# ANR PIPELINE CO — Notice of Amendment

- **operation:** document
- **citation:** CPF 12024014NOA
- **title:** ANR PIPELINE CO — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2024-03-19
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 192.303.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-12024014noa.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-12024014noa.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-12024014noa
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/12024014NOA
**body:**

Notice of Amendment involving ANR PIPELINE CO. PHMSA's enforcement data identifies the cited regulation as 192.303. The case was opened on 2024-03-19 and is reported as closed as of 2024-05-21. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

12024014NOA_Closure Letter_05212024_(23-264553).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024014NOA/12024014NOA_Closure%20Letter_05212024_(23-264553).pdf

12024014NOA_Closure Letter_05212024_(23-264553)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024014NOA/12024014NOA_Closure%20Letter_05212024_(23-264553)_text.pdf

12024014NOA_Notice of Amendment_03192024_(23-264553).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024014NOA/12024014NOA_Notice%20of%20Amendment_03192024_(23-264553).pdf

12024014NOA_Notice of Amendment_03192024_(23-264553)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024014NOA/12024014NOA_Notice%20of%20Amendment_03192024_(23-264553)_text.pdf

12024014NOA_Operator Response to Notice_04172024_(23-264553).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024014NOA/12024014NOA_Operator%20Response%20to%20Notice_04172024_(23-264553).pdf

12024014NOA_Closure Letter_05212024_(23-264553)_text.pdf

VIA ELECTRONIC MAIL TO: tina faraca@tcenergy.com
May 21, 2024
Ms. Tina Faraca
President and Chief Executive Officer
ANR Pipeline Company
a subsidiary of TC Energy Corporation
700 Louisiana Street
Houston, Texas 77002
CPF 1-2024-014-NOA
Dear Ms. Faraca:
From March 14 to July 23, 2023, a representative from the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site
pipeline safety inspection of ANR Pipeline Co.’s (ANR) procedures in Charleston, West Virginia,
which was part of the construction inspected at ANR’s Delhi Compressor Station. As a result of the
inspection, ANR was issued a Notice of Amendment on March 19, 2024, which proposed amendment
of your procedures.
ANR submitted its amended procedures on April 17, 2024. My staff reviewed the amended procedures,
and it appears that the inadequacies outlined in this Notice of 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,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
Cc: Amy Willis <amy_willis@tcenergy.com>
Dan Cerkoney dan_cerkoney@tcenergy.com

12024014NOA_Notice of Amendment_03192024_(23-264553)_text.pdf

NOTICE OF AMENDMENT
OVERNIGHT EXPRESS DELIVERY
March 19, 2024
Ms. Tina Faraca
President and Chief Executive Officer
ANR Pipeline Company
a subsidiary of TC Energy Corporation
700 Louisiana Street
Houston, Texas 77002
CPF 1-2024-014-NOA
Dear Ms. Faraca:
From March 14 to July 23, 2023, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected
the construction of ANR Pipeline Co.’s (ANR) Delhi Compressor Station. This inspection
included reviews of procedures for maintenance and normal operations as part of the inspection in
Charleston, West Virginia.
As a result of the inspection, PHMSA has identified the apparent inadequacy found within ANR’s
plans or procedures. The item inspected and the inadequacy is described below:
1. § 192.303 Compliance with specifications or standards.
Each transmission line or main must be constructed in accordance
with comprehensive written specifications or standards that are
consistent with this part.
ANR’s written specifications or standards required for constructing its pipeline in accordance with
the requirements of Subpart G of 49 CFR Part 192 are inadequate to assure pipeline safety.
Specifically, ANR’s TC Energy Engineering Specification: TES-MA-FLGEU-GL Carbon Steel
Butt-Welding Flanges, Rev. 03, 3/1/2021 (TES-MA-FLGEU-GL), failed to reference the correct
edition of the Manufacturers Standardization Society of the Valve and Fittings Industry, Inc.
(MSS), Standard Practice MSS SP–44 that is required by § 192.147(a)1 and incorporated by
1 § 192.147 Flanges and flange accessories.
(a) Each flange or flange accessory (other than cast iron) must meet the minimum requirements of
ASME/ANSI B 16.5 and MSS SP–44 (incorporated by reference, see § 192.7), or the equivalent.



reference in § 192.7(g)(1)2
.
During the inspection, PHMSA reviewed TES-MA-FLGEU-GL, which contained information
regarding ANR’s use of manufactured carbon steel butt-welding flanges with a specified outside
diameter of NPS 16 (406.4 mm) and larger, and Carbon Steel Grade F42 (Grade 290) to Grade
F80 (Grade 550). TES-MA-FLGEU-GL identified that it was written based on the 2019 edition
of MSS SP–44. TES-MA-FLGEU-GL also required it be used in conjunction with MSS SP-44,
Specification for Steel Pipeline Flanges, latest edition. However, § 192.147(a) specifies that each
flange or flange accessory (other than cast iron) must meet the minimum requirements of MSS
SP–44, and § 192.7(g)(1) incorporates by reference MSS SP–44–2010, Standard Practice, “Steel
Pipeline Flanges,” 2010 edition, (including Errata (May 20, 2011)).
Therefore, ANR’s written specifications or standards pursuant to the requirements of § 192.303 as
it relates to § 192.147(a) and § 192.7(g)(1) are inadequate to assure pipeline safety. ANR must
revise its specification to reference and adhere to the minimum requirements of the 2010 edition
of MSS SP-44 that is required and incorporated by reference.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as
part of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement
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).
Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under § 190.211. 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 an Order Directing Amendment. If 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. § 190.206). If you are not contesting this
Notice, we propose that you submit your amended procedures to my office within 30 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
2 § 192.7 What documents are incorporated by reference partly or wholly in this part?
(a) ….
(g) Manufacturers Standardization Society of the Valve and Fittings Industry, Inc. (MSS), 127 Park St. NE.,
Vienna, VA 22180, phone: 703–281–6613, Web site: http://www.mss-hq.org/.
(1) MSS SP–44–2010, Standard Practice, “Steel Pipeline Flanges,” 2010 edition, (including Errata (May
20, 2011)), (MSS SP–44), IBR approved for § 192.147(a).



action will be closed.
It is requested (not mandated) that ANR Pipeline Co. maintain documentation of the safety
improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of
plans, procedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and
Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer
to CPF 1-2024-014-NOA and, for each document you submit, please provide a copy in electronic
format whenever possible.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
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