{"operation":"document","citation":"CPF 320141005H","title":"ANR PIPELINE CO — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-09-25","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320141005h.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320141005h.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320141005h","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320141005H","body":"Corrective Action Order involving ANR PIPELINE CO. The dataset does not identify a cited regulation for this case. The case was opened on 2014-09-25 and is reported as closed as of 2018-08-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320141005H_Closure Letter_08102018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320141005H/320141005H_Closure%20Letter_08102018.pdf\n\n320141005H_Closure Letter_08102018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320141005H/320141005H_Closure%20Letter_08102018_text.pdf\n\n320141005H_Corrective Action Order_09252014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320141005H/320141005H_Corrective%20Action%20Order_09252014.pdf\n\n320141005H_Corrective Action Order_09252014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320141005H/320141005H_Corrective%20Action%20Order_09252014_text.pdf\n\n320141005H_Corrective Action Order_09252014_text.pdf\n\nSeptember 25, 2014\nVIA CERTIFIED MAIL AND FACSIMILE TO 403.920.2412:\nMr. Russell Girling\nPresident and CEO\nTransCanada Corporation\n450 1st St SW\nCalgary, Alberta T2P 5H1\nRe: CPF No. 3-2014-1005H\nDear Mr. Girling:\nEnclosed is a Corrective Action Order. It requires TransCanada Corporation’s ANR Pipeline\nCompany to take certain corrective actions with respect to its natural gas transmission system as\na result of the rupture of the 22-inch natural gas transmission pipeline near Benton Harbor,\nMichigan, reported to the National Response Center on September 16, 2014 at 5:09 am, Eastern\nDaylight Time (EDT). Service is being made by certified mail and facsimile. Service of this\nCorrective Action Order by facsimile or other electronic means is complete upon transmission or\nreceipt as provided under 49 CFR § 190.5. The terms and conditions of this Order are effective\nimmediately upon service.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Weise\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\nCc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS\nMr. Vern Meier, VP of Field Operations,\nANR Pipeline - 717 Texas Ave., Houston, TX 77002\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n___________________________________\nIn the Matter of )\n)\n)\nANR Pipeline Company , )\na subsidiary of TransCanada Corp.,)\n)\nRespondent )\n___________________________________ )\nCORRECTIVE ACTION ORDER\n) CPF No. 3-2014-1005H\nPurpose and Background\nThis Corrective Action Order (Order) is being issued, under the authority of 49 USC § 60112\nand 49 CFR § 190.233, to require TransCanada Corporation’s subsidiary ANR Pipeline Co.\n(TransCanada/ANR or Respondent) to take the necessary corrective action to protect the public,\nproperty, and environment from potential hazards associated with a recent rupture involving\nTransCanada/ANR’s 22-inch natural gas transmission pipeline near Benton Harbor, Michigan.\nOn September 16, 2014, a failure occurred on Respondent’s 22-inch diameter 0-100 Line at MP\n933.59, approximately 1.4 miles east of the I-94 exit to Benton Harbor, Michigan, resulting in\nthe release of an estimated 99.8 million cubic feet (MMCF) of natural gas into the atmosphere\nand the ejection of approximately fifty feet of pipe from the ground (Failure). The cause of the\nFailure has not yet been determined.\nPursuant to 49 USC § 60117, the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety (OPS), initiated an investigation of the Failure. The\npreliminary findings of the ongoing investigation are set forth below.\nPreliminary Findings\n• ANR Pipeline Co., a subsidiary of TransCanada Corporation, owns and operates\napproximately 9,946.8 miles of natural gas transmission pipelines in Illinois, Indiana,\nIowa, Kansas, Michigan, Missouri, Nebraska, Ohio, Wisconsin, Kentucky, Mississippi,\nTennessee, Arkansas, Louisiana, Oklahoma, and Texas, as listed in ANR Pipeline Co.’s\n2013 annual report to PHMSA.\n• The pipeline that failed is a 22-inch diameter steel pipeline referred to as the 0-100 Line.\nA 30-inch diameter steel pipeline referred to as the 1-100 Line runs parallel to the 0-100\n\n\n\n2\nLine, and is approximately 25 feet away at the failure location. The nearest compressor\nstations are the Bridgeman Compressor Station (MP 915.82) and the Hamilton\nCompressor Station (MP 977.5). For the purposes of this Order, the pipelines affected\nare TransCanada/ANR’s 0-100 Line and the 1-100 Line between MP 915.82 and MP\n977.5 (“Affected Segment”). The Affected Segment traverses Berrien, Van Buren, and\nAllegan Counties in Michigan. The Failure occurred in Berrien County, Michigan, near\nmilepost 933.59.\n• The Failure took place in a wooded area with creeks and farm ponds in close proximity.\nThe specific area of the Failure is considered a Class 1 location. The nearest Class 2\nlocations are approximately 850 feet to the south, and 2700 feet to the north. The nearest\nClass 3 locations are 5100 feet to the north, and 2.7 miles to the south. The nearest High\nConsequence Area (HCA) is approximately 4700 feet to the north. The pipeline also\ncrosses rivers and an interstate highway (I-94) near the Failure location.\n• No ignition, fatalities, or injuries were reported as a result of the Failure. Approximately\n550 people, reportedly comprising approximately 200 households, were evacuated as a\nresult of the Failure, and nine roads were closed to limit access to the Failure location.\nEvacuated residents were permitted to return to their homes at 5:15 p.m. EDT on\nSeptember 16, 2014.\n• The 0-100 Line is currently isolated from Main Line Valve 61 (MP 931.72) to Main Line\nValve 62 (MP 946.99), a distance of approximately 15.27 miles (Isolated Segment).\nTransCanada/ANR has reported to PHMSA that the 1-100 Line and the balance of the 0-\n100 Line within the Affected Segment have been reduced to a maximum discharge\npressure of 724 psig at the Bridgeman Compressor Station. The pipelines are typically\noperated in common.\n• According to TransCanada/ANR reports, the 0-100 Line in the area of the Failure was\noriginally installed in 1949. It is 22-inch diameter with a wall thickness of 0.250 inches.\nThe pipe is Grade X52 and has a flash-welded longitudinal seam with coal tar enamel and\nliquid epoxy coating. The pipe was manufactured by A.O. Smith. TransCanada/ANR has\nreported that a portion of pipe in the area of the Failure was replaced in 1960 following\nan in-service failure.\n• Two pipeline fragments have been recovered, one approximately 30 feet in length and the\nother approximately 20 feet in length. Onsite observations appear to show the rupture was\nthe result of longitudinally-oriented external cracking.\n• According to information provided to PHMSA during the initial investigation, SCADA\nand pipeline instrumentation indicate that the failure occurred at 1:59 a.m. EDT.\nTransCanada/ANR’s Gas Control received an external call at 2:45 a.m. EDT reporting\nun-odorized gas blowing at a very high pressure. The On-Call technician was dispatched\nby Gas Control at 2:50 a.m. EDT. The pipeline was equipped with automatic shutoff\nvalves; however, only three of the four valves are reported to have closed as intended.\nThe failed pipeline segment was reported to have been isolated from MP 931.72 to MP\n946.99 at 4:50 a.m. EDT. TransCanada/ANR reported the incident to the National\n\n\n\n3\nResponse Center (NRC) on September 16, 2014 at 5:09 a.m. EDT (NRC Report\n#1095426). PHMSA initiated an investigation of the incident, which involved an on-site\ninvestigation at the failure location by the Michigan Public Service Commission\n(PHMSA’s agent for interstate natural gas pipelines in Michigan).The maximum\nallowable operating pressure (MAOP) of the pipeline at the Failure site was 850 psig. At\nthe time of the failure, the actual operating pressure of the pipeline at the closest\nmonitoring point to the failure location (Benton Harbor Meter Station) was 805 psig.\n• The 1-100 Line within the Affected Segment is 30-inch diameter, and a majority of the\npipeline was also manufactured by AO Smith. It has a flash-welded longitudinal seam. It\nis predominantly composed of 0.438-inch wall thickness Grade X-52 pipe and has a coal\ntar enamel coating. The 0-100 Line and the 1-100 Line are generally subject to the same\nenvironmental conditions.\n• A Safety Related Condition Report (SRCR 20140045) was filed with PHMSA on May 1,\n2014, by TransCanada/ANR for the segment of the 0-100 Line between the Sandwich, IL\nCompressor Station (MP 796) and the Bridgeman, MI Compressor Station (MP 915.82).\nThe SRCR was related to seam-weld anomalies reported as a result of an EMAT In-line\nInspection (ILI) tool run which necessitated pressure reductions.\nDetermination of Necessity for Corrective Action Order and Right to Hearing\nSection 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action\nOrder, after reasonable notice and the opportunity for a hearing, requiring corrective action,\nwhich may include the suspended or restricted use of a pipeline facility, physical inspection,\ntesting, repair, replacement, or other action as appropriate. The basis for making the\ndetermination that a pipeline facility is hazardous, requiring corrective action, is set forth both in\nthe above-referenced statute and 49 CFR § 190.233, a copy of which is enclosed.\nSection 60112 and the regulations promulgated thereunder provide for the issuance of a\nCorrective Action Order without prior opportunity for notice and hearing, upon a finding that\nfailure to issue the Order expeditiously will likely result in serious harm to life, property, or the\nenvironment. In such cases, an opportunity for a hearing will be provided as soon as practicable\nafter the issuance of the Order.\nAfter evaluating the foregoing preliminary findings of fact, I find that continued operation of the\nAffected Segment without corrective measures would be hazardous to life, property, and the\nenvironment. Additionally, having considered the nature of the Failure, the location of the\nFailure, the proximity of the Affected Segment to populated areas, rivers, an interstate highway,\nand other sensitive areas, the apparent malfunction of an automatic shutoff valve, and the nature\nof the product being transported, I find that a failure to issue this Order expeditiously to require\nimmediate corrective action would result in the likelihood of serious harm to life, property, or the\nenvironment.\nAccordingly, this Corrective Action Order mandating immediate corrective action is issued\nwithout prior notice and opportunity for hearing. The terms and conditions of this Order are\neffective upon receipt.\n\n\n\n4\nWithin 10 days of receipt of this Order, Respondent may request a hearing, to be held as soon as\npracticable, by notifying the Associate Administrator for Pipeline Safety in writing, with a copy\nto the Director of Central Region OPS, PHMSA (Director). If a hearing is requested, it will be\nheld telephonically or in-person in Kansas City, MO or Washington, DC.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective measures that need to be taken. In that event, Respondent will be\nnotified of any additional measures required and amendment of this Order will be considered. To\nthe extent consistent with safety, Respondent will be afforded notice and an opportunity for a\nhearing prior to the imposition of any additional corrective measures.\nRequired Corrective Actions\nPursuant to 49 USC § 60112, I hereby ORDER TransCanada/ANR to immediately take the\nfollowing corrective actions regarding the Affected Segment:\n1. Operation. Respondent must not operate the 0-100 Line between MP 931.72 and MP\n946.99 (Isolated Segment) until authorized in writing to do so by the Director.\n2. Operating Pressure Restriction.\na. Respondent must not operate the Affected Segment at a pressure greater than 80%\nof actual operating pressure at the time of the Failure. At the time of the failure,\nthe pipeline was flowing from Bridgeman to Hamilton, but the line is capable of\nreverse operation. Submit the operating pressures for each compressor station on\nthe Affected Segment at the time of failure and reduced discharge pressure limits\nfor approval by the Director in the Restart plan referenced in Item 3. The pressure\nlimits shall take into consideration both possible directions of flow (from\nBridgeman to Hamilton and vice versa). This pressure restriction will remain in\neffect until written approval to increase or modify the pressure or return the\npipeline to its pre-failure operating pressure is obtained from the Director\npursuant to Items 5 and 6.\nRespondent may not operate any other portion of the 0-100 Line or the 1-100 Line\nat a pressure greater than the actual operating pressure at the time of the Failure.\nThis pressure restriction is to remain in effect until written approval to increase\nthe pressure or return the pipeline to its pre-failure operating pressure is obtained\nfrom the Director.\nWithin 5 days of receipt of this Order, Respondent must provide the Director with\nthe actual operating pressures of each compressor station and each main line\npressure regulating station at the time of Failure and the documentation associated\nwith the revised maximum pressure set-points at these same locations.\nb. c. d.\n\n\n\n3. 5\ne. These pressure restrictions require any relevant remote or local alarm limits,\nsoftware programming set-points or control points, and mechanical over-pressure\ndevices to be adjusted accordingly and documentation provided to the Director.\nf. When determining the pressure restriction set-points, Respondent must take into\naccount any ILI features or anomalies present to provide for continued safe\noperation while further corrective actions are completed.\ng. Respondent must review the pressure restriction quarterly by analyzing operating\ndata, including pressure and ILI data. ILI features or anomalies present in the\nAffected Segment must be reviewed, and operating pressure must be immediately\nreduced to maintain the safe operations of the Affected Segment. Results of the\nquarterly review must be submitted to the Director. The results must include, at a\nminimum, the current discharge set-point (including any additional pressure\nreductions) values per location, the highest experienced operating pressure and\nassociated date for each location, and the total number of pressure exceedances\nduring this time frame.\nRestart Plan. Prior to resuming operation of the Isolated Segment, develop and\nsubmit a written Restart Plan to the Director for prior approval.\na. The Director may approve the Restart Plan incrementally without approving the\nentire plan, but the Isolated Segment cannot resume operation until the Restart\nPlan is approved in its entirety and implemented as approved.\nb. Once approved by the Director, the Restart Plan will be incorporated by reference\ninto this Order.\nc. The Restart Plan must provide for adequate patrolling of the Isolated Segment\nduring the restart process and must include incremental pressure increases during\nstart-up, with each increment to be held for at least 2 hours.\nd. The Restart Plan must include sufficient surveillance of the pipeline during each\npressure increment to ensure that no leaks are present when operation of the line\nresumes.\ne. The Restart Plan must specify a day-light restart and include advance\ncommunications with local emergency response officials.\nf. The Restart Plan must provide for a review of the Affected Segment for\nconditions similar to those of the Failure, including a review of construction,\noperating and maintenance (O&M) and integrity management records such as ILI\nresults, hydrostatic tests, root cause failure analysis of prior failures, aerial and\nground patrols, corrosion, cathodic protection, excavations and pipe replacements.\nRespondent must address any findings that require remedial measures to be\nimplemented prior to restart.\n\n\n\n6\n4. 5. 6. 7. 8. g. The Restart Plan must include documentation of the completion of all mandated\nactions, and a management of change plan to ensure that all procedural\nmodifications are incorporated into Respondent’s O&M manual.\nh. The Restart Plan must provide for hydrostatic pressure testing within the Affected\nSegment in accordance with a written plan which must be approved by the\nDirector.\nReturn to Service. After the Director approves the Restart Plan, Respondent may\nreturn the Isolated Segment to service in accordance with the Restart Plan, but the\noperating pressure may not exceed 80% of the actual operating pressure in effect\nimmediately prior to the Failure in accordance with Item 2 above.\nRemoval of Pressure Restriction. The Director may allow the removal or\nmodification of the pressure restriction upon a written request from Respondent\ndemonstrating that restoring the pipeline to its pre-failure operating pressure is\njustified, based on a reliable engineering analysis showing that the pressure increase\nis safe considering all known defects, anomalies, and operating characteristics of the\npipeline.\nModification of Pressure Restriction. The Director may allow the temporary removal\nor modification of the pressure restrictions upon a written request from Respondent.\nShould this be requested, the written request will define other temporary mitigative\nand preventive measures that are to be implemented prior to and during the temporary\nremoval or modification of the pressure restriction. The Director's determination will\nbe based on the failure cause and provision of evidence that preventive and mitigative\nactions taken by the operator provide for the safe operation of the Affected Segment\nduring the temporary removal or modification of the pressure restriction. After the\ntemporary removal or modification is completed, documentation shall be provided to\nthe Director substantiating other measures completed. Appeals to determinations of\nthe Director in this regard will be decided by the Associate Administrator for Pipeline\nSafety.\nInstrumented Leakage Survey. Within 60 days of the receipt of this Order,\nRespondent must perform an aerial or ground instrumented leakage survey of the\nAffected Segment, using technology acceptable to the Director. Respondent must\ninvestigate all leak indications and remediate all leaks discovered. Respondent must\nsubmit documentation of this survey to the Director within 15 days of completion of\nthis survey. Documentation related to remedial measures taken and associated\ncompletion dates must be submitted to the Director within 60 days of completion.\nRecords Verification. As recommended in PHMSA Advisory Bulletin 2012-06,\nverify the records for the Affected Segment to confirm the MAOP. Respondent must\nsubmit documentation of this record verification to the Director within 45 days of\nreceipt of this Order and report any required changes or record discrepancies\nidentified during this review.\n\n\n\n7\n9. Review of Prior ILI Results. Within 60 days of the receipt of this Order, Respondent\nmust complete a review of any previous ILI results of the Affected Segment.\nRespondent must re-evaluate all ILI results from the past 10 calendar years, including\na review of the ILI vendors' raw data and analysis. In the course of this review and\nre-evaluation, Respondent must determine whether any features were present in the\nfailed pipe joint and/or any other pipe removed, and determine if any features with\nsimilar characteristics are present elsewhere on the Affected Segment. Report to\nPHMSA any wall thickness discrepancies found during the records reviewed.\nRespondent must submit documentation of this ILI review to the Director within 15\ndays of the completion of this Review as follows:\na. List all ILI tool runs, tool types, and the date of the tool runs.\nb. List (describe type, size, wall loss, etc.) and identify the specific location of all ILI\nfeatures present in the failed joint and/or other pipe removed.\nc. List (describe type, size, wall loss, etc.) and identify the specific location of all ILI\nfeatures present elsewhere on the Affected Segment.\nd. Explain the process used to review the ILI results and the results of the re-\nevaluation.\n10. Mechanical and Metallurgical Testing. Within 45 days of the receipt of this Order,\ncomplete mechanical and metallurgical testing and failure analysis of the failed pipe,\nincluding an analysis of soil samples and any foreign materials. Complete the testing\nand analysis as follows:\na. Document the chain-of-custody when handling and transporting the failed pipe\nsection and other evidence from the failure site.\nb. Within 10 days of receipt of this Order, develop and submit the testing protocol\nand the proposed testing laboratory to the Director for prior approval.\nc. Prior to beginning the mechanical and metallurgical testing, provide the Director\nwith the scheduled date, time, and location of the testing to allow for an OPS\nrepresentative to witness the testing.\nd. Ensure the testing laboratory distributes all reports, whether draft or final, in their\nentirety to the Director at the same time they are made available to Respondent.\n11. Root Cause Failure Analysis. Within 90 days following receipt of this Order,\ncomplete a root cause failure analysis (RCFA) and submit a final report of this RCFA\nto the Director. The RCFA must be supplemented/facilitated by an independent\nthird-party expert acceptable to the Director and must document the decision-making\nprocess and all factors contributing to the cause or extent of the Failure. The RCFA\nmust provide a detailed review of all SCADA and Controller activities that relate to\nthe Failure. SCADA enhancements identified during this review shall be included in\nthe report, which will include approximate timelines for implementation of such\nenhancements. Activities reviewed and summarized must include, but may not be\n\n\n\n8\nlimited to: controller actions on the day before the Failure, the day of the Failure, and\nthe day after the Failure; maintenance activities (same three days); automatic shutoff\nvalve configuration, control operations, controller notes or logs (same three days);\nactual and calculated instrumentation readings (same three days); available\ncommunication statistics (same three days, including pressure and flow value poll\ntimes); other SCADA equipment functions (same three days); and SCADA\nmaintenance requests and status (during the 6 months preceding the incident). The\nreport should also include a review of 30 days of detailed pressure information to\ndocument any changes in operating conditions. The report should provide a specific\nsummary regarding whether or not the controller(s) had adequate information to\nrecognize and respond to abnormal operating conditions. If adequate information did\nnot exist to recognize these conditions, identify enhancements for the SCADA system\n(display changes, added instrumentation, alarms, etc.) and controller activities that\ncould provide the necessary data and allow for controller recognition. The final\nreport must include findings, contributory factors, training considerations (if\nidentified during the analysis), any lessons learned, and an identification of whether\nthe findings and lessons learned are applicable to other locations within Respondent’s\npipeline system.\n12. Emergency Response Plan and Training Review. Within 45 days of the receipt of\nthis Order, Respondent must review and assess the effectiveness of its emergency\nresponse plan with regards to the Failure. Respondent must include in the review and\nassessment the on-scene response and support, coordination, and communication with\nemergency responders and public officials, as well as a review and assessment of the\neffectiveness of its emergency training program. Respondent must amend its\nemergency response plan and emergency training, if necessary, to reflect the results\nof this review. The documentation of this Emergency Response Plan and Training\nReview and any proposed corrective measures must be provided to the Director.\n13. Integrity Work Plan (IWP). Within 90 days of the receipt of this Order, Respondent\nmust submit an Integrity Work Plan (IWP) to the Director for approval.\na. The Director may approve the IWP incrementally without approving the entire\nIWP.\nb. Once approved by the Director, the IWP will be incorporated by reference into\nthis Order.\nc. The IWP must specify the tests, inspections, assessments, evaluations, and\nremedial measures Respondent will use to verify the integrity of the Affected\nSegment. It must address all known or suspected factors and causes of the\nFailure. Respondent should consider both the risk of another failure and the\nconsequence of another failure to develop a prioritized schedule for IWP related\nwork along the Affected Segment.\nd. The IWP must include a procedure or process to:\n\n\n\n9\ni. ii. iii. iv. v. Identify pipe in the Affected Segment with characteristics similar to the\ncontributing factors identified for the Failure.\nGather all data necessary to review the failure history (in service and\npressure test failures) of the Affected Segment and to prepare a written\nreport containing all the available information, such as the locations, dates,\nand causes of leaks and failures.\nIntegrate the results of the metallurgical testing, root cause failure\nanalysis, and other corrective actions required by this Order with all\nrelevant pre-existing operational and assessment data for the Affected\nSegment. Pre-existing operational data includes, but is not limited to,\nconstruction, operations, maintenance, testing, repairs, prior metallurgical\nanalyses, and any third-party consultation information. Pre-existing\nassessment data includes, but is not limited to, ILI tool runs, hydrostatic\npressure testing, direct assessments, close interval surveys, and\nDCVG/ACVG surveys.\nDetermine if conditions similar to those contributing to the Failure are\nlikely to exist elsewhere on the Affected Segment.\nConduct additional field tests, inspections, assessments, and/or evaluations\nto determine whether, and to what extent, the conditions associated with\nthe Failure and other failures from the failure history (see [13(d)(ii)]\nabove) or any other integrity threats are present elsewhere on the Affected\nSegment. At a minimum, this process must consider all failure causes and\nspecify the use of one or more of the following:\n1. ILI tools that are technically appropriate and sufficiently reliable for\nassessing the pipeline system based on the cause of the Failure,\n2. Hydrostatic pressure testing,\n3. Close-interval surveys,\n4. Cathodic protection surveys, to include interference surveys in\ncoordination with other utilities (e.g. underground utilities, overhead\npower lines, etc.) in the area,\n5. Coating surveys,\n6. Stress corrosion cracking surveys,\n7. Selective seam corrosion surveys; and,\n8. Other tests, inspections, assessments, and evaluations appropriate for\nthe failure causes (such as soil analysis).\n\n\n\n10\ne. f. g. Note: Respondent may use the results of previous tests, inspections,\nassessments, and evaluations if approved by the Director, provided the\nresults of the tests, inspections, assessments, and evaluations are analyzed\nwith regard to the factors known or suspected to have contributed to the\nFailure.\nvi. Describe the inspection and repair criteria that will be used to prioritize,\nexcavate, evaluate, and repair anomalies, imperfections, and other\nidentified integrity threats, including a description of how any defects will\nbe graded and a schedule for repairs or replacement.\nvii. Describe, based on the known history and condition of the Affected\nSegment, the methods that will be used to repair, replace, or take other\ncorrective measures to remediate the conditions associated with the\nFailure and to address other known integrity threats along the Affected\nSegment. The repair, replacement, or other corrective measures must\nmeet the criteria specified in [13(d)(vi)] above.\nviii. Implement continuing long-term periodic testing and integrity verification\nmeasures to ensure the ongoing safe operation of the Affected Segment,\nconsidering the results of the analyses, inspections, evaluations, and\ncorrective measures undertaken pursuant to the Order.\nInclude a proposed schedule for completion of the IWP.\nRespondent must revise the IWP as necessary to incorporate new information\nobtained during the failure investigation and remedial activities, to incorporate the\nresults of actions undertaken pursuant to this Order, and/or to incorporate\nmodifications required by the Director.\ni. Submit any plan revisions to the Director for prior approval.\nii. The Director may approve plan revisions incrementally.\niii. Any and all revisions to the IWP after it has been approved and\nincorporated by reference into this Order will be fully described and\ndocumented in the CAO Documentation Report (CDR).\nImplement the IWP as it is approved by the Director, including any revisions to\nthe plan.\n14. Quarterly Reports. Respondent must submit quarterly reports to the Director that\ninclude all available data and results of the testing and evaluations required by this\nOrder and describe the progress of the repairs or other remedial actions being\nundertaken. The first quarterly report is due on January 15, 2015, and will cover the\nperiod from the Failure until December 31, 2014. Subsequent Quarterly Reports are\ndue 15 days after the end of the applicable quarter. The Director may change the\ninterval for the submission of these reports.\n\n\n\n11\n15. Documentation of Costs. It is requested but not required that Respondent maintain\ndocumentation of the costs associated with implementation of this Corrective Action\nOrder. Include in each quarterly report the to-date costs and cost totals associated\nwith each Item of this Order.\n16. Approvals. With respect to each submission that under this Order requires the\napproval of the Director, the Director may (a) approve, in whole or in part, the\nsubmission; (b) approve the submission on specified conditions; (c) modify the\nsubmission to cure any deficiencies; (d) disapprove in whole or in part, the\nsubmission, directing that Respondent modify the submission, or (e) any combination\nof the above. In the event of approval, approval upon conditions, or modification by\nthe Director, Respondent shall proceed to take all action required by the submission\nas approved or modified by the Director. If the Director disapproves of all or any\nportion of the submission, Respondent must correct all deficiencies within the time\nspecified by the Director and resubmit it for approval.\n17. Extensions of Time. The Director may grant an extension of time for compliance\nwith any of the terms of this Order upon a written request timely submitted\ndemonstrating good cause for an extension.\n18. CAO Documentation Report (CDR). Respondent must create and revise, as\nnecessary, a CAO Documentation Report (CDR). When Respondent has concluded\nall the items in this Order, it will submit the final CDR in its entirety to the Director.\nThis will allow the Director to complete a thorough review of all actions taken by\nRespondent with regards to this Order prior to approving the closure of this Order.\nThe intent is for the CDR to summarize all activities and documentation associated\nwith this Order in one document.\na. The Director may approve the CDR incrementally without approving the entire\nCDR.\nb. Once approved by the Director, the CDR will be incorporated by reference into\nthis Order.\nc. The CDR must include but not be limited to:\ni. Table of Contents;\nii. iii. Summary of the pipeline failure of Sept 16, 2014, and the response activities;\nSummary of pipe data/properties and all prior assessments of the Affected\nSegment;\niv. Summary of all tests, inspections, assessments, evaluations, and analysis\nrequired by the Order;\nv. Summary of the Mechanical and Metallurgical Testing as required by the\nOrder;\nvi. Summary of the RCFA with all root causes and contributory factors as\nrequired by the Order;\nvii. Documentation of all actions taken by TransCanada/ANR to implement the\n\n\n\n12\nIWP, the results of those actions, and the inspection and repair criteria used;\nviii. Documentation of any revisions to the IWP including those necessary to\nincorporate the results of actions undertaken pursuant to this Order and\nwhenever necessary to incorporate new information obtained during the failure\ninvestigation and remedial activities;\nix. x. Lessons learned while completing this Order;\nA path forward describing specific actions Respondent will take on its entire\npipeline system as a result of the lessons learned from work on this Order; and\nxi. Appendices (if required).\nThe actions required by this Corrective Action Order are in addition to and do not waive any\nrequirements that apply to Respondent’s pipeline system under 49 CFR Part 192, under any other\norder issued to Respondent under authority of 49 USC § 60101 et seq., or under any other\nprovision of Federal or State law.\nRespondent may appeal any decision of the Director to the Associate Administrator for Pipeline\nSafety. Decisions of the Associate Administrator shall be final.\nBe advised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 USC 552(b), along with the complete original document you must\nprovide a second copy of the document with the portions you believe qualify for confidential\ntreatment redacted and an explanation of why you believe the redacted information qualified for\nconfidential treatment under 5 USC 552(b).\nFailure to comply with this Order may result in the assessment of civil penalties and in referral to\nthe Attorney General for appropriate relief in United States District Court pursuant to 49 USC §\n60120.\nIn your correspondence on this matter, please refer to CPF No. 3-2014-1005H. For each\ndocument you submit, please provide a copy in electronic format whenever possible.\nThe terms and conditions of this Corrective Action Order are effective upon receipt.\n____________________________ ________________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n320141005H_Closure Letter_08102018_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 10, 2018\nMr. Russell Girling\nPresident and CEO\nTransCanada Corporation\n450 1st St SW\nCalgary, Alberta T2P 5H1\nCPF 3-2014-1005H\nDear Mr. Girling:\nOn September 25, 2014, the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) issued to TransCanada a Corrective Action Order in the above-referenced case.\nThis Order included a requirement to take corrective actions on your pipeline. Based on our\nreview of the documentation you provided, it has been determined that you have complied\nwith the terms of this Order.\nAccordingly, this case is now closed and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nAllan C. Beshore\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":35340}