The Notice alleged that Respondent’s procedures were inadequate with regard to
49 C.F.R. § 195.579(c), which states:
§ 195.579 What must I do to mitigate internal corrosion?
(a) . . . .
(c) Removing pipe. Whenever you remove pipe from a pipeline, you
must inspect the internal surface of the pipe for evidence of corrosion. If
you find internal corrosion requiring corrective action under § 195.585, you
must investigate circumferentially and longitudinally beyond the removed
pipe (by visual examination, indirect method, or both) to determine whether
additional corrosion requiring remedial action exists in the vicinity of the
removed pipe.
The Notice alleged that Respondent’s procedure regarding the inspection of removed pipe
pursuant to 49 C.F.R. § 195.579(c) was inadequate because it did not require the removed pipe to
be investigated circumferentially and longitudinally beyond the removed pipe to determine
whether additional corrosion requiring remedial action existed in the vicinity of the removed
pipe.
In its Response, TransCanada did not contest the allegation and stated that it would revise its
procedures to address the deficiencies alleged in the Notice. Respondent submitted amended
procedures to PHMSA by email on August 26, 2016, which stated: “If internal corrosion is
found, the adjacent pipe is investigated circumferentially and longitudinally beyond the removed
pipe to determine the extent of internal corrosion in accordance with O&M procedure 195.587.
Required remedial measures are performed in accordance with O&M Procedure 195.585.”8
7 See Operator NOA Follow Up Response Email, dated October 24, 2016 (“Section 4.3.2 (of the referenced
document, Atmospheric Corrosion Inspection) identifies a requirement to evaluate the geometry of an installation to
determine location of inspection ports to facilitate inspection and it provides criteria for its selection . . . .”) (on file
with PHMSA).
8 Revisions identified in italics.



CPF No. 4-2016-5013M
Page 13
Having reviewed TransCanada’s procedures, I find that Respondent has amended its procedure
for § 195.579 to include the language specifically identified in the Notice. Accordingly, I find
that TransCanada’s original procedures were inadequate, but that the inadequacies identified in
the Notice have been corrected and that the amended procedures for § 195.579 are adequate to
assure safe operation of its pipeline system.
For the amendments to procedures required by this Order, 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 the administrative assessment of civil penalties
not to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), 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.
Under 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this Order
Directing Amendment to the Associate Administrator, Office of Pipeline 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, no later than 20 days after receipt of
service of this Order Directing Amendment by the Respondent. Any petition submitted must
contain a statement of the issue(s) and meet all other requirements of 49 C.F.R. § 190.243. The
terms of the order, including corrective action, remain in effect unless the Associate
Administrator, upon request, grants a stay.
The terms and conditions of this Order Directing Amendment are effective upon service in
accordance with 49 C.F.R. § 190.5.
February 4, 2019
___________________________________ __________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/420165013M>
- Source ID: `phmsa-enforcement`
- SHA-256: `7a9f92e412ef31a9ea3d973b272a923722e1ea203c568a130c7fddb63f6c71e6`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T19:56:46.848Z
- Document slug: `phmsa-enforcement-420165013m`

### Source metadata

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  "operator": "TC OIL PIPELINE OPERATIONS INC",
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  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
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    "195.54(a)",
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    "195.571",
    "195.579(c)",
    "195.583(a)",
    "195.583(b)"
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