{"operation":"document","citation":"CPF 32025018CAO","title":"SOUTH BOW INFRASTRUCTURE OPERATIONS INC. — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2025-04-11","effective_on":null,"summary":"OPEN corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025018cao.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025018cao.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025018cao","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32025018CAO","body":"Corrective Action Order involving SOUTH BOW INFRASTRUCTURE OPERATIONS INC.. The dataset does not identify a cited regulation for this case. The case was opened on 2025-04-11 and is reported as open. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32025018CAO_Corrective Action Order_04112025_(25-338014).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025018CAO/32025018CAO_Corrective%20Action%20Order_04112025_(25-338014).pdf\n\n32025018CAO_Corrective Action Order_04112025_(25-338014)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025018CAO/32025018CAO_Corrective%20Action%20Order_04112025_(25-338014)_text.pdf\n\n32025018CAO_Corrective Action Order_04112025_(25-338014)_text.pdf\n\nApril 11, 2025\nVIA ELECTRONIC MAIL TO: richard.prior@southbow.com\nRichard Prior\nPresident/CEO, Liquids Pipelines\nSouth Bow Infrastructure Operations, Inc.\n920 Memorial City Way, Suite 800\nHouston, Texas 77024\nRe: CPF No. 3-2025-018-CAO\nDear Mr. Prior,\nEnclosed please find a Corrective Action Order (CAO or Order) issued by the Pipeline and\nHazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS). The\nCAO requires South Bow Infrastructure Operations, Inc., to take certain corrective actions with\nrespect to the pipeline failure that occurred on April 8, 2025, on the 30-inch South Bow\nKeystone Pipeline approximately thirty-two miles south of Valley City, North Dakota.\nService of the CAO by electronic mail is effective upon the date of transmission and\nacknowledgment of receipt as provided under 49 CFR § 190.5. The terms and conditions of this\nOrder are effective upon completion of service.\nSincerely,\nOn behalf of\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure: CAO\ncc: Mr. Gregory Ochs, Director, Central Region, OPS, PHMSA\nCONFIRMATION OF RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\n)\nIn the Matter of )\n)\nSouth Bow Infrastructure )\nOperations, Inc., ) CPF No. 3-\n2025-018-CAO\n)\nRespondent. )\n)\n____________________________________)\nCORRECTIVE ACTION ORDER\nPurpose and Background\nThis Corrective Action Order (CAO or Order) is being issued by the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to the\nauthority provided in 49 U.S.C. § 60112. The CAO requires South Bow Infrastructure\nOperations, Inc. (South Bow or Respondent), to take certain necessary corrective actions to\nprotect the public, property, and the environment from the potential hazards associated with the\ncontinued operation of the South Bow Keystone Pipeline, which recently ruptured at a location\napproximately thirty-two miles south of Valley City, North Dakota (Failure). The Failure\nresulted in the release of approximately 3,500 barrels of crude oil in a rural area.\nThe South Bow Keystone Pipeline is a 1,025-mile, 30-inch diameter hazardous liquid pipeline\nsystem, formerly known as Phase 1 of TC Oil Pipeline Operations, Inc.’s (TC Oil) Keystone\npipeline.1 The South Bow Keystone Pipeline runs from the US-Canadian border at Cavalier\nCounty, North Dakota, through the States of South Dakota, Nebraska, Kansas, and Missouri, to\nWood River, Illinois. The maximum operating pressure (MOP) of the South Bow Keystone\nPipeline is 1,440 pounds per square inch gauge (psig).\nThe Failure appears to have occurred shortly before 07:44 AM CDT, when a technician at a\nnearby pump station heard a loud noise indicative of a potential rupture. The technician\nresponded by immediately performing an emergency shut down of the pump station. South\nBow’s control center in Calgary, Canada, also shortly thereafter by shutting down the pipeline\nand remotely closing the valves necessary to isolate the site of the Failure.\n1 South Bow became the designated operator of the pipeline on March 22, 2024.\n\n\n\nOn April 10, 2025, South Bow sent a letter to PHMSA addressing the Failure. In that letter,\nSouth Bow “committed to performing a complete investigation into the root cause of the release\nand developing a corresponding comprehensive program to verify the safe and reliable operation\nof the pipeline.”2 As part of that commitment, South Bow identified a series of voluntary actions\nthat would be implemented to ensure the safe and reliable operation of the Keystone Pipeline.\nPursuant to 49 U.S.C. § 60117, PHMSA has initiated an investigation of the Failure. The\npreliminary findings of PHMSA’s ongoing investigation are as follows:\nPreliminary Findings\nApril 8, 2025 Accident\n• On April 8, 2025, shortly before 07:44 AM CDT, a South Bow technician working at the\nFort Ransom Pump Station heard a loud noise indicative of a potential rupture. The\ntechnician responded by initiating an emergency shutdown locally at the pump station.\nThe Fort Ransom Pump Station is approximately 32 miles south of Valley City, North\nDakota.\n• South Bow’s control center in Calgary, Canada, received alarms following the Failure\nand responded by initiating a shutdown of the pipeline. The control center also actuated\nremotely controlled valves to isolate the pipeline on either side of the spill site.\n• After the Failure, Respondent initiated spill response efforts to contain the release and\nbegan recovery of spilled crude oil. South Bow has recovered approximately 1,170\nbarrels of crude oil to date.\n• The Failure occurred in a rural area, did not impact any surface waterways, and did not\nresult in any fatalities, injuries, or fires.\n• South Bow notified the National Response Center (NRC) of the Failure on April 8, 2025,\nat approximately 08:46 AM CDT (NRC Incident Report # 1428025). South Bow\nsubmitted a supplemental notification to the NRC on April 10, 2025, reporting an\nestimated spill volume of 3,500 barrels of crude oil (NRC Incident Report # 148221).\n• PHMSA launched an onsite investigation and investigators arrived at the site of the\nFailure on April 8, 2025. PHMSA also deployed investigators to South Bow’s control\nroom in Calgary, Canada, on that same date.\n• South Bow’s spill response crew exposed the Failure location on April 10, 2025.\nPHMSA investigators at the site saw the ruptured pipeline. The rupture has the\nappearance of a fish-mouth opening and is approximately 45-inches long by 8-inches\nwide. The axis of the fish-mouth rupture aligns with the pipe’s longitudinal seam.\n2 https://www.phmsa.dot.gov/news/april-10-2025-south-bow-keystone-letter-commitment.\n\n\n\n• The failed pipe is 30-inch diameter with API 5L X70 double-submerged arc welded\n(DSAW) longitudinal seam manufactured by the Berg Steel Pipe Corporation.\n• Multiple wall thicknesses of pipe were used in the construction the Keystone pipeline,\nincluding, but not limited to, 0.386-inch, 0.437-inch, 0.515-inch, and 0.622-inch pipe.\n• Approximately 211.18 miles of 30-inch diameter, Berg Steel Pipe Corporation\nmanufactured pipe is installed in the South Bow Keystone Pipeline.\n• On October 29, 2019, pipe manufactured by Berg Steel Pipe Corporation in the Keystone\npipeline experienced a rupture at the longitudinal seam. The rupture occurred\ndownstream of South Bow’s Edinburg Pump Station (MP 34.3) in North Dakota and\nresulted in the release of approximately 4,515 barrels of crude oil. PHMSA issued a\nCAO in response to the release (CPF No. 3-2019-5023H).\n• Visual examination of the ruptured pipe at the Failure location is similar in appearance to\nthe pipe that ruptured in October 2019. Metallurgical testing of the pipe will determine if\nthe failure mechanisms are the same.\n• The pipeline at the Failure location was previously assessed using in-line inspection\n(ILI), including an ultrasonic metal loss tool and an ultrasonic crack detection tool.\n• The pipeline at the Failure location was hydrostatically tested prior to commencement of\npipeline operations in 2010.\n• The design pressure of the South Bow Keystone Pipeline is 1,800 psig, and the maximum\noperating pressure (MOP) is 1,440 psig. The operating pressure of the pipeline at the\ntime of the Failure was operating at 1,251 psig as recorded at the Fort Ransom Pump\nStation, which is 69.5% of SMYS. Flow rate at the time of Failure was 17,844 barrels\nper hour.\n• The South Bow Keystone Pipeline traverses several high consequence areas (HCAs),\ncould affect HCA areas, and navigable rivers. According to the most recent annual report\nsubmitted by South Bow, the number of miles that could affect HCAs is as follows:\nIllinois – 22.52 miles, Kansas – 79.88 miles, Missouri – 56.15 miles, Nebraska – 100.56\nmiles, North Dakota – 14.3 miles, and South Dakota – 14.11 miles.\nSpecial Permit\n• On April 30, 2007, PHMSA issued a special permit to TC Oil for the construction and\noperation of Phase 1 and Phase 2 of the Keystone pipeline.3 The special permit waived\nthe design pressure requirements in 49 CFR § 195.106 and authorized the Keystone\n3 PHMSA Special Permit Docket Number: PHMSA-2006-26617 (April 30, 2007).\n\n\n\npipeline to be operated at a stress level of up to 80 percent of specified minimum yield\nstrength (SMYS). Without a special permit, the operating stress level of the pipeline\ncould not exceed 72 percent of SMYS. To provide an equivalent or greater level of\nsafety, PHMSA included 51 conditions in the special permit for the design, construction,\ntesting, operation, maintenance of the Keystone pipeline.\nPrior Operation\n• The 1,025 miles of the South Bow Keystone Pipeline was previously known as Phase 1\nof TC Oil’s Keystone pipeline. South Bow became the operator of the pipeline on March\n22, 2024.\nPrior Accidents\n• On April 2, 2016, a reportable accident due to a leak in a cracked tie-in weld occurred on\nthe Phase 1 Keystone pipeline on the 48.1-mile segment between Freeman (Pump Station\n23) and Hartington (Pump Station 24). Per the “Accident Report – Hazardous Liquid\nPipeline Systems, Form PHMSA F 7000-1” submitted by TC Oil, approximately 20,400\ntons of solid materials were removed from the spill site, and 1,170 tons of liquid wastes\nwere disposed. On April 9, 2016, PHMSA issued a CAO requiring Respondent to take\ncertain corrective actions (CPF No. 3-2016-5002H). The CAO was closed on March 30,\n2017, after TC Oil completed the required corrective actions.\n• On November 16, 2017, an incident occurred on Phase 1 due to a fracture that initiated at\nan area of previous mechanical damage, resulting in a crude oil release. On November\n28, 2017, PHMSA issued a CAO (CPF No. 3-2017-5008H) to TC Oil that required\ncertain corrective actions. This CAO was closed on January 29, 2019, after Respondent\ncompleted the required corrective actions.\n• On October 30, 2019, a reportable non-girth weld accident occurred on the 41.9-mile\nPhase 1 Keystone pipeline segment that runs between the Edinburg Pump Station and the\nNiagara Pump Station, near Niagara, North Dakota. This failure exhibited characteristics\nof fatigue from pressure cycles and manufacturing defects in the longitudinal weld seam.\nThe failure mechanism in this event appears to be similar to the failure mechanism that\ncaused the current Failure. On November 5, 2019, PHMSA issued a CAO requiring\nRespondent to take certain corrective actions (CPF No. 3-2019-5023H). The CAO was\nclosed on February 3, 2022, after TC Oil completed the required corrective actions.\n• On October 14, 2022, PHMSA issued a Notice of Probable Violation, Proposed Civil\nPenalty, and Proposed Compliance Order (CPF No. 3-2022-025-NOPV) to TC Oil based\non the results of a special inspection of its Lucas delivery facility in Beaumont, Texas.\nThe special inspection followed a crude oil spill that occurred on the Keystone Gulf\nCoast system on May 7, 2020. The case was closed on May 2, 2023, after TC Oil\ncompleted the required compliance actions.\n• On December 7, 2022, a failure occurred on the 36-inch diameter Phase 2 of the\nKeystone pipeline due to failed girth welds, resulting in the release of 12,937 barrels of\n\n\n\ncrude oil. PHMSA issued a CAO in response to the release (CPF 3-2022-074-CAO),\nrequiring TC Oil to take certain corrective actions. PHMSA issued an amended CAO\nshortly thereafter, expanding the scope of the required corrective actions to include a\nreduction of the MOP to 72% of SMYS (1,296 psig), and extending them to other\nportions of the Keystone pipeline. The CAO remains in effect at this time.\n• The spills of 2016, 2017, 2019, 2020, and 2022, which resulted in reported releases of\n400, 6,592, 4,515, 442, 12,937 barrels of crude oil, respectively, show a tendency or\npattern in recent years of increasingly frequent incidents resulting in larger releases.\nDetermination of Necessity for Corrective Action Order and Right to Hearing\nSection 60112 of title 49, United States Code, authorizes PHMSA to determine that a pipeline\nfacility is or would be hazardous to life, property, or the environment and if there is a likelihood\nof serious harm, to expeditiously order the operator of the facility to take necessary corrective\naction, including suspended or restricted use of the facility, physical inspection, testing, repair,\nreplacement, or other appropriate action. An order issued expeditiously must provide an\nopportunity for a hearing as soon as practicable after the order is issued.\nIn deciding whether to issue an order, PHMSA must consider the following, if relevant: (1) the\ncharacteristics of the pipe and other equipment used in the pipeline facility, including the age,\nmanufacture, physical properties, and method of manufacturing, constructing, or assembling the\nequipment; (2) the nature of the material the pipeline facility transports, the corrosive and\ndeteriorative qualities of the material, the sequence in which the material is transported, and the\npressure required for transporting the material; (3) the aspects of the area in which the pipeline\nfacility is located, including climatic and geologic conditions and soil characteristics; (4) the\nproximity of the area in which the hazardous liquid pipeline facility is located to environmentally\nsensitive areas; (5) the population density and population and growth patterns of the area in\nwhich the pipeline facility is located; (6) any recommendation of the National Transportation\nSafety Board made under another law; and (7) any other factors PHMSA may consider as\nappropriate.\nAfter evaluating the foregoing preliminary findings of fact, and having considered the\ncharacteristics of the pipeline, including the prior and most current failures of the pipeline; the\nhazardous nature of the material (crude oil) transported; the existing and potential additional\nimpacts to property, the environment, and wildlife; the indications that South Bow’s operating,\nmaintenance, and/or integrity management programs may be inadequate to address the\nrepetitious pattern of seam weld and girth weld failures related to the original design,\nmanufacture, and construction of the pipeline; the tendency of flaws to grow from operating\npressure cycles; the occurrence of girth weld in-service leaks and seam ruptures at pressures\nbelow 72 percent SMYS, suggesting issues with girth weld quality; the increasing severity of\nspills in recent years; the prior failures of Berg Steel Pipe Corporation manufactured pipe; the\npossibility of future failures caused by a combination of factors similar to those involved in the\nApril 8, 2025 and prior failures, including transition welds and the potential for earth movement;\nand the possibility that the same condition(s) that may have caused the failure remain present and\ncould lead to additional failures in the South Bow Keystone Pipeline; it is hereby determined that\ncontinued operation of the Accident Segment and Affected Pipeline of the South Bow Keystone\n\n\n\nPipeline, as defined below, without corrective measures is or would be hazardous to life,\nproperty, or the environment, and that failure to issue this Order expeditiously would result in the\nlikelihood of serious harm.\nAccordingly, this Order mandating immediate corrective action is issued expeditiously without\nprior notice and opportunity for a hearing. The terms and conditions of this Order are effective\nupon completion of service.\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, PHMSA, OPS Central Region. If a hearing is requested, it will be held in\naccordance with 49 CFR § 190.211.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective measures that need to be taken. Respondent will be notified of any\nadditional measures required and, if appropriate, PHMSA will consider a further amended order.\nTo the extent consistent with safety, Respondent will be afforded notice and an opportunity for a\nhearing prior to the imposition of any additional corrective measures.\nDefinitions\nAffected Pipeline – The “Affected Pipeline” means the 30-inch diameter, 1,025-mile hazardous\nliquid South Bow Keystone Pipeline, formerly known as Phase 1 of TC Oil’s Keystone pipeline,\nthat runs from the U.S.-Canada border in North Dakota (M.P. 0.0) to the Steel City, Nebraska\nStation (MP 639.8) and on to the Patoka Delivery Station (M.P. 1084.7) in Illinois.\nAccident Segment – The “Accident Segment” means the 30-inch diameter South Bow Keystone\nPipeline, formerly known as Phase 1 of TC Oil’s Keystone pipeline, that runs from Fort Ransom\nPump Station (approximately MP 171.0) to Ludden Pump Station (approximately MP 216.7).\nDirector – The “Director” means the Director, PHMSA, OPS Central Region.\nRequired Corrective Actions\nPursuant to 49 U.S.C. § 60112, I hereby order South Bow to take the following corrective\nactions:\n1. Shutdown of the Accident Segment. The Accident Segment must remain shut-in and\nmay not be operated until authorized in writing to be restarted by the Director in\naccordance with the terms of this Order.\na. Prior to restarting the pipeline, South Bow must provide the Director the\nplanned pressure set-points at all pump stations and facilities necessary to limit\nthe operation of the South Bow Keystone Pipeline on sections of the pipeline\ncontaining pipe manufactured by Berg Steel Pipe Corporation installed in the\nUnited States.\nb. Prior to restart of the Accident Segment, South Bow must provide the Director\ndocumentation that all set-points to maintain the maximum operating pressure\nlimits specified below have been implemented, including any necessary updates\n\n\n\n2. 3. or changes to controls and protective equipment.\nOperating Pressure Restriction. After receiving authorization from the Director for\nrestart of the Accident Segment, discharge pressure at Fort Ransome Pump Station on\nthe Accident Segment shall be limited to no more than 80% of the pressure at the time of\nfailure, i.e., 1,000 psig, until otherwise authorized by the Director. On the remainder of\nthe Affected Pipeline, where pipe manufactured by Berg Steel Pipe Corporation has\nbeen installed, the discharge pressure for each pump station section containing Berg\nSteel pipe must be reduced to no more than 80% of the highest steady state pressure\nexperienced in the 60-day period prior to April 8, 2025. This pressure restriction is to\nremain in effect until written approval to increase the pressure is obtained from the\ndirector.\na. b. c. d. e. This pressure restriction requires any relevant remote or local alarm limits,\nsoftware programing set-points or control points, and mechanical over-pressure\ndevices to be adjusted accordingly.\nWhen determining the pressure restriction set-points, South Bow must take into\naccount any ILI features or anomalies present in the South Bow Keystone\nPipeline to provide for the continued safe operations of the pipeline, as required\nby 49 CFR § 195.401 and the anomaly evaluation and repair requirements of\nspecial permit PHMSA-2006-26617.\nAdequate controls and protective equipment must be in place to maintain\npressure within the limit required by 49 CFR § 195.406(b) during surges and\nother variations from normal operations.\nSouth Bow must review the pressure restriction monthly by analyzing the\noperating pressure data, taking into account any ILI features or anomalies\npresent in Affected Pipeline. South Bow must immediately reduce the\noperating pressure further to maintain the safe operations of the Affected\nPipeline, if warranted by the monthly review. Further, South Bow must submit\nthe results of the monthly review to the Director including, at a minimum, the\ncurrent discharge set-points (including any additional pressure reductions), and\nany pressure exceedance at discharge set-points. Submittals may be made\nquarterly, in accordance with paragraph 13 below.\nSouth Bow may request approval from the Director to increase the operating\npressure on individual segments on the Affected Pipeline based on an\nengineering analysis or other justification that the segment does not pose a\nsafety risk.\nReview of Prior In-Line Inspection (ILI) Results. Within 30 days of receipt of the\nCAO, South Bow must conduct a review of any previous ILI results of the failed pipe\nand adjacent pipe joints. In its review, South Bow must re-evaluate all ILI results from\nthe past 10 calendar years, including a review of the ILI vendors’ raw data and\nanalysis. South Bow must determine whether any features or abnormalities were\npresent in the failed pipe and adjacent joints from the April 8, 2025 failure. South\nBow must determine if any features with similar characteristics are present elsewhere\non the Accident Segment. South Bow must submit documentation of this ILI review to\nthe Director within 45 days of receipt of the CAO, as follows:\ni. List all ILI tool runs, tool types, and the calendar years of the tool runs.\n\n\n\n4. 5. 6. ii. iii. iv. List, describe (type, size, wall loss, etc.), and identify the specific location\nof all ILI features present in the failed joint and other pipe removed.\nList, describe (type, size, wall loss, etc.), and identify the specific location\nof all ILI features with similar characteristics present elsewhere on the\nAccident Segment.\nExplain the process used to review the ILI results and the results of the\nreevaluation.\nMechanical and Metallurgical Testing. Within 45 days of receipt of the CAO, South\nBow must complete mechanical and metallurgical testing and failure analysis of the\nfailed pipe, including an analysis of the soil samples and any foreign materials.\nMechanical and metallurgical testing must be conducted by an independent third-party\nacceptable to the Director and must document the decision-making process and all\nfactors contributing to the failure. South Bow must complete the testing and analysis\nas follows:\ni. ii. iii. iv. Document the chain-of-custody when handling and transporting the failed\npipe section and other evidence from the failure site.\nWithin 10 days of receipt of the CAO, develop and submit the testing\nprotocol and the proposed testing laboratory to the Director for prior\napproval.\nPrior to beginning the mechanical and metallurgical testing, provide the\nDirector with the scheduled date, time, and location of the testing to allow\nfor a PHMSA representative to witness the testing.\nEnsure the testing laboratory distributes all reports whether draft or final\nin their entirety to the Director at the same time they are made available to\nSouth Bow.\nRoot Cause Failure Analysis. Within 90 days following receipt of the CAO, complete\na root cause failure analysis (RCFA) and submit a final report of the RCFA to the\nDirector. The RCFA must be supplemented or facilitated by an independent third-\nparty acceptable to the Director and must document the decision-making process and\nall factors contributing to the failure. The final report must include findings and any\nlessons learned and whether the findings and lessons learned are applicable to other\nlocations within South Bow’s pipeline system. South Bow must ensure that all RCFA\nreports whether draft or final in their entirety are made available to the Director at the\nsame time they are made available to South Bow.\nSpecial Permit Evaluation. Within 90 days following receipt of the CAO, South Bow\nmust complete an evaluation of its adherence with PHMSA special permit PHMSA-\n2006-26617. The evaluation must include whether additional, modified, or more\nstringent conditions should be incorporated into the special permit to prevent incidents\nsimilar to the April 8, 2025 failure, or any other reportable accident that has occurred\nsince the Keystone Pipeline went into service. This evaluation must be supplemented\nor facilitated by an independent third-party acceptable to the Director and must\ndocument the decision-making process and all factors taken into consideration. All\nreports from the evaluation whether draft or final in their entirety must be provided to\n\n\n\n7. the Director at the same time they are made available to South Bow.\nRemedial Work Plan (RWP). Within 90 days following receipt of the CAO, South Bow\nmust submit a remedial work plan (RWP) to the Director for approval.\na. The Director may approve the RWP incrementally without approving the entire\nRWP.\nb. Once approved by the Director, the RWP will be incorporated by reference into\nthis Order.\nc. The RWP must specify the tests, inspections, assessments, evaluations, and\nremedial measures South Bow will use to verify the integrity of the Affected\nPipeline. It must address all known or suspected factors and causes of the April\n8, 2025 failure. South Bow must consider the risks and consequences of another\nfailure to develop a prioritized schedule for RWP- related work along the\nAffected Pipeline.\nd. The RWP must include a procedure or process to:\ni. Identify pipe in the Affected Pipeline with characteristics similar to the\ncontributing factors identified for the April 8, 2025 failure, including the\nage and manufacture of the entire length of the Affected Pipeline.\nii. Gather all data necessary to review the failure history (in service and\npressure test failures) of the Affected Pipeline and to prepare a written\nreport containing all the available information such as the locations,\ndates, and causes of leaks and failures.\niii. Integrate 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\nPipeline. Pre-existing operational data includes, but is not limited to,\ndesign, construction, operations, maintenance, testing, repairs, prior\nmetallurgical analyses, and any third-party consultation information. Pre-\nexisting assessment data includes, but is not limited to, ILI tool runs,\nhydrostatic pressure testing, direct assessments, close interval surveys,\nand DCVG/ACVG surveys.\niv. Determine if conditions similar to those contributing to the failure on\nApril 8, 2025, are likely to exist elsewhere on the Affected Pipeline.\nv. Conduct additional field tests, inspections, assessments, and evaluations\nto determine whether, and to what extent, the conditions associated with\nthe failure on April 8, 2025, and other failures from the failure history or\nany other integrity threats are present elsewhere on the Affected Pipeline.\nAt a minimum, this process must consider all failure causes and specify\nthe use of one or more of the following:\n1. ILI tools that are technically appropriate for assessing the pipeline\nsystem based on the cause of failure on April 8, 2025, and that\ncan reliably detect and identify anomalies;\n2. Hydrostatic pressure testing;\n3. Close-interval surveys;\n\n\n\n8. e. f. 4. Cathodic protection surveys, to include interference surveys in\ncoordination with other utilities (e.g., underground utilities,\noverhead power 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\nfor the failure causes, including hydrostatic pressure testing or\nother measures to confirm the effectiveness of the remedial work\nplan.\nvi. South Bow 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 caused the April 8,\n2025 failure.\nvii. Describe the inspection and repair criteria South Bow will use to\nprioritize, excavate, evaluate, and repair anomalies, imperfections, and\nother identified integrity threats. Include a description of how any\ndefects will be graded and a schedule for repairs or replacement.\nviii. Based on the known history and condition of the Affected Pipeline,\ndescribe the methods South Bow will use to repair, replace, or take other\ncorrective measures to remediate the conditions associated with the\npipeline failure on April 8, 2025, and address other known integrity\nthreats along the Affected Pipeline. The repair, replacement, or other\ncorrective measures must meet the criteria specified in above.\nix. Implement continuing long-term periodic testing and integrity\nverification measures to ensure the ongoing safe operation of the Affected\nPipeline considering the results of the analyses, inspections, evaluations,\nand corrective measures undertaken pursuant to the Order.\nx. Include a proposed schedule for completion of the RWP.\nSouth Bow must revise the RWP as necessary to incorporate new information\nobtained during the failure investigation and remedial activities, to incorporate\nthe results of actions undertaken pursuant to this Order, and 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. All revisions to the RWP after it has been approved and incorporated by\nreference into this Order will be fully described and documented in the\nCAO Documentation Report.\nImplement the RWP as it is approved by the Director, including any revisions to\nthe plan.\nCAO Documentation Report (CDR). South Bow must create and revise, as necessary, a\nCDR. When South Bow has concluded all the items in this Order it will submit the final\n\n\n\n9. CDR in its entirety to the Director. This will allow the Director to complete a thorough\nreview of all actions taken by South Bow with regards to this Order prior to approving\nthe closure of this Order. The intent is for the CDR to summarize all activities and\ndocumentation associated with 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 is not necessarily limited to, the following:\ni. Table of Contents;\nii. Summary of the pipeline failure of April 8, 2025, and the response\nactivities;\niii. Summary of pipe data, material properties, and all prior assessments of\nthe Affected Pipeline;\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. vii. viii. Summary of the RCFA with all root causes as required by the Order;\nSummary of the special permit evaluation as required by the Order\nDocumentation of all actions taken by South Bow to implement the\nRWP, the results of those actions, and the inspection and repair criteria\nused;\nix. Documentation of any revisions to the RWP including those necessary to\nincorporate the results of actions undertaken pursuant to this Order and\nwhenever necessary to incorporate new information obtained during the\nfailure investigation and remedial activities;\nx. xi. Lessons learned while completing this Order;\nA path forward describing specific actions South Bow will take on its\nentire pipeline system as a result of the lessons learned from work on this\nOrder; and\nxii. Appendices (if required).\nRestart Plan. Prior to resuming operation of the Affected Pipeline, develop and submit a\nwritten Restart Plan to the Director for prior approval.\na. The Director may approve the Restart Plan incrementally without approving the\nentire plan, but the Accident Segment cannot resume operation until the Restart\nPlan is approved in its entirety.\nb. Once approved by the Director, the Restart Plan will be incorporated by\nreference into this Order.\nc. The Restart Plan must provide for adequate patrolling of the Accident 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.\n\n\n\nd. e. f. g. 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.\nThe Restart Plan must specify a daylight restart and include advance\ncommunications with local emergency response officials and adjacent\nlandowners.\nThe Restart Plan must provide for a review of the Accident 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\nILI results, hydrostatic tests, root cause failure analysis of prior failures, aerial\nand ground patrols, corrosion, cathodic protection, excavations, and pipe\nreplacements. South Bow must address any findings that require remedial\nmeasures to be implemented prior to restart.\nThe Restart Plan must also include documentation of the completion of all\nmandated actions, and a management of change plan to ensure that all procedural\nmodifications are incorporated into South Bow’s O&M procedures manual.\n10. Return to Service. After the Director approves the Restart Plan, South Bow may resume\noperation of the Affected Pipeline according to the terms of the Restart Plan, but the\noperating pressure must not exceed the limit in accordance with paragraph 2 above.\nOther Requirements:\n11. Approvals. With respect to each submission under this Order that requires the approval\nof the Director, the Director may: (a) approve, in whole or part, the submission; (b)\napprove the submission on specified conditions; (c) modify the submission to cure any\ndeficiencies; (d) disapprove in whole or in part, the submission, directing that\nRespondent modify the submission, or (e) any combination of the above. In the event of\napproval, approval upon conditions, or modification by the Director, Respondent shall\nproceed to take all action required by the submission as approved or modified by the\nDirector. If the Director disapproves all or any portion of the submission, Respondent\nmust correct all deficiencies within the time specified by the Director and resubmit it for\napproval.\n12. Extensions of Time. The Director may grant an extension of time for compliance with\nany ofthe terms of this Order upon a written request timely submitted demonstrating\ngood cause for an extension.\n13. Reporting. Submit quarterly reports to the Director that: (1) include all available data\nand results of the testing and evaluations required by this Order; and (2) describe the\nprogress of the repairs or other remedial actions being undertaken. The first quarterly\nreport is due on July 18, 2025, covering the period through June 30, 2025. The Director\nmay change the interval for the submission of these reports.\n14. Documentation of the Costs. It is requested that Respondent maintain documentation of\nthe costs associated with implementation of this CAO. Include in each monthly report\n\n\n\nsubmitted, the to-date total costs associated with: (1) preparation and revision of\nprocedures, studies, and analyses; (2) physical changes to pipeline infrastructure,\nincluding repairs, replacements, and other modifications; and (3) environmental\nremediation, if applicable.\nBe advised that all material submitted in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. § 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. § 552(b).\nIn your correspondence on this matter, please refer to “CPF No. 3-2025-018-CAO” and for\neach document you submit, please provide a copy in electronic format whenever possible. The\nactions required by this Order are in addition to and do not waive any requirements that apply\nto Respondent’s pipeline system under 49 CFR Parts 190 through 199, under any other order\nissued to Respondent under authority of 49 U.S.C. Chapter 601, or under any other provision of\nfederal or state law.\nRespondent may appeal any decision of the Director to the Associate Administrator for\nPipeline Safety. Decisions of the Associate Administrator shall be final.\nFailure to comply with this Order may result in the assessment of civil penalties and in referral\ntothe Attorney General for appropriate relief in United States District Court pursuant to 49\nU.S.C. § 60120.\nThe terms and conditions of this Order are effective upon service in accordance with 49 CFR\n§ 190.5.\nApril 11, 2025\n_____________________________ __________________________\nOn behalf of\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":37686}