# ANR PIPELINE CO — Notice of Amendment

- **operation:** document
- **citation:** CPF 12024052NOA
- **title:** ANR PIPELINE CO — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2024-07-05
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 192.303.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-12024052noa.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-12024052noa.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-12024052noa
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/12024052NOA
**body:**

Notice of Amendment involving ANR PIPELINE CO. PHMSA's enforcement data identifies the cited regulation as 192.303. The case was opened on 2024-07-05 and is reported as closed as of 2024-11-06. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

12024052NOA_Closure Letter_11062024_(24-297439).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024052NOA/12024052NOA_Closure%20Letter_11062024_(24-297439).pdf

12024052NOA_Closure Letter_11062024_(24-297439)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024052NOA/12024052NOA_Closure%20Letter_11062024_(24-297439)_text.pdf

12024052NOA_Notice of Amendment_07052024_(24-297439).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024052NOA/12024052NOA_Notice%20of%20Amendment_07052024_(24-297439).pdf

12024052NOA_Notice of Amendment_07052024_(24-297439)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024052NOA/12024052NOA_Notice%20of%20Amendment_07052024_(24-297439)_text.pdf

12024052NOA_Operator Response to Notice_08012024_(24-297439).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024052NOA/12024052NOA_Operator%20Response%20to%20Notice_08012024_(24-297439).pdf

12024052NOA_Closure Letter_11062024_(24-297439)_text.pdf

VIA ELECTRONIC MAIL TO: tina faraca@tcenergy.com
November 6, 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 1-2024-052-NOA
Dear Ms. Faraca:
From January 30 to January 31, 2024, a representative from the Pipeline and Hazardous Materials
Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code (U.S.C.), inspected
ANR Pipeline Co.’s (ANR) construction procedures in Delhi, Louisiana, as 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 July 5, 2024, which proposed amendment of your procedures.
ANR submitted its amended procedures on August 1, 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

12024052NOA_Notice of Amendment_07052024_(24-297439)_text.pdf

NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: tina faraca@tcenergy.com
July 5, 2024
Ms. Tina Faraca
President and Chief Executive Officer
ANR Pipeline Company
a subsidiary of TC Energy Corporation
700 Louisiana Street, Suite 700
Houston, Texas 77002
CPF 1-2024-052-NOA
Dear Ms. Faraca:
From January 30 to January 31, 2024, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),
inspected ANR Pipeline Co.’s (ANR) construction procedures in Delhi, Louisiana, as part of the
construction inspected at ANR’s Delhi Compressor Station.
As a result of the inspection, PHMSA has identified an 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 procedures for constructing its pipeline in accordance with the requirements of
Subpart G of 49 CFR Part 192 were inadequate to ensure pipeline safety. Specifically, ANR’s TC
Energy Engineering Specification: TES-MA-VALV-G Steel Valves for Gas Service Specification,
Rev. 02, 2022-Dec-01 (TES-MA-VALV-G), failed to adequately reference the correct edition of
the American Petroleum Institute (API), Specification ANSI/API 6D that is required by
§ 192.145(a)1 and incorporated by reference in § 192.7(b)(8).2
During the inspection, PHMSA reviewed TES-MA-VALV-G, which contained information



regarding ANR’s use of manufactured carbon steel ball, check, gate, and plug valves with a
specified outside diameter of NPS 16 (406.4 mm) and larger, and a pressure class of PN 20 (ASME
150) and higher. TES-MA-VALV-G stated in part that it was written based on the 25th edition of
API 6D, November 2021 and errata 1 and 2. However, § 192.145(a) specifies that each valve
(other than cast iron and plastic) must meet the minimum requirements of ANSI/API Spec 6D, and
§ 192.7(b)(8) incorporates by reference ANSI/API Specification 6D, “Specification for Pipeline
Valves,” 23rd edition. TES-MA-VALV-G also required its utilization in conjunction with API
6D, Specification for Valves, latest edition; however, § 192.7(b)(8) does not incorporate by
reference the latest edition of API 6D but instead incorporates by reference ANSI/API
Specification 6D, “Specification for Pipeline Valves,” 23rd edition.
Therefore, ANR’s written specifications were inadequate pursuant to the requirements of
§ 192.303 as it relates to § 192.145(a) and § 192.7(b)(8). ANR must revise its specification to
meet the requirements of § 192.303.
Response to this Notice
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
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 1-2024-052-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
1 § 192.145 Valves.
(a) Except for cast iron and plastic valves, each valve must meet the minimum requirements of ANSI/API Spec 6D
(incorporated by reference, see § 192.7), or to a national or international standard that provides an equivalent
performance level. A valve may not be used under operating conditions that exceed the applicable pressure-temperature
ratings contained in those requirements.
2 § 192.7 What documents are incorporated by reference partly or wholly in this part?
(a) …
(b) (1) …
(8) American Petroleum Institute (API), 200 Massachusetts Ave. NW, Suite 1100, Washington, DC 20001, and phone:
202–682–8000, website: https://www.api.org/.
ANSI/API Specification 6D, “Specification for Pipeline Valves,”23rd edition, effective October 1, 2008, including
Errata 1 (June 2008), Errata2 (/November 2008), Errata 3 (February 2009), Errata 4 (April 2010), Errata 5
(November 2010), Errata 6 (August 2011) Addendum 1 (October 2009), Addendum 2 (August 2011), and
Addendum 3 (October 2012), (ANSI/API Spec 6D), IBR approved for § 192.145(a).
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