{"operation":"document","citation":"CPF 32026018WL","title":"SOUTH BOW INFRASTRUCTURE OPERATIONS INC. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2026-06-29","effective_on":null,"summary":"CLOSED warning letter citing 195.446(c)(2), 195.446(e)(5).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32026018wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32026018wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32026018wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32026018WL","body":"Warning Letter involving SOUTH BOW INFRASTRUCTURE OPERATIONS INC.. PHMSA's enforcement data identifies the cited regulations as 195.446(c)(2),  195.446(e)(5). The case was opened on 2026-06-29 and is reported as closed as of 2026-06-29. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32026018WL_Warning Letter_06292026_(25-332256).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32026018WL/32026018WL_Warning%20Letter_06292026_(25-332256).pdf\n\n32026018WL_Warning Letter_06292026_(25-332256)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32026018WL/32026018WL_Warning%20Letter_06292026_(25-332256)_text.pdf\n\n32026018WL_Warning Letter_06292026_(25-332256)_text.pdf\n\nU.S. Department of Transportation\nPipeline and Hazardous\nMaterials Safety Administration\n1100 Main Street, Suite 800\nKansas City, MO 64105\n(816) 329-3800\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: richard.prior@southbow.com;\nerik.hughes@southbow.com\nJune 29, 2026\nRichard Prior\nSenior Vice-President and Chief Operating Officer,\nSouth Bow Infrastructure Operations, Inc.\n920 Memorial City Way, Suite 800\nHouston, TX 77024\nCPF 3-2026-018-WL\nDear Mr. Prior:\nFrom September 8 through November 7, 2025, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\n(U.S.C.), conducted an inspection of procedures and records for the South Bow Infrastructure\nOperations, Inc., control room located in Calgary, Alberta, Canada.\nAs a result of the inspection, it is alleged that South Bow Infrastructure Operations, Inc., has\ncommitted probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal\nRegulations (CFR). The items inspected, and the probable violations are:\n1. § 195.446 Control Room Management.\n(a) . . . .\n(c) Provide adequate information. Each operator must provide its controllers with\nthe information, tools, processes and procedures necessary for the controllers to\ncarry out the roles and responsibilities the operator has defined by performing\neach of the following:\n(1) . . . .\n(2) Conduct a point-to-point verification between SCADA displays and\nrelated field equipment when field equipment is added or moved and when\n\n\n\nCPF 3-2026-018-WL\nother changes that affect pipeline safety are made to field equipment and\nSCADA displays.\nSouth Bow failed to conduct a point-to-point verification between SCADA displays and related\nfield equipment when changes that affect pipeline safety were made, as required by\n§195.446(c)(2).\nIn July of 2025, South Bow moved its LPCC from the TC Tower (TCT) location in Airdrie,\nAlberta, to the current location in Calgary, Alberta. PHMSA requested records of point-to-point\ntesting that South Bow performed after moving the Liquid Pipeline Control Cener (LPCC) to the\nnew control center in Calgary. South Bow failed to provide PHMSA with records to confirm that\nthey performed a point-to-point as part of the control room location change. After South Bow\nreceived the post-inspection written preliminary findings report, South Bow provided additional\nrecords, but the records were incomplete and failed to show that South Bow followed its procedural\nrequirements for conducting a point-to-point verification. The records provided indicated that\nSouth Bow tested SCADA operational functionality in general and server performance after they\nmoved the LPCC to the new control room, but South Bow did not perform a point-to-point\ndemonstrating verification of points from SCADA to the field end device and failed to provide its\ncontrollers with the information, tools, processes and procedures necessary for the controllers to\ncarry out the roles and responsibilities. Database records before and after the control room\nrelocation were not compared to indicate that the points were the same.\nSouth Bow’s response to PHMSA after receiving the post-inspection written preliminary findings\nwas that no field equipment monitored by SCADA was moved and there were no changes to field\nequipment or displays that affect pipeline safety.\nPHMSA did not find evidence to validate this response. South Bow’s records at the time of the\ncontrol center move or at the time of the inspection do not show no changes that affect pipeline\nsafety were made to field equipment or displays. Field equipment includes all equipment\nassociated with getting information to the SCADA system hardware including communication\nequipment, routers, switches, repeaters, and other pieces of equipment as may be required for data\nto be communicated to the SCADA system. A laptop or cell phone can be part of field equipment,\njust as calling into a Citrix system to access SCADA data can be part of field equipment. Changing\ncommunication equipment can affect pipeline safety. When South Bow changed the control room\nlocation, equipment used for communication with the field was added or moved. Consequently, a\npoint-to-point was required.\n2. § 195.446 Control Room Management.\n(a) . . . .\n(e) Alarm Management. Each operator using a SCADA system must have a written\nalarm management plan to provide for effective controller response to alarms.\nAn operator’s plan must include provisions to:\n(1) . . . .\nPage 2 of 4\n\n\n\nCPF 3-2026-018-WL\n(5) Monitor the content and volume of general activity being directed to and\nrequired of each controller at least once each calendar year, but at intervals\nnot exceeding 15 months, that will assure controllers have sufficient time\nto analyze and react to incoming alarms.\nSouth Bow’s written alarm management plan to provide for effective controller response to alarms\nfailed to include provisions satisfying the requirement of § 195.446(e)(5). Specifically, South\nBow’s CRM Alarm Management Plan and the LPCC Workload Study Procedure failed to ensure\nrecords of general activity and controller response were complete. Controller workload review and\nassociated records did not incorporate the time taken to acknowledge alarms based on severity or\npriority. By not reviewing the time to acknowledge alarms based on severity or priority, alarm\nrationalization was not confirmed. South Bow failed to effectively monitor the content and volume\nof general activity being directed to and required of each controller to assure controllers have\nsufficient time to analyze and react to incoming alarms.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a related\nseries of violations. For violation occurring on or after December 28, 2023, and before December\n30, 2024, the maximum penalty may not exceed $266,015 per violation per day the violation\npersists, up to a maximum of $2,660,135 for a related series of violations. For violation occurring\non or after January 6, 2023, and before December 28, 2023, the maximum penalty may not exceed\n$257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related\nseries of violations. For violation occurring on or after March 21, 2022, and before January 6,\n2023, the maximum penalty may not exceed $239,142 per violation per day the violation persists,\nup to a maximum of $2,391,142 for a related series of violations. For violation occurring on or\nafter May 3, 2021, and before March 21, 2022, the maximum penalty may not exceed $225,134\nper violation per day the violation persists, up to a maximum of $2,251,334 for a related series of\nviolations. For violation occurring on or after January 11, 2021, and before May 3, 2021, the\nmaximum penalty may not exceed $222,504 per violation per day the violation persists, up to a\nmaximum of $2,225,034 for a related series of violations. For violation occurring on or after July\n31, 2019, and before January 11, 2021, the maximum penalty may not exceed $218,647 per\nviolation per day the violation persists, up to a maximum of $2,186,465 for a related series of\nviolations.\nWe have reviewed the circumstances and supporting documents involved in this case and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the items identified in this letter. Failure to do so will result in\nSouth Bow Infrastructure Operations, Inc., being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 3-2026-018. Be advised that all material you submit in response to this enforcement action is\nsubject to being made publicly available. If you believe that any portion of your responsive\nmaterial qualifies for confidential treatment under 5 U.S.C. § 552(b), along with the complete\noriginal document you must provide a second copy of the document with the portions you believe\nPage 3 of 4\n\n\n\nCPF 3-2026-018-WL\nqualify for confidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. § 552(b).\nSincerely,\nAJ McKean\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Erik Hughes, Manager U.S. Regulatory Compliance, erik.hughes@southbow.com\nPage 4 of 4","truncated":false,"body_characters":9292}